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PETITIONS FOR THE IMPOSITION OF ANTIDUMPING DUTIES ON IMPORTS OF REFILLABLE STAINLESS STEEL KEGS FROM GERMANY, MEXICO, AND THE PEOPLE’S REPUBLIC OF CHINA AND COUNTERVAILING DUTIES ON IMPORTS OF REFILLABLE STAINLESS STEEL KEGS FROM THE PEOPLE’S REPUBLIC OF CHINA

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

II.  Product: The merchandise covered by this investigation are cylindrical kegs, vessels, or containers capable of being pressurized made from stainless steel (i.e. , steel containing at least 10.5 percent chromium by weight and less than 1.2 percent carbon by weight, with or without other elements) (“refillable stainless steel kegs”) with a nominal liquid volume capacity of 10 liters or more, regardless of the type of finish, gauge, thickness, or grade of stainless steel, regardless of finish, and whether or not covered by or encased in other materials. Refillable stainless steel kegs may be imported assembled or unassembled, with or without all components (including spears, couplers or taps, necks, collars, and valves), and filled or unfilled. Assembled refillable stainless steel kegs must be capable of being pressurized to 60 pounds per square inch (“PSI”) and must be tested to 90 PSI.”Unassembled” or “unfinished” refillable stainless steel kegs include drawn stainless steel cylinders that have been welded to form the body of the keg and welded to an upper (top) chime and/or lower (bottom) chime. Unassembled refillable stainless steel kegs may or may not be welded to a neck, may or may not have a valve assembly attached, and may be otherwise complete except for testing, certification and/or marking. Subject merchandise also includes refillable stainless steel kegs that have been further processed in a third country, including but not limited to, attachment of necks, collars, spears or valves, heat treatment, pickling, passivation, painting, testing, certification or any other processing that would not otherwise remove the merchandise from the scope of the investigation if performed in the country of manufacture of the in-scope refillable stainless steel keg.

Specifically excluded are the following:

(1)        vessels or containers that are not cylindrical in nature;

(2)        stainless steel kegs, vessels, or containers that have either a “ball lock” valve system or a “pin lock” valve system (commonly known as a “Cornelius,” “corny” or “ball lock” kegs);

(3)        any fully assembled or finished stainless steel keg, vessel, or container that is incompatible with a “D Sankey” extractor (commonly known as a “D Coupler” or “Sankey”); and

(4)        necks, spears, couplers or taps, collars, and valves that are not imported with the subject merchandise.

(5)        stainless steel kegs that are filled with beer, wine, or other liquid and that are designated by the Commissioner of Customs as Instruments of International Traffic within the meaning of section 332(a) of the Tariff Act of 1930, as amended.

III.  HTS classifications: The merchandise covered by this investigation are currently classified in the Harmonized Tariff Schedule of the United States (“HTSUS”) under subheading 7310.10.0010, 7310.10.0050, 7310.29.0025, and 7310.29.0050. These HTSUS subheadings are provided for convenience and customs purposes; the written description of the scope of this investigation is dispositive.

IV.  Date of Filing: September 20, 2018

V.  Petitioners: American Keg Company LLC

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.

Alleged Dumping Margin:

China: 196.55%;

Germany: 76.36%;

Mexico: 25.39%;

IX.  Comments:

A.  Projected date of ITC Preliminary Conference: October 10, 2018.

Please contact our office for a complete projected schedule for the AD investigation.

B.  The earliest theoretical date for retroactive suspension of liquidation for the antidumping duty is November 29, 2018; for countervailing duty is October 10, 2018.

Please contact our office for a complete projected schedule for the CVD investigation.

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 any 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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