New Antidumping and Countervailing Duty Petitions on Brass Rod from Brazil, India, Israel, Mexico, South Africa, and South Korea
Wednesday, October 18, 2023

On April 27, 2023, the American Brass Rod Fair Trade Coalition, Mueller Brass Co., and Wieland Chase LLC filed antidumping duty (AD) and countervailing duty (CVD) petitions on brass rod from Brazil, India, Israel, Mexico, South Africa, and South Korea.

This is one of two AD/CVD petitions filed on April 27, 2023, calling for the imposition of additional duties on certain brass and steel products.

The Coalition, Mueller, and Wieland collectively allege that imports of in scope brass rod from Brazil, India, Israel, Mexico, South Africa, and South Korea are injuring the US domestic industry because they are sold in the United States for less than “normal value” and that imports from India, Israel, and South Korea are unfairly subsidized.

The Coalition, Mueller, and Wieland request the imposition of significant AD duties between 10.20% to 63.76% ad valorem. AD/CVD duties will be imposed if the US Department of Commerce (DOC) determines that such alleged dumping is occurring and if the US International Trade Commission (ITC) determines that there is “material injury” (or the threat thereof) by reason of the dumped or subsidized imports.

If the investigations are initiated, importers of in-scope brass rod from the countries above will be liable for any potential AD and/or CVD duties imposed. These investigations may also impact US purchasers via increased prices or decreased supplies of brass rod. Certain imports of brass rod from China are also currently subject to Section 301 (List 3) duties. Imports of other brass products, such as brass sheet and strip from some of the same countries are already subject to AD/CVD duties.

Scope of Investigation

Per the petition, the scope of this investigation covers brass rod, which is defined as leaded, low-lead, and no-lead solid brass made from alloys such as, but not limited to: Alloys C36000, C37700, C3700, C36300, C27450, C27451, C69300, C35300, C34500, C67600, C35330, C48500, and C67300, and their international equivalents.

The brass rod described in the petitions has a cross-section greater than one quarter of one inch (0.25 inches) outside diameter but less than or equal to 12 inches outside diameter. Brass rod cross-sections may be round, hexagonal, square, or octagonal shapes as well as special profiles (e.g., angles, shapes).

Standard leaded brass rod covered by the scope contains, by weight, 57.0 - 65.0% copper; 1.5 - 3.0% lead; no more than 0.35% iron; and at least 15% zinc. No-lead or low-lead brass rod covered by the scope contains by weight 59.0- 76.0% copper; 0 - 1.5% lead; no more than 0.35%iron; and at least 15%zinc. Brass rod may also include other elements.

The petition also alleges that covered brass rod is finished or unfinished. It may be produced in accordance with ASTM Bl 6, ASTM B124, ASTM B981, ASTM B371, ASTM B453, ASTM B21, ASTM B138, and ASTM B927, but such conformity to an ASTM standard is not required for the merchandise to be included within the scope.

Brass rod is produced by melting and casting into billets or strand casting into rod. Brass rod may or may not be heated, extruded, pickled, or cold-drawn.

Although not dispositive, the brass rod covered by these petitions is currently classifiable under subheadings 7407.21.9000, 7403.21.0000, 7407.21.1500,7407.21.3000, 7407.21.5000, and 7407.21.7000 of the Harmonized Tariff Schedule of the United States (HTSUS).

Estimated AD Margins

The Coalition, Mueller, and Wieland allege the following dumping margins exist:

  • Israel – 20%
  • Brazil – 62.62%
  • Mexico – 63.76%
  • South Africa – 27.99%
  • India – 10.20%
  • South Korea – 12.75%

Estimated Key Dates of Interest to Exporters and Importers

The ITC is evaluating the petition and expected to initiate the investigations quickly. The following are estimated key dates for these investigations, once initiated by the DOC and the ITC:

Estimated Key Dates of Interest

Initial Deadlines: 
ITC Preliminary Injury Phase

approx. May 11, 2023questionnaire responses will be due.
May 18, 2023 – ITC Preliminary Staff Conference
June 12, 2023 - ITC Preliminary injury determination
DOC Initiation Date May 17, 2023

DOC Preliminary 
AD Determinations

October 4, 2023 - AD preliminary determination 
The preliminary results deadline can be extended.

Commerce Preliminary CVD Determinations

July 21, 2023 - CVD preliminary determination 
DOC Preliminary Determination (if ALLIGNED with AD): October 4, 2023 
The preliminary results deadline can be extended.

Earliest Suspension of Liquidation (theoretical) July 6, 2023 – Subject to both affirmative critical circumstances finding by ITC and DOC.
 

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