WT/DS523 /2 
 
12 May 2017  
(17-2656) Page: 1/12 
  Original: English  
 
UNITED STATES – COUNTERVAILING MEASU RES ON CERTAIN PIPE  
AND TUBE PRODUCTS FR OM TURKEY  
REQUEST FOR THE ESTA BLISHMENT OF A PANEL  BY TURKEY  
The following communication, dated 11 May 2017 , from the delegation of Turkey  to the 
Chairperson of the Dispute Settlem ent Body, is circulated pursuant to Article 6.2 of the DSU.  
 
_______________  
 
 
 My authorities have instructed me to request the establishment of a panel pursuant to 
Article 6 of the WTO Understanding on Rules and Procedures Governing the Settlement of Dis putes  
("DSU"), Article XXIII of the General Agreement on Tariffs and Trade 1994  (GATT 1994), and 
Article 30 of the Agreement on Subsidies and Countervailing Measures  (SCM Agreement) with 
respect to the preliminary and final countervailing duty measures imp osed by the United States on 
Turkish imports of Certain Oil Country Tubular Goods ( "OCTG "); Welded Line Pipe ( "WLP"); Heavy 
Walled Rectangular Welded Carbon Steel Pipes and Tubes ( "HWRP "); and Circular Welded Carbon 
Steel Pipes and Tubes ( "CWP"). 
Backgroun d 
1. On 8 March 2017, Turkey requested consultations with the Government of the United States 
pursuant to Articles 1 and 4 of the DSU, Article XXII:1 of the GATT 1994, and Article 30 of the 
SCM Agreement, with regard to the aforementioned preliminary and f inal countervailing duty 
measures imposed by the United States.  
2. Consultations were held on 28 April 2017.  Unfortunately, the consultations failed to settle 
the dispute. Therefore, Turkey respectfully requests, pursuant to A rticle 6 of the DSU and 
Article 30 of the SCM Agreement, that a Panel be established with the standard terms of reference 
as set out in Article 7.1 of the DSU with respect to the following matter:   
Measures at Issue  
3. The United States initiated a countervailing duty investigation o f OCTG from Turkey (C -489-
817) on 29 July 2013. The United States issued a negative preliminary countervailing duty 
determination on 23 December 2013, and an affirmative final countervailing duty determination on 
18 July 2014.  The United States issued an affirmative final injury determination in September 
2014, and issued an order imposing final countervailing duty measures on 10 September 2014.  A 
non-exhaustive list of the determinations, memoranda, etc. issued or relied upon by the United 
States on the record of this proceeding is attached in Annex 1 . These measures continue to be in 
force.  
4. The United States initiated a countervailing duty investigation of WLP from Turkey (C -489-
823) on 13 November 2014. The United States issued an affirmative prelimi nary countervailing 
duty determination and imposed provisional countervailing duty measures on 20 March 2015.  The 
United States issued an affirmative final countervailing duty determination on 13 October 2015 , 
and an affirmative final injury determination  in November 2015.  The United States issued an 
order imposing final countervailing duty measures on 1 December 2015 .  A non -exhaustive list of 
the determinations, memoranda, etc. issued or relied upon by the United States on the record of 
this proceeding is attached in Annex 1 . These measures continue to be in force.  WT/DS523/2  
 
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  5. The United States initiated a countervailing duty investigation of HWRP from Turkey (C -489-
825) on 17 August 2015. The United States issued an affirmative preliminary countervailing duty 
determination and imposed provisional countervailing duty measures on 28 December 2015. The 
United States issued an affirmative final countervailing duty determination on 21 July 2016, and an 
affirmative final injury determination in September 2016. The Unit ed States issued an amended 
final countervailing duty determination and an order imposing final countervailing duty measures 
on 13 September 2016. A non -exhaustive list of the determinations, memoranda, etc. issued or 
relied upon by the United States on th e record of this proceeding is attached in Annex 1 .  These 
measures continue to be in force.  
6. The United States issued an order imposing countervailing duties on CWP from Turkey (C -
489-502) on 7 March 1986.  The United States has conducted several five -year "sunset " reviews of 
this order, most recently including the third five -year review of the order. The United States issued 
its final determination in the third five -year review of the order in 19 October 2011 and issued a 
continuation of the order on 17  July 2012. The United States has also conducted several 
administrative reviews of the order, initiating its administrative review for calendar year 2013 on 
30 April 2014.  The United States issued a final determination in this administrative review on 13 
October 2015, and an amended final determination on 13 November 2015.  A non -exhaustive list 
of the determinations, memoranda, etc. issued or relied upon by the United States on the record 
of this proceeding is attached in Annex 1 . These measures continue to be in force.  
7. This request covers the determination by the United States to initiate the identified 
countervailing duty proceedings, the conduct of those proceedings, any preliminary or final 
countervailing duty or injury determinations issued in thos e proceedings, and any definitive 
countervailing duties imposed as a result of those proceedings.  This request also covers certain 
practices followed by the United States in the identified countervailing duty proceedings related to 
the cumulation of subsi dized and non -subsidized imports in the assessment of injury and the 
rejection of in -country prices in the assessment of benefit. This request also covers any 
amendments, redeterminations, or other subsequent measures in connection with the measures 
cited herein.  
Legal Basis of the Complaint  
8. Turkey considers that the United States ' determinations and the countervailing duty 
measures imposed in the aforementioned proceedings, and/or the specific practices on which such 
determinations and measures were bas ed, are inconsistent with Articles 1, 2, 12, 14, and 15 of the 
SCM Agreement as follows:  
(A) OCTG from Turkey (C -489-817)  
 In connection with the alleged Provision of Hot Rolled Steel for Less Than 
Adequate Remuneration:  
1. Article 1.1(a)(1) of the SCM Agreem ent 
a.   In determining that OYAK is a "public body, " the U.S. Department of 
Commerce ( "USDOC ") failed to adhere to the appropriate legal standard under 
Article 1.1(a)(1) and follow the Appellate Body 's guidance regarding the 
interpretation of that standard.  Instead, the USDOC determined that OYAK is 
a public body based on formal indicia of government ownership or control, with 
no consideration of whether OYAK in fact exercises or is vested with 
governmental authority.  The USDOC also failed to provide a reas oned and 
adequate explanation, based on the evidence on the record, for its finding that 
OYAK is a public body.  
b.   In determining that Eregli Demir ve Celik Fabrikalari T.A.S. ( "Erdemir ") and its 
subsidiary, Iskenderun Iron & Steel Works Co. ( "Isdemir "), are "public bodies, " 
the USDOC failed to adhere to the appropriate legal standard under  
Article  1.1(a)(1) and follow the Appellate Body 's guidance regarding the 
interpretation of that standard. The USDOC 's determination was improperly 
confined to formal indi cia of government ownership or control, with no WT/DS523/2  
 
