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PETITIONS FOR THE IMPOSITION OF ANTIDUMPING DUTIES AND COUNTERVAILING DUTIES ON FLUID END BLOCKS FROM CHINA, GERMANY, INDIA, AND ITALY

I.  Type of Action: Antidumping Duty (“AD”): Germany, India, and Italy; Countervailing Duty (“CVD”): China, Germany, India, and Italy

II.  Product:

The products covered by these petitions are forged steel fluid end blocks (“FEBs”), whether unfinished, semi-finished, or finished, and which are typically used in the manufacture or service of hydraulic pumps.

The term “forged” is an industry term used to describe the grain texture of steel resulting from the application of localized compressive force. Illustrative forging standards include, but are not limited to, American Society for Testing and Materials (“ASTM”) specifications A668 and A788.

For purposes of these petitions, the term “steel” denotes metal containing the following chemical elements, by weight: (i) iron greater than or equal to 60 percent; (ii) nickel less than or equal to 8.5 percent; (iii) copper less than or equal to 6 percent; (iv) chromium greater than or equal to 0.4 percent, but less than or equal to 20 percent; and (v) molybdenum greater than or equal to 0.15 percent, but less than or equal to 3 percent. Illustrative steel standards include, but are not limited to, American Iron and Steel Institute (“AISI”) or Society of Automotive Engineers (“SAE”) grades 4130, 4135, 4140, 4320, 4330, 4340, 8630, 15-5, 17-4, F6NM, F22, F60, and XM25, as well as modified varieties of these grades.

The products covered by these petitions are either (1) cut-to-length FEBs with a height (measured from its highest point) of 8 inches (203.2 mm) to 40 inches (1,016.0 mm), a width (measured from its widest point) of 8 inches (203.2 mm) to 40 inches (1,016.0 mm), and a length (measured from its longest point) of 11 inches (279.4 mm) to 75 inches (1,905.0 mm), or (2) strings of FEBs with a height (measured from its highest point) of 8 inches (203.2 mm) to 40 inches (1,016.0 mm), a width (measured from its widest point) of 8 inches (203.2 mm) to 40 inches (1,016.0 mm), and a length (measured from its longest point) up to 360 inches (9,144.0 mm).

The products included in the scope of these petitions have a tensile strength of at least 70 KSI (measured in accordance with ASTM A370) and a hardness of at least 140 HBW (measured in accordance with ASTM E10).

FEBs may be unfinished or have undergone one or more of the following finishing operations: (1) milling one or more flat surfaces; (2) contour machining to custom shapes or dimensions; (3) drilling or boring holes; (4) heat treating; (5) painting, varnishing, or coating; (6) threading; and/ or (7) the attachment of flanges, valves, seals, or connectors.

III.  HTS classifications:

The products included in the scope of these petitions may enter under Harmonized Tariff System of the United States (“HTSUS”) subheadings 7218.91.0030, 7218.99.0030, 7224.90.0015, 7224.90.0045, 7326.19.0010, 7326.90.8688, or 8413.91.9055. While these HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of the petitions is dispositive.

IV.  Date of Filing: December 19, 2019

V.  Petitioners: FEB Fair Trade Coalition, Ellwood Group, and Finkl Steel

VI.  Foreign Producers/Exporters:Please contact our office for a list filed with the petition.

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

VII.  U.S. Importers named:

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

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

Germany: 69.37 Percent

India: 12.82 Percent

Italy: 77.24 Percent

IX.  Comments:

A.  Projected date of ITC Preliminary Conference: January 9, 2020.

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

B.  The earliest theoretical date for retroactive suspension of liquidation for the AD is February 27, 2020; CVD is January 8, 2020.

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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