On October 4, 2023, the US Aluminum Extruders Coalition and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union (collectively, the "Petitioners") filed an antidumping ("AD") and countervailing ("CVD") duty petition before the U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) concerning aluminum extrusions and merchandise produced from aluminum extrusions.
The petition covers imports from Colombia, the Dominican Republic, Ecuador, India, Indonesia, Italy, Malaysia, Mexico, the People's Republic of China (“China”), the Republic of Korea ("Korea"), Taiwan, Thailand, Turkey, the United Arab Emirates ("UAE"), and Vietnam. While the petition includes allegations of “dumping” – or sales of subject merchandise at less than fair value – against each of these countries, it also includes allegations of unfair and countervailable subsidies that are provided by the governments of Indonesia, Mexico, China, and Turkey. Petitioners allege that the aluminum extrusion manufacturing industry in the U.S. has been materially injured and is threatened with further material injury by the subject imports.
The proposed scope of subject merchandise in these petitions includes all types of aluminum shapes and forms that are produced by an extrusion process. It includes aluminum extrusions “regardless of form, finishing, or fabrication, whether assembled with other parts or unassembled, [and] whether coated, painted, anodized, or thermally improved.” Notably, this scope includes many kinds of downstream products that are manufactured from aluminum extrusions, specifically including vehicle roof rails, solar panel racking rails and framing, tradeshow display fixtures and framing, parts for tents or clear span structures, fence posts, drapery rails or rods, electrical conduits, door thresholds, flooring trim, electric vehicle battery trays, heat sinks, signage or advertising poles, picture frames, telescoping poles, or cleaning system components. The scope also includes aluminum extrusions that are imported in kits or unassembled with other non-aluminum components that are “designed to be a part or subassembly of a larger product or system.”
The case is one of the largest and most expansive AD/CVD petitions filed in recent memory. The total value of imports of aluminum extrusions from the 15 targeted countries in 2022 amounts to $3.19 billion. This petition expands upon AD/CVD orders that were issued in 2011 and that are currently in place for Aluminum Extrusions from China. The proposed scope of subject merchandise in the new petitions, summarized above, expands that of the existing orders to capture various additional types of aluminum extrusions that had been excluded from the 2011 orders, either intentionally or as a result of intervening litigation.
Based on the current deadlines established in the investigation process, the DOC could begin to impose preliminary countervailing duties on subject merchandise from Indonesia, Mexico, China, and/or Turkey by late December 2023, while preliminary antidumping determinations for the 15 covered countries is currently scheduled for mid-March 2024. While these deadlines are subject to change, there is also the potential—depending on the circumstances—for the DOC to impose duties retroactively.
For the proposed scope of the AD/CVD orders, exclusions, dumping/subsidization margins, and the next steps please contact one of the trade professionals listed here.
AD/CVD Investigation Broadly Targets Aluminum Extrusions and Downstream Products