U.S. International Trade Commission

Publication 4505 December 2014

Washington, DC 20436

Certain Welded Line Pipe 

from Korea and Turkey

Investigation Nos. 701-TA-524-525 and 731-TA-1260-1261 (Preliminary)
U.S. International Trade Commission

COMMISSIONERS 

 

Meredith M. Broadbent, Chairman 

Dean A. Pinkert, Vice Chairman 

Irving A. Williamson 

David S. Johanson 

F. Scott Kieff 

Rhonda K. Schmidtlein

Karen Laney

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Acting Director of Operations

Michael Szustakowski, Investigator 

Mahnaz Khan, Industry Analyst 

Jessica Pugliese, Industry Analyst 

Tana Farrington, Economist 

Mary Klir, Accountant 

Maureen Letostak, Statistician 

Darlene Smith, Statistical Assistant 

Peter Sultan, Attorney 

Douglas Corkran, Supervisory Investigator
U.S. International Trade Commission

Washington, DC 20436 

www.usitc.gov

Publication 4505 December 2014

Certain Welded Line Pipe 

from Korea and Turkey

Investigation Nos. 701-TA-524-525 and 731-TA-1260-1261 (Preliminary)

  

CONTENTS

Page

i

Determinations............................................................................................................................... 1

Views of the Commission ............................................................................................................... 3

Part I: Introduction................................................................................................................ I‐1

Background................................................................................................................................ I‐1

Statutory criteria and organization of the report..................................................................... I‐2

Statutory criteria ................................................................................................................... I‐2

Organization of report........................................................................................................... I‐3

Market summary....................................................................................................................... I‐3

Summary data and data sources............................................................................................... I‐4

Previous and related investigations.......................................................................................... I‐4

Nature and extent of alleged subsidies and sales at LTFV........................................................ I‐8

Alleged subsidies................................................................................................................... I‐8

Alleged sales at LTFV ............................................................................................................. I‐9

The subject merchandise ........................................................................................................ I‐10

Commerce’s scope .............................................................................................................. I‐10

Tariff treatment................................................................................................................... I‐10

The product............................................................................................................................. I‐11

Overview.............................................................................................................................. I‐11

Description and applications............................................................................................... I‐12

Manufacturing processes.................................................................................................... I‐13

Domestic like product issues................................................................................................... I‐17

Physical characteristics and uses......................................................................................... I‐19

Manufacturing facilities and production employees.......................................................... I‐19

Interchangeability................................................................................................................ I‐19

Producer and customer perceptions................................................................................... I‐20

Channels of distribution ...................................................................................................... I‐20

Price..................................................................................................................................... I‐20
  

CONTENTS

Page

ii

Part II: Conditions of competition in the U.S. market............................................................ II‐1

U.S. market characteristics....................................................................................................... II‐1

Channels of distribution........................................................................................................... II‐1

Geographic distribution ........................................................................................................... II‐2

Supply and demand considerations......................................................................................... II‐3

U.S. supply ............................................................................................................................ II‐3

U.S. demand ......................................................................................................................... II‐7

Substitutability issues............................................................................................................. II‐12

Lead times .......................................................................................................................... II‐12

Comparison of U.S.‐produced and imported certain welded line pipe ............................. II‐13

Part III: U.S. producers’ production, shipments, and employment....................................... III‐1

U.S. producers......................................................................................................................... III‐1

U.S. production, capacity, and capacity utilization................................................................. III‐4

U.S. producers’ U.S. shipments and exports........................................................................... III‐6

U.S. producers’ inventories..................................................................................................... III‐8

U.S. producers’ imports and purchases.................................................................................. III‐8

U.S. employment, wages, and productivity ............................................................................ III‐8

Part IV: U.S. imports, apparent U.S. consumption, and market shares ................................IV‐1

U.S. importers..........................................................................................................................IV‐1

U.S. imports............................................................................................................................. IV‐2

Negligibility.............................................................................................................................. IV‐6

Cumulation considerations .....................................................................................................IV‐7

Fungibility ............................................................................................................................ IV‐7

Presence in the market .......................................................................................................IV‐8

Geographical markets .......................................................................................................IV‐10

Apparent U.S. consumption ..................................................................................................IV‐11

U.S. market shares ................................................................................................................IV‐13
  

CONTENTS

Page

iii

Part V: Pricing data...............................................................................................................V‐1

Factors affecting prices............................................................................................................V‐1

Raw material costs ...............................................................................................................V‐1

U.S. inland transportation costs...........................................................................................V‐2

Pricing practices .......................................................................................................................V‐2

Pricing methods....................................................................................................................V‐2

Sales terms and discounts....................................................................................................V‐3

Price data..................................................................................................................................V‐4

Price trends...........................................................................................................................V‐9

Price comparisons ................................................................................................................V‐9

Lost sales and lost revenue ....................................................................................................V‐10

Part VI: Financial experience of U.S. producers....................................................................VI‐1

Introduction.............................................................................................................................VI‐1

Operations on certain welded line pipe..................................................................................VI‐1

Variance analysis.................................................................................................................VI‐4

Capital expenditures, research and development expenses, and total assets...................VI‐5

Capital and investment........................................................................................................VI‐5

Part VII: Threat considerations and information on nonsubject countries..........................VII‐1

The industry in Korea .............................................................................................................VII‐3

Overall capacity and production of welded tubular products...........................................VII‐3

Operations on certain welded line pipe.............................................................................VII‐3

Operations on welded line pipe not more than sixteen inches in outside diameter ........VII‐4

Operations on welded line pipe greater than sixteen inches in outside diameter and less

than or equal to twenty four inches...................................................................................VII‐4
  

CONTENTS

Page

iv

The industry in Turkey............................................................................................................VII‐4

Overall capacity and production of welded tubular products...........................................VII‐5

Operations on certain welded line pipe.............................................................................VII‐5

Operations on welded line pipe not more than sixteen inches in outside diameter ........VII‐6

Operations on welded line pipe greater than sixteen inches in outside diameter and less

than or equal to twenty four inches...................................................................................VII‐6

Subject countries combined...................................................................................................VII‐6

U.S. inventories of imported merchandise ............................................................................VII‐7

U.S. importers’ outstanding orders........................................................................................VII‐7

Trade remedy actions in third‐country markets....................................................................VII‐8

Information on nonsubject countries....................................................................................VII‐8

Mexico ................................................................................................................................VII‐8

Japan.................................................................................................................................VII‐10

Appendixes

A. Federal Register notices................................................................................................. A‐1

B. List of conference witnesses .......................................................................................... B‐1

C. Summary data ................................................................................................................ C‐1

D. Nonsubject price data (Japan and Mexico).................................................................... D‐1

   

Note.—Information that would reveal confidential operations of individual concerns may not

be published and therefore has been deleted.  Such deletions are indicated by asterisks.
UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation Nos. 701-TA-524-525 and 731-TA-1260-1261 (Preliminary)

CERTAIN WELDED LINE PIPE FROM KOREA AND TURKEY

DETERMINATIONS

On the basis of the record1 developed in the subject investigations, the United States 

International Trade Commission (“Commission”) determines, pursuant to sections 703(a) and 

733(a) of the Tariff Act of 1930 (19 U.S.C. '' 1671b(a) and 1673b(a)) (“the Act”), that there is a 

reasonable indication that an industry in the United States is materially injured by reason of 

imports from Korea and Turkey of certain welded line pipe, provided for in subheadings 

7305.11, 7305.12, 7305.19, and 7306.19 of the Harmonized Tariff Schedule of the United 

States, that are alleged to be sold in the United States at less than fair value (“LTFV”), and that 

are allegedly subsidized by the governments of Korea and Turkey.

COMMENCEMENT OF FINAL PHASE INVESTIGATIONS

Pursuant to section 207.18 of the Commission=s rules, the Commission also gives notice 

of the commencement of the final phase of its investigations. The Commission will issue a 

final phase notice of scheduling, which will be published in the Federal Register as provided in 

section 207.21 of the Commission=s rules, upon notice from the Department of Commerce 

(“Commerce”) of affirmative preliminary determinations in the investigations under sections 

703(b) or 733(b) of the Act, or, if the preliminary determinations are negative, upon notice of 

affirmative final determinations in those investigations under sections 705(a) or 735(a) of the 

Act. Parties that filed entries of appearance in the preliminary phase of the investigations 

need not enter a separate appearance for the final phase of the investigations. Industrial 

users, and, if the merchandise under investigation is sold at the retail level, representative 

consumer organizations have the right to appear as parties in Commission antidumping and 

countervailing duty investigations. The Secretary will prepare a public service list containing 

the names and addresses of all persons, or their representatives, who are parties to the 

investigations.

BACKGROUND

On October 16, 2014, a petition was filed with the Commission and Commerce by 

American Cast Iron Pipe Company, Birmingham, Alabama; Energex, a division of JMC Steel 

Group, Chicago, Illinois; Maverick Tube Corporation, Houston, Texas; Northwest Pipe Company, 

Vancouver, Washington; Stupp Corporation, Baton Rouge, Louisiana; Tex-Tube Company, 

Houston, Texas; TMK IPSCO, Houston, Texas; and Welspun Tubular LLC USA, Little Rock, 

Arkansas, alleging that an industry in the United States is materially injured or threatened with 

 1 The record is defined in sec. 207.2(f) of the Commission=s Rules of Practice and Procedure 

(19 CFR ' 207.2(f)).

 
material injury by reason of subsidized imports of certain welded line pipe from Korea and 

Turkey and LTFV imports of certain welded line pipe from Korea and Turkey. Accordingly, 

effective October 16, 2014, the Commission instituted countervailing duty investigation Nos. 

701-TA-524-525 and antidumping duty investigation Nos. 731-TA-1260-1261 (Preliminary).

Notice of the institution of the Commission=s investigations and of a public conference 

to be held in connection therewith was given by posting copies of the notice in the Office of the 

Secretary, U.S. International Trade Commission, Washington, DC, and by publishing the notice 

in the Federal Register of October 23, 2013 (79 FR 63438). The conference was held in 

Washington, DC, on November 6, 2014, and all persons who requested the opportunity were 

permitted to appear in person or by counsel.
3

Views of the Commission

Based on the record in the preliminary phase of these investigations, we find that there

is a reasonable indication that an industry in the United States is materially injured by reason of

imports of certain welded line pipe from Korea and Turkey that are allegedly sold in the United

States at less than fair value and that are allegedly subsidized by the governments of Korea and

Turkey.

I. The Legal Standard for Preliminary Determinations  

The legal standard for preliminary antidumping and countervailing duty determinations

requires the Commission to determine, based upon the information available at the time of the

preliminary determinations, whether there is a reasonable indication that a domestic industry is

materially injured or threatened with material injury, or that the establishment of an industry is

materially retarded, by reason of the allegedly unfairly traded imports.1  In applying this

standard, the Commission weighs the evidence before it and determines whether “(1) the

record as a whole contains clear and convincing evidence that there is no material injury or

threat of such injury; and (2) no likelihood exists that contrary evidence will arise in a final

investigation.”2

II. Background  

The petitions in these investigations were filed on October 16, 2014 by the American

Cast Iron Pipe Company (“ACIPCO”), EnergeX, a division of JMC Steel Group (“Energex”),

Maverick Tube Corporation (“Maverick”), Northwest Pipe Company (“Northwest Pipe”), Stupp

Corporation (“Stupp”), a division of Stupp Bros., Inc., Tex‐Tube Company (“Tex‐Tube”), TMK

IPSCO, and Welspun Tubular LLC USA (“Welspun”), U.S. producers of certain welded line pipe.  

Petitioners and United States Steel Corporation (“U.S. Steel”), another U.S. producer of certain

welded line pipe, appeared at the staff conference and submitted postconference briefs.3

  

Another domestic producer of certain welded line pipe, California Steel Industries (“CSI”), also

appeared at the staff conference.

The following respondents appeared at the staff conference and submitted

postconference briefs:  (i) Husteel Co., Ltd., Hyundai HYSCO, SeAH Steel Corporation, and

Nexteel Co., Ltd., producers of subject merchandise in Korea (collectively “Korean

                                                       1 19 U.S.C. §§ 1671b(a), 1673b(a) (2000); see also American Lamb Co. v. United States, 785 F.2d

994, 1001‐04 (Fed. Cir. 1986); Aristech Chem. Corp. v. United States, 20 CIT 353, 354‐55 (1996).  No party

argues that the establishment of an industry in the United States is materially retarded by the allegedly

unfairly traded imports. 2 American Lamb Co., 785 F.2d at 1001; see also Texas Crushed Stone Co. v. United States, 35

F.3d 1535, 1543 (Fed. Cir. 1994).

3 Maverick, the other petitioning firms (“Other Petitioners”), and U.S. Steel each filed separate

briefs.
4

Respondents”); (ii) Çayirova Boru Sanayi ve Ticaret A.S. and its affiliated exporter, Yücel Boru

Ithalat‐Ihracatve Pazarlama A.S. (collectively, “Yücel”); and Tosçelik Profil ve Sac Endüstrisi A.S.

and its affiliated exporter, Tosyali Dis Ticaret A.S. (“TDT”) (collectively,“Tosçelik”);4 and (iii) the

Turkish Steel Exporters Association, and its members: Borusan İstikbal Tic. AŞ., Borusan

Mannesmann Boru San.ve Tic. A.S., Guven Celik Boru San. ve Tic.Lt D.Sti., Hatboru Çelik Boru

San. ve Ticaret Ltd. Şti., Mazlum Mangtay Boru Sondajcilik İnş. Tar. Ür. San. ve Tic. A.Ş.,

Metaleks Çelik Ürünleri San. ve Tic. Ltd. Şti., Tosyali Dis Ticaret A.S., and Yucel Boru Ihr. Ith.ve

Paz. A.S. (collectively “TSEA”).

U.S. industry data are based on the questionnaire responses of 12 producers, believed

to account for the vast majority of U.S. production of certain welded line pipe.5  U.S. import

data are based on official import statistics.6

  The Commission received useable responses to its

questionnaires from seven foreign producers/exporters of subject merchandise:  four

producers/exporters in Korea, accounting for approximately *** percent of U.S. imports of

subject merchandise from Korea in 2013;7 and three producers/exporters in Turkey, accounting

for approximately *** percent of U.S. imports of subject merchandise from Turkey in 2013.8

III. Domestic Like Product

A. In General

In determining whether there is a reasonable indication that an industry in the United

States is materially injured or threatened with material injury by reason of imports of the

subject merchandise, the Commission first defines the “domestic like product” and the

“industry.”9  Section 771(4)(A) of the Tariff Act of 1930, as amended (“the Tariff Act”), defines

the relevant domestic industry as the “producers as a whole of a domestic like product, or

those producers whose collective output of a domestic like product constitutes a major

proportion of the total domestic production of the product.”10  In turn, the Tariff Act defines

“domestic like product” as “a product which is like, or in the absence of like, most similar in

characteristics and uses with, the article subject to an investigation.”11

The decision regarding the appropriate domestic like product(s) in an investigation is a

factual determination, and the Commission has applied the statutory standard of “like” or

                                                       4 The Yücel and Tosçelik parties produce and export subject merchandise from Turkey. 5 Confidential Report, Memorandum INV‐MM‐121 (Nov. 21, 2014)(“CR”) at III‐1; Certain Welded

Line Pipe from Korea and Turkey, Inv. Nos. 701‐TA‐524‐525 and 731‐TA‐1260‐1261 (Preliminary),USITC

Pub. 4505 (Dec. 2014) (“PR”) at III‐1.

6 CR/PR at IV‐1 n.2. 7 CR at VII‐3, PR at VII‐3.

8 CR at VII‐9, PR at VII‐4.

9 19 U.S.C. § 1677(4)(A).

10 19 U.S.C. § 1677(4)(A). 11 19 U.S.C. § 1677(10).
5

“most similar in characteristics and uses” on a case‐by‐case basis.12  No single factor is

dispositive, and the Commission may consider other factors it deems relevant based on the

facts of a particular investigation.13  The Commission looks for clear dividing lines among

possible like products and disregards minor variations.14  Although the Commission must accept

Commerce’s determination as to the scope of the imported merchandise that is subsidized

and/or sold at less than fair value,15 the Commission determines what domestic product is like

the imported articles Commerce has identified.16

B. Product Description

In its notice of initiation, Commerce defined the imported merchandise within the scope

of these investigations as follows:

The merchandise covered by these investigations is circular welded

carbon and alloy steel (other than stainless steel) pipe of a kind used for

oil or gas pipelines (welded line pipe), not more than 24 inches in nominal

outside diameter, regardless of wall thickness, length, surface finish, end

finish, or stenciling. Welded line pipe is normally produced to the

American Petroleum Institute (API) specification 5L, but can be produced

                                                       12 See, e.g., Cleo Inc. v. United States, 501 F.3d 1291, 1299 (Fed. Cir. 2007); NEC Corp. v.

Department of Commerce, 36 F. Supp. 2d 380, 383 (Ct. Int’l Trade 1998); Nippon Steel Corp. v. United

States, 19 CIT 450, 455 (1995); Torrington Co. v. United States, 747 F. Supp. 744, 749 n.3 (Ct. Int’l Trade

1990), aff’d, 938 F.2d 1278 (Fed. Cir. 1991) (“every like product determination ‘must be made on the

particular record at issue’ and the ‘unique facts of each case’”).  The Commission generally considers a

number of factors including the following:  (1) physical characteristics and uses; (2) interchangeability;

(3) channels of distribution; (4) customer and producer perceptions of the products; (5) common

manufacturing facilities, production processes, and production employees; and, where appropriate, (6)

price.  See Nippon, 19 CIT at 455 n.4; Timken Co. v. United States, 913 F. Supp. 580, 584 (Ct. Int’l Trade

1996).

13 See, e.g., S. Rep. No. 96‐249 at 90‐91 (1979). 14 See, e.g., Nippon, 19 CIT at 455; Torrington, 747 F. Supp. at 748‐49; see also S. Rep. No. 96‐249

at 90‐91 (Congress has indicated that the like product standard should not be interpreted in “such a

narrow fashion as to permit minor differences in physical characteristics or uses to lead to the

conclusion that the product and article are not ‘like’ each other, nor should the definition of ‘like

product’ be interpreted in such a fashion as to prevent consideration of an industry adversely affected

by the imports under consideration.”).

15 See, e.g., USEC, Inc. v. United States, 34 Fed. App’x 725, 730 (Fed. Cir. 2002) (“The ITC may not

modify the class or kind of imported merchandise examined by Commerce.”); Algoma Steel Corp. v.

United States, 688 F. Supp. 639, 644 (Ct. Int’l Trade 1988), aff’d, 865 F.3d 240 (Fed. Cir.), cert. denied,

492 U.S. 919 (1989).

16 Hosiden Corp. v. Advanced Display Mfrs., 85 F.3d 1561, 1568 (Fed. Cir. 1996) (the Commission

may find a single like product corresponding to several different classes or kinds defined by Commerce);

Cleo, 501 F.3d at 1298 n.1 (“Commerce’s {scope} finding does not control the Commission’s {like

product} determination.”); Torrington, 747 F. Supp. at 748‐52 (affirming the Commission’s

determination defining six like products in investigations where Commerce found five classes or kinds).
6

to comparable foreign specifications, to proprietary grades, or can be

non‐graded material. All pipe meeting the physical description set forth

above, including multiple‐stenciled pipe with an API or comparable

foreign specification line pipe stencil, is covered by the scope of these

investigations.

The welded line pipe that is subject to these investigations is currently

classifiable in the Harmonized Tariff Schedule of the United States

(HTSUS) under subheadings 7305.11.1030, 7305.11.5000, 7305.12.1030,

7305.12.5000, 7305.19.1030, 7305.19.5000, 7306.19.1010,

7306.19.1050, 7306.19.5110, and 7306.19.5150. The subject

merchandise may also enter in HTSUS 7305.11.1060 and 7305.12.1060.

