GDLSK: Grunfeld Desiderio Lebowitz Silverman & Klestadt LLP
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Scope / Anticircumvention Inquiries

The Department of Commerce (“DOC”) has the responsibility to investigate whether products are covered by the scope of an antidumping duty (“ADD”) and/or countervailing duty (“CVD”) order and whether merchandise imported from a third country is circumventing an existing ADD/CVD Order.

GDLSK provides clients with confidential advice as to whether their products can be drawn into an existing ADD/CVD Order through a scope and/or anticircumvention (“AC”) proceeding. We represent clients in formal scope/AC cases.

The following cases are among our recent formal “scope” success stories.

  • Bathroom furniture not subject to the ADD Order on Wooden Bedroom Furniture from China
  • Mobile Utility Carts not subject to the ADD Order on Hand Trucks from China
  • Wheel caps not subject to the ADD Order on Chassis from China

Rather than file new petitions targeting products from additional countries, domestic interests have at times filed AC petitions with the DOC claiming that third country processing is not sufficient to remove a product from an existing ADD/CVD Order. The DOC also has self-initiated AC proceedings. GDLSK is able to respond to these AC proceedings with the same expertise and dedication provided in our traditional ADD/CVD practice.

Our recent AC success stories include:

  • Hydrofluorocarbon (HFC) components from China not circumventing ADD order on HFC blends from China
  • Pipe from the United Arab Emirates not circumventing ADD order on pipe from India

GDLSK also has been successful in convincing DOC that our client’s products remain outside ADD/CVD Orders by submitting “certifications” attesting to their provenance.

  • quartz surface products (QSP) in Malaysia
  • Hydrofluorocarbon (HFC) components in India
Scope/Anticircumvention Inquiries
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