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Petitions for the Imposition of Antidumping and Countervailing Duties on Certain Vertical Shaft Engines Between 99cc and up to 225cc and Parts Thereof

Case Summary

II.  Product:

The merchandise covered by this investigation consists of spark ignited, non-road, vertical shaft engines, whether finished or unfinished, whether assembled or unassembled, whether mounted or unmounted, primarily for walk-behind lawn mowers. Engines meeting this physical description may also be for other non-handheld outdoor power equipment, including but not limited to, pressure washers. The subject engines are spark ignition, single cylinder, air cooled, internal combustion engines with vertical power take off shafts with a minimum displacement of 99 cubic centimeters (“cc”) and a maximum displacement of up to 225cc. Typically, engines with displacements of this size generate gross power of between 1.95 kilowatts (“kw”) to 4.75 kw.

Engines covered by this scope normally must comply with and be certified under Environmental Protection Agency (EPA) air pollution controls title 40, chapter I, subchapter U, part 1054 of the Code of Federal Regulations standards for small non-road spark ignition engines and equipment. Engines that otherwise meet the physical description of the scope but are not certified under 40 CFR part 1054 and are not certified under other parts of subchapter U of the EPA air pollution controls are not excluded from the scope of this proceeding. Engines that may be certified under both 40 CFR part 1054 as well as other parts of subchapter U remain subject to the scope of this proceeding.

Certain small vertical shaft engines, whether or not mounted on non-hand-held outdoor power equipment, including but not limited to walk-behind lawn mowers and pressure washers, are included in the scope. However, if a subject engine is imported mounted on such equipment, only the engine is covered by the scope. Subject merchandise includes certain small vertical shaft engines produced in the subject country whether mounted on outdoor power equipment in the subject country or in a third country. Subject engines are covered whether or not they are accompanied by other parts.

For purposes of this investigation, an unfinished engine covers at a minimum a sub-assembly comprised of, but not limited to, the following components: crankcase, crankshaft, camshaft, pistons(s), and connecting rod(s). Importation of these components together, whether assembled or unassembled, and whether or not accompanied by additional components such as a sump, carburetor spacer, cylinder head(s), valve train, or valve cover(s), constitutes an unfinished engine for purposes of this investigation. The inclusion of other products such as spark plugs fitted into the cylinder head or electrical devices (e.g., ignition coils) for synchronizing with the engine to supply tension current does not remove the product from the scope. The inclusion of any other components not identified as comprising the unfinished engine subassembly in a third-country does not remove the engine from the scope.


Type of Action
Antidumping Duty (“AD”): China; Countervailing Duty (“CVD”): China
HTS Classifications
The engines subject to this investigation are predominantly classified in the Harmonized Tariff Schedule of the United States (HTSUS) at subheading 8407.90.1010. The engine subassemblies that are subject to this investigation enter under HTSUS 8409.91.9990. The mounted engines that are subject to this investigation enter under HTSUS 8433.11.0050, 8433.11.0060, and 8424.30.9000. Engines subject to this investigation may also enter under HTSUS 8407.90.1020, 8407.90.9040, and 8407.90.9060.
Date of Filing
March 18, 2020
Briggs & Stratton Corporation
Foreign Producers and Exporters
Please contact our office for a list filed with the petition.
US Named Importers
Please contact our office for a list filed with the petition.
Alleged Dumping Margins

(No CVD Margins Listed)

China: 324.73-637.73%

Additional Notes


A.  Projected date of ITC Preliminary Conference: April 8, 2020.

B.  The earliest theoretical date for retroactive suspension of liquidation for the AD is May 27, 2020; CVD is April 7, 2020.

Please contact our office for a complete projected schedule for the AD/CVD investigations.

C.  Volume and Value of Imports:

Please contact our office for a summary of the data filed with the petition.

D.  List of Alleged Subsidy Programs:

Please contact our office for a list of alleged subsidy programs.

If you have questions regarding how this investigation may impact future imports of scope merchandise or whether a particular product is within the scope of the investigation, please contact one of our attorneys.

Patrick J. Caulfield
Patrick J. Caulfield
Harold M. Grunfeld
Founding Partner