While the HTSUS subheadings are provided for convenience and customs

purposes, the written description of the scope of these investigations is

dispositive.17

The line pipe subject to these investigations is a welded circular pipe product, not more

than 24 inches (609.6 millimeters) in outside diameter (“OD”), regardless of wall thickness,

length, surface finish, or end finish.18  Line pipe is generally produced in the United States in

lengths of 40 feet or greater,19 and with either a bare finish or a black (lacquered) finish to

protect the pipe from rust.  End finishes typically include square cut or beveled for welding in

the field.20 Subject line pipe is normally produced in conformance with the API 5L specifications

of the American Petroleum Institute (“API”), which provides standards for pipe suitable for use

in conveying gas, water, and oil in both the oil and gas industries.21

Certain welded line pipe is used in oil and gas pipelines for the gathering, transmission,

and distribution of oil and gas.  Gathering is an upstream application in which welded line pipe

is used to move the natural gas out of the fields and into the processing plants, or gather oil for

further processing in oil refineries.  Transmission of oil and gas is considered a midstream

application in which welded line pipe is used to move oil and gas to any type of collection or

                                                       17 Welded Line Pipe From the Republic of Korea and the Republic of Turkey: Initiation of

Countervailing Duty Investigations, 79 Fed. Reg. 67419 (Nov. 13, 2014).

18 Although the scope of the investigation does not take into account wall thickness, API 5L

specifications have thickness requirements.  CR at I‐14 n.13, PR at I‐12 n.13.

19 Nominal 40‐45 foot lengths are referred to by the industry as “double random lengths” or

“DRL.”  CR at I‐14 n.14, PR at I‐12 n.14.

20 Annual Book of ASTM Standards, Section One, Iron and Steel Products, Volume 01.01, 2009,

p.6, and Mohinder L. Nayyar, “Piping Handbook,” Sixth Edition, 1992, p. A.49.   21 The API 5L specification covers both seamless and welded steel line pipe. Although seamless

pipe is covered by the API 5L specification, it is outside the scope of these investigations. API,

Specification for Line Pipe, API Specification 5L, 44th Edition, October 1, 2007.  
7

distribution point, often over long distances. Distributing oil and gas is a downstream

application in which welded line pipe is used to move the oil and gas to the end customer.22  

C. Arguments and Analysis

Petitioners argue that the Commission should find a single domestic like product,

coextensive with the scope of Commerce’s investigations.23  Korean Respondents argue that

there are two domestic like products: (1) line pipe equal to or less than 16 inches OD, and (2)

line pipe made by the electric resistance welding (“ERW”) method that is greater than 16 inches

OD. 24  

Based on the record, we define a single domestic like product consisting of certain

welded line pipe.  For ease of reference in this discussion of the domestic like product, we refer

to line pipe equal to or less than 16 inches in OD as “smaller” line pipe and line pipe more than

16 inches and equal to or less than 24 inches in OD as “larger” line pipe.

Physical Characteristics and Uses.  All welded line pipe up to 24 inches OD has nearly

identical physical characteristics.  It is all made to the 5L physical specifications of the API,25

although some line pipe may be made to more exacting specifications.26  It consists of a

continuum of diameters.  All U.S. producers and most importers addressing the question agreed

that the smaller and larger line pipe have similar physical characteristics.27  Line pipe generally

is used in three functions:  gathering, transmission, and distribution.28

There are some distinctions in the uses of the smaller and the larger line pipe.  There is

evidence on the record that the smaller line pipe generally is used for gathering and

distribution, whereas the larger pipe is used for transmission.  For example, one domestic

producer, ***, reported that the smaller line pipe tends to be used for gathering lines, whereas

the larger line pipe tends to be used for pipeline projects.29  A number of importers agreed.30  

On the other hand, there was testimony at the staff conference that, because of changes in

drilling technology the diameter of line pipe used for gathering purposes has increased.  As the

number of oil or gas wells per pad has grown (to the point, for example, where one pad might

have 32 wells attached to it), so has the need to move greater volumes of oil and gas at the

                                                       22 CR at I‐14‐15, PR at I‐12.   23 Maverick Postconference Brief at 5‐9; Other Petitioners’ Postconference Brief at 3‐4, and 7‐

10.

24 Korean Respondents’ Postconference Brief at 7‐9.  No U.S. producer made line pipe greater

than 24 inches in OD by the ERW method.  CR/PR at Table III‐3.

25 CR at I‐15, PR at I‐12.

26 Conference Transcript at 55 (Barnes) and 56 (Clark).

27 CR/PR at Table I‐4.

28 CR at I‐14‐15, PR at I‐11.

29 CR/PR at Table I‐4.

30 CR/PR at Table I‐4 (responses of ***).
8

gathering stage, resulting in the use of line pipe with a larger OD.31  One domestic producer

reported that line pipe up to 24 inches OD is used in gathering lines.32

Manufacturing Facilities, Production Processes and Employees.  The manufacturing

facilities, production processes, and employees used to make both the smaller and larger line

pipe are sometimes the same.33  The range of products that individual domestic producers

manufacture varies from one producer to another.  Of 12 responding domestic producers, four

produced both the smaller and larger diameter products, eight produced only the smaller

diameter product, and none produced only the larger diameter product.34  At the conference,

the representative of one producer explained that it was unlikely that the full range of OD sizes

would be made at the same facility because it would be inefficient to do so.35  On the other

hand, the representative of another producer, CSI, reported that its new mill will make line pipe

from 8 inches to 24 inches OD.36  Larger equipment may be required to make the larger line

pipe.37  Almost all line pipe up to 24 inches OD is made using the ERW method,38 whereas line

pipe larger than 24 inches OD is usually made using a submerged arc welding (“SAW”)

process.39

Channels of Distribution.  Both the smaller and larger line pipe are sold through the

same channels of distribution, namely to distributors and end users, although a larger

proportion of the larger line pipe is sold to distributors.40

Interchangeability.  Although most domestic producers reported that the smaller and

larger line pipe is interchangeable, most qualified this response by explaining that the size is

determined by specific end‐use requirements.41  Most importers reported that the products are

not interchangeable, and they made similar points about the end‐use requirements.42

Producer and Customer Perceptions.  Most domestic producers reported that the

smaller and larger line pipe are perceived to be similar.43  Twelve of the 24 importers

responding to the Commission’s questionnaire reported that the products are not perceived to

be similar.44  To the extent that these importers provided reasons, they explained that the

perceptions differ because the end uses are different.

                                                       31 Conference Transcript at 65 and 66 (Noland and Barnes).

32 CR/PR at Table I‐4 (response of ***).

33 CR/PR at Table I‐5, Conference Transcript at 67 (Clark).

34 CR at I‐27, PR at I‐19.

35 Conference Transcript at 69 (Barnes).    36 Conference Transcript at 68‐69 (Dubreuil).

37 CR/PR at Table I‐5 (responses of Boomerang and Tex‐Tube).

38 CR at I‐18, PR at I‐14.

39 Conference Transcript at 61 (Fisher).

40 CR at I‐32, PR at I‐20.  In 2013, *** percent of U.S. producers’ commercial shipments of the

smaller line pipe were made to distributors, and *** percent of commercial shipments of the larger line

pipe were sold through this channel. 41 CR/PR at Table I‐6.

42 CR/PR at Table I‐6.

43 CR/PR at Table I‐7. 44 CR/PR at Table I‐7.
9

Price.  The unit values of the smaller and larger line pipe were similar in 2011 and 2012,

but they diverged in 2013, when the unit value of the smaller line pipe dropped considerably,

while that of the larger line pipe rose slightly.45

Conclusion.  All certain welded line pipe shares the same basic physical characteristics.  

The uses are somewhat different, in that the smaller line pipe is typically used in gathering and

distribution functions, whereas the larger line pipe is used for transmission of oil and gas,

although there is evidence in the record that this distinction is no longer as clear‐cut, as larger

sizes of line pipe are used for gathering functions, as a result of changes in drilling technology.  

The manufacturing facilities, production processes, and employees used to make both the

smaller and larger line pipe appear to be basically the same, to the extent that they are made

by the ERW process.  Channels of distribution also are the same, with a majority of both the

smaller and larger line pipe being sold to distributors, although a greater proportion of the

larger line pipe is sold to distributors.  The smaller and larger line pipe appear not to be

interchangeable, because the size of pipe used depends on the end‐use requirements.  The

information on producer and customer perceptions is mixed.  Finally, the smaller and larger line

pipe had similar unit values for much of the January 2011 – June 2014 period of investigation

(“POI”).  While the evidence in these preliminary phase investigations concerning the like

product factors overall is mixed, we find that, on balance, the record indicates that the

similarities in line pipe with an OD equal to or less than 16 inches on the one hand, and line

pipe with an OD more than 16 inches and equal to or less than 24 inches, on the other,

outweigh the differences.  We consequently define a single domestic like product that is

coextensive with the scope of these investigations.46

IV. Domestic Industry  

The domestic industry is defined as the domestic “producers as a whole of a domestic

like product, or those producers whose collective output of a domestic like product constitutes

a major proportion of the total domestic production of the product.”47  In defining the domestic

industry, the Commission’s general practice has been to include in the industry producers of all

domestic production of the like product, whether toll‐produced, captively consumed, or sold in

the domestic merchant market.  

We must determine whether any producer of the domestic like product should be

excluded from the domestic industry pursuant to Section 771(4)(B) of the Tariff Act.  This

provision allows the Commission, if appropriate circumstances exist, to exclude from the

domestic industry producers that are related to an exporter or importer of subject merchandise

                                                       45 CR/PR at Table I‐10.

46 We intend, in any final phase investigations, to examine further the degree of

interchangeability between line pipe of various ODs and the question of whether larger pipe is now used

in applications where smaller pipe was previously appropriate. 47 19 U.S.C. § 1677(4)(A).
10

or which are themselves importers.48  Exclusion of such a producer is within the Commission’s

discretion based upon the facts presented in each investigation.49

*** is ***, that imported certain welded line pipe from Korea and Turkey.50  ***

accounted for *** percent of total subject imports from Turkey in 2013.51  The volume of

subject merchandise imported by *** was much smaller than the volume produced by ***

during all parts of the POI.52  *** supports the petition.53  Because *** principal interest

appears to be in domestic production and there is no indication that it benefitted from subject

imports through its ***, we find that appropriate circumstances do not exist to exclude ***

from the domestic industry.  Accordingly, we define the domestic industry to include all U.S.

producers of certain welded line pipe.

V. Negligible Imports  

Pursuant to Section 771(24) of the Tariff Act, imports from a subject country of

merchandise corresponding to a domestic like product that account for less than 3 percent of

all such merchandise imported into the United States during the most recent 12 months for

which data are available preceding the filing of the petition shall be deemed negligible.54  

Negligibility is not an issue in these investigations.  In the October 2013‐September 2014

period, subject imports from Korea accounted for 57.2 percent of total imports of certain

welded line pipe and subject imports from Turkey accounted for 5.6 percent.55

                                                       48 See Torrington Co. v. United States, 790 F. Supp. 1161, 1168 (Ct. Int’l Trade 1992), aff’d

without opinion, 991 F.2d 809 (Fed. Cir. 1993); Sandvik AB v. United States, 721 F. Supp. 1322, 1331‐32

(Ct. Int’l Trade 1989), aff’d mem., 904 F.2d 46 (Fed. Cir. 1990); Empire Plow Co. v. United States, 675 F.

Supp. 1348, 1352 (Ct. Int’l Trade 1987).

49 The primary factors the Commission has examined in deciding whether appropriate

circumstances exist to exclude a related party include the following:

(1) the percentage of domestic production attributable to the importing producer;

(2) the reason the U.S. producer has decided to import the product subject to investigation, i.e.,

whether the firm benefits from the LTFV sales or subsidies or whether the firm must import in order to

enable it to continue production and compete in the U.S. market; and

(3) the position of the related producer vis‐a‐vis the rest of the industry, i.e., whether inclusion

or exclusion of the related party will skew the data for the rest of the industry.  See, e.g., Torrington Co.

v. United States, 790 F. Supp. at 1168.

50 CR/PR at Table III‐1 n.8.

51 CR/PR at Table IV‐1.  During 2013, ***.  Id.

52 Compare *** U.S. Importers’ Questionnaire Response Questions II‐5 and II‐7 with *** U.S.

Producers’ Questionnaire Response at Question II‐3a.

53 CR/PR at Table III‐1.

54 19 U.S.C. §§ 1671b(a), 1673b(a), 1677(24)(A)(i), 1677(24)(B);  see also 15 C.F.R. § 2013.1

(developing countries for purposes of 19 U.S.C. § 1677(36)). 55 CR/PR at Table IV‐3.
11

VI. Cumulation

For purposes of evaluating the volume and effects for a determination of reasonable

indication of material injury by reason of subject imports, section 771(7)(G)(i) of the Tariff Act

requires the Commission to cumulate subject imports from all countries as to which petitions

were filed and/or investigations self‐initiated by Commerce on the same day, if such imports

compete with each other and with the domestic like product in the U.S. market.  In assessing

whether subject imports compete with each other and with the domestic like product, the

Commission generally has considered four factors:

(1) the degree of fungibility between subject imports from different

countries and between subject imports and the domestic like product,

including consideration of specific customer requirements and other

quality related questions;

(2) the presence of sales or offers to sell in the same geographic markets of

subject imports from different countries and the domestic like product;

(3) the existence of common or similar channels of distribution for subject

imports from different countries and the domestic like product; and

(4) whether the subject imports are simultaneously present in the market.56

While no single factor is necessarily determinative, and the list of factors is not

exclusive, these factors are intended to provide the Commission with a framework for

determining whether the subject imports compete with each other and with the domestic like

product.  

Petitioners argue that the Commission should cumulatively assess imports from Korea

and Turkey.57  Yücel/Tosçelik argues that the Commission should not cumulate subject imports

from Turkey with subject imports from Korea.58   

The threshold requirement for cumulation is satisfied because Petitioners filed the

antidumping duty and countervailing duty petitions with respect to Korea and Turkey on the

same day, October 16, 2014.  In addition, none of the statutory exceptions to cumulation

applies.  As discussed below, we find a reasonable overlap of competition between subject

imports from Korea and Turkey and between subject imports from these countries and the

domestic like product.

Fungibility.  Certain welded line pipe, regardless of source, is generally produced in

accordance with standards set by the API.59  All responding domestic producers and a majority

of importers reported that subject imports from the subject countries are “always” or

“frequently” used interchangeably with each other and with the domestic like product.  Almost

                                                       56 See Certain Cast‐Iron Pipe Fittings from Brazil, the Republic of Korea, and Taiwan, Inv. Nos.

731‐TA‐278‐80 (Final), USITC Pub. 1845 (May 1986), aff’d, Fundicao Tupy, S.A. v. United States, 678 F.

Supp. 898 (Ct. Int’l Trade), aff’d, 859 F.2d 915 (Fed. Cir. 1988). 57 Maverick Postconference Brief at 10‐12, Other Petitioners’ Postconference Brief at 10‐14.   58 Yücel/Tosçelik Postconference Brief at 2‐10.

59 CR/PR at II‐1.
12

all of the remaining importers indicated that subject imports from the subject countries are

“sometimes” used interchangeably with each other and with the domestic like product.  Only

one importer reported that subject imports from Korea are “never” used interchangeably with

the domestic like product.60

When asked whether differences other than price are ever significant in their sales in

choosing between certain welded line pipe from different sources, all domestic producers

responded “sometimes” or “never.”61  Importers were more divided on this question, but a

majority of importers also answered “sometimes” or “never.”62

Several factors, however, may limit the fungibility between and among subject imports

from each source and the domestic like product.  First, end users of line pipe sometimes specify

certain unique requirements over and above API specifications.63  However, the limited

information on the record suggests that such “API‐plus” specifications are not an impediment

for subject producers.  A representative of the domestic industry testified that “most every mill

can comply with these above‐API specifications, both domestically and importers.”64  Neither

the Korean nor the Turkish respondents claimed that they are not able to produce line pipe to

API‐plus specifications.  In short, it does not appear that these end user specifications limit the

fungibility of the domestic like product and subject imports to any significant degree.

  Fungibility may be somewhat limited by the use of Approved Manufacturers Lists

(“AMLs”) by some end users.  There is conflicting evidence on the record as to the prevalence

of AMLs.  On the one hand, a representative from a distributor of line pipe testified at the staff

conference that she believes that most end users now have an AML.65  On the other hand,

Maverick’s U.S. Sales Director submitted a sworn statement stating that (1) many end users do

not use AMLs and will buy any line pipe as long as it meets API specifications; (2) that even

those that use AMLs do not restrict all of their line pipe purchases to mills on their AML; and (3)

most distributors do not have their own AMLs.66   

There is also conflicting evidence on the record as to whether Turkish line pipe

producers are on any AMLs.  Most U.S. producers are on these AMLs, as well as most Korean

producers.67  The Turkish respondent, Tosçelik, however, contends that it is not.68 Although

Petitioners did not specifically address Tosçelik’s contention that it is not on the AMLs of U.S.

end users, Maverick’s U.S. Sales Director stated that “{o}ften Korean and/or Turkish producers

                                                       60 CR/PR at Table II‐4.

61 CR/PR at Table II‐5.

62 CR/PR at Table II‐5.

63 Conference Transcript at 55 (Barnes) and 56 (Clark).   64 Conference Transcript at 56‐57 (Fisher).

65 Conference Transcript at 133 (Snow).

66 Maverick Postconference Brief at Exh. 11.

67 CR at V‐4, PR at V‐3‐4.

68 CR at V‐4, PR at V‐4.   Yücel/Tosçelik state that Tosçelik accounted for over *** percent of

subject imports from Turkey during the POI.  Yücel/Tosçelik Postconference Brief at 5.  When asked who

in the United States is consuming Tosçelik’s product, its counsel said that Tosçelik “doesn’t know that

information.”  Conference Transcript at 134 (Simon).  
13

are on the same AML” and that “{l}ine pipe producers from the subject countries are frequently

listed on these AMLs.”69

Overall, the record does not suggest that fungibility of subject imports from Turkey with

subject imports from Korea and with the domestic like product is significantly limited by the use

of AMLs.  *** subject imports from Korea and *** subject imports from Turkey were sold to

distributors, as was the majority of U.S. producers’ shipments.70 Most distributors appear not to

use AMLs (although they may take the fact that a customer uses an AML into account when

quoting to that customer).71  Even with respect to sales to end users, it is not clear that all end

users use AMLs, or, if they do, that they make all of their purchases from AMLs.  Finally, based

on the statement by Maverick’s Sales Director, some Turkish producers – although apparently

not Tosçelik, the largest exporter of subject merchandise to the United States during the POI –

may be on AMLs.

Fungibility may be limited to some extent by the fact that the Turkish producers did not

supply line pipe in the over 16 inches to 24 inches OD range.72  We do not, however, view this

as a significant limitation on fungibility, given that most of the shipments by both the domestic

industry and of subject imports from Korea were in the smaller size range up to 16 inches OD.73  

We are unpersuaded by the argument of Yücel/Tosçelik that subject imports from Turkey,

which are mainly in the size range of 12 inches and smaller, barely compete with domestic

producers.74  Yücel/Tosçelik reviews the production of only five of the 12 domestic producers of

certain welded line pipe.  (These producers accounted for *** percent of total domestic

production in 2013.)75  Thus, there is no indication of whether the other seven domestic

producers compete in the 12 inches and under size range.  Moreover, even with respect to the

five producers listed by Yücel/Tosçelik, the assertion that these producers do not compete with

subject imports from Turkey is not persuasive.  For example, with respect to the domestic

producer CSI, Yücel/Tosçelik asserts that Turkish product does not compete because “none of

the Turkish pipe was imported into the West Coast.”  West Coast producer CSI, however,

reported selling in ***.76  Moreover, the other four domestic producers listed by Yücel/Tosçelik

make at least some line pipe in the under 12 inches OD range.  We also note that the quarterly

pricing data collected for Products 1 and 2 (line pipe with ODs of 6.625 inches and 8.625 inches)

shows sales of these smaller‐diameter products by domestic producers, in substantial

quantities, in every quarter.77

On balance, we believe information on the record concerning product characteristics

indicates a substantial degree of competition between and among subject imports from each

source and the domestic like product, notwithstanding the factors that may limit fungibility.

