Lithographic Printing Plates: New AD/CVD Investigations Deadlines & Scope

The Commerce Department issued notices in the Federal Register on its recently initiated antidumping duty investigations on aluminum lithographic printing plates from China and Japan (A-570-156, A-588-881), and its countervailing duty investigation on aluminum lithographic printing plates from China (C-570-157). The CVD investigation covers entries for the calendar year 2022. The AD investigation on Japan covers entries July 1, 2022, through June 30, 2023, and the AD investigation on China covers entries Jan. 1, 2023, through June 30, 2023.

The International Trade Commission will conduct a concurrent investigation to determine whether imports of dumped and illegally subsidized lithographic printing plates are injuring U.S. industry. If the ITC finds no injury in its preliminary injury determination, due Nov. 13, the investigations will immediately end. If Commerce finds dumping or illegal subsidization in the preliminary determinations of these investigations, due in December for CVD and March for AD, it will set AD and/or CVD cash deposit requirements for imports of merchandise subject to the investigation. If both Commerce and the ITC reach affirmative final determinations, Commerce will issue an AD and/or CVD order making duties permanent and beginning a process of annual administrative reviews to set final assessments of AD/CVD on importers and potentially change AD/CVD cash deposit rates.

AD/CVD Respondent Selection

Commerce said it will pick respondents to its AD investigation on Japan and its CVD investigation on China based on CBP import data. Comments are due Oct. 30.

For its AD investigation on China, Commerce will send quantity and value questionnaires to each potential respondent, and will base respondent selection on the responses it receives. Exporters that don't get a quantity and value questionnaire can submit one using the form provided by Commerce. Responses are due Nov. 1.

Scope of the AD/CVD Investigations

“The merchandise covered by this investigation is aluminum lithographic printing plates. Aluminum lithographic printing plates consist of a flat substrate containing at least 90 percent aluminum. The aluminum-containing substrate is generally treated using a mechanical, electrochemical, or chemical graining process, which is followed by one or more anodizing treatments that form a hydrophilic layer on the aluminum-containing substrate. An image-recording, oleophilic layer that is sensitive to light, including but not limited to ultra-violet, visible, or infrared, is dispersed in a polymeric binder material that is applied on top of the hydrophilic layer, generally on one side of the aluminum lithographic printing plate. The oleophilic light-sensitive layer is capable of capturing an image that is transferred onto the plate by either light or heat. The image applied to an aluminum lithographic printing plate facilitates the production of newspapers, magazines, books, yearbooks, coupons, packaging, and other printed materials through an offset printing process, where an aluminum lithographic printing plate facilitates the transfer of an image onto the printed media. Aluminum lithographic printing plates within the scope of this investigation include all aluminum lithographic printing plates, irrespective of the dimensions or thickness of the underlying aluminum substrate, whether the plate requires processing after an image is applied to the plate, whether the plate is ready to be mounted to a press and used in printing operations immediately after an image is applied to the plate, or whether the plate has been exposed to light or heat to create an image on the plate or remains unexposed and is free of any image.

“Subject merchandise also includes aluminum lithographic printing plates produced from an aluminum sheet coil that has been coated with a light-sensitive image-recording layer in a subject country and that is subsequently unwound and cut to the final dimensions to produce a finished plate in a third country (including the United States), or exposed to light or heat to create an image on the plate in a third country (including in a foreign trade zone within the United States).

“Excluded from the scope of this investigation are lithographic printing plates manufactured using a substrate produced from a material other than aluminum, such as rubber or plastic.

“Aluminum lithographic printing plates are currently classifiable under Harmonized Tariff of the United States (HTSUS) subheadings 3701.30.0000 and 3701.99.6060. Further, merchandise that falls within the scope of this investigation may also be entered into the United States under HTSUS subheadings 3701.99.3000 and 8442.50.1000. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of this investigation is dispositive.”

Comments on the scope of these investigations are due by 5 p.m. EST Nov. 7.

Investigations Timetable

These deadlines may be, and usually are, extended. The Commerce Department fact sheet on the initiation of these investigations is (here). See 2310030055 for a summary of the petition requesting these investigations.