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PETITIONS FOR THE IMPOSITION OF ANTIDUMPING AND COUNTERVAILING DUTIES ON TWIST TIES FROM CHINA

I.  Type of Action: Antidumping Duty (“AD”): China; Countervailing Duty (“CVD”): China

II. Product:

The merchandise covered by these investigations consists of twist ties, which are thin, bendable ties for closing containers, such as bags, bundle items, or identifying objects. A twist tie is comprised of one or more metal wires encased in a covering material, which allows the tie to retain its shape and bind against itself. The metal wire in a twist tie is typically stainless or galvanized steel and typically measures between the gauges of 19 (.0410” diameter) and 31 (.0132”) (American Standard Wire Gauge).  A twist tie usually has a width between .075” and 1” in the cross-machine direction (width of the tie – measurement perpendicular with the wire); a thickness between .015” and .045” over the wire or other metal; and a thickness between .002” and .020” in areas without wire or other metal. Twist ties are commonly available individually in pre-cut lengths (“singles”), wound in large spools to be cut later by machine or hand, or in perforated sheets of spooled or single twist ties that are later slit by machine or by hand (“gangs”).

The covering material of a twist tie may be paper (metallic or plain), plastic, or polyethylene, and can be dyed in a variety of colors with or without printing.  A twist tie may have the same covering material on both sides or one side of paper and one side of plastic. When comprised of two sides of paper, the paper material is bound together with an adhesive or plastic.  A twist tie also may have a tag or label attached to it or a pre-applied adhesive attached to it.

The scope includes ties used for television cable, computer cords, other appliances and household ties, all of which are manufactured by Petitioner. Twist ties without metal wire also are covered in the scope.  An all plastic tie contains a plastic core as well as a plastic covering (the wing) over the core, just like paper and/or plastic in a metal tie. The scope does not include products with wire and plastic material (e.g., pipe cleaners used in craft activities, wire bristle brushes), or plastic “zip” ties.

III.  HTS classifications:

Twist ties are imported into the United States under Harmonized Tariff System of the United States (“HTSUS”) subheadings 8309.90.0000 and 5609.00.3000.  Subject merchandise may also enter under HTSUS subheadings 3906.90.2000, 3920.51.5000, 3923.90.0080, 3926.90.9990, 4811.59.6000, 4821.10.4000, 4821.90.2000, and 4823.90.8600. These HTSUS subheadings are provided for reference only.  The written description of the scope of the investigations is dispositive.

IV.  Date of Filing: June 26, 2020

V.  Petitioners: Bedford Industries, Inc.

VI.  Foreign Producers/Exporters:

Please contact our office for a list filed with the petition.

VII.  US Importers named:

Please contact our office for a list filed with the petition.

VIII.  Alleged Dumping Margins (No CVD Margins Listed):

China: 67.92%

IX.  Comments:

A.  Projected date of ITC Preliminary Conference: July 17, 2020.

B.  The earliest theoretical date for retroactive suspension of liquidation for the AD is September 4, 2020; CVD is July 16, 2020.

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

C.  Volume and Value of Imports: Not Provided in Public 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.

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