                                                       69 Maverick Postconference Brief at Exh. 11.

70 CR/PR at II‐1. 71 Conference Transcript at 133 (Snow).

72 See CR/PR at Table IV‐4.

73 See CR/PR at Table IV‐4. 74 Yücel/Tosçelik Postconference Brief at 5‐6. 75 See CR/PR at Table III‐1.

76 CSI U.S. Producer Questionnaire Response at Question V‐10. 77 CR/PR at Tables V‐3 and V‐4.
14

Channels of Distribution.  *** subject imports from Korea and *** subject imports from

Turkey were sold to distributors, as was the majority of U.S. producers’ shipments.78

Geographic Overlap.  The majority of subject imports from both Korea and Turkey were

concentrated in the Central Southwest.79 The Pacific Coast and Southeast received the second

greatest coverage by subject imports, although generally not subject imports from Turkey.80  All

responding U.S. producers reported making sales to the Central Southwest, 11 of 12 reported

making sales in the Southeast, and nine of 12 reported making sales to the Pacific Coast

region.81  Consequently, the record does not support Yücel/Tosçelik’s assertions regarding lack

of geographic overlap.82

Simultaneous Presence in Market.  Subject imports from Korea were present in all 45

months during January 2011‐September 2014, and subject imports from Turkey were present in

37 months of this period.83

Conclusion.  Because the relevant antidumping duty petitions and countervailing duty

petitions were filed on the same day, and the record indicates that there is a reasonable

overlap of competition between and among subject imports and the domestic like product, we

cumulate subject imports from Korea and Turkey for purposes of our analysis of whether there

is a reasonable indication of material injury by reason of subject imports.

VII. Reasonable Indication of Material Injury by Reason of Subject Imports  

A. Legal Standard

In the preliminary phase of antidumping and countervailing duty investigations, the

Commission determines whether there is a reasonable indication that an industry in the United

States is materially injured or threatened with material injury by reason of the imports under

investigation.84  In making this determination, the Commission must consider the volume of

subject imports, their effect on prices for the domestic like product, and their impact on

domestic producers of the domestic like product, but only in the context of U.S. production

operations.85  The statute defines “material injury” as “harm which is not inconsequential,

immaterial, or unimportant.”86  In assessing whether there is a reasonable indication that the

domestic industry is materially injured by reason of subject imports, we consider all relevant

                                                       78 CR/PR at II‐1.

79 CR/PR at II‐2 and Table II‐2.

80 CR/PR at Table II‐2.

81 CR/PR at Table II‐2.

82 Yücel/Tosçelik Postconference Brief at 3‐4.

83 CR at IV‐9‐10, PR at IV‐8 and CR/PR at Table IV‐5.

84 19 U.S.C. §§ 1671b(a), 1673b(a).

85 19 U.S.C. § 1677(7)(B).  The Commission “may consider such other economic factors as are

relevant to the determination” but shall “identify each {such} factor ... {a}nd explain in full its relevance

to the determination.”  19 U.S.C. § 1677(7)(B).

86 19 U.S.C. § 1677(7)(A).
15

economic factors that bear on the state of the industry in the United States.87  No single factor

is dispositive, and all relevant factors are considered “within the context of the business cycle

and conditions of competition that are distinctive to the affected industry.”88

Although the statute requires the Commission to determine whether there is a

reasonable indication that the domestic industry is “materially injured by reason of” unfairly

traded imports,89 it does not define the phrase “by reason of,” indicating that this aspect of the

injury analysis is left to the Commission’s reasonable exercise of its discretion.90  In identifying a

causal link, if any, between subject imports and material injury to the domestic industry, the

Commission examines the facts of record that relate to the significance of the volume and price

effects of the subject imports and any impact of those imports on the condition of the domestic

industry.  This evaluation under the “by reason of” standard must ensure that subject imports

are more than a minimal or tangential cause of injury and that there is a sufficient causal, not

merely a temporal, nexus between subject imports and material injury.91

In many investigations, there are other economic factors at work, some or all of which

may also be having adverse effects on the domestic industry.  Such economic factors might

include nonsubject imports; changes in technology, demand, or consumer tastes; competition

among domestic producers; or management decisions by domestic producers.  The legislative

history explains that the Commission must examine factors other than subject imports to

ensure that it is not attributing injury from other factors to the subject imports, thereby

inflating an otherwise tangential cause of injury into one that satisfies the statutory material

injury threshold.92  In performing its examination, however, the Commission need not isolate

                                                       87 19 U.S.C. § 1677(7)(C)(iii).

88 19 U.S.C. § 1677(7)(C)(iii).

89 19 U.S.C. §§ 1671b(a), 1673b(a).

90 Angus Chemical Co. v. United States, 140 F.3d 1478, 1484‐85 (Fed. Cir. 1998) (“{T}he statute

does not ‘compel the commissioners’ to employ {a particular methodology}.”), aff’g 944 F. Supp. 943,

951 (Ct. Int’l Trade 1996).

91 The Federal Circuit, in addressing the causation standard of the statute, has observed that

“{a}s long as its effects are not merely incidental, tangential, or trivial, the foreign product sold at less

than fair value meets the causation requirement.”  Nippon Steel Corp. v. USITC, 345 F.3d 1379, 1384

(Fed. Cir. 2003).  This was re‐affirmed in Mittal Steel Point Lisas Ltd. v. United States, 542 F.3d 867, 873

(Fed. Cir. 2008), in which the Federal Circuit, quoting Gerald Metals, Inc. v. United States, 132 F.3d 716,

722 (Fed. Cir. 1997), stated that “this court requires evidence in the record ‘to show that the harm

occurred “by reason of” the LTFV imports, not by reason of a minimal or tangential contribution to

material harm caused by LTFV goods.’”  See also Nippon Steel Corp. v. United States, 458 F.3d 1345,

1357 (Fed. Cir. 2006); Taiwan Semiconductor Industry Ass’n v. USITC, 266 F.3d 1339, 1345 (Fed. Cir.

2001).

92 SAA, H.R. Rep. 103‐316, Vol. I at 851‐52 (1994) (“{T}he Commission must examine other

factors to ensure that it is not attributing injury from other sources to the subject imports.”); S. Rep. 96‐

249 at 75 (1979) (the Commission “will consider information which indicates that harm is caused by

factors other than less‐than‐fair‐value imports.”); H.R. Rep. 96‐317 at 47 (1979) (“in examining the

overall injury being experienced by a domestic industry, the ITC will take into account evidence

presented to it which demonstrates that the harm attributed by the petitioner to the subsidized or

dumped imports is attributable to such other factors;” those factors include “the volume and prices of

(Continued...)
16

the injury caused by other factors from injury caused by unfairly traded imports.93  Nor does the

“by reason of” standard require that unfairly traded imports be the “principal” cause of injury

or contemplate that injury from unfairly traded imports be weighed against other factors, such

as nonsubject imports, which may be contributing to overall injury to an industry.94  It is clear

that the existence of injury caused by other factors does not compel a negative

determination.95

Assessment of whether material injury to the domestic industry is “by reason of” subject

imports “does not require the Commission to address the causation issue in any particular way”

as long as “the injury to the domestic industry can reasonably be attributed to the subject

imports” and the Commission “ensure{s} that it is not attributing injury from other sources to

the subject imports.”96 97  Indeed, the Federal Circuit has examined and affirmed various

Commission methodologies and has disavowed “rigid adherence to a specific formula.”98

                                                                                                                                                                              

(...Continued)

nonsubsidized imports or imports sold at fair value, contraction in demand or changes in patterns of

consumption, trade restrictive practices of and competition between the foreign and domestic

producers, developments in technology and the export performance and productivity of the domestic

industry”); accord Mittal Steel, 542 F.3d at 877.

93 SAA at 851‐52 (“{T}he Commission need not isolate the injury caused by other factors from

injury caused by unfair imports.”); Taiwan Semiconductor Industry Ass’n , 266 F.3d at 1345. (“{T}he

Commission need not isolate the injury caused by other factors from injury caused by unfair imports ... .  

Rather, the Commission must examine other factors to ensure that it is not attributing injury from other

sources to the subject imports.” (emphasis in original)); Asociacion de Productores de Salmon y Trucha

de Chile AG v. United States, 180 F. Supp. 2d 1360, 1375 (Ct. Int’l Trade 2002) (“{t}he Commission is not

required to isolate the effects of subject imports from other factors contributing to injury” or make

“bright‐line distinctions” between the effects of subject imports and other causes.); see also Softwood

Lumber from Canada, Inv. Nos. 701‐TA‐414 and 731‐TA‐928 (Remand), USITC Pub. 3658 at 100‐01 (Dec.

2003) (Commission recognized that “{i}f an alleged other factor is found not to have or threaten to have

injurious effects to the domestic industry, i.e., it is not an ‘other causal factor,’ then there is nothing to

further examine regarding attribution to injury”), citing Gerald Metals, 132 F.3d at 722 (the statute

“does not suggest that an importer of LTFV goods can escape countervailing duties by finding some

tangential or minor cause unrelated to the LTFV goods that contributed to the harmful effects on

domestic market prices.”).

94 S. Rep. 96‐249 at 74‐75; H.R. Rep. 96‐317 at 47.

95 See Nippon, 345 F.3d at 1381 (“an affirmative material‐injury determination under the statute

requires no more than a substantial‐factor showing.  That is, the ‘dumping’ need not be the sole or

principal cause of injury.”).

96 Mittal Steel, 542 F.3d at 877‐78; see also id. at 873 (“While the Commission may not enter an

affirmative determination unless it finds that a domestic industry is materially injured ‘by reason of’

subject imports, the Commission is not required to follow a single methodology for making that

determination ... {and has} broad discretion with respect to its choice of methodology.”) citing United

States Steel Group v. United States, 96 F.3d 1352, 1362 (Fed. Cir. 1996) and S. Rep. 96‐249 at 75.   97 Vice Chairman Pinkert does not join this paragraph or the following three paragraphs.  He

points out that the Federal Circuit, in Bratsk, 444 F.3d 1369, and Mittal Steel, held that the Commission

is required, in certain circumstances when considering present material injury, to undertake a particular

(Continued...)
17

The Federal Circuit’s decisions in Gerald Metals, Bratsk, and Mittal Steel all involved

cases in which the relevant “other factor” was the presence in the market of significant

volumes of price‐competitive nonsubject imports.  The Commission interpreted the Federal

Circuit’s guidance in Bratsk as requiring it to apply a particular additional methodology

following its finding of material injury in cases involving commodity products and a significant

market presence of price‐competitive nonsubject imports.99  The additional

“replacement/benefit” test looked at whether nonsubject imports might have replaced subject

imports without any benefit to the U.S. industry.  The Commission applied that specific

additional test in subsequent cases, including the Carbon and Certain Alloy Steel Wire Rod from

Trinidad and Tobago determination that underlies the Mittal Steel litigation.

Mittal Steel clarifies that the Commission’s interpretation of Bratsk was too rigid and

makes clear that the Federal Circuit does not require the Commission to apply an additional

test nor any one specific methodology; instead, the court requires the Commission to have

“evidence in the record ‘to show that the harm occurred ‘by reason of’ the LTFV imports,’” and

requires that the Commission not attribute injury from nonsubject imports or other factors to

subject imports.100  Accordingly, we do not consider ourselves required to apply the

replacement/benefit test that was included in Commission opinions subsequent to Bratsk.

The progression of Gerald Metals, Bratsk, and Mittal Steel clarifies that, in cases

involving commodity products where price‐competitive nonsubject imports are a significant

factor in the U.S. market, the Court will require the Commission to give full consideration, with

adequate explanation, to non‐attribution issues when it performs its causation analysis.101

                                                                                                                                                                              

(...Continued)

kind of analysis of non‐subject imports, albeit without reliance upon presumptions or rigid formulas.  

Mittal Steel explains as follows:

What Bratsk held is that “where commodity products are at issue and fairly traded, price

competitive, non‐subject imports are in the market,” the Commission would not fulfill

its obligation to consider an important aspect of the problem if it failed to consider

whether non‐subject or non‐LTFV imports would have replaced LTFV subject imports

during the period of investigation without a continuing benefit to the domestic industry.  

444 F.3d at 1369.  Under those circumstances, Bratsk requires the Commission to

consider whether replacement of the LTFV subject imports might have occurred during

the period of investigation, and it requires the Commission to provide an explanation of

its conclusion with respect to that factor.   

542 F.3d at 878.    98 Nucor Corp. v. United States, 414 F.3d 1331, 1336, 1341 (Fed. Cir. 2005); see also Mittal Steel,

542 F.3d at 879 (“Bratsk did not read into the antidumping statute a Procrustean formula for

determining whether a domestic injury was ‘by reason’ of subject imports.”).

99 Mittal Steel, 542 F.3d at 875‐79.

100 Mittal Steel, 542 F.3d at 873 (quoting from Gerald Metals, 132 F.3d at 722), 875‐79 & n.2

(recognizing the Commission’s alternative interpretation of Bratsk as a reminder to conduct a non‐

attribution analysis).

101 To that end, after the Federal Circuit issued its decision in Bratsk, the Commission began to

present published information or send out information requests in final phase investigations to

producers in nonsubject countries that accounted for substantial shares of U.S. imports of subject

(Continued...)
18

The question of whether the material injury threshold for subject imports is satisfied

notwithstanding any injury from other factors is factual, subject to review under the substantial

evidence standard.102  Congress has delegated this factual finding to the Commission because

of the agency’s institutional expertise in resolving injury issues.103

B. Conditions of Competition and the Business Cycle

The following conditions of competition inform our analysis of whether there is a

reasonable indication of material injury by reason of subject imports.

1. Demand Conditions

End users generally use certain welded line pipe for gathering oil and gas from the point

of production, transmission of oil and gas to collection or distribution points, and for

distributing oil and gas to end users.104  Demand for line pipe is therefore derived from oil and

gas production.105  Oil and gas exploration and production is, in turn, directly affected by oil and

gas prices.106

Rig count is a leading indicator of oil and gas sector activity.107  Although overall oil and

gas rig count fluctuated in a relatively narrow band over the POI, there was a shift to oil drilling

and away from gas drilling.  The rig count for oil production in the United States increased from

777 rigs in the first week of January 2011 to 1,558 rigs in the last week of June 2014.  The rig

count for gas production declined from 914 rigs to 314 rigs over the same period.108   

                                                                                                                                                                              

(...Continued)

merchandise (if, in fact, there were large nonsubject import suppliers).  In order to provide a more

complete record for the Commission’s causation analysis, these requests typically seek information on

capacity, production, and shipments of the product under investigation in the major source countries

that export to the United States.  The Commission plans to continue utilizing published or requested

information in final phase investigations in which there are substantial levels of nonsubject imports.

102 We provide in our respective discussions of volume, price effects, and impact a full analysis of

other factors alleged to have caused any material injury experienced by the domestic industry.

103 Mittal Steel, 542 F.3d at 873; Nippon Steel Corp., 458 F.3d at 1350, citing U.S. Steel Group, 96

F.3d at 1357; S. Rep. 96‐249 at 75 (“The determination of the ITC with respect to causation is ... complex

and difficult, and is a matter for the judgment of the ITC.”).    104 CR at I‐14, PR at I‐12.

105 CR at II‐11, PR at II‐8.

106 CR at II‐11‐12, PR at II‐8.

107 Rig count may not, however, correlate precisely with demand for line pipe.  As noted above,

because of changes in drilling technology, the number of oil or gas wells per pad has grown.

108 CR at II‐12, PR at II‐9, and CR/PR at Figure II‐2.  We note that the TSEA has argued that

demand for certain welded line pipe is more closely impacted by gas drilling activity than oil drilling

activity.  It contends that this is because larger diameter line pipe is more frequently used for oil drilling

activity and that there are means of transporting oil other than by pipe.  For this reason, the TSEA argues

that the decline in gas drilling over the POI had a particularly severe impact on the demand for certain

welded line pipe.  TSEA Postconference Brief at 2‐5.
19

Apparent U.S. consumption of certain welded line pipe increased from 2.5 million short

tons in 2011 to 3.3 million short tons in 2012 but then declined to 2.5 million short tons in

2013.109   

2. Supply Conditions

The three sources of certain welded line pipe supply in the U.S. market are domestic

production, imports of subject merchandise, and imports from nonsubject countries.  The 12

domestic producers that responded to the Commission’s U.S. producers’ questionnaire are

believed to account for the vast majority of certain welded line pipe produced in the United

States.110  There was one new domestic producer of certain welded line pipe during the POI

(Welspun), and a number of domestic producers expanded their line pipe production capacity.  

Companies that announced plans to add capacity included ACIPCO, CSI, EnergeX, Northwest

Pipe, and Prolamsa.  There was also a closure of a production facility; U.S. Steel closed its

McKeesport, PA plant in 2014.111  The domestic industry consistently held the largest share of

apparent U.S. consumption.   

In 2011 and 2013, cumulated subject imports were the next largest source of supply

other than the domestic industry.  The market share of cumulated subject imports rose from

22.7 percent in 2011 to 24.9 percent in 2012 and to 31.2 percent in 2013.112

Imports from nonsubject countries were present in the U.S. market throughout the

POI.113  They originated from a variety of countries, including Canada, Germany, Greece, Japan,

Mexico, and the United Kingdom.114  The market share of nonsubject imports rose from 22.3

percent in 2011 to 27.5 percent in 2012 and fell to 20.3 percent in 2013.115  ***.116

                                                       109 CR/PR at Table IV‐6.  Apparent U.S. consumption for January‐June (“interim”) 2014 was 1.2

million short tons, lower than the 1.4 million short tons in interim 2013.  We note that Maverick

suggests that apparent U.S. consumption might not be the best measure of demand in these

investigations.  Specifically, it contends that the relatively large swings in apparent U.S. consumption,

compared to the modest changes in drilling activity, reflect the significant increase in subject imports

over the POI, and the exit of nonsubject imports in 2013.   Maverick Postconference Brief at 16.  We

invite the parties, in their comments on the questionnaires to be issued in any final phase investigations,

to indicate whether apparent consumption is an appropriate measure of demand, and, if not, how

demand should be measured.

110 CR/PR at III‐1. 111 CR at III‐3, PR at III‐2, CR/PR at Table III‐2. 112 CR/PR at Table IV‐7.  The market share of cumulated subject imports was 32.9 percent in

interim 2013 and 31.8 percent in interim 2014.  Id.

113 CR/PR at Table IV‐2. 114 CR/PR at Table IV‐2.

115 CR/PR at Table IV‐7.  The market share of nonsubject imports was 21.1 percent in interim

2013 and 18.1 percent in interim 2014.  Id.

116 CR at III‐3, PR at III‐2.
20

3. Substitutability and Other Conditions

Certain welded line pipe is normally produced to the API’s 5L specifications, which

provide standards for pipe suitable for use in conveying gas, water, and oil in both the oil and

gas industries.117  Based on the evidence in these preliminary investigations, we find a

moderate‐to‐high degree of substitutability between U.S.‐produced certain welded line pipe

and subject imports.118  All responding domestic producers and a majority of importers

reported that subject imports and the domestic like product are “always” or “frequently”

interchangeable, as discussed above.   