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  consideration of whether Erdemir and its subsidiary Isdemir in fact exercise or 
are vested with governmental authority. The USDOC also failed to provide a 
reasoned and adequate explanation, based on the evide nce on the record, for 
its finding that Erdemir and its subsidiary Isdemir are public bodies.  
2. Article 1.1(b) and 14(d) of the SCM Agreement  
a.  The USDOC has a practice, in assessing whether a good is provided for less 
than adequate remuneration thereby confe rring a benefit, of rejecting in -
country prices as a benchmark based solely on evidence that the government 
owns or controls the majority or a substantial portion of the market for the 
good, with no consideration of whether in -country prices are distorted.  Turkey 
considers that this USDOC practice is inconsisten t with Article 14(d) of the 
SCM Agreement both "as such ", as a practice, and as applied in this 
investigation.  
b.  The USDOC failed to conduct a proper analysis of whether in -country prices for 
hot roll ed steel are market determined, and therefore improperly rejected in -
country prices as the benchmark for less than adequate remuneration under 
Article 14(d).  
c.  The USDOC failed to establish that the provision of hot rolled steel by Erdemir 
and Isdemir confe rred a benefit within the meaning of Article 1.1(b).  
3. Article 12.7 of the SCM Agreement  
a.  The USDOC failed to take due account of difficulties Borusan Istikbal Ticaret 
and Borusan Mannesmann Boru Sanayi (collectively "Borusan ") experienced in 
gathering and r eporting information requested by the USDOC.  
b.  The USDOC drew adverse inferences in selecting among the facts available for 
the purpose of punishing Borusan for its alleged failure to cooperate.  
4. Articles 2.1(c) and 2.4 of the SCM Agreement  
a.  In finding speci ficity in terms of use by a limited number of industries or 
enterprises, the USDOC failed to identify, or substantiate based on positive 
evidence on the record, a "subsidy programme " related to the alleged 
provision of hot rolled steel for less than adequa te remuneration.  
b.  The USDOC failed to consider the extent of diversification of the Turkish 
economy or the length of time the alleged subsidy programme has been in 
operation.  
In connection with the injury determination:  
5. Article 15.3 of the SCM Agreement  
a.  The U.S. International Trade Commission ( "ITC") has a practice, in assessing 
material injury, of cumulating imports that are subject to countervailing duty 
investigations with imports that are subject only to antidumping duty 
investigations, i.e., non -subsidized imports, from all countries with respect to 
which antidumping or countervailing duty petitions are filed on the same day.  
In investigations, the ITC considers this practice to be required under section 
771(7)(G)(i) of the Tariff Act of 1930, if the subsidized and non -subsidized 
imports compete with each other and with the domestic like product in the 
U.S. market.  
b.  Turkey considers that the ITC 's practice of "cross-cumulating " subsidized and 
non-subsidized imports, with respect to which antidumping or  countervailing 
duty petitions are filed on the same day, is inconsistent with Article 15.3 of the WT/DS523/2  
 
