Commerce Preliminarily Finds Countervailable Subsidization of Imports of Circular Welded Carbon-Quality Steel Pipe from Pakistan

On April 4, 2016, the Department of Commerce (Commerce) announced its affirmative preliminary

determination in the countervailing duty (CVD) investigation of imports of circular welded carbon quality

steel pipe from Pakistan.

  • The CVD law provides U.S. business and workers with a transparent, quasi-judicial, and

internationally accepted mechanism to seek relief from the market distorting effects caused by

injurious subsidization of imports into the United States, establishing an opportunity to compete on a

level playing field.

  • For the purpose of CVD investigations, a countervailable subsidy is financial assistance from foreign

governments that benefits the production of goods from foreign companies and is limited to specific

enterprises or industries, or is contingent either upon export performance or upon the use of domestic

goods over imported goods.

  • Commerce calculated a preliminary subsidy rate of 64.81 percent for the mandatory respondent,

International Industries Limited. The preliminary subsidy rate is based on facts available and adverse

inferences following Commerce’s preliminary determination that the mandatory respondent and the

Government of Pakistan had not fully cooperated in the investigation. All other exporters/producers

in Pakistan have also been assigned a preliminary subsidy rate of 64.81 percent.

  • As a result of the preliminary affirmative determination, Commerce will instruct U.S. Customs and

Border Protection to require cash deposits based on these preliminary rates.

  • The petitioners in this investigation are Bull Moose Tube Company (MO), EXLTUBE (MO),

Wheatland Tube (IL), and Western Tube & Conduit (CA).

  • The investigation covers welded carbon-quality steel pipes and tube, of circular cross-section, with an

outside diameter (O.D.) not more than nominal 16 inches (406.4 mm), regardless of wall thickness,

surface finish (e.g., black, galvanized, or painted), end finish (plain end, beveled end, grooved,

threaded, or threaded and coupled), or industry specification (e.g., American Society for Testing and

Materials International (ASTM), proprietary, or other), generally known as standard pipe, fence pipe

and tube, sprinkler pipe, and structural pipe (although subject product may also be referred to as

mechanical tubing). Specifically, the term “carbon quality” includes products in which:

(a) iron predominates, by weight, over each of the other contained elements;

(b) the carbon content is 2 percent or less, by weight; and

(c) none of the elements listed below exceeds the quantity, by weight, as indicated:

(i) 1.80 percent of manganese;

(ii) 2.25 percent of silicon;

(iii) 1.00 percent of copper;

U.S. Department of Commerce |International Trade Administration

(iv) 0.50 percent of aluminum;

(v) 1.25 percent of chromium;

(vi) 0.30 percent of cobalt;

(vii) 0.40 percent of lead;

(viii) 1.25 percent of nickel;

(ix) 0.30 percent of tungsten;

(x) 0.15 percent of molybdenum;

(xi) 0.10 percent of niobium;

(xii) 0.41 percent of titanium;

(xiii) 0.15 percent of vanadium; or

(xiv) 0.15 percent of zirconium.

Covered products are generally made to standard O.D. and wall thickness combinations. Pipe multistenciled

to a standard and/or structural specification and to other specifications, such as American

Petroleum Institute (API) API-5L specification, may also be covered by the scope of these

investigations. In particular, such multi-stenciled merchandise is covered when it meets the physical

description set forth above, and also has one or more of the following characteristics: is 32 feet in

length or less; is less than 2.0 inches (50 mm) in outside diameter; has a galvanized and/or painted

(e.g., polyester coated) surface finish; or has a threaded and/or coupled end finish.

Standard pipe is ordinarily made to ASTM specifications A53, A135, and A795, but can also be

made to other specifications. Structural pipe is made primarily to ASTM specifications A252 and

A500. Standard and structural pipe may also be produced to proprietary specifications rather than to

industry specifications.

Sprinkler pipe is designed for sprinkler fire suppression systems and may be made to industry

specifications such as ASTM A53 or to proprietary specifications.

The scope of this investigation does not include:

(a) pipe suitable for use in boilers, superheaters, heat exchangers, refining furnaces and feedwater

heaters, whether or not cold drawn, which are defined by standards such as ASTM A178 or ASTM


(b) finished electrical conduit, i.e., Electrical Rigid Steel Conduit (aka Electrical Rigid Metal Conduit

and Electrical Rigid Metal Steel Conduit), Finished Electrical Metallic Tubing, and Electrical

Intermediate Metal Conduit, which are defined by specifications such as American National Standard

(ANSI) C80.1-2005, ANSI C80.3-2005, or ANSI C80.6-2005, and Underwriters Laboratories Inc.

(UL) UL-6, UL-797, or UL-1242;

(c) finished scaffolding, i.e., component parts of final, finished scaffolding that enter the United

States unassembled as a “kit.” A kit is understood to mean a packaged combination of component

parts that contains, at the time of importation, all of the necessary component parts to fully assemble

final, finished scaffolding;

(d) tube and pipe hollows for redrawing;

(e) oil country tubular goods produced to API specifications;

(f) line pipe produced to only API specifications, such as API 5L, and not multi-stenciled; and

(g) mechanical tubing, whether or not cold-drawn, other than what is included in the above


The products subject to this investigation are currently classifiable in Harmonized Tariff Schedule of

the United States (HTSUS) statistical reporting numbers 7306.19.1010, 7306.19.1050, 7306.19.5110,

7306.19.5150, 7306.30.1000, 7306.30.5015, 7306.30.5020, 7306.30.5025, 7306.30.5032,

7306.30.5040, 7306.30.5055, 7306.30.5085, 7306.30.5090, 7306.50.1000, 7306.50.5030,

U.S. Department of Commerce |International Trade Administration

7306.50.5050, and 7306.50.5070. The HTSUS subheadings above are provided for convenience and

U.S. Customs purposes only. The written description of the scope of the investigation is dispositive.

  • In 2014, imports of circular welded carbon-quality steel pipe from Pakistan were valued at an

estimated $17 million.


  • Commerce is scheduled to announce its final determination in this investigation on August 16, 2016,

unless the statutory deadline is extended.

  • If Commerce makes an affirmative final determination, and the U.S. International Trade Commission

(ITC) makes an affirmative final determination that imports of circular welded carbon-quality steel

pipe from Pakistan materially injure, or threaten material injury to, the domestic industry, Commerce

will issue a CVD order. If either Commerce’s or the ITC’s final determination is negative, no CVD

order will be issued. The ITC is scheduled to make its final injury determination approximately 45

days after Commerce issues its final determination, if affirmative.

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