Korean Respondents and TSEA maintain that a number of factors limit the

substitutability of subject imports with the domestic like product.  They contend that domestic

producers have shorter lead times and offer greater flexibility in delivery than importers, and

that some end users insist on domestic line pipe due to “Buy American” requirements or for

liability reasons.  They further assert that some end users also are increasingly requiring “API

plus” requirements which stipulate tighter tolerances for the pipe over and above the API

specifications.  Respondents maintain that many end users have AMLs, and some subject

producers are not on these lists due to the difficulties in certifying and auditing production in

overseas mills.  TSEA states that Korean line pipe producers are generally more accepted on

AMLs than Turkish line pipe producers.119  Petitioners, on the other hand, argue that these

factors do not present any real obstacle to sales in the U.S. market by the subject imports.120

Hot‐rolled steel is the primary raw material used in the production of certain welded

line pipe and raw material costs accounted for an average 78.7 percent of total the cost of

goods sold (“COGS”) during the POI.  The domestic industry’s average raw material costs

declined by 7.2 percent from 2011 to 2013 and were lower in interim 2014 than in interim

2013.121

C. Volume of Subject Imports  

Section 771(7)(C)(i) of the Tariff Act provides that the “Commission shall consider

whether the volume of imports of the merchandise, or any increase in that volume, either in

absolute terms or relative to production or consumption in the United States, is significant.”122

Cumulated subject imports held a substantial presence in the U.S. market throughout

the POI.  Cumulated subject imports increased from 573,000 short tons in 2011 to 816,000

                                                       117 CR at I‐15, PR at I‐12.

118 CR at II‐16, PR at II‐12.

119 TSEA Postconference Brief at 7.

120 Maverick Postconference Brief at 18‐19 and Exh. 1, pp. 10‐12.  We will examine in any final

phase investigations the extent to which these factors are important to purchasing decisions and affect

the substitutability between the domestic like product and the subject imports.    121 Average raw material costs, per short ton, were $860 in 2011, $857 in 2012, $798 in 2013,

$807 in interim 2013, and $794 in interim 2014.  CR/PR at Table VI‐1.   122 19 U.S.C. § 1677(7)(C)(i).
21

short tons in 2012, and declined to 789,000 short tons in 2013.123  As explained above,

apparent U.S. consumption rose sharply (by 30.1 percent) from 2011 to 2012, but then declined

in 2013 (by 23.0 percent) roughly to where it was in 2011.124   

The volume of cumulated subject imports rose faster (by 42.2 percent) than apparent

U.S. consumption from 2011 to 2012, and declined more slowly (by 3.3 percent) between 2012

and 2013.125  Consequently, the market share (by quantity) of cumulated subject imports

increased from 22.7 percent in 2011 to 24.9 percent in 2012 and 31.2 percent in 2012.126  This

gain in market share came at the expense of both the domestic industry and nonsubject

imports.  The domestic industry’s market share decreased from 55.0 percent in 2011 to 47.7

percent in 2012 and rose to 48.5 percent in 2013.127 Nonsubject imports’ market share

increased from 22.3 percent in 2011 to 27.5 percent in 2012 and decreased to 20.3 percent in

2014.128

Cumulated subject imports were also at substantial levels relative to domestic

production, which increased from 2011 to 2013.  The ratio of cumulated subject imports to

domestic production increased from 39.6 percent in 2011 to 50.5 percent in 2012 and

increased to 60.4 percent in 2013.129

For purposes of these preliminary determinations, we find that the cumulated volume

of subject imports, and the increase in that volume, is significant both in absolute terms and

relative to consumption and production in the United States.

D. Price Effects of the Subject Imports

Section 771(7)(C)(ii) of the Tariff Act provides that, in evaluating the price effects of

subject imports, the Commission shall consider whether –  

(I) there has been significant price underselling by the imported merchandise as

compared with the price of domestic like products of the United States, and  

                                                       123 CR/PR at Table IV‐6.  Cumulated subject imports were 457,000 short tons in interim 2013 and

379,000 short tons in interim 2014.   124 CR/PR at Table C‐1.  Apparent U.S. consumption in interim 2014 was 14.4 percent lower than

in interim 2013.  Id.

125 CR/PR at Table C‐1.  The volume of cumulated subject imports in interim 2014 was 17.1

percent lower than in interim 2013, a decline that was greater than the decline in apparent U.S.

consumption (14.4 percent).  Id.   126 CR/PR at Table IV‐7.  Cumulated subject imports held 32.9 percent of U.S. market share in

interim 2013 and 31.8 percent of market share in interim 2014.  Id.

127 CR/PR at Table IV‐8.  The domestic industry’s market share was 46.1 percent in interim 2013

and 50.1 percent in interim 2014.  Id.

128 CR/PR at Tables IV‐8 and C‐1.  The market share of nonsubject imports was 21.1 percent in

interim 2013 and 18.1 percent in interim 2014.  Id.   129 CR/PR at Table IV‐2.  The ratio was 65.3 percent in interim 2013 and 55.2 percent in interim

2014.  Id.
22

(II) the effect of imports of such merchandise otherwise depresses prices to a

significant degree or prevents price increases, which otherwise would have

occurred, to a significant degree.130

The record in these preliminary phase investigations indicates that there is a moderate‐

to‐high degree of substitutability between subject imports and domestically produced certain

welded line pipe, and that price is an important factor in purchasing decisions.131

The Commission collected quarterly pricing data on four certain welded line pipe

products.132  Eleven U.S. producers and ten importers provided usable pricing data for sales of

the requested products, although not all firms reported pricing for all products and all

quarters.133

The pricing data show that the subject imports undersold the domestic like product in

all 55 quarterly comparisons.134  The margins of underselling ranged from 12.0 percent to 35.3

percent, and the average margin of underselling was 23.6 percent.135  Given the high frequency

and substantial margins of underselling and the fact that price is an important consideration in

purchasing decisions, we find the underselling to be significant.  This underselling allowed

subject imports to increase their market share at the expense of the domestic industry during

the 2011‐13.136

Prices generally decreased from 2011 through the first half of 2014.  Price declines for

domestically produced products 1, 2, and 3 ranged from *** to *** percent from the first

quarter of 2011 to the second quarter of 2014, while prices for product 4 increased ***

percent.  Prices for subject imports from Korea fell for each of the four products, with

decreases ranging from *** to *** percent.  Due to limited data points and coverage, price

trend data for subject imports from Turkey could not be calculated.137

We recognize that declines in the domestic industry’s raw material costs over the POI may

have played some role in the decline in the domestic industry’s prices.  However, the

                                                       130 19 U.S.C. § 1677(7)(C)(ii).

131 CR/PR at Tables II‐4 and II‐5.

132 The pricing products were:  Product 1 ‐‐ API 5L Grade B/X42 welded pipe, 6‐inch nominal size

(6.625 inch O.D.), plain end, with a wall thickness of 0.280 inch; Product 2 ‐‐ API 5L Grade B/X42 welded

pipe, 8‐inch nominal size (8.625 inch O.D.), plain end, with wall thickness of 0.322 inch; Product 3 ‐‐ API

5L Grade B/X42 welded pipe, 12‐inch nominal size (12.75 inch O.D.), plain end, with a wall thickness of

0.375 inch; and Product 4 ‐‐ API 5L Grade B/X60 welded pipe, 24‐inch nominal size (24 inch O.D.), plain

end, with a wall thickness of 0.375 inch.  CR at V‐5, PR at V‐4.

133 CR at V‐5, PR at V‐4.  Reported pricing products represented *** percent of U.S. shipments of

U.S.‐produced products, *** percent of shipments of imported product from Korea, and *** percent of

shipments of imported product from Turkey.   Id.

134 CR/PR at Table V‐7.

135 CR/PR at Table V‐7.

136 As noted above, from 2011 to 2013, the market share of subject imports rose from 22.7

percent to 31.2 percent, while the domestic industry’s market share fell from 55.0 percent to 48.5

percent.  CR/PR at Table C‐1.   137 CR at V‐14, PR at V‐9.
23

magnitude of the price declines was greater than the fall in raw material costs.138  We also

recognize that declining demand in the U.S. market in 2013 may have contributed to declining

prices that year.  Apparent U.S. consumption of certain welded line pipe increased from 2.5

million short tons in 2011 to 3.3 million short tons in 2012 but then declined to 2.5 million short

tons in 2013.139  Nevertheless, in light of the significant volume of low priced subject imports

with an increasing presence in the U.S. market, the record in this phase of the investigations

supports a preliminary finding that subject imports had significant price depressing effects.140

Information on the lost sales and lost revenue experienced by the domestic industry

provides further support for our findings concerning significant underselling and price

depression.  Petitioners made 35 lost sales allegations totaling $*** and involving *** short

tons and a lost revenue allegation involving $*** and *** short tons. In total, purchasers

agreed with allegations totaling *** short tons of lost sales, accounting for $***, as well as with

the lost revenue allegation.141  Additionally, four of ten responding purchasers reported

switching purchases from U.S. production to subject imports for price reasons.142

Accordingly, based on the record in the preliminary phase of these investigations, we

find the price underselling by the subject imports to be significant and that the price of subject

imports depressed prices to a significant degree.  We thus find for the purposes of these

preliminary determinations evidence that subject imports had significant effects on prices of

the domestic like product.

E. Impact of the Subject Imports143

Section 771(7)(C)(iii) of the Tariff Act provides that the Commission, in examining the

impact of the subject imports on the domestic industry, “shall evaluate all relevant economic

factors which have a bearing on the state of the industry.”  These factors include output, sales,

inventories, capacity utilization, market share, employment, wages, productivity, profits, cash

flow, return on investment, ability to raise capital, research and development, and factors

affecting domestic prices.  No single factor is dispositive and all relevant factors are considered

                                                       138 As previously stated, prices for three of the four pricing products decreased by over ***

percent between the first quarter of 2011 and the second quarter of 2014.  The average unit value

(“AUV”) of U.S. producers’ U.S. shipments declined by 13.5 percent from 2011 to 2013.  CR/PR at Table

C‐1.  By contrast, the domestic industry’s average unit raw material costs declined by 7.2 percent over

this period.  CR/PR at Table VI‐1.  We recognize that AUV data must be analyzed with caution because

changes in AUVs may reflect differences in product mix rather than differences in price.

139 CR/PR at Table IV‐6.  Apparent U.S. consumption for interim 2014 was 1.2 million short tons,

lower than the 1.4 million short tons in interim 2013.      140 In any final phase investigations we will examine further the role that falling raw material

costs and weakening demand played in the decline in prices for certain welded line pipe.   141 CR at V‐16, PR at V‐10‐11, CR/PR at Table V‐8.

142 CR at V‐20, PR at V‐11‐12.

143 In its notice initiating the antidumping duty investigations Commerce reported estimated

dumping margins ranging from 48.49 to 202.31 percent for imports from Korea, and 9.85 percent for

imports from Turkey.  Welded Line Pipe From the Republic of Korea and the Republic of Turkey: Initiation

of Less‐Than‐Fair‐Value Investigations, 79 FR 68213 (Nov. 14, 2014).
24

“within the context of the business cycle and conditions of competition that are distinctive to

the affected industry.”

Indicators of the domestic industry’s output and employment generally followed trends

in apparent consumption, with most increasing from 2011 to 2012 and declining from 2012 to

2013.  Operating performance, however, declined throughout the period, with a particularly

sharp decline from 2012 to 2013.

The domestic industry’s production increased from 1.4 million short tons in 2011 to 1.6

million short tons in 2012 and declined to 1.3 million short tons in 2013.144  The domestic

industry’s production capacity was 2.2 million short tons in 2011, 2.3 million short tons in 2012,

and 2.3 million short tons in 2013.145  Capacity utilization improved from 66.1 percent in 2011

to 70.5 percent in 2012 but then declined to 55.8 percent in 2013.146  The domestic industry’s

U.S. shipments increased from 1.4 million short tons in 2011 to 1.6 million short tons in 2012

but then declined to 1.2 million short tons in 2013.147  Ending inventory quantities were 92,457

short tons in 2011, 102,614 short tons in 2012, and 108,518 short tons in 2013.148

The number of production workers in the domestic industry was 1,815 in 2011, 2,167 in

2012, and 1,864 in 2013.149  Hours worked totaled 3.9 million in 2011, 4.5 million in 2012, and

3.7 million in 2013.150  Wages paid were $93.1 million in 2011, $115.4 million in 2012, and $98.5

million in 2013.151  Productivity, by contrast, declined throughout the POI.152

The domestic industry’s total net sales increased from $1.8 billion in 2011 to $2.1 billion in

2012 and declined to $1.5 billion in 2013.153  Operating income increased from $258.8 million in

2011 to $276.6 million 2012, but then declined to $18.6 million in 2013.154  On a per unit basis,

                                                       144 CR/PR at Table III‐4.  Production of 687,000 short tons in interim 2014 was lower than

699,000 short tons in interim 2013.  Id.

145 CR/PR at Table III‐4.  Capacity was 1.2 million short tons in both interim 2013 and interim

2014.  Id.

146 CR/PR at Table III‐4.  Capacity utilization was 57.9 percent in interim 2013 and 57.7 percent in

interim 2014. Id. 147 CR/PR at Table III‐5.  The industry’s U.S. shipments were 639,964 short tons in interim 2013

and 595,675 short tons in interim 2014.  Id.

148 CR/PR at Table III‐6.  Ending inventories were 143,575 short tons in interim 2013 and 161,243

short tons in interim 2014.  Id.

149 CR/PR at Table III‐7.  There were 1,960 production workers in interim 2013 and 2,012

production workers in interim 2014.  Id.

150 CR/PR at Table III‐7.  Hours worked were 1.9 million in interim 2013 and 2.0 million in interim

2014.  Id.

151 CR/PR at Table III‐7.   Wages paid were $49.6 million in interim 2013 and $51.8 in interim

2014.    152 Productivity (in short tons per 1,000 hours) was 371.8 in 2011, 359.6 in 2012, 348.8 in 2013,

362.9 in interim 2013, and 342.0 in interim 2014.  CR/PR at Table III‐7.

153 CR/PR at Table VI‐1.  The domestic industry’s total net sales were $773 million in interim

2013 and $673 million in interim 2014. Id.   154 CR/PR at Table VI‐1.  Operating income was $37.4 million in interim 2013, and in interim 2014

the domestic industry experienced a loss of $1.0 million.  Id.  We recognize that operating income was

impacted by ***.  CR at VI‐8 n.8, PR at VI‐3 n.8.  In any final‐phase investigations, we will review the

(Continued...)
25

raw materials costs declined from 2011 to 2012, and again from 2012 to 2013.  By contrast, the

ratio of both raw materials costs and COGS to net sales was higher in 2013 than in either prior

year of the POI.155  As the ratio of COGS to net sales increased, operating ratios fell.  Operating

income margins declined from 14.0 percent in 2011, to 13.1 percent in 2012, and then to 1.3

percent in 2013.156

The domestic industry made significant capital expenditures during the POI‐‐ $*** in

2011, $*** in 2012, and $*** in 2013.157  The parties were divided as to the significance of

these expenditures.  Petitioners contend that these investments in new plant and equipment

reflect, to a large extent, decisions made before, or early in, the POI, and do not reflect

confidence in the domestic industry’s future.158  Respondents argue that these investments are

a sign of confidence in the U.S. line pipe market.159  We invite further comment on this issue in

any final phase of these investigations.  

As discussed above, we have found the volume of cumulated subject imports and the

increase in the market share of those imports to have been significant over the POI, that these

imports undersold the domestic like product to a significant degree, and that there is evidence

of price depression by the subject imports.  Many of the domestic industry’s performance

indicators declined from 2012 to 2013, often to levels lower than in 2011.  Consequently, we

find, for purposes of the preliminary phase of these investigations, that there is a reasonable

indication that the large and increasing volume of subject imports, at prices that consistently

undersold the domestic like product and depressed domestic prices, had a significant impact on

the domestic industry by reducing its shipments, revenues, and financial performance from

levels that would have been reached otherwise.

In conducting our impact analysis, we have also considered the role of nonsubject

imports so as not to attribute injury from them to subject imports.  The volume and market

share of nonsubject imports increased from 2011 to 2012, but then declined in 2013 to levels

                                                                                                                                                                              

(...Continued)

impact of a new entrant and a facility closure on the domestic industry’s operating income.  We will also

examine further the role of subject imports in the facility closure.

Respondents argued that the industry’s operating data were skewed because some producers

reported unusually high raw material costs.  Korean Respondents’ Postconference Brief at 23‐29.  The

domestic producers have stated that they accurately reported raw material costs.  CR at VI‐6 nn. 1, 2, PR

at VI‐3 nn. 1, 2.  In any final phase investigations, the data of certain domestic producers will be more

closely examined.

155 The ratio of COGS to net sales increased from 81.7 percent in 2011 to 82.5 percent in 2012

and then to 92.8 percent in 2013.  It was 89.3 percent in interim 2013 and 94.6 percent in interim 2014.  

CR/PR, Table VI‐1.

156 CR/PR at Table VI‐1.  The operating margin was 4.8 percent in interim 2013 and negative 0.2

percent in interim 2014.  Id.

157 CR/PR at Table VI‐4.  Capital expenditures were $*** in interim 2013 and $*** in interim

2014.  The domestic industry’s research and development expenses were $*** in 2011, $*** in 2012,

$*** in 2013, $*** in interim 2013, and $*** in interim 2014.  Id.

158 Maverick Postconference Brief at 29.

159 TSEA Postconference Brief at 6.
26

below those of 2011.  The market share of nonsubject imports, measured by quantity, was 22.3

percent in 2011, 27.5 percent in 2012, and 20.3 percent in 2013.160  By contrast, the market

share of subject imports increased from 2011 to 2013.  The AUVs of imports from nonsubject

sources were greater than the AUVs of imports from subject sources throughout 2011‐June

2014, by amounts ranging from $110 per short ton to $286 per short ton.161  In light of these

considerations, the adverse effects of the subject imports are distinct from any attributable to

the nonsubject imports.162

We have also considered the role of declining demand in 2013.  As noted above,

apparent U.S. consumption of certain welded line pipe increased from 2.5 million short tons in

2011 to 3.3 million short tons in 2012 but then declined to 2.5 million short tons in 2013.163  The

decline in demand from 2012 to 2013, however, cannot account for the adverse impact

attributable to the domestic industry’s loss of market share to the subject imports from 2011 to

2013.  Although the level of demand in 2013 was roughly unchanged from that in 2011, the

domestic industry’s market share declined from 55.0 percent in 2011 to 48.5 percent in 2013.164  

Moreover, the pervasive underselling by subject imports also cannot be explained by declining

demand in 2013.  

VIII. Conclusion

For the reasons stated above, we determine that there is a reasonable indication that an

industry in the United States is materially injured by reason of subject imports of certain

welded line pipe from Korea and Turkey that are allegedly sold in the United States at less than

fair value and that are allegedly subsidized by the governments of Korea and Turkey.

                                                       160 CR/PR at Tables IV‐2 and IV‐8.  The volume of nonsubject imports was 562,605 short tons in

2011, 901,143 short tons in 2012, and 512,453 short tons in 2013.  Both the volume and market share of

nonsubject imports were lower in interim 2014, at 215,364 short tons and 18.1 percent, than in interim

2013, when they were 292,733 short tons and 21.1 percent.  Id.

161 CR/PR at Table IV‐2.  We recognize that average unit values are of limited value because they

may reflect differences in product mix rather than differences in price.