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  SCM Agreement both "as such ", as a practice, and as applied in this 
proceeding.  
(B) WLP from Turkey (C -489-823)  
In connection with the alleged Provision of H ot Rolled Steel for Less Than 
Adequate Remuneration:  
1. Article 1.1(a)(1) of the SCM Agreement  
a.  In determining that OYAK is a "public body, " the USDOC failed to adhere to the 
appropriate legal standard under Article 1.1(a)(1) and follow the Appellate 
Body's guidance regarding the interpretation of that standard. Instead, the 
USDOC determined that OYAK is a public body based on formal indicia of 
government ownership or control, with no consideration of whether OYAK in 
fact exercises or is vested with government al authority. The USDOC also failed 
to provide a reasoned and adequate explanation, based on the evidence on the 
record, for its finding that OYAK is a public body.  
b.  In determining that Erdemir and its subsidiary Isdemir are "public bodies, " the 
USDOC fail ed to adhere to the appropriate  legal standard under  
Article  1.1(a)(1) and follow the Appellate Body 's guidance regarding the 
interpretation of that standard. The USDOC 's determination was improperly 
confined to formal indicia of government ownership or co ntrol, with no 
consideration of whether Erdemir and its subsidiary Isdemir in fact exercise or 
are vested with governmental authority. The USDOC also failed to provide a 
reasoned and adequate explanation, based on the evidence on the record, for 
its findin g that Erdemir and its subsidiary Isdemir are public bodies.  
2. Article 12.7 of the SCM Agreement  
a.  The USDOC drew adverse inferences in selecting among the facts available for 
the purpose of punishing Borusan for its alleged failure to cooperate.  
3. Articles 2.1 (c) and 2.4 of the SCM Agreement  
a.  In finding specificity in terms of use by a limited number of industries or 
enterprises, the USDOC failed to identify, or substantiate based on positive 
evidence on the record, a "subsidy programme " related to the provisio n of hot 
rolled steel for less than adequate remuneration.  
b.  The USDOC failed to consider the extent of diversification of the Turkish 
economy or the length of time the alleged subsidy programme has been in 
operation.  
In connection with the injury determina tion:  
4. Article 15.3 of the SCM Agreement  
a.  The U.S. International Trade Commission ( "ITC") has a practice, in assessing 
material injury, of cumulating imports that are subject to countervailing duty 
investigations with imports that are subject only to antidu mping duty 
investigations, i.e., non -subsidized imports, from all countries with respect to 
which antidumping or countervailing duty petitions are filed on the same day.  
In investigations, the ITC considers this practice to be required under section 
771(7 )(G)(i) of the Tariff Act of 1930, if the subsidized and non -subsidized 
imports compete with each other and with the domestic like product in the 
U.S. market.  
b.  Turkey considers that the ITC 's practice of "cross-cumulating " subsidized and 
non-subsidized imp orts, with respect to which antidumping or countervailing WT/DS523/2  
 
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  duty petitions are filed on the same day, is inconsistent with Article 15.3 of the 
SCM Agreement both "as such ", as a practice, and as applied in this 
proceeding.  
 (C) HWRP from Turkey (C -489-825)  
In connection with the alleged Provision of Hot Rolled Steel for Less Than 
Adequate Remuneration:  
1. Article 1.1(a)(1) of the SCM Agreement  
a.   In determining that OYAK is a "public body, " the USDOC failed to adhere to 
the appropriate legal standard under Articl e 1.1(a)(1) and follow the Appellate 
Body's guidance regarding the interpretation of that standard.  Instead, the 
USDOC determined that OYAK is a public body based on formal indicia of 
government ownership or control, with no consideration of whether OYAK in 
fact exercises or is vested with governmental authority.  The USDOC also failed 
to provide a reasoned and adequate explanation, based on the evidence on the 
record, for its finding that OYAK is a public body.  
b.   In determining that Erdemir and its subsid iary Isdemir are "public bodies, " the 
USDOC failed to adhere to the appropriate legal standard under Article 
1.1(a)(1) and follow the Appellate Body 's guidance regarding the interpretation 
of that standard.  The USDOC 's determination was improperly confine d to 
formal indicia of government ownership or control, with no consideration of 
whether Erdemir and its subsidiary Isdemir in fact exercise or are vested with 
governmental authority. The USDOC also failed to provide a reasoned and 
adequate explanation, ba sed on the evidence on the record, for its finding that 
Erdemir and its subsidiary Isdemir are public bodies.  
2. Articles 2.1(c) and 2.4 of the SCM Agreement  
a.   In finding specificity in terms of use by a limited number of industries or 
enterprises, the USDOC failed to identify, or substantiate based on positive 
evidence on the record, a "subsidy programme " related to the provision of hot 
rolled steel for less than adequate remuneration.  
b.  The USDOC failed to consider the extent of diversification of the Turkish  
economy or the length of time the alleged subsidy programme has been in 
operation.  
In connection with "other subsidies " not previously reported to the USDOC:  
3. Article 12.7 of the SCM Agreement  
a.  The USDOC drew adverse inferences in selecting among the facts  available for 
the purpose of punishing MMZ Onur Boru Profil uretim Sanayi Ve Tic. A.S. 
("MMZ") and Ozdemir Boru Profil Sanayi ve Tic. Ltd. Sti. ( "Ozdemir ") for their 
alleged failure to cooperate.  
In connection with the injury determination:  
4. Article 15.3 o f the SCM Agreement  
a.  The U.S. International Trade Commission ( "ITC") has a practice, in assessing 
material injury, of cumulating imports that are subject to countervailing duty 
investigations with imports that are subject only to antidumping duty 
investiga tions, i.e., non -subsidized imports, from all countries with respect to 
which antidumping or countervailing duty petitions are filed on the same day.  
In investigations, the ITC considers this practice to be required under section 
771(7)(G)(i) of the Tarif f Act of 1930, if the subsidized and non -subsidized WT/DS523/2  
 
