Commerce Finds Car Window Parts Covered by AD/CV Duties on Aluminum Extrusions

Automotive window parts imported by WKW Erbsloeh North America are subject to antidumping and countervailing duties on aluminum extrusions from China (A-570-967/C-570-968), the Commerce Department said in a recent scope ruling. While rubber window seals and rolled aluminum window trim are not aluminum extrusions and aren’t covered by the orders, other window components containing extruded aluminum are covered because they are components of a finished car, rather than “finished merchandise” on their own, Commerce said.

WKW imports the automotive window components specially designed and ready for installation into various types of vehicles, including the Buick Verano, Volkswagen Passat and the BMW X5, X6 and X7. The parts include rear quarter finishers made from rolled aluminum sheets, to be installed around the small window on the rear sides of a vehicle, as well as rubber window seals sometimes imported on their own.

The importer also brings in waist finishers, belt moldings and outer waist belts, designed to be installed at the bottom of the car window where the glass goes when the window is rolled down. Fully fabricated at the time of importation and also specially designed for each type of automobile, the waist finishers, belt moldings and outer waist belts consist of extruded series 6 aluminum alloys, with a rubber seal attached. No further fabrication or additional work is required prior to installation by the automaker.

Commerce found the rear quarter finishers and the rubber seals imported on their own are not subject to AD/CV duties on aluminum extrusions because they are not made from extruded aluminum. “Based on the plain language of the scope, we determine that the scope of the Orders does not include" WKW’s rear quarter finishers and rubber seals, the agency said.

But the waist finishers, belt moldings and outer waist belts are composed of extruded aluminum, and satisfy the description of subject merchandise in the scope, Commerce said. And the scope of the AD/CV duty orders covers aluminum extrusions that are attached to components of other materials to make up “assemblies,” it said.

WKW argued that the waist finishers, belt moldings and outer waist belts are nonetheless exempt from AD/CV duties as “finished merchandise,” but Commerce disagreed. “To perform their function of keeping road debris, rain, noise, and outside elements from entering the car, WKW’s window trims must work in tandem with the glass of the car window and the car door,” the agency said. They do not have their “own function independent of the completed automobile,” making them subassemblies, which are subject to AD/CV duties, Commerce said.

“WKW’s window trims are less than the full, permanent, and completed final product, the automobile,” Commerce said. “We similarly find that WKW’s window trims are intermediary products that require incorporation in a downstream product to function.” Because they aren’t fully assembled and complete at the time of importation, the waist finishers, belt moldings and outer waist belts are ineligible for the finished merchandise and finished goods kit exemptions, and are included under the scope of the aluminum extrusions orders, Commerce said.

Email ITTNews@warren-news.com for a copy of the scope ruling.