162 Based on the evidence in these preliminary investigations, Vice Chairman Pinkert finds that

certain welded line pipe is a commodity product for purposes of a Bratsk/Mittal Steel analysis, and that

price‐competitive nonsubject imports were a significant factor in the U.S. market.  He finds, however,

that there would have been a price benefit for the domestic industry to the extent that nonsubject

imports would have replaced the subject imports during the period of investigation.  Nonsubject import

prices were higher than subject import prices in six of the nine available price comparisons.  Compare

CR/PR at Tables V‐3, V‐5 to CR/PR at Tables D‐1, D‐2.  Moreover, nonsubject import AUVs were higher

than the AUVs of imports from subject sources throughout the period of investigation.  CR/PR at Table

IV‐2.

163 CR/PR at Table IV‐6.  Apparent U.S. consumption for interim 2014 was 1.2 million short tons,

lower than the 1.4 million short tons in interim 2013.      164 CR/PR at IV‐8.
I‐1

PART I: INTRODUCTION

BACKGROUND

These investigations result from petitions filed with the U.S. Department of Commerce

(“Commerce”) and the U.S. International Trade Commission (“USITC” or “Commission”) by

American Cast Iron Pipe Company (“ACIPCO”), Birmingham, Alabama; Energex, a division of

JMC Steel Group, Chicago, Illinois; Maverick Tube Corporation (“Maverick”), Houston, Texas;

Northwest Pipe Company (“Northwest Pipe”), Vancouver, Washington; Stupp Corporation

(“Stupp”), Baton Rouge, Louisiana; Tex‐Tube Company (“Tex‐Tube”), Houston, Texas; TMK

IPSCO, Houston, Texas; and Welspun Tubular LLC USA (“Welspun”), Little Rock, Arkansas, on

October 16, 2014, alleging that an industry in the United States is materially injured and

threatened with material injury by reason of subsidized and less‐than‐fair‐value (“LTFV”)

imports of welded API line pipe (“certain welded line pipe”) 1 from Korea and Turkey. The

following tabulation provides information relating to the background of these investigations.2 3

  

Effective date Action 

October 16, 2014 Petitions filed with Commerce and the Commission; 

institution of Commission investigations (79 FR 63438, 

October 23, 2014) 

November 6, 2014 Commission’s conference 

November 13, 2014 Commerce’s notice of initiation of countervailing duty 

investigations (79 FR 67419, November 13, 2014) 

November 14, 2014 Commerce’s notice of initiation of antidumping 

investigations (79 FR 68213, November 14, 2014) 

November 26, 2014 Commission’s vote 

December 1, 2014 Commission’s determination 

December 8, 2014 Commission’s views 

                                                      

1 See the section entitled “The Subject Merchandise” in Part I of this report for a complete

description of the merchandise subject to these investigations. 2 Pertinent Federal Register notices are referenced in appendix A, and may be found at the

Commission’s website (www.usitc.gov).

3 A list of witnesses appearing at the conference is presented in appendix B of this report.
I‐2

STATUTORY CRITERIA AND ORGANIZATION OF THE REPORT

Statutory criteria

Section 771(7)(B) of the Tariff Act of 1930 (the “Act”) (19 U.S.C. § 1677(7)(B)) provides

that in making its determinations of injury to an industry in the United States, the Commission‐‐ 

shall consider (I) the volume of imports of the subject merchandise, (II) the

effect of imports of that merchandise on prices in the United States for

domestic like products, and (III) the impact of imports of such

merchandise on domestic producers of domestic like products, but only in

the context of production operations within the United States; and. . .

may consider such other economic factors as are relevant to the

determination regarding whether there is material injury by reason of

imports.

Section 771(7)(C) of the Act (19 U.S.C. § 1677(7)(C)) further provides that‐‐ 

In evaluating the volume of imports of merchandise, the Commission shall

consider whether the volume of imports of the merchandise, or any

increase in that volume, either in absolute terms or relative to production

or consumption in the United States is significant.

. . .

In evaluating the effect of imports of such merchandise on prices, the

Commission shall consider whether. . .(I) there has been significant price

underselling by the imported merchandise as compared with the price of

domestic like products of the United States, and (II) the effect of imports

of such merchandise otherwise depresses prices to a significant degree or

prevents price increases, which otherwise would have occurred, to a

significant degree.

. . .

In examining the impact required to be considered under subparagraph

(B)(i)(III), the Commission shall evaluate (within the context of the

business cycle and conditions of competition that are distinctive to the

affected industry) all relevant economic factors which have a bearing on

the state of the industry in the United States, including, but not limited to

. . . (I) actual and potential decline in output, sales, market share, profits,

productivity, return on investments, and utilization of capacity, (II) factors

affecting domestic prices, (III) actual and potential negative effects on

cash flow, inventories, employment, wages, growth, ability to raise

capital, and investment, (IV) actual and potential negative effects on the

existing development and production efforts of the domestic industry,

including efforts to develop a derivative or more advanced version of the
I‐3

domestic like product, and (V) in {an antidumping investigation}, the

magnitude of the margin of dumping.

Organization of report

Part I of this report presents information on the subject merchandise, alleged dumping

margins and subsidies, and domestic like product. Part II of this report presents information on

conditions of competition and other relevant economic factors. Part III presents information on

the condition of the U.S. industry, including data on capacity, production, shipments,

inventories, and employment. Parts IV and V present the volume of subject imports and pricing

of domestic and imported products, respectively. Part VI presents information on the financial

experience of U.S. producers. Part VII presents the statutory requirements and information

obtained for use in the Commission’s consideration of the question of threat of material injury

as well as information regarding nonsubject countries.

MARKET SUMMARY

Certain welded line pipe includes welded line pipe used in pipelines for the gathering,

transmission, and distribution of oil and gas. The leading U.S. producers of certain welded line

pipe are Stupp, ACIPCO, and California Steel Industries (“CSI”). The leading producers of certain

welded line pipe in subject countries include Hyundai HYSCO and SeAH in Korea and Toscelik

Profil ve Sac Endustrisi A.S (“Toscelik”) and Borusan Mannesmann Boru Sanayi Ve Ticaret

(“Borusan Mannesmann”) in Turkey.  Leading countries producing welded tubes outside the

United States include China, Russia, Korea, Japan, and Turkey.4 The leading U.S. importers of

certain welded line pipe from Korea are ***, while the leading importer of certain welded line

pipe from Turkey is ***. Leading importers of product from nonsubject countries (primarily

Japan and Mexico) include ***.

Apparent U.S. consumption of certain welded line pipe totaled approximately 2.5 million

short tons ($2.6 billion) in 2013. Twelve firms accounting for the vast majority of U.S.

production of certain welded line pipe responded to the Commission’s request for data. U.S.

producers’ U.S. shipments of certain welded line pipe totaled 1.2 million short tons ($1.4

billion) in 2013, and accounted for 48.5 percent of apparent U.S. consumption by quantity and

53.5 percent by value. U.S. imports from subject sources totaled nearly 789,000 short tons

(approximately $654 million) in 2013 and accounted for 31.2 percent of apparent U.S.

consumption by quantity and 25.2 percent by value. U.S. imports from nonsubject sources

totaled approximately 512,000 short tons (approximately $551 million) in 2013 and accounted

for 20.3 percent of apparent U.S. consumption by quantity and 21.3 percent by value.  

                                                      

4 World Steel Association, Steel Statistical Yearbook, 2014; the product category, welded tubes,

includes all types of welded pipe and tubes and is broader than Commerce’s scope.
I‐4

SUMMARY DATA AND DATA SOURCES

A summary of data collected in these investigations is presented in appendix C.

Appendix C presents summary data for welded line pipe not more than 24 inches in outside

diameter (table C‐1), welded line pipe not more than 16 inches in outside diameter (table C‐2),

and welded line pipe greater than 16 inches in outside diameter and less than or equal to 24

inches (table C‐3). U.S. industry data are based on questionnaire responses of 12 firms that

accounted for a vast majority of U.S. production of certain welded line pipe during 2013. U.S.

imports are based on official import statistics for the following seven statistical reporting

numbers from the Harmonized Tariff Schedule of the United States (“HTSUS”): 7305.11.1030,

7305.12.1030, 7305.19.1030, 7306.19.1010, 7306.19.1050, 7306.19.5110, and 7306.19.5150.5

PREVIOUS AND RELATED INVESTIGATIONS

The Commission has conducted several previous import relief investigations on line

pipe.  Table I‐1 presents information on investigations for line pipe not exceeding 16 inches in

outside diameter (for purposes of this table, referred to as “small diameter”).  Table I‐2

presents information on investigations that have included imports of welded line pipe not

exceeding 16 inches in outside diameter, in whole or in part.  Table I‐3 presents information on

investigations for welded line pipe exceeding 16 inches in outside diameter (for purposes of this

table, referred to as “large diameter”).   

                                                      

5 The scope of these investigations identifies 12 HTSUS subheadings or statistical reporting numbers

under which subject merchandise may be imported. Three HTS subheadings (7305.11.5000,

7305.12.5000, and 7305.19.5000) cover alloy steel pipe with no outside diameter size restriction. Import

questionnaire responses, staff interviews, and analysis of confidential import statistics show that there

were few entries of in‐scope merchandise under these three subheadings (see EDIS document no.

545605). Accordingly, the official import statistics presented in this report do not include data for these

three statistical subheadings. Counsel for petitioners and respondents agree with excluding these data

from the import statistics. Conference transcript, p. 48 (Schagrin); postconference brief of petitioner

Maverick, Exh. 1, p. 1 (noting that it reserves the right to provide further comments should there be final

phase investigations; and conference transcript, p. 127 (Cameron, Simon, and Nolan). Furthermore, the

scope states that the subject merchandise may also enter in HTSUS statistical reporting numbers

7305.11.1060 and 7305.12.1060. These HTSUS statistical reporting numbers are for LSAW line pipe or

other longitudinally welded pipe of iron or steel with an external diameter exceeding 24 inches. Staff

notes that the scope defines certain welded line pipe as not being more than 24 inches in nominal

outside diameter. Accordingly, these two statistical reporting numbers are also excluded from the

import data presented in this report.  
I‐5

Table I-1 

Certain welded line pipe: Previous small diameter line pipe Title VII and safeguard investigations 

Investigations Dates 

Outcome 

Number Product / Country Begin End 

701-TA-165, 168 

Welded Carbon Steel 

Pipes and Tubes from 

Brazil and Korea 

05/07/1982 

12/27/1982 

Brazil - terminated after 

Commission preliminary affirmative 

determination 

02/08/1983 

Korea - Commission final 

affirmative determination;1

 order 

revoked by Commerce effective 

October 1, 1984 

731-TA-212 

Welded Carbon Steel 

Pipes and Tubes from 

Venezuela 

12/18/1984 02/01/1985 Commission preliminary negative 

determination2

701-TA-242 & 

731-TA-253 

Welded Carbon Steel 

Pipes and Tubes from 

Venezuela 

02/28/1985 12/05/1985 

Terminated by Commerce 

following Commission preliminary 

affirmative determination2

701-TA-252-253 

& 

731-TA-272-274 

Welded Carbon Steel 

Pipes and Tubes from 

Taiwan, Turkey, and 

Yugoslavia 

07/16/1985 

01/08/1986 

Taiwan and Yugoslavia - 

terminated by Commerce following 

Commission preliminary affirmative 

determinations 

02/21/1986 

Turkey - Commission final 

affirmative determination;2

countervailing duty order revoked 

by Commerce effective January 1, 

2000 

731-TA-375 Certain Line Pipes and 

Tubes from Canada 02/11/1987 03/30/1987 Commission preliminary negative determination3

TA-201-70 Circular Welded Carbon 

Quality Line Pipe 06/30/1999 12/22/1999 

Commission affirmative 

determination with respect to all 

countries except Mexico and 

Canada;4

 relief ended effective 

March 1, 2003. 

731-TA-1073-

1075 

Circular Welded Carbon 

Quality Line Pipe from 

China, Korea, Mexico 

10/06/2004 

12/14/2004 

China - terminated by Commerce 

following Commission preliminary 

affirmative determination 

02/17/2005 Korea and Mexico terminated after 

petition withdrawn5

Notes continued on next page. 
I‐6

Table I-1--Continued 

Certain welded line pipe: Previous small diameter line pipe Title VII and safeguard investigations 

Investigations Dates 

Outcome 

Number Product / Country Begin End 

731-TA-1150 

Circular Welded Carbon 

Quality Steel Line Pipe 

from Korea 

04/03/2008 11/25/2008 Terminated after petition withdrawn 

701-TA-455 

Circular Welded Carbon 

Quality Steel Line Pipe 

from China 

04/03/2008 01/07/2009 Commission affirmative 

determination6

731-TA-1149 

Circular Welded Carbon 

Quality Steel Line Pipe 

from China 

04/03/2008 05/06/2009 Commission affirmative 

determination6

701-TA-455 & 

731-TA-1149 

(Review) 

Circular Welded Carbon 

Quality Steel Line Pipe 

from China 

12/02/2013 05/02/2014 Commission affirmative 

continuation of the orders 

1

 The Commission found small (16 inches or less) diameter welded carbon steel standard, line, and structural pipes 

and tubes to constitute a single like product. 

2

 The Commission found separate like products consisting of welded standard pipe and welded line pipe. 3

 The Commission found that the product Alike@ welded line pipe from Canada was welded line pipe. Commissioner 

Brunsdale concurred with reservations, writing that A...while I do not do so here, it appears appropriate to find that 

the like product consists of both standard and line pipe.@ 4

 The Commission found that the domestic product Alike or directly competitive@ with line pipe (including multiplestenciled line pipe) was line pipe. Commissioner Crawford concluded that the record would justify defining the like 

or directly competitive product as both line pipe and standard pipe, although she declined to do so. 5

 The Commission found small (16 inches or less) diameter welded line pipe to constitute a single like product but in 

the final phase sought data on both welded standard pipe and welded line pipe. 6

 The Commission found small (16 inches or less) diameter circular welded carbon quality steel line pipe to 

constitute a single like product, noting that it had found in a previous investigation that large diameter line pipe is a 

distinct like product from line pipe 16 inches and under in diameter. 

Source: Various Commission publications and Federal Register notices. 
I‐7

Table I-2 

Certain welded line pipe: Related Commission investigations 

Investigations Dates 

Outcome 

Number Product / Country Begin End 

TA-201-51 Carbon and Certain Alloy 

Tool Steel Products 01/24/1984 07/24/1984 Commission negative determination1

731-TA-732-733 

Circular Welded Nonalloy 

Steel Pipe from Romania 

and South Africa 

04/26/1995 06/27/1996 Commission final negative 

determination2

731-TA-943-947 

Circular Welded 

Non-Alloy Steel Pipe from 

China, Indonesia, 

Malaysia, Romania, and 

South Africa 

05/24/2001 

07/16/2001 

Indonesia, Malaysia, Romania, and 

South Africa - Commission 

preliminary negative determination 

07/02/2002 China - Commission final negative 

determination3

TA-421-06 

Circular Welded NonAlloy Steel Pipe from 

China 

08/02/205 10/21/2005 

Commission affirmative4

 followed 

by a Presidential determination 

that import relief was not in the 

national interest 

701-TA-447 & 

731-TA-1116 

Circular Welded Carbon 

Quality Steel Pipe from 

China 

06/07/2007 07/02/08 Commission affirmative final 

determinations5

701-TA-447 & 

731-TA-1116 

(Review) 

Circular Welded Carbon 

Quality Steel Pipe from 

China 

06/03/2013 11/18/13 Commission affirmative 

continuation of the order 

1

 The Commission found that the like or directly competitive product was all welded and seamless pipe. 2

 In the final phase of the investigations, the Commission found that the domestic product Alike@ subject imports of 

standard pipe (including multiple-stenciled pipe used in standard pipe applications) included all multiple-stenciled 

pipe. Commissioners Crawford and Watson concluded that the record would justify defining the domestic like 

product to include all (welded) line pipe, although they declined to do so. 

3

 In the final phase of the investigation, the Commission found that the domestic product Alike@ subject imports of 

standard pipe (including multiple-stenciled pipe used in standard pipe applications) was standard pipe (including 

multiple-stenciled pipe used in standard pipe applications), Aabsent argument and information to the contrary.@ 4

 The Commission found that the domestic product Alike or directly competitive@ subject imports of standard pipe 

(including multiple-stenciled pipe used in standard pipe applications) was standard pipe (including multiple-stenciled 

pipe used in standard pipe applications). 

5

 The Commission defined the domestic like product as coterminous with Commerce=s scope. Commerce's scope 

includes multiple-stenciled line pipe when it meets the physical description (in the scope) and also has one or more 

of the following characteristics: is 32 feet in length or less; is less than 2.0 inches (50 mm) in outside diameter; has 

a galvanized and/or painted surface finish; or has a threaded and/or coupled end finish. 

Source: Various Commission publications and Federal Register notices. 
I‐8

Table I-3 

Certain welded line pipe: Related Commission investigations, large diameter line pipe 

Investigations Dates 

Outcome 

Number Product / Country Begin End 

731-TA-183 

Large Diameter Carbon 

Steel Welded Pipes from 

Brazil 

March 

1984 

March 

1985 

Commission termination of 

investigation following withdrawal 

of petition 

731-TA-919 

Certain Welded Large 

Diameter Line Pipe from 

Japan and Mexico 

January 

2001 

October 

2001 

Japan-Commission affirmative 

determination1

February 

2002 

Mexico-Commission affirmative 

determination 

TA-201-73 Certain Steel Products June 2001 December 

2001 

Commission affirmative 

determination, relief ended 

effective December 4, 20032

731-TA-919 

(Review) 

Certain Welded Large 

Diameter Line Pipe from 

Japan and Mexico 

November 

2006 

October 

2007 

Commission affirmative 

continuation of the order on Japan 

and revocation of the order on 

Mexico 

731-TA-919 

(Second Review) 

Certain Welded Large 

Diameter Line Pipe from 

Japan 

October 

2012 

September 

2013 

Commission affirmative 

continuation of the order 

1

 The Commission found that the domestic like product as welded carbon and alloy line pipe with an outside diameter 

greater than 16 inches but less than 64 inches. 

2

 The Commission majority found that the domestic like product was welded pipe other than OCTG. The like or 

directly competitive product did not include welded pipe with an outside diameter that does not exceed 16 inches (the 

excluded welded line pipe 16 inches or less in diameter was covered by the section 201 relief request on line pipe, 

TA-201-70, which is discussed above). 

Source: Various Commission publications and Federal Register notices.