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  imports compete with each other and with the domestic like product in the 
U.S. market.  
b.  Turkey considers that the ITC 's practice of "cross-cumulating " subsidized and 
non-subsidized imports, with respect t o which antidumping or countervailing 
duty petitions are filed on the same day, is inconsistent with Article 15.3 of the 
SCM Agreement both "as such ", as a practice, and as applied in this 
proceeding.  
 (D) CWP from Turkey (C -489-502)  
In connection with the  alleged Provision of Hot Rolled Steel for Less Than 
Adequate Remuneration:  
1. Article 1.1(a)(1) of the SCM Agreement  
a.  In determining that OYAK is a "public body, " the USDOC failed to adhere to the 
appropriate legal standard under Article 1.1(a)(1) and follow  the Appellate 
Body's guidance regarding the interpretation of that standard. Instead, the 
USDOC determined that OYAK is a public body based on formal indicia of 
government ownership or control, with no consideration of whether OYAK in 
fact exercises or is  vested with governmental authority. The USDOC also failed 
to provide a reasoned and adequate explanation, based on the evidence on the 
record, for its finding that OYAK is a public body.  
b.  In determining that Erdemir and its subsidiary Isdemir are "public bodies, " the 
USDOC failed to adhere to the appropriate legal standard under  
Article  1.1(a)(1) and follow the Appellate Body 's guidance regarding the 
interpretation of that standard. The USDOC 's determination was improperly 
confined to formal indicia of gov ernment ownership or control, with no 
consideration of whether Erdemir and its subsidiary Isdemir in fact exercise or 
are vested with governmental authority. The USDOC also failed to provide a 
reasoned and adequate explanation, based on the evidence on the  record, for 
its finding that Erdemir and its subsidiary Isdemir are public bodies.  
2. Articles 2.1(c) and 2.4 of the SCM Agreement  
a.  In finding specificity in terms of use by a limited number of industries or 
enterprises, the USDOC failed to identify, or subs tantiate based on positive 
evidence on the record, a "subsidy programme " related to the provision of hot 
rolled steel for less than adequate remuneration.  
b.  The USDOC failed to consider the extent of diversification of the Turkish 
economy or the length of t ime the alleged subsidy programme has been in 
operation.  
In connection with the injury determination:  
3. Article 15.3 of the SCM Agreement  
a.  The U.S. International Trade Commission ( "ITC") has a practice, in assessing 
material injury, of cumulating imports tha t are subject to countervailing duty 
investigations with imports that are subject only to antidumping duty 
investigations, i.e., non -subsidized imports, from all countries with respect to 
which antidumping or countervailing duty petitions are filed on the same day.  
In five -year reviews, the ITC considers cumulation to be discretionary under 
section 1675a of the Tariff Act of 1930, but as a matter of practice the ITC 
cumulates subsidized and non -subsidized imports if the subject imports are 
likely to compet e with each other and the domestic like product in the U.S. 
market, and if subject imports are not likely to have no discernible adverse 
impact on the domestic industry.  WT/DS523/2  
 
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  b.  Turkey considers that the ITC 's practice of "cross-cumulating " subsidized and 
non-subsidized imports, with respect to which five -year reviews of antidumping 
or countervailing duty orders are initiated on the same day, is inconsistent with 
Article 15.3 of the SCM Agreement both "as such ", as a practice, and as 
applied in this proceeding.  
9. To the extent that the United States ' practices described above  are inconsistent with 
Articles  1.1(a)(1), 1.1(b), 2.1(c), 12.7, 14(d) and 15.3 of the SCM Agreement, the United States is 
also in violation of its obligations under Article VI:3 of the GATT 1 994 and Articles 10, 19.4, and 
32.1 of the SCM Agreement.  
10. Turkey considers that the measures at issue have a serious adverse effect on the export of 
subject merchandise from Turkey to the United States. Turkey further considers that the measures 
also c ause nullification or impairment of benefits accruing to Turkey under the aforementioned 
covered agreements.  
11. Turkey therefore respectfully requests that the Dispute Settlement Body establish a panel to 
examine this matter, with the standard terms of re ference as set out in Article 7.1 of the DSU and 
asks that this request for the establishment of a Panel be placed on the agenda of the 
DSB meeting to be held on 22 May 2017.  
 
