Commerce Finds SDABS Couplers Not Subject to China Forged Steel Fittings Duties
Self-drilling anchor bolt system (SDABS) couplers imported by Midwest Diversified Technologies (MDT) are likely not subject to antidumping and countervailing duties on forged steel fittings from China (A-570-067/C-570-068), the Commerce Department said in a preliminary scope ruling issued May 17. While the scope of the order says it covers all fittings, it also indicates that low-pressure fittings are exempt, and MDT’s fittings, intended to connect hollow bars, are not able to convey liquids and gases at high pressure, Commerce said.
The SDABS for which MDT imports the couplers are used to improve the structural integrity of soil or rock to provide a stable foundation for construction. Hollow bars are drilled into the soil, then cement grout is piped in, surrounding the SDABS from the bottom up and encapsulating the SDABS in a continuous grout column. MDT’s couplers are used to join hollow bars when it is necessary for the SDABS to go deeper into the ground.
The scope of the forged steel fittings orders says it covers “all types of fittings … regardless of nominal pipe size (which may or may not be expressed in inches of nominal pipe size), pressure rating … wall thickness, and whether or not heat treated.” But it also excludes “all fittings that have a maximum pressure rating of 300 pounds of pressure/PSI or less.”
Based on that exclusion and other materials from the original AD/CVD investigations, Commerce found MDT’s couplings meet that exclusion, and are otherwise not “forged” for the purposes of the scope language. The term “forged” is “an industry term intended to cover various manufacturing processes.” During the original AD/CVD investigations, the petitioner explained that “the level of pressure rating was key to determining whether a product was within or outside the scope of the Orders,” and that “the fittings that petitioners intend to cover can be limited to exclude low pressure fittings based on pressure ratings.”
MDT’s couplings lack any pressure rating at all, and testing showed that they leak water at 40 psi, well below the 300 psi exclusion threshold in the scope. “We find that the lack of a pressure rating altogether (as evidenced by the record information discussed below) is a significant fact that weighs in favor of finding that MDT’s SDABS couplers are more akin to low-pressure fittings which are not forged steel fittings within the meaning of the scope of the Orders,” Commerce said in the scope ruling.
Subject forged steel fittings are also used in distribution of liquids and gases under high pressure, or of liquids and gases that are corrosive in nature. “Although cement grout is pumped through the SDABS, the ‘distribution’ of the cement grout is both within and on the exterior of the SDABS to fix the SDABS within the rock and/or soil formation. In other words, MDT’s SDABS couplers are not part of a piping system with the purpose of transporting liquids and gases to a particular destination,” Commerce said.
Commerce said comments on its preliminary scope ruling are due in 20 days, and rebuttal comments are due 10 days after that.