NATURE AND EXTENT OF ALLEGED SUBSIDIES AND SALES AT LTFV

Alleged subsidies

On November 13, 2014, Commerce published a notice in the Federal Register of the

initiation of its countervailing duty investigation on certain welded line pipe from Korea.6

Commerce identified the following government programs in Korea:

 Korean Export‐Import Bank (KEXIM) Countervailable Subsidy Programs

 Korea Development Bank (KDB) and Industrial Bank of Korea (IBK) Short‐Term

Discounted Loans for Export Receivables

 Korea Trade Insurance Corporation (K‐SURE) ‐ Export Insurance and Export Credit

Guarantees

                                                      

6 Welded Line Pipe From the Republic of Korea and the Republic of Turkey: Initiation of Countervailing

Duty Investigations, 79 FR 67419, November 13, 2014.
I‐9

 GOK Facilities Investment Support: Article 26 of the Restriction of Special

Taxation Act (RSTA)

 GOK Targeted “Stimulus” Subsidies

 Subsidies to Companies Located in Free Economic Zones (FEZs)

 Research and Development (R&D) Grants under the Industrial Technology

Innovation Promotion Act (ITIPA)

 Modal Shift Program

 Grants to HYSCO and Husteel

 Provision of Electricity for Less Than Adequate Remuneration (LTAR)

On November 13, 2014, Commerce published a notice in the Federal Register of the

initiation of its countervailing duty investigation on certain welded line pipe from Turkey.7

Commerce identified the following government programs in Turkey:

 Provision of Hot‐Rolled Steel for LTAR Program 2

 Provision of Electricity for LTAR

 Provision of Land for LTAR

 Provision of Lignite for LTAR

 Deductions from Taxable Income for Export Revenue

 Incentives for Research & Development (R&D) Activities

 Short‐Term Pre‐Shipment Rediscount Program

 Pre‐Export Credits Program

 Export Insurance Provided by Turk Eximbank

 Investment Encouragement Program Customs Duty and VAT Exemptions

 Large‐Scale Investment Incentives

 Strategic Investment Incentives

 Law 5084: Withholding of Income Tax on Wages and Salaries

 Exemption from Property Tax

 Law 5084: Incentive for Employer’s Share in Insurance Premiums  

Alleged sales at LTFV

On November 14, 2014, Commerce published a notice in the Federal Register of the

initiation of its antidumping duty investigations on certain welded line pipe from Korea and

Turkey.8 Commerce has initiated antidumping duty investigations based on estimated dumping

margins of 48.49 to 202.31 percent for certain welded line pipe from Korea and 9.85 percent

for certain welded line pipe from Turkey.

                                                      

7 Welded Line Pipe From the Republic of Korea and the Republic of Turkey: Initiation of Countervailing

Duty Investigations, 79 FR 67419, November 13, 2014.

8 Welded Line Pipe From the Republic of Korea and the Republic of Turkey: Initiation of Less‐Than‐

Fair‐Value Investigations, 79 FR 68213, November 14, 2014.
I‐10

THE SUBJECT MERCHANDISE

Commerce’s scope

Commerce has defined the scope of this investigation as follows:

The merchandise covered by these investigations is circular welded

carbon and alloy steel (other than stainless steel) pipe of a kind used for

oil or gas pipelines (welded line pipe), not more than 24 inches in nominal

outside diameter, regardless of wall thickness, length, surface finish, end

finish, or stenciling. Welded line pipe is normally produced to the

American Petroleum Institute (API) specification 5L, but can be produced

to comparable foreign specifications, to proprietary grades, or can be

non‐graded material. All pipe meeting the physical description set forth

above, including multiple‐stenciled pipe with an API or comparable

foreign specification line pipe stencil is covered by the scope of these

investigations.

The welded line pipe that is subject to these investigations is currently

classifiable in the Harmonized Tariff Schedule of the United States

(HTSUS) under subheadings 7305.11.1030, 7305.11.5000, 7305.12.1030,

7305.12.5000, 7305.19.1030, 7305.19.5000, 7306.19.1010,

7306.19.1050, 7306.19.5110, and 7306.19.5150. The subject

merchandise may also enter in HTSUS 7305.11.1060 and 7305.12.1060.

While the HTSUS subheadings are provided for convenience and customs

purposes, the written description of the scope of these investigations is

dispositive.9

Tariff treatment

Based upon the scope set forth by the Department of Commerce, information available

to the Commission indicates that the merchandise subject to this investigation is imported

under statistical reporting numbers 7305.11.1030, 7305.11.5000, 7305.12.1030, 7305.12.5000,

7305.19.1030, 7305.19.5000, 7306.19.1010, 7306.19.1050, 7306.19.5110, and 7306.19.5150 of

the Harmonized Tariff Schedule of the United States (“HTS”).10 The general rate of duty for

these statistical reporting numbers is free.  

                                                      

9 Welded Line Pipe From the Republic of Korea and the Republic of Turkey: Initiation of Countervailing

Duty Investigations, 79 FR 67419, November 13, 2014.

10 The scope of these investigations identifies 12 HTSUS provisions under which imports of subject

merchandise may be reported. The scope includes seven HTSUS statistical reporting numbers under

which subject line pipe primarily enters the United States (7305.11.1030, 7305.12.1030, 7305.19.1030,

(continued...)
I‐11

THE PRODUCT

Overview

Line pipe11 is a classified as a long‐rolled steel pipe product that can be either welded or

seamless, and produced in sizes from 1/8 inches to 36 inches in outside diameter. The most

common application for line pipe is the gathering, transmission, and distribution of oil and gas.

Line pipe can be produced with plain ends, threaded, beveled, grooved, flanged or expanded,

depending on the requirements.12 Figure I‐1 is a visual depiction of welded line pipe.  

           Figure I‐1: Welded API line pipe

 Source: http://www.apisteel.com/api-5l-x42-steel-line-pipe-813/

                                                      

(...continued)

7306.19.1010, 7306.19.1050, 7306.19.5110, and 7306.19.5150). Data collected under these seven

HTSUS statistical reporting numbers are presented in this report. The scope also includes three HTS

subheadings (7305.11.50, 7305.12.50, and 7305.19.50) which cover alloy steel pipe with no outside

diameter size restriction, thus covering goods of larger diameter along with subject goods.  Separate

data for subject merchandise classified in those subheadings are not available, but based on the staff

research referenced above, entries of subject merchandise are believed to be limited.  Finally, the

references two additional HTSUS statistical reporting numbers (7305.11.1060 and 7305.12.1060),

covering LSAW line pipe or other longitudinally welded pipe of iron or steel exceeding 24 inches in

outside diameter. 11 The terms “pipes” and “tubes” are interchangeable in common usage and in the HTSUS. However,

tubular product manufacturers typically classify “pipes” as having a circular cross‐section in a few

standard sizes, whereas “tubes” may have any cross‐sections (circular, square, rectangular or others).

Steel pipes can be manufactured in either a welded or seamless process.  Steel pipes can be further

subdivided according to the grades of steel (carbon, alloy and stainless) used in steel production.

Moreover, the American Iron and Steel Institute (AISI) further categorizes steel pipes and tubes by six‐

end uses: line pipe, standard pipe, structural pipe and tubing, mechanical tubing, pressure tubing and oil

country tubular goods. Seamless pipe and stainless steel pipe are outside the scope of these

investigations.   12 Mohinder L. Nayyar, “Piping Handbook,” Seventh Edition, 2000, pp. C‐238‐230.  
I‐12

Description and applications

The line pipe subject to these investigations is a welded circular pipe product, not more

than 24 inches (609.6 millimeters) in outside diameter, regardless of wall thickness, length,

surface finish, or end finish.13 Line pipe is generally produced in the United States in lengths of

40 feet or greater,14 and with either a bare finish or a black (lacquered) finish to protect the

pipe from rust, which is especially important for storage in humid climates or for waterborne

transportation. End finishes typically include square cut or beveled for welding in the field.15   

The subject product includes welded line pipe used in oil and gas pipelines for the

gathering, transmission, and distribution of oil and gas. Gathering is an upstream application in

which welded line pipe is used to move the natural gas out of the fields and into the processing

plants, or gather oil for further processing in oil refineries.16 According to petitioners, the use of

welded line pipe from 16 to 24 inches in diameter has recently become more common in

gathering applications like pad drilling, which is the practice of drilling multiple entry points into

oil wells from a single surface location, as opposed to drilling a single well.17 Transmission of oil

and gas is considered a midstream application in which welded line pipe is used to move oil and

gas to any type of collection or distribution point, often over long distances.18 Distributing oil

and gas is a downstream application in which welded line pipe is used to move the oil and gas

to the end customer.19 Petitioners state that line pipe between 16 and 24 inches is also being

used to distribute oil and gas to consumers.20  

Subject line pipe is normally produced in conformance with the American Petroleum

Institute’s API 5L specifications, which provides standards for “pipe suitable for use in conveying

gas, water, and oil in both the oil and gas industries.”21 The subject product generally bears an

API line pipe stencil.22 The API 5L grades define the strength level of the pipe and of the steel

                                                      

13 Although the scope of the investigation does not take into account wall thickness, API 5L

specifications have thickness allocations for their specifications.   14 Nominal 40‐45 foot lengths are referred to by the industry as “double random lengths” or “DRL.”   15 Annual Book of ASTM Standards, Section One, Iron and Steel Products, Volume 01.01, 2009, p.6,

and Mohinder L. Nayyar, “Piping Handbook,” Sixth Edition, 1992, p A.49.   16 Conference transcript, pp. 59‐60 (Nolan).   17 Conference transcript, pp. 53‐54 (Barnes).   18 Certain Welded Large Diameter Line Pipe from Japan, Investigation No. 731‐TA‐919 (Second

Review), USITC Publication 4427, September 2013, p. 24, and U.S. Steel Tubular Products’ website,

Standard and Line Steel Pipe, http://usstubular.com/standard‐and‐line‐steel‐pipe/, (accessed on

November 18, 2014).   19 Conference transcript, pp. 85‐86 (Fisher).   20 Postconference brief of petitioner ACIPCO et al., p. 4, and conference transcript, p.65 (Noland).   21 API, Specification for Line Pipe, API Specification 5L, 44th Edition, October 1, 2007. The API 5L

specification covers both seamless and welded steel line pipe. Although seamless pipe is covered by the

API 5L specification, it is outside the scope of these investigations. 22 A “stencil” is information marked by the manufacturer with paint stenciled on the outside of the

pipe indicating the specification in conformance with which it has been manufactured. However, the

purchaser and manufacturer can agree to put all or part of the markings on the inside of the pipe. Pipe

(continued...)
I‐13

used to make the pipe. For grade A25 and X42 to X80, the last two digits reflect the yield

strength of the steel.23 Lower grades of line pipe, namely A25, grades A and B, have lower

strength but have other desirable properties. For example, grade A line pipe is more malleable

and more readily weldable than pipes of higher grade. The API 5L specification also suggests

that “products in compliance with multiple compatible standards may be marked with the

name of each standard.” Thus, line pipe can bear multiple stencils, signifying compliance with

one or more certifications (such as grade B/ X‐42), as well as standard pipe,24 piling,25 or

structural26 pipe certifications.  

Manufacturing processes

Welded line pipe is most commonly manufactured by the electric resistance weld

(“ERW”) process or the submerged arc welding process (“SAW”). SAW encompasses both

helical (spiral) welding (“HSAW”) and longitudal welding (“LSAW”).27 The ERW manufacturing

process is the least expensive production method, and the LSAW manufacturing process is the

most expensive manufacturing method for producing line pipe.28 Line pipe produced from

LSAW is mainly used for transporting oil and gas, either onshore or offshore, while ERW‐ and

HSAW‐produced line pipe are mainly used for transporting oil and gas onshore.  The ERW

method cannot produce welded line pipe with a very heavy wall thickness, and therefore does

not work well in offshore or deep‐water applications where a heavier internal pressure is

needed to move crude oil or gas through a pipeline.29

                                                      

(...continued)

that is 1‐1/2 inches and smaller has identification markings die‐stamped on a metal tag fixed to the

bundle or printed on the straps or binding clips used to tie the bundle.   23 Tensile strength is measured in thousands of pounds per square inch (psi). Grades A and B require

yield strength of 30,000 and 35,000 psi, respectively.   24 ASTM A‐53, Grade B covers both welded and seamless pipe with a minimum tensile strength of

60,000 psi and minimum yield strength of 35,000 psi. The weld seam for ERW line pipe meeting ASTM A‐

53, Grade B specifications must be heat‐treated after welding. Annual Book of ASTM Standards, Section

One, Iron and Steel Products, Volume 01.01, 2009, p.2.

25 ASTM 252, Grade 3 covers welded and seamless steel pipe for piling application or permanent load

carrying member with a minimum yield strength of 45,000 psi. Annual Book of ASTM Standards, Section

One, Iron and Steel Products, Volume 01.01, 2009, p.149‐150.

26 ASTM A‐500, Grade C covers overs cold‐formed welded and seamless carbon round, square,

rectangular, or special shape structural tubing for general structural with a minimum yield strength of

50,000 psi. Annual Book of ASTM Standards, Section One, Iron and Steel Products, Volume 01.01, 2009,

p.355.

27 Petitioners noted that HSAW and LSAW manufacturing methods are more popular for welded API

line pipe above to the 24 inch to 48 inch diameter sizes in the United States. Conference transcript, p. 61

(Fisher).   28 Certain Welded Large Diameter Line Pipe from Japan, Investigation No. 731‐TA‐919 (Second

Review), USITC Publication 4427, September 2013, p. I‐18.   29 Conference transcript, p. 81 (Fisher, Clark).  
I‐14

Line pipe manufactured using the HSAW and ERW methods are produced from steel

sheet in coils in a continuous forming process. 30 By contrast, LSAW pipe requires piece‐by‐piece

production from thicker steel plates, and is used in more demanding applications.31 The ERW

process is limited by the width of the available steel coils and suitable for thinner‐walled and

small diameter pipes, and is used to produce pipe with a maximum outside diameter of 24

inches, maximum length of 80 feet, and a maximum pipe wall thickness of 0.63 inches. The

LSAW method of production can produce line pipe with a maximum outside diameter of 48

inches, and maximum length of 40 feet, and a maximum pipe wall thickness of 1.25 inches. 32  

According to conference testimony, line pipe below 24 inches in outside diameter can be

manufactured either by LSAW or HSAW method, but tend to be cost‐prohibitive.33

ERW Manufacturing Method

ERW is the dominant manufacturing method for producing welded line pipe up to 24

inches; and virtually all U.S. producers manufacturing line pipe up to 24 inches in outside

diameter use the ERW method.34 The ERW manufacturing process begins with coils of hot‐

rolled sheet steel, which are cut by a slitting machine into strips of the precise width needed to

produce a desired diameter of pipe. The slit coils are fed into tube mills, which cold‐form the

flat ribbon of steel into a tubular cylinder by a series of tapered forming rolls. The product is

then welded along the joint axis by heat obtained from the pipe’s resistance to the flow of

electric current of which it is part, and by applied pressure to form a forged weld. The welded

tube next passes under a tool that removes the outside flash (the metal extruded by the weld

process) resulting from pressure during the welding. Inside flash is likewise removed by cutting

tools. The tube is then subjected to such post‐weld heat treatment as is required, and may

involve heat treatment of the welded seam only or treatment of the full cross‐section of the

pipe. After heat treatment, sizing rolls shape the tube to specific diameter tolerances. The

product is then cooled and cut to length at the end of the tube mill. In the finishing stage, the

welded line pipe also may be beveled, inspected and hydrostatically tested (figure I‐2). The

same equipment and workers can be used to product standard pipe as well as other tubular

products, most commonly oil tubular goods (“OCTG”).35

                                                      

30 A continuous forming process is completed in one step versus the multi‐step, piece‐by‐piece

production of LSAW.   31 Seamless line pipe is mostly used for offshore drilling. Staff conference transcript, p. 80‐82.

32 Certain Welded Large Diameter Line Pipe from Japan, Investigation No. 731‐TA‐919 (Second

Review), USITC Publication 4427, September 2013, p. I‐17‐18.

33 Conference transcript, p. 59‐60 (Noland).

34 Compiled from data submitted in response to Commission’s questionnaire responses.   35 Circular Welded Carbon Quality Steel Line Pipe from China and Korea, Inv. Nos. 701‐TA‐455 and

731‐TA‐1149‐1150, USITC Publication 4003, May 2008, p. 32.  
I‐15

Figure I-2: ERW manufacturing process 

Source: Sunny Steel Enterprise Ltd., ERW Manufacturing Process, http://www.sunnysteel.com/erw-pipeprocesses.php#.VE5ySk10yic 

HSAW Manufacturing Method

Like ERW, the HSAW manufacturing method uses coiled hot‐rolled steel strip as the

starting material for formation of pipes. The coiled steel strip is loaded on a decoiler and the

strip is straightened and edges are milled to the desired joint configuration. The steel strip is

then formed to produce a cylinder hollowed body which is then welded spirally, like a helix, so

that the coil strip assumes the shape of the pipe at a predetermined forming angle. Inside and

outside welding is performed by an automatic submerged arc process. HSAW line pipe is not

limited by coil width because of the helical wrap of the steel, and is generally used for larger

diameter pipe projects in the United States. The HSAW method of line pipe production has

become more prevalent due to certain technological advances such as the ability to produce

wider and thicker hot‐rolled coils and improvements in welding technology for large diameter

pipes. The HSAW method of production can produce line pipe with a maximum outside

diameter of 64 inches, and maximum length of 80 feet, and a maximum pipe wall thickness of

1.03 inches.36 Figure I‐3 visually depicts the HSAW manufacturing process for welded line pipes.  

                                                      

36 Certain Welded Large Diameter Line Pipe from Japan, Investigation No. 731‐TA‐919 (Second

Review), USITC Publication 4427, September 2013, p. I‐18.  
I‐16

Figure I-3: HSAW manufacturing process 

Source: Indsur, HSAW Manufacturing Process, http://indsur.com/images/HSAW-ManufacturingProcess.jpg 

LSAW Manufacturing Method

Unlike the ERW and HSAW manufacturing methods, which begin with steel coils, the

LSAW method produces line pipe from cut‐to‐length steel plates. Each individual plate proceeds

through various steps including (a) shearing and edge planing to ensure that the plate is flat and

aligned so that the two edges of the steel plate are parallel and square with the ends and (b)

crimping or bending of the plate edges in order to avoid a flat surface along the seam of the

pipe and (c) bending the plate to the desired form.  The two primary methods of shaping line

pipe in the LSAW process are the pyramid rolling 37and the U‐O‐E methods.38 Figure I‐4 visually

depicts the LSAW manufacturing process for welded line pipes.  

                                                      

37 The pyramid rolling machine consists of an elongated three‐roll bending apparatus with the two

bottom rolls fixed and the top roll movable along a vertical plane.  The steel plate moves into position

beneath the top roll and, through the proper combination of force and counter pressure, is shaped into

a cylinder around the top roll. The edges of the pipe are formed by a continuous crimping machine,

which prepares the edges for welding. When this is accomplished, the pipe is welded along the joint

axis. Finally, the pipe is sized to ensure that it meets specifications on roundness and diameter at the

ends. The sizing machine consists of a top and bottom roll shaped to the desired configuration of the

pipe. Pressure is applied on the top roll to exert a force on the pipe as it passes between the rolls.

Certain Welded Large Diameter Line Pipe from Japan, Investigation No. 731‐TA‐919 (Second Review),

USITC Publication 4427, September 2013, p. I‐17‐20.

38 In the U‐O‐E method, the plate is crimped by bending the edges upward; it then enters the

U‐press, where a die bends it into a “U” shape. Next, the “U” enters the O‐press, where the walls of the

(continued...)
I‐17

Figure I-4: LSAW manufacturing process, U-O-E method 

Source: Oil and Gas Journal, Volume 109, Issue 49, December 2011, 

http://www.ogj.com/content/dam/ogj/print-articles/Volume%20109/December%205/z111205OGJtfr04.jpg

DOMESTIC LIKE PRODUCT ISSUES

Petitioners ACIPCO et al. and Maverick (“Petitioning Coalition”) contend that the

Commission should find one domestic like product coextensive with Commerce’s scope.39

                                                      

(...continued)

“U” are forced together, resulting in an “O” shaped pipe. The pipe is then welded along the joint axis. In

order to round the pipe and to ensure proper yield strength (which may be reduced in the O‐press), two

methods of expansion can be used, mechanical or hydraulic. In the mechanical expander, the pipe is

moved over a head mechanism with symmetrical segments that can exert force on the inside of the

pipe, thereby causing it to expand. In the hydraulic expander, the pipe is closed at both ends, filled with

water and then pressurized. Under high pressure, the pipe expands to fill outside dies of the desired

size. The pipe is then tested and inspected. LSAW pipe is welded with an electric arc that heats the

metal edges and a consumable electrode or electrodes which provide the filler metal. The weld is

blanketed by a shield of granular, fusible flux to protect the hot weld from chemically reacting with the

surrounding air. Pipes usually are welded on both the outside and the inside of the same seam.