_______________  
 
 WT/DS523/2  
 
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  Annex I  
C-489-817: Certain Oil Country Tubular Goods from Tur key 
1. Certain Oil Country Tubular Goods from India and Turkey: Initiation of Countervailing 
Duty Investigations , 78 FR 45502 (July 29, 2013).  
2. Decision Memorandum for the Negative Preliminary Determination in the Countervailing 
Duty Investigation of Certain O il Country Tubular Goods from the Republic of Turkey  
(December 16, 2013).  
3. Countervailing Duty Investigation of Certain Oil Country Tubular Goods from the Republic 
of Turkey: Preliminary Determination Calculation Memorandum for Borusan Mannesmann 
Boru Sanay i ve Ticaret A.S., Borusan Istikbal Ticaret, Borusan Mannesmann Boru Yatirim 
Holding A.S., and Borusan Holding A.S. (collectively, "Borusan")  (December 16, 2013).  
4. Countervailing Duty Investigation of Certain Oil Country Tubular Goods from the Republic 
of Turkey: Preliminary Determination Calculation Memorandum for Tosçelik Profil ve Sac 
Endustrisi A.S., Tosyali Dis Ticaret A.S., Tosyali Elektrik Enerjisi Toptan Satis Ith. Ihr. 
A.S., Tosyali Holding A.S., and Tosyali Demir Celik San. A.S. (collectively, "Tos celik")  
(December 16, 2013).  
5. Countervailing Duty Investigation of Certain Oil Country Tubular Goods (OCTG) from the 
Republic of Turkey (Turkey): Analysis of New Subsidy Allegations  (December 17, 2013).  
6. Certain Oil Country Tubular Goods from the Republic of  Turkey: Preliminary Negative 
Countervailing Duty Determination and Alignment of Final Determination with Final 
Antidumping Determination , 78 FR 77420 (December 23, 2013).  
7. Countervailing Duty Investigation of Certain Oil Country Tubular Goods from the Repu blic 
of Turkey: Post -Preliminary Analysis Memorandum for Borusan Mannesmann Boru Sanayi 
ve Ticaret A.S. ("BMB"), Borusan Istikbal Ticaret ("Istikbal"), Borusan Mannesmann Boru 
Yatirim Holding A.S., and Borusan Holding A.S. (collectively, "Borusan")  (April 18, 2014).  
8. Countervailing Duty Investigation of Certain Oil Country Tubular Goods from the Republic 
of Turkey: Post -Preliminary Analysis Memorandum for Borusan Mannesmann Boru Sanayi 
ve Ticaret A.S. ("BMB"), Borusan Istikbal Ticaret ("Istikbal"), Borusan M annesmann Boru 
Yatirim Holding A.S., and Borusan Holding A.S. (collectively, "Borusan"): Calculation 
Attachments  (April 18, 2014).  
9.   Countervailing Duty Investigation of Certain Oil Country Tubular Goods from the Republic 
of Turkey: Post -Preliminary Analys is Memorandum for Tosçelik Profil ve Sac Endustrisi A.S. 
("Toscelik Profil"), Tosyali Dis Ticaret A.S., Tosyali Elektrik Enerjisi Toptan Satis Ith. Ihr. 
A.S., Tosyali Holding A.S., and Tosyali Demir Celik San. A.S. (collectively, "Toscelik")  
(April  18, 201 4). 
10. Countervailing Duty Investigation of Certain Oil Country Tubular Goods from the Republic 
of Turkey: Post -Preliminary Analysis Memorandum for Tosçelik Profil ve Sac Endustrisi 
A.S. ("Toscelik Profil"), Tosyali Dis Ticaret A.S., Tosyali Elektrik Enerjisi  Toptan Satis Ith. 
Ihr. A.S., Tosyali Holding A.S., and Tosyali Demir Celik San. A.S. (collectively, "Toscelik"): 
Calculation Attachments  (April 18, 2014).  
11. Countervailing Duty Investigation: Certain Oil Country Tubular Goods from the Republic of 
Turkey: Ve rification Report: Government of the Republic of Turkey  (May 12, 2014).  
12. Countervailing Duty Investigation: Certain Oil Country Tubular Goods from the Republic of 
Turkey: Verification Report: Tosyali Dis Ticaret A.S., Tosyali Elektrik Enerjisi Toptan Satis 
Ith. Ihr. A.S., Tosyali Holding A.S.,Tosçelik Profil ve Sac Endustrisi A.S., and Tosyali 
Demir Celik San. A.S. (collectively, "Toscelik")  (May 12, 2014).  WT/DS523/2  
 
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  13. Countervailing Duty Investigation: Certain Oil Country Tubular Goods from the Republic of 
Turkey: Veri fication Report: Borusan Mannesmann Boru Sanayi ve Ticaret A.S.,, Borusan 
Istikbal Ticaret, Borusan Mannesmann Boru Yatirim Holding A.S., and Borusan Holding 
A.S. (collectively, "Borusan")  (May 15, 2014).  
14. Issues and Decision Memorandum for the Final Determ ination in the Countervailing Duty 
Investigation of Certain Oil Country Tubular Goods from the Republic of Turkey  
(July 10, 2014).  
15. Countervailing Duty Investigation of Certain Oil Country Tubular Goods from the Republic 
of Turkey: Final Determination Calcu lation Memorandum for Borusan Mannesmann Boru 
Sanayi ve Ticaret A.S., Borusan Istikbal Ticaret, Borusan Mannesmann Boru Yatirim 
Holding A.S., and Borusan Holding A.S. (collectively, "Borusan")  (July 10, 2014).  
16. Countervailing Duty Investigation of Certain O il Country Tubular Goods from the Republic 
of Turkey: Final Determination Calculation Memorandum for Tosçelik Profil ve Sac 
Endustrisi A.S., Tosyali Dis Ticaret A.S., Tosyali Elektrik Enerjisi Toptan Satis Ith. Ihr. 
A.S., Tosyali Holding A.S., and Tosyali Demir Celik San. A.S. (collectively, "Toscelik")  
(July 10, 2014).  
17. Certain Oil Country Tubular Goods From the Republic of Turkey: Final Affirmative 
Countervailing Duty Determination and Final Affirmative Critical Circumstances 
Determination , 79 FR 41964 (Ju ly 18, 2014).  
18. Certain Oil Country Tubular Goods from India, Korea, the Philippines, Taiwan, Thailand, 
Turkey, Ukraine, and Vietnam , Investigation Nos. 701 -TA-499-500 and 731 -TA-1215-
1217 and 1219 -1223 (Final), International Trade Commission Publication 448 9 
(September 2014).  
19. Certain Oil Country Tubular Goods from India and the Republic of Turkey: Countervailing 
Duty Orders and Amended Affirmative Final Countervailing Duty Determination for India , 
79 FR 53688 (September 10, 2014).  
20. Office of Policy Memorandum , Section 129 Determination of the Countervailing Duty 
Investigation of Circular Welded Carbon Quality Steel Pipe; Light -Walled Rectangular Pipe 
and Tube; Laminated Woven Sacks; and Off -the-Road Tires from the People 's Republic of 
China: An Analysis of Pub lic Bodies in the People 's Republic of China in Accordance with 
the WTO Appellate Body 's Findings in WTO DS379  (May 18, 2012).  
21. Draft Remand Redetermination Calculations for Borusan Mannesmann Boru Sanayi ve 
Ticaret A.S. and Borusan Istikbal Ticaret (collec tively, Borusan) and Toscelik Profil ve Sac 
Endustrisi A.S. (Toscelik)  (July 20, 2015).  
22. Final Results of Remand Redetermination: Borusan Mannesmann Boru Sanayi Ve Ticaret 
A.S. and Borusan Istikbal Ticaret v. United States; Maverick Tube Corporation v. Unit ed 
States, Consol. Ct. No. 14 -00229, 61 F. Supp. 3d 1306 and Slip Op. 15 -59 
(August  31, 2015).  
C-489-823: Welded Line Pipe from Turkey  
1. Welded Line Pipe from the Republic of Korea and the Republic of Turkey: Initiation of 
Countervailing Duty Investigations , 79 FR 67419 (November 13, 2014).  
2. Decision Memorandum for the Affirmative Preliminary Determination in the Countervailing 
Duty Investigation of Welded Line Pipe from the Republic of Turkey  (March 16, 2015).  
3. Countervailing Duty Investigation: Welded Line Pi pe from the Republic of Turkey: 
Preliminary Determination Calculation Memorandum for Tosçelik Profil ve Sac Endustrisi 
A.S. (Toscelik Profil), Tosyali Dis Ticaret A.S. (Tosyali Dis), Tosyali Elektrik Enerjisi Toptan 
Satis Ith. Ihr. A.S., Tosyali Holding A. S., and Tosyali Demir Celik San. A.S. (Tosyali 
Demir) (collectively, Toscelik)  (March 16, 2015).  WT/DS523/2  
 