Following the welding process, the scaly deposit left from the flux must be scraped away and the pipe

cleaned. The weld is then inspected to correct any defects. Certain Welded Large Diameter Line Pipe

from Japan, Investigation No. 731‐TA‐919 (Second Review), USITC Publication 4427, September 2013, p.

I‐17‐20.

39 Postconference brief of petitioner Maverick, p. 4 and postconference brief of petitioner ACIPCO et

al., p. 2. Petitioners ACIPCO et al. do, however, acknowledge that earlier investigations found that all

welded line pipe 16 inches and under constituted a single like product, and that all welded line pipe

greater than 16 inches and less than 64 inches constituted a single like product.
I‐18

Petitioner Maverick argues that all welded line pipe up to 24 inches in outside diameter has the

same physical characteristics and end uses, the same producer and consumer perceptions, the

same channels of distribution, and the same manufacturing processes and employees.40

Petitioner Maverick also contends that there is a clear dividing line between line pipe up to 24

inches in outside diameter and line pipe greater than 24 inches in outside diameter.41

Petitioners ACIPCO et al. noted that firms’ responses to the “interchangeability” domestic like

product factor generally commented that the size of the pipe used depends on the volume of

product it will transmit, and that the difference between 6 inches and 8 inches is similar to the

differences between 16 inches and 18 inches.42 Petitioners ACIPCO et al. addressed the  

“price” domestic like product factor by summarizing questionnaire responses.43

Korean respondents44 argue that there is one domestic like product consisting of line

pipe equal to or less than 16 inches and another domestic like product of ERW pipe greater

than 16 inches.45 Korean respondents argue that line pipe 16 inches and under is used in

gathering lines while line pipe over 16 inches is used for large pipeline transmission projects.46

Korean respondents argue that pipeline projects determine the size of pipe required and that

16 inch pipe can never be used on a 24 inch pipeline. Korean respondents also contend that for

the ERW production process, sizes above 16 inches would be made on a separate production

line dedicated to the larger diameter product.47 48 Korean respondents acknowledge that both

size ranges are sold to end users, but larger line pipe is more likely directly sold to end users for

projects. Furthermore, customers demand pipe to meet specific end uses, and as those end

uses vary, so do customer perceptions.  Finally, Korean respondents argue that line pipe equal

to or less than 16 inches is generally lower in price.  

                                                      

40 Postconference brief of petitioner Maverick, p. 4. Maverick did not address domestic like product

factors for price and interchangeability. 41 Postconference brief of petitioner Maverick, p. 5.

42 Postconference brief of petitioner ACIPCO et al., pp. 5‐6.

43 Postconference brief of petitioner ACIPCO et al., pp. 9‐10. 44 Respondent Turkish Steel Exporters Association do not object to the petitioners’ definition of the

like product and domestic industry but do reserve the option to reconsider this matter should the

Commission reach preliminary affirmative determinations. Postconference brief of Respondent Turkish

Steel Exporters Association (“Turkish Exporters”), p. 11. Respondent Turkish producers did not comment

on the definitions of the domestic like product or the domestic industry.

45 Postconference brief of Korean respondents, p. 7.

46 Postconference brief of Korean respondents, p. 7. 47 Korean respondents claim that “sizes above 16 inches require much larger and stronger

equipment.” Postconference brief of Korean respondents, p. 8.

48 Korean respondents also state (based on conference testimony) that the HSAW and LSAW

production processes are not used to produce line pipe 24 inches and under, therefore pipe produced

by these processes should be excluded from their proposed like product definition for 16 inch pipe or

more. Postconference brief of Korean respondents, p. 8. However, as shown in table III‐3, the ***

production process is used to produce a small quantity of welded line pipe 24 inches and under.
I‐19

The Commission’s decision regarding the appropriate domestic product(s) that are “like”

the subject imported product is based on a number of factors including: (1) physical

characteristics and uses; (2) common manufacturing facilities and production employees; (3)

interchangeability; (4) customer and producer perceptions; (5) channels of distribution; and (6)

price. Information regarding these factors is discussed below.

Physical characteristics and uses

Table I‐4 presents the information provided by U.S. producers and importers on the

comparison of the physical characteristics and uses of welded line pipe not more than 16 inches

in diameter and welded line pipe greater than 16 inches in outside diameter and less than or

equal to 24 inches.

Table I-4 

Certain welded line pipe: Comparison of physical characteristics and uses 

* * * * * * * 

Manufacturing facilities and production employees

Table I‐5 presents the information provided by U.S. producers in their comparison of the

manufacturing facilities, processes, and employees of welded line pipe not more than 16 inches

in diameter and welded line pipe greater than 16 inches in outside diameter and less than or

equal to 24 inches. Of the responding producers, eight only produced welded line pipe 16

inches in diameter or less. There were no producers that exclusively produced welded line pope

greater than 16 inches but not greater than 24 inches. The four producers that produced

welded line pipe greater than 16 inches but not greater than 24 inches also produced welded

line pipe not more than 16 inches in diameter.

Table I-5 

Certain welded line pipe: Comparison of manufacturing facilities and production employees 

* * * * * * * 

Interchangeability

Table I‐6 presents the information provided by U.S. producers and importers on the

interchangeability of welded line pipe not more than 16 inches in diameter and welded line

pipe greater than 16 inches in outside diameter and less than or equal to 24 inches.

Table I-6 

Certain welded line pipe: Assessment of interchangeability 

* * * * * * * 
I‐20

Producer and customer perceptions

Table I‐7 presents the information provided by U.S. producers and importers on

producer and customer perceptions of welded line pipe not more than 16 inches in diameter

and welded line pipe greater than 16 inches in outside diameter and less than or equal to 24

inches.

Table I-7 

Certain welded line pipe: Assessment of producer and customer perceptions 

* * * * * * * 

Channels of distribution

Table I‐8 presents the information provided by U.S. producers and importers on the

channels of distribution of welded line pipe not more than 16 inches in diameter and welded

line pipe greater than 16 inches in outside diameter and less than or equal to 24 inches. U.S.

producers of welded line pipe not more than 16 inches in diameter reported that *** percent

of their U.S. commercial shipments were to distributors and *** percent were to end users in

2013. U.S. producers of welded line pipe greater than 16 inches in outside diameter and less

than or equal to 24 inches reported that *** percent of their U.S. commercial shipments were

to distributors and *** percent of their U.S. shipments were to end users in 2013.49

Table I-8 

Certain welded line pipe: Comparison of channels of distribution 

* * * * * * * 

Price

Table I‐9 presents the information provided by U.S. producers and importers on the

price of welded line pipe not more than 16 inches in diameter and welded line pipe greater

than 16 inches in outside diameter and less than or equal to 24 inches. Table I‐10 presents the

average unit values of domestic producers’ U.S. shipments of welded line pipe not more than

16 inches in diameter and welded line pipe greater than 16 inches in outside diameter and less

than or equal to 24 inches. The average unit values of welded line pipe not more than 16 inches

in diameter were consistently lower than average unit values of domestic producers’ U.S.

shipments of welded line pipe greater than 16 inches in outside diameter and less than or equal

to 24 inches during 2011‐13 and January‐June 2014.

                                                      

49 For more information on channels of distribution, see Part II.
I‐21

Table I-9 

Certain welded line pipe: Comparison of prices 

* * * * * * * 

Table I-10 

Certain welded line pipe: Average unit values of domestic producers’ U.S. shipments of welded 

line pipe <= 16 inches and welded line pipe > 16 inches and <= 24 inches, 2011-13, January-June 

2013, and January-June 2014 

* * * * * * * 

II‐1

PART II: CONDITIONS OF COMPETITION IN THE U.S. MARKET

U.S. MARKET CHARACTERISTICS

Certain welded line pipe is used to transport oil and gas at all three stages of

production: gathering at the production source, transmission across regions, and distribution to

consumers. It is produced in compliance with the American Petroleum Institute’s (API) 5L

standard. This standard was revised in July 2013 to ensure quality standards and address

concerns regarding liability.1 Petitioners stated that U.S. producers and importers produce

welded line pipe meeting the API 5L specification as well as additional requirements requested

by end users.2 Demand for certain welded line pipe depends on various factors, including oil

and natural gas prices, and project‐specific factors based on the volume of oil or natural gas

produced to warrant the construction of a pipeline. There are at least 12 U.S. producers, eight

of which are the petitioners.   

CHANNELS OF DISTRIBUTION

U.S. producers sold to distributors and end users with a slight majority to distributors,

while importers sold mainly to distributors, as shown in table II‐1.

 

1 Conference transcript, p. 57 (Fisher and Dubreuil). Also, see API 5L 45th Edition Memorandum

certifying the July 1, 2013 effective date, http://www.api.org/certification‐programs/api‐monogram‐

program‐and‐apiqr/~/media/Files/Certification/Monogram‐APIQR/program‐

updates/API%20Spec%205L%2045th%20Ed%20Notification.pdf, November 20, 2014 2 Conference transcript, pp. 55‐58 (Barnes, Clark, Fisher, Dubreuil).  
II‐2

Table II-1 

Certain welded line pipe: U.S. producers’ and importers’ U.S. commercial shipments, by sources 

and channels of distribution, 2011-13, January-June 2013, and January-June 2014 

Item 

Period 

Calendar year January-June 

2011 2012 2013 2013 2014 

 Share of reported shipments (percent) 

U.S. producers’ U.S. commercial shipments of certain welded line pipe: 

 Distributors 61.8 55.9 57.8 58.1 62.0

 End users 38.2 44.1 42.2 41.9 38.0

U.S. importers’ U.S. commercial shipments of certain welded line pipe from Korea: 

 Distributors *** *** *** *** ***

 End users *** *** *** *** ***

U.S. importers’ U.S. commercial shipments of certain welded line pipe from Turkey: 

 Distributors *** *** *** *** ***

 End users *** *** *** *** ***

U.S. importers’ U.S. commercial shipments of certain welded line pipe from all other countries: 

 Distributors 51.7 40.4 52.4 46.3 48.1

 End users 48.3 59.6 47.6 53.7 51.9

Source: Compiled from data submitted in response to Commission questionnaires. 

GEOGRAPHIC DISTRIBUTION

More than half of the twelve responding U.S. producers reported selling certain welded

line pipe to all regions in the contiguous United States; most U.S. producers reported selling to

the Northeast, Midwest, Southeast, Central Southwest, and Mountain regions (table II‐2).

Importers reported selling primarily to the Central Southwest region, followed by the Southeast

and Pacific Coast. While both U.S. producers and importers sold certain welded line pipe

throughout the United States, only one importer of subject merchandise from Korea reported

serving the entire contiguous United States. Importers of subject merchandise from Turkey sold

mainly to the Central Southwest. For U.S. producers, *** percent of sales were within 100 miles

of their production facility, *** percent were between 101 and 1,000 miles, and *** percent

were over 1,000 miles. Importers’ U.S. shipments from Korea sold *** percent within 100 miles

of their U.S. point of shipment and *** percent between 101 and 1,000 miles, while importers’

U.S. shipments from Turkey sold *** percent within 100 miles of their U.S. point of shipment.  
II‐3

Table II-2 

Certain welded line pipe: Geographic market areas in the United States served by U.S. producers 

and importers, by number of responding firms 

Region U.S. producers 

Importers 

Korea Turkey 

Northeast1 11 4 0 

Midwest2 11 3 0 

Southeast3 11 8 1 

Central Southwest4 12 11 3 

Mountain5 12 1 0 

Pacific Coast6 9 8 0 

Other7 2 0 0 

All regions (except Other) 7 1 0 

Reporting firms 12 12 4 

1 Includes CT, ME, MA, NH, NJ, NY, PA, RI, and VT. 

2 Includes IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI. 3

 Includes AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV. 

4

 Includes AR, LA, OK, and TX. 

5 Includes AZ, CO, ID, MT, NV, NM, UT, and WY. 

6

 Includes CA, OR, and WA. 

7

All other U.S. markets, including AK, HI, PR, and VI, among others. 

Source: Compiled from data submitted in response to Commission questionnaires. 

SUPPLY AND DEMAND CONSIDERATIONS

U.S. supply

Domestic production

Based on available information, U.S. producers of certain welded line pipe have the

ability to respond to changes in demand with moderate changes in the quantity of shipments of

U.S.‐produced certain welded line pipe to the U.S. market. The main contributing factors to this

degree of responsiveness of supply are the availability of unused capacity and the ability to

produce alternate products.

Industry capacity

U.S. production of certain welded line pipe was 1.5 million short tons in 2011 and

decreased to 1.3 million short tons in 2013. Domestic capacity totaled 2.2 million short tons in

2011 and increased to 2.3 million short tons in 2013. Domestic capacity utilization decreased

from 66.1 percent in 2011 to 55.8 percent in 2013 and was 57.7 percent in interim January‐June

2014, compared to 57.9 percent in interim January‐June 2013. This relatively low level of

capacity utilization suggests that U.S. producers may have a moderate‐to‐large ability to

increase production of certain welded line pipe in response to an increase in prices.
II‐4

Alternative markets

U.S. producers’ exports, as a ratio to total shipments, increased from 2.3 percent in

2011 to 5.4 percent in 2013. U.S. producers’ export shipments were 2.7 percent during interim

January‐June 2013 and 5.8 percent during interim January‐June 2014. This proportion of total

shipments indicates that U.S. producers may have a limited ability to shift shipments between

the U.S. market and other markets in response to price changes. Six U.S. producers indicated

that they export to Canada, *** of which exports to *** as well.  

Inventory levels

U.S. producers’ inventories, as a ratio to total shipments, increased from 6.5 percent in

2011 to 8.4 percent in 2013 and were 10.9 percent during interim January‐June 2013 and 12.8

percent during interim January‐June 2014. These inventory levels suggest that U.S. producers

may have a limited‐to‐moderate ability to respond to changes in demand with changes in the

quantity shipped from inventories.

Production alternatives

All responding U.S. producers stated that they could switch production from certain

welded line pipe to other products. More than half of overall U.S. production was dedicated to

other products over the period. Other products that producers reportedly can produce on the

same equipment as certain welded line pipe are OCTG, welded standard pipe, welded structural

pipe, water transmission pipe, mining pipe, and piling (construction) pipe.  

Supply constraints

Ten of twelve responding U.S. producers reported they did not experience constraints

on their ability to supply certain welded line pipe. The remaining two reported instances in

which they declined to supply certain welded line pipe. *** declined to accept new business in

early 2013 and sold off prior scheduled rollings and inventory. *** reported that it had ample

capacity to fully satisfy all orders but was forced to decline certain sales because it could not

meet customer demands for prices as low as those of subject imports.  

Subject imports from Korea3

  

Based on available information, producers of certain welded line pipe from Korea have

the ability to respond to changes in demand with small‐to‐moderate changes in the quantity of

shipments of certain welded line pipe to the U.S. market. The main contributing factors to this

 

3 The Commission received four useable questionnaire responses from Korean producers. These

firms’ exports to the United States were equivalent to *** percent of U.S. imports of certain welded line

pipe from Korea in 2013.   
II‐5

degree of responsiveness of supply are limited unused capacity, some ability to shift shipments

to alternate markets, limited inventories, and the ability to produce alternate products.

Industry capacity

Korean capacity utilization increased from *** percent in 2011 to *** percent in 2012

and decreased to *** percent in 2013. This relatively high level of capacity utilization suggests

that Korean producers may have a limited ability to increase production of certain welded line

pipe in response to an increase in prices. Korean capacity was approximately *** percent of

U.S. capacity and Korean production was approximately *** percent of U.S. production in 2013.

Alternative markets

Korean producers’ exports represented *** of their total shipments since January 1,

2011. Korean producers’ export shipments to non‐U.S. markets declined from *** percent in

2011 to *** percent in 2013 and were *** percent and *** percent, respectively, in the interim

January‐June periods of 2013 and 2014. Projections indicate expansion of sales to markets

other than the United States. Countries and regions that Korean producers shipped to include

***. Therefore, Korean producers may have some ability to shift shipments between the U.S.

market and other markets in response to price changes.  

Inventory levels

Korean producers’ inventories, as a ratio to total shipments, increased from *** percent

in 2011 to *** percent in 2013. These inventory levels suggest that Korean producers may have

a limited ability to respond to changes in demand with changes in the quantity shipped from

inventories.

Production alternatives

*** responding Korean producers stated that they could switch production from certain

welded line pipe to other products. Nearly *** percent of overall Korean production was

dedicated to other products over the period. Other products that producers reportedly can

produce on the same equipment as certain welded line pipe are OCTG, standard pipe, boiler

tube, and structural pipe.  

Supply constraints

*** responding Korean producers reported constraints on their ability to supply certain

welded line pipe. *** reported product specification, line speed, and facility maintenance as

constraints. *** reported that machinery trouble and bottle necks during hydrostatic and non‐

destructive processes slow production.  
II‐6

Subject imports from Turkey4

  

Based on available information, producers of certain welded line pipe from Turkey have

the ability to respond to changes in demand with moderate changes in the quantity of

shipments of certain welded line pipe to the U.S. market. The main contributing factors to this

degree of responsiveness of supply are the availability of unused capacity, inventories, and the

ability to produce alternate products.

Industry capacity

Turkish capacity utilization decreased from *** percent in 2011 to *** percent in 2013

and was *** percent during interim January‐June 2014 compared to *** percent during interim

January‐June 2013. This relatively low level of capacity utilization suggests that U.S. producers

may have a moderate‐to‐large ability to increase production of product in response to an

increase in prices. Turkish capacity and production were approximately *** of Korea’s capacity

and production and *** of U.S. capacity and production in 2013.  

Alternative markets

Turkish producers’ exports, as a ratio to total shipments, represented roughly *** of

their total shipments since January 1, 2011. Turkish producers’ export shipments to non‐U.S.

markets declined from *** percent in 2011 to *** percent in 2013 and were *** percent and

*** percent, respectively, in the interim January‐June periods of 2013 and 2014. Projections

indicate expansion of sales to markets other than the United States. Countries that Turkish

producers shipped to include ***.5 Therefore, Turkish producers may have a moderate ability

to shift shipments between the U.S. market and other markets in response to price changes.  

Inventory levels

Turkish producers’ inventories, as a share of total shipments, increased from ***

percent in 2011 to *** percent in 2012 but fell to *** percent in 2013. These inventory levels

suggest that Turkish producers may have some ability to respond to changes in demand with

changes in the quantity shipped from inventories.

 

4 The Commission received *** questionnaire responses from Turkish producers. These firms’

exports to the United States were equivalent to *** percent of U.S. imports of certain welded line pipe

from Turkey in 2013.    5 According to the Turkish Steel Exporter’s Association, the United States is not the primary export

market for line pipe, and nor will it become a primary export market as announced projects (Trans‐

Anatolian gas systems, an Iran‐Turkey‐Europe natural gas pipeline, and a Trans‐Adriatic natural gas

pipeline) will increase domestic demand for large diameter pipe. Respondent Turkish Steel Exporters

Association postconference brief, p. 35. Respondents also indicated that Turkish pipes are also being

used in the Melen Project for water in Istanbul as well as for local gas distribution arms in Turkey to

renovate and upgrade facilities in and around Istanbul. Conference transcript, p. 112 (Nolan).
II‐7

Production alternatives

*** responding Turkish producers stated that they could switch production from certain

welded line pipe to other products. Over *** percent of overall Turkish production was

dedicated to other products over the period. Other products that producers reportedly can

produce on the same equipment as certain welded line pipe are OCTG, standard pipe, hollow

section, water pipe, structural pipe, and galvanized pipe.  

Supply constraints

*** responding Turkish producers reported constraints on their ability to supply certain

welded line pipe. *** reported these constraints as the particular size and strength capabilities

of particular lines, requirements for inside weld scarfing, high material grade, low diameter‐to‐

thickness ratio, low diameter‐to‐length ratio, seam annealing process, non‐destructive test,

drift test, and hydrotest. *** reported no constraints other than the “capabilities of the

equipment”. *** reported that “destructive and non‐destructive test capacities (Ultrasonic

Testing, Hydrotest), and heat treatment capacity are limited; finishing facilities such as

packaging and coating (mill lacquer) are also less than actual pipe capacity; unused space in the

plant is limited for setting up extra capacity for testing and further finishing operations; speed

of mill's welding capacity is limited; and, more importantly, allocation of resources for other

product lines.”

Nonsubject imports

Based on official import statistics, the largest sources of nonsubject imports during

2011‐13 were Canada, Germany, Greece, Japan, Mexico, and the United Kingdom.6 Combined,

these countries accounted for 78.9 percent of imports from nonsubject sources and 30.8

percent of total imports in 2013.7 8

  

 

6 Official statistics based on HTS statistical reporting numbers 7305.11.1030, 7305.12.1030,

7305.19.1030, 7306.19.1010, 7306.19.1050, 7306.19.5110, and 7306.19.5150. 7 Petitioners stated that there were 300,000 tons of nonsubject imports from Japan and Germany in

2012 that did not compete with domestic or subject imports because the product went into deep

offshore wells with heavy walls. Conference transcript, p. 158 (Schagrin).

8 There are already existing AD/CVD orders on line pipe no larger than 16 inches from China and an

existing AD order on line pipe larger than 16 inches but no larger than 24 inches from Japan. Circular

Welded Carbon Quality Steel Line Pipe From the People’s Republic of China: Continuation of Antidumping

and Countervailing Duty Orders, 79 FR 28894, May 20, 2014, and Welded Large Diameter Line Pipe From

Japan: Continuation of Antidumping Duty Order, 78 FR 64477, October 29, 2013.
II‐8

U.S. demand

Based on available information, the overall demand for certain welded line pipe is likely

to experience small‐to‐moderate changes in response to changes in price. The main

contributing factors are the lack of substitute products and the moderate‐to‐large cost share of

product in most of its end‐use products, depending on the identified end use.

U.S. demand for certain welded line pipe depends on the demand for energy products,

such as oil and natural gas, which require pipe capable of transporting these products under

pressure from gathering to transmission to distribution. According to Petitioners, the U.S.

domestic energy market has been strong and has created higher demand for certain welded

line pipe in the United States than in other international markets.9 The United States has been

producing oil and gas at historic levels since 2011, after the effects of the financial crisis

waned.10 According to the Turkish Steel Exporters Association, demand for the natural gas

sector declined overall, falling in the second part of 2012 and further in 2013. Demand for line

pipe declined as natural gas production declined, and the number of pipeline projects and the

rate of their approval slowed.11

Spot prices for oil and natural gas fluctuated between January 2011 and June 2014

(figure II‐1). Domestic crude oil prices began the period at $89 per barrel, reached $106 per

barrel in March 2012 and $107 per barrel in August 2013, and were $106 per barrel in June

2014. Spot prices for natural gas declined from $4.55 per million btu in June 2011 to $1.95 per

million btu in April 2012, then gradually increased until a sharp peak at $6 per million btu in

February 2014, and then returned to $4.55 per million btu by June 2014. Subsequent to June

2014, oil and gas prices have declined.

 

 

9 Conference transcript, p.19 (Clark).

10 Conference transcript, p. 39 (Lowe). 11 Turkish Steel Exporters Associate postconference brief, pp. 3‐4
II‐9

Figure II-1 

Crude oil (WTI) and natural gas (Henry Hub spot) prices, monthly, January 2011-September 2014 

Source: Energy Information Administration. 

Production of oil and gas can affect demand conditions for certain welded line pipe, and

rig count is a leading indicator of oil and gas sector activity. The rig count for oil production in

the United States increased from 777 rigs in the first week of January to 1,558 rigs in the last

week of June 2014 (figure II‐2). The rig count for gas production declined from 914 rigs to 314

rigs over the same period.  Respondents stated that demand for certain welded line pipe

depends on drilling activity, which can be illustrated by rig count over the period.12 Petitioners

contend that demand for certain welded line pipe is unlike that of OCTG, which is heavily

dependent on oil exploration, but is dependent on critical mass volumes being reached in order

to justify the construction of a pipeline.13

 

 

12 Conference transcript, pp. 118‐119 (Quaia)

13 Conference transcript, pp. 24‐25, 53 (Barnes), 54 (Herald).
II‐10

Figure II-2 

Baker-Hughes United States Oil and Gas Rig Count, weekly, January 2011-September 2014

Source: Baker Hughes North America Rotary Rig Count, November 18, 2014.

End uses

Certain welded line pipe is an intermediate good that is integrated in large pipeline

infrastructure projects at various stages of transportation of oil and natural gas (e.g. gathering,

transmission, and distribution).  

Business cycles

Four of six U.S. producers and 8 of 21 responding importers, indicated that the market

was subject to business cycles or conditions of competition. Specifically, firms identified

economic growth that increases the demand for energy, and seasonal effects, such as increased

demand for gas during the winter. Overall economic growth broadly drives oil and gas demand

and, therefore, demand for certain welded line pipe. Figure II‐3 illustrates the quarterly percent

change in U.S. real gross domestic product from 2011 to the third quarter of 2014. Project‐

specific demand for certain welded line pipe increases when oil and gas production in a

geographic region reaches a critical mass that justifies the construction of a pipeline versus

other transportation methods, such as by truck and rail.14  

 

 

14 Conference transcript, p. 25 (Barnes).
II‐11

Figure II-3 

U.S. real gross domestic product, quarter-over-quarter percent change, January 2011-September 

2014 

Source: Bureau of Economic Analysis. 

Apparent consumption

Apparent U.S. consumption of certain welded line pipe fluctuated from 2.5 million short

tons in 2011 to 3.3 million short tons in 2012 to 2.6 million short tons in 2013. Overall, apparent

U.S. consumption in 2013 was 0.5 percent higher than in 2011.

Demand trends

Almost all market participants (11 of 12 U.S. producers and 16 of 21 importers) reported

either increasing or fluctuating U.S. demand for certain welded line pipe since 2011 (table II‐3).  

Table II-3 

Certain welded line pipe: Firms’ responses regarding U.S. demand, by number of responding 

firms 

Item Increase No change Decrease Fluctuate 

Demand in the United States 

U.S. producers 5 0 1 6

Importers 10 4 1 6

Demand outside the United States 

U.S. producers 2 1 0 4

Importers 3 6 1 5

Source: Compiled from data submitted in response to Commission questionnaires.
II‐12

Substitute products

Most U.S. producers and importers reported that there were no substitutes for certain

welded line pipe.15 Substitutes are limited and can include seamless pipe, high density

polyethylene pipe, or plastic PVC pipe, depending on the application. Those that referenced

seamless pipe as a substitute also noted its higher price relative to welded line pipe.16  

Cost share

Certain welded line pipe accounts for a moderate‐to‐large share of the cost of the end‐

use products in which it is used. Several U.S. producers reported cost shares for certain welded

line pipe ranging from 25 percent to 75 percent when integrated into a larger pipeline project.

Others indicated that certain welded line pipe is itself an end‐use product and is, therefore, 100

percent of the cost.    

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported certain welded line pipe

depends upon such factors as relative prices, quality (e.g., grade standards, reliability of supply,

defect rates, etc.), and conditions of sale (e.g., price discounts/rebates, lead times between

order and delivery dates, payment terms, product services, etc.). Based on available data, staff

believes that there is moderate‐to‐high degree of substitutability between domestically

produced certain welded line pipe and certain welded line pipe imported from subject sources.  

Lead times

Certain welded line pipe is primarily produced‐to‐order.  U.S. producers reported that

86.1 percent of their commercial shipments were produced‐to‐order, with lead times ranging

from 10 to 170 days, with most reporting in the 30‐90 day range.17  The remaining 13.9 percent

of their commercial shipments came from inventories, with lead times ranging from 5 to 30

days.18 Importers reported that 99.2 percent of commercial shipments from Korea were

produced‐to‐order, with lead times ranging from 90 to 150 days, and *** percent of

 

15 Conference transcript, pp. 80 (Noland), 144 (Snow), and 145 (Cameron).

16 *** in their U.S. producer questionnaire responses. 17 *** of *** responding U.S. producers reported lead times included in this range for produced‐to‐

order certain welded line pipe.

18 *** U.S. producers, ***, reported lead times from inventory in the *** day range. *** reported

lead times from inventory of *** days.
II‐13

commercial shipments from Turkey were produced‐to‐order, with lead times averaging ***

days.19     

Comparison of U.S.‐produced and imported certain welded line pipe

To determine whether U.S.‐produced certain welded line pipe can generally be used in

the same applications as imports from Korea and Turkey, U.S. producers and importers were

asked whether the products can “always,” “frequently,” “sometimes,” or “never” be used

interchangeably. As shown in table II‐4, most U.S. producers reported that domestically

produced welded line pipe and imported welded line pipe are “always” interchangeable.

Importer responses were mixed; most importers (13 of 19 importers comparing the United

States and Korea and 9 of 13 comparing the United States and Turkey) reported that welded

line pipe is either “always” or “frequently” interchangeable between the U.S.‐produced welded

line pipe and pipe produced in Korea or Turkey. Importers that reported welded line pipe as

“sometimes” interchangeable between the United States and subject countries referenced lead

times, product range, and quality requirements as limiting factors.     

In addition, producers and importers were asked to assess how often differences other

than price were significant in sales of certain welded line pipe from the United States, subject,

or nonsubject countries. As seen in table II‐5, most U.S. producers reported that there are no

significant differences other than price between certain welded line pipe produced in the

United States and in other countries. Importer responses were mixed; most importers (11 of 19

importers comparing the United States and Korea and 8 of 14 comparing the United States and

Turkey) reported that there are “sometimes” or “never” significant differences other than price

between certain welded line pipe produced in the United States and in Korea or Turkey.

Importers that reported there are “frequently” significant differences other than price between

the United States and subject countries referenced lead times, product range, and quality

requirements.

 

19 The remaining 0.9 percent of commercial shipments from Korea came from inventories. One

importer, ***, reported that the lead time from U.S. inventory is *** days.
II‐14

Table II-4 

Certain welded line pipe: Interchangeability between certain welded line pipe produced in the 

United States and in other countries, by country pair 

Country pair Number of U.S. producers 

reporting 

Number of U.S. importers 

reporting 

A F S N A F S N 

U.S. vs. subject countries: 

 U.S. vs. Korea 9 2 0 0 6 7 5 1

 U.S. vs. Turkey 9 2 0 0 6 3 4 0

Subject countries comparisons: 

Korea vs. Turkey 8 0 0 0 6 4 2 0

Nonsubject countries 

comparisons: 

 U.S. vs. Japan 10 1 0 0 6 6 1 0

 U.S. vs. Mexico 9 2 0 0 6 4 3 0

 U.S. vs. Other 7 2 0 0 5 4 4 1

 Korea vs. Japan 8 0 0 0 5 4 1 0

 Korea vs. Mexico 8 0 0 0 7 4 0 0

 Korea vs. Other 6 0 0 0 5 4 2 0

 Turkey vs. Japan 8 0 0 0 5 1 3 0

 Turkey vs. Mexico 8 0 0 0 7 3 0 0

 Turkey vs. Other 6 0 0 0 6 3 0 0

 Japan vs. Mexico 8 0 0 0 4 2 2 0

 Japan vs. Other 6 0 0 0 5 2 3 0

 Mexico vs. Other 6 0 0 0 6 4 0 0

Note.—A=Always, F=Frequently, S=Sometimes, N=Never.

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐15

Table II-5 

Certain welded line pipe: Significance of differences other than price between certain welded line 

pipe produced in the United States and in other countries, by country pair 

Country pair Number of U.S. producers 

reporting 

Number of U.S. importers 

reporting 

A F S N A F S N 

U.S. vs. subject countries: 

 U.S. vs. Korea 0 0 3 8 3 5 7 4

 U.S. vs. Turkey 0 0 3 8 2 4 5 3

Subject countries comparisons: 

 Korea vs. Turkey 0 0 0 8 0 1 6 4

Nonsubject countries 

comparisons: 

 U.S. vs. Japan 0 0 3 8 1 2 8 2

 U.S. vs. Mexico 0 0 3 8 1 4 5 4

 U.S. vs. Other 0 0 3 5 1 4 6 3

 Korea vs. Japan 0 0 0 8 1 0 6 2

 Korea vs. Mexico 0 0 0 8 0 1 5 4

 Korea vs. Other 0 0 1 5 0 0 5 4

 Turkey vs. Japan 0 0 0 8 1 1 6 2

 Turkey vs. Mexico 0 0 0 8 0 1 6 3

 Turkey vs. Other 0 0 1 5 0 0 5 4

 Japan vs. Mexico 0 0 0 8 1 1 6 3

 Japan vs. Other 0 0 1 5 0 2 6 2

 Mexico vs. Other 0 0 1 5 0 1 4 5

Note.--A = Always, F = Frequently, S = Sometimes, N = Never. 

Source: Compiled from data submitted in response to Commission questionnaires. 

III‐1

PART III: U.S. PRODUCERS’ PRODUCTION, SHIPMENTS, AND

EMPLOYMENT

The Commission analyzes a number of factors in making injury determinations (see 19

U.S.C. §§ 1677(7)(B) and 1677(7)(C)). Information on the alleged subsidies and dumping

margins was presented in Part I of this report and information on the volume and pricing of

imports of the subject merchandise is presented in Part IV and Part V. Information on the other

factors specified is presented in this section and/or Part VI and (except as noted) is based on

the questionnaire responses of 12 firms that accounted for the vast majority of U.S. production

of certain welded line pipe during 2013.

U.S. PRODUCERS

The Commission issued a U.S. producer questionnaire to the 18 firms identified in the

petition. Sixteen firms provided responses. One firm reported that it does not produce certain

welded line pipe,1 three firms provided limited data,2 and the remaining twelve firms provided

useable data on their certain welded line pipe productive operations. Staff believes that these

responses represent the vast majority of U.S. production of certain welded line pipe.3

  

Table III‐1 lists U.S. producers of certain welded line pipe, their production locations,

positions on the petition, total production, and shares of total production.

                                                      

1 ***.   2 ***. Their data are included in table III‐3. *** reported production of certain welded line pipe, ***.

***.

3 There are several other producers of welded line pipe that did not provide questionnaire responses

to these investigations but did for the five‐year review on certain welded large diameter line pipe from

Japan, which was completed in September 2013. These firms include ***. *** reported that it produced

*** short tons of ***. Various U.S. producers’ questionnaire responses from Investigation No. 731‐TA‐

919 (Second Review): Welded Large Diameter Line Pipe from Japan.
III‐2

Table III-1 

Certain welded line pipe: U.S. producers of certain welded line pipe, their positions on the petition, 

production locations, production, and shares of reported production, 2013 

Firm Position on petition Production location(s) 

Share of 

production 

(percent) 

ACIPCO Petitioner Birmingham, AL ***

Berg1 *** Panama City, FL ***

Boomerang2 *** Liberty, TX ***

CSI3 *** Fontana, CA ***

Energex4 Petitioner Wheatland, PA; Warren, OH ***

Maverick5 Petitioner Hickman, AR; Counce, TN ***

Northwest Pipe Petitioner Atchison, KS; Bossier, LA ***

Paragon6 *** Sapulpa, OK; Muskogee, OK ***

Stupp7 Petitioner Baton Rouge, LA ***

Tex-Tube8 Petitioner Houston, TX ***

TMK IPSCO9 Petitioner Blytheville, AR; Camanche, IA; Wilder, KY ***

US Steel10 *** McKeesport, PA; Lone Star, TX ***

Welspun11 Petitioner Little Rock, AR ***

Total ***

Source: Compiled from data submitted in response to Commission questionnaires. 

1

 Berg is ***. 

2

 Boomerang is ***. 

3

 CSI is ***. 

4

 EnergeX is ***. 

5

 Maverick is *** and is related to ***. 

6

 Paragon is ***. 

7

 Stupp is ***. 

8

 Tex-Tube is ***. ***. Tex-Tube ***. 

9

 TMK-IPSCO is ***. 

10 U.S. Steel ***. 

11 Welspun is ***. 

As indicated in table III‐1, no U.S. producer is related to a foreign producer of the

subject merchandise. ***. No U.S. producer directly imports subject merchandise.  

Since 2011‐14, a prevailing trend in the welded line pipe industry was the expansion of

production capacity.  Companies that announced plans to add capacity for line pipe production

in the United States include: ACIPCO, CSI, EnergeX, Northwest Pipe, Prolamsa, and Welspun. In

addition, certain firms expanded their ability to produce larger outside diameters of line pipe at

U.S. locations.  

A major operational change in the industry during this period was the acquisition of

Lake Steel by JMC Steel in 2012, which led to the subsequent formation of EnergeX. Later, in

2014, U.S. Steel closed two line pipe facilities in Bellville, Texas and McKeesport, Pennsylvania.  
III‐3

The McKeesport facility produced line pipe up to 20 inches in outside diameter; while the

Bellville facility produced high‐strength line pipe and OCTG.4 Table III‐2 summarizes industry

events.

Table III-2 

Certain welded line pipe: Important industry events since 2011 

Date Company Event 

2011 

January 

Lakeside Steel Capacity expansion: Lakeside Steel confirmed investment in its 

Thomasville, AL mill, which added 192,000 short tons of annual capacity 

to produce API OCTG and line pipe up to 10.75 inches outside 

diameter. 

2011 

April 

Northwest Pipe Capacity expansion: Northwest Pipe added an annual capacity of 

100,000 short tons and announced upgrades to its Atchison, KS facility 

to produce ERW line pipe up to 16 inches OD. 

2011 

May 

U.S. Steel Operational changes: U.S. Steel took operational control over the 

Mckeesport, PA pipe mill formerly operated by Camp Hill Corporation. 

2012 

May 

JMC Steel Operational changes: JMC Steel acquired Lakeside Steel in a $58 

million purchase. Lakeside Steel facilities were combined with JMC 

Steel tubular assets and renamed EnergeX. 

2012 

November 

Welspun Capacity expansion: Welspun announced production at its Little Rock, 

AR facility that has an annual capacity between 175,000-225,000 short 

tons per year. The facility will produce ERW line pipe between 6 -20 

inches OD in grades up to X80. 

2013 

May 

Prolamsa Capacity expansion: Prolamsa stated that it will build a pipe and tube 

facility at Bryan, TX with an annual capacity of 300,000 short tons to 

produce ERW pipe and tube products up to 16 inches OD at API and 

ASTM specifications. 

2013 

October 

American Steel 

Pipe (ACIPCO) 

Capacity expansion: American Steel Pipe announced an expansion of 

its North and South mills by an annual capacity of 350,000 short tons. 

The South mill produces line pipe up to 20 inches OD while the North 

mill produces up to 24 inches OD. 

2014 

March 

Northwest Sale of facility: Northwest sold its assets (***) in Bossier City, LA to SB 

International. 

2014 

April 

EnergeX Capacity expansion: ***. 

2014 

JuneAugust 

U.S. Steel Closure: U.S. Steel closed its Bellville, TX (100,000 short tons annual 

capacity) and Mckeesport, PA (315,000 short tons annual capacity) 

facilities that produced line pipe and OCTG products. 

2014 

September 

California Steel 

Industries 

Capacity expansion: California Steel Industries produced its first pipe 

at its pipe mill near Fontana, CA. The mill