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  4. Countervailing Duty Investigation: Welded Line Pipe from the Republic of Turkey: 
Preliminary Determination Calculation Memorandum for Borusan Mannesmann Boru 
Sanayi ve Ticaret A.S. (BMB) and Borusan Istikbal Ticaret (Istikbal) (collectively, Borusan)  
(March 16, 2015).  
5. Countervailing Duty Investigation: Welded Line Pipe from the Republic of Turkey: 
Recalculation of Percentage of Domestic Supply of Hot -Rolled Stee l (HRS) Accounted for 
by Eregli Demir ve Celik Fabrikalari T.A.S. (Erdemir) and Iskenderun Iron & Steel Works 
Co. (Isdemir) (March 16, 2015).  
6. Welded Line Pipe From the Republic of Turkey: Preliminary Affirmative Countervailing 
Duty Determination and Alignm ent of Final Determination With Final Antidumping 
Determination , 80 FR 14943 (March 20, 2015).  
7. Countervailing Duty Investigation of Welded Line Pipe from Turkey: Ministerial Error 
Allegations in the Preliminary Determination  (April 10, 2015).  
8. Countervailin g Duty Investigation: Welded Line Pipe from the Republic of Turkey: 
Verification of Questionnaire Responses of Toscelik Profil ve Sac Endustrisi A.S.  
(June  9, 2015).  
9. Countervailing Duty Investigation: Welded Line Pipe from the Republic of Turkey: 
Verificat ion of Questionnaire Responses of the Government of Turkey (GOT)  
(June  18, 2015).  
10. Issues and Decision Memorandum for the Final Determination in the Countervailing Duty 
Investigation of Welded Line Pipe from the Republic of Turkey  (October 5, 2015).  
11. Counter vailing Duty Investigation: Welded Line Pipe from the Republic of Turkey: Final 
Determination Calculation Memorandum for Tosçelik Profil ve Sac Endustrisi A.S. (Toscelik 
Profil), Tosyali Dis Ticaret A.S., Tosyali Elektrik Enerjisi Toptan Satis Ith. Ihr. A. S., Tosyali 
Holding A.S., and Tosyali Demir Celik San. A.S. (collectively, Toscelik)  (October 5, 2015).  
12. Welded Line Pipe From the Republic of Turkey: Final Affirmative Countervailing Duty 
Determination , 80 FR 61371 (October 13, 2015).  
13. Certain Welded Line P ipe from Korea and Turkey , Investigation Nos. 701 -TA-525 and 
731-TA-1260-1261 (Final), International Trade Commis sion Publication 4580 
(November  2015).  
14. Welded Line Pipe From the Republic of Turkey: Countervailing Duty Order , 80 FR 75054 
(December 1, 2015).  
C-489-825: Heavy Walled Rectangular Welded Carbon Steel Pipes and Tubes from 
Turkey  
1. Heavy Walled Rectangular Welded Carbon Steel Pipes and Tubes from the Republic of 
Turkey: Initiation of Countervailing Duty Investigation , 80 FR 49207 (August 17, 2015).  
2. Countervailing Duty Investigation of Heavy Walled Rectangular Welded Carbon Steel Pipes 
and Tubes from the Republic of Turkey: Preliminary Determination Calculations for 
Ozdemir Boru Profil San ve Tic. Ltd. Sti.  (December 18, 2015).  
3. Countervailing Duty Inve stigation of Heavy Walled Rectangular Welded Carbon Steel Pipes 
and Tubes from the Republic of Turkey: Preliminary Determination Calculations for MMZ 
Onur Boru Profil uretim San Ve Tic. A.S.  (December 18, 2015).  
4. Countervailing Duty Investigation of Heavy W alled Rectangular Welded Carbon Steel Pipes 
and Tubes from the Republic of Turkey: Decision Memorandum for the Preliminary 
Determination (December 18, 2015).  WT/DS523/2  
 
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  5. Countervailing Duty Investigation of Heavy Walled Rectangular Welded Carbon Steel Pipes 
and Tubes from the Republic of Turkey: Additional Information  (December 21, 2015).  
6. Heavy Walled Rectangular Welded Carbon Steel Pipes and Tubes from the Republic of 
Turkey: Preliminary Affirmative Countervailing Duty Determination and Alignment of Final 
Determinatio n With Final Antidumping Determination , 80 FR 80749 (December 28, 2015).  
7. Countervailing Duty Investigation of Heavy Walled Rectangular Welded Carbon Steel Pipes 
and Tubes from the Republic of Turkey: Ministerial Error Allegations on the Preliminary 
Determi nation  (January 21, 2016).  
8. Countervailing Duty Investigation of Heavy Walled Rectangular Welded Carbon Steel Pipes 
and Tubes from the Republic of Turkey: Verification of the Questionnaire Responses of 
MMZ Onur Boru Profil uretim San Ve Tic. A.S. (March 10,  2016).  
9. Countervailing Duty Investigation of Heavy Walled Rectangular Welded Carbon Steel Pipes 
and Tubes from the Republic of Turkey: Verification of the Questionnaire Responses of 
Ozdemir Boru Profil San ve Tic. Ltd Sti. (March 10, 2016).  
10. Countervailing Duty Investigation of Heavy Walled Rectangular Welded Carbon Steel Pipes 
and Tubes from the Republic of Turkey: Issues and Decision Memorandum for the Final 
Determination  (July 14, 2016).  
11. Heavy Walled Rectangular Welded Carbon Steel Pipes and Tubes From th e Republic of 
Turkey: Final Affirmative Countervailing Duty Determination , 81 FR 47349 
(July 21, 2016).  
12. Countervailing Duty Investigation of Heavy Walled Rectangular Welded Carbon Steel Pipes 
and Tubes from the Republic of Turkey: Amended Final Determinati on Subsidy Rate for 
MMZ Onur Boru Profil uretim San Ve Tic. A.S.  (August 19, 2016).  
13. Countervailing Duty Investigation of Heavy Walled Rectangular Welded Carbon Steel Pipes 
and Tubes from the Republic of Turkey: Ministerial Error Allegations in the Final 
Determination  (August 19, 2016).  
14. Heavy Walled Rectangular Welded Carbon Steel Pipes and Tubes from Korea, Mexico, and 
Turkey , Investigation Nos. 701 -TA-539 and 731 -TA-1280-1282 (Final), International 
Trade Commission Publication 4633 (September 2016).  
15. Heavy Walled Rectangular Welded Carbon Steel Pipes and Tubes From the Republic of 
Turkey: Amended Final Affirmative Countervailing Duty Determination and Countervailing 
Duty Order , 81 FR 62874 (September 13, 2016).  
C-489-502: Circular Welded Carbon Steel Pipes a nd Tubes from Turkey  
1. Countervailing Duty Order; Certain Welded Carbon Steel Pipe and Tube Products from 
Turkey , 51 FR 7984 (March 7, 1986).  
2. Welded Carbon Steel Pipe and Tube from Turkey: Final Results of Expedited Sunset 
Review of Countervailing Duty Order , 76 FR 64900 (October 19, 2011).  
3. Certain Circular Welded Pipe and Tube from Brazil, India, Korea, Mexico, Taiwan, 
Thailand, and Turkey , Investigation Nos. 701 -TA-253 and 731 -TA-132, 252, 271, 273, 
532-534 and 536 (Third Review), International Trade Co mmis sion Publication 4333 
(June  2012).  
4. Certain Circular Welded Pipe and Tube from Brazil, India, Korea, Mexico, Taiwan, 
Thailand, and Turkey , 77 FR 39736 (July 5, 2012).  
5. Certain Circular Welded Carbon Steel Pipes and Tubes from India, Thailand, and Turkey; 
Certain Circular Welded Non -Alloy Steel Pipe from Brazil, Mexico, the Republic of Korea, WT/DS523/2  
 
- 12 - 
 
  and Taiwan; and Certain Circular Welded Carbon Steel Pipes and Tubes from Taiwan: 
Continuation of Antidumping and Countervailing Duty Orders , 77 FR 41967 
(July 17, 2012).  
6. Initiation of Antidumping and Countervailing Duty Administrative Reviews and Request for 
Revocation in Part , 79 FR 24398 (April 30, 2014).  
7. Administrative Review of the Countervailing Duty Order on Welded Carbon Steel Pipes 
and Tubes from Turkey; 2013: New  Subsidy Allegation Memorandum  
(November  6, 2014).  
8. Countervailing Duty Administrative Review: Circular Welded Carbon Steel Pipes and Tubes 
from Turkey: Verification of Information Submitted by the Government of Turkey  
(March  31, 2015).  
9. Countervailing Duty Administrative Review: Circular Welded Carbon Steel Pipes and Tubes 
from Turkey: Verification of the Questionnaire Responses submitted by Borusan 
Mannesmann Boru Sanayi ve Ticaret A.S. (BMB), and Borusan Istikbal Ticaret T.A.S. 
(Istikbal), (collectively, B orusan)  (March 31, 2015).  
10. Decision Memorandum for the Preliminary Results of Countervailing Duty (CVD) 
Administrative Review: Circular Welded Carbon Steel Pipes and Tubes from Turkey , POR 
01/01/13 -12/31/13  (March 31, 2015).  
11. Administrative Review of Counter vailing Duty Order on Certain Welded Carbon Steel 
Standard Steel Pipes and Tubes from Turkey: Preliminary Calculations for the Borusan 
Group, Borusan Mannesmann Boru Sanayi ve Ticaret A.S. (BMB), and Borusan Istikbal 
Ticaret T.A.S. (Istikbal), (collectivel y, Borusan)  (March 31, 2015).  
12. Circular Welded Carbon Steel Pipes and Tubes From Turkey: Preliminary Results of 
Countervailing Duty Administrative Review and Preliminary Intent To Rescind in Part; 
Calendar Year 2013 , 80 FR 18809 (April 8, 2015).  
13. Decision Me morandum for the Final Results of Countervailing Duty Administrative Review: 
Circular Welded Carbon Steel Pipes and Tubes from Turkey , POR 01/01/13 -12/31/13  
(October 5, 2015).  
14. Administrative Review of Countervailing Duty Order on Certain Welded Carbon Stee l 
Standard Steel Pipes and Tubes from Turkey: Final Calculations for the Borusan Group, 
Borusan Mannesmann Boru Sanayi ve Ticaret A.S. (BMB), and Borusan Istikbal Ticaret 
T.A.S. (Istikbal), (collectively, the Borusan Companies)  (October 5, 2015).  
15. Circular Welded Carbon Steel Pipes and Tubes From Turkey: Final Results of 
Countervailing Duty Administrative Review; Calendar Year 2013 and Rescission of 
Countervailing Duty Administrative Review, in Part , 80 FR 61361 (October 13, 2015).  
16. Administrative Review of C ountervailing Duty Order on Certain Welded Carbon Steel 
Standard Pipes and Tubes from Turkey: Amended Final Calculations for the Borusan 
Group, Borusan Mannesmann Boru Sanayi ve Ticaret A.S. (BMB), and Borusan Istikbal 
Ticaret T.A.S. (Istikbal), (collectiv ely, the Borusan Companies)  (November 5, 2015).  
17. Certain Welded Carbon Steel Pipe and Tube from Turkey: Amended Final Results of 
Countervailing Duty Administrative Review, 2013: Final Results Ministerial Error Allegation  
(November 5, 2015).  
18. Circular Welded Carbon Steel Pipes and Tubes from Turkey: Amended Final Results of 
Countervailing Duty Administrative Review, 2013 , 80 FR 70186 (November 13, 2015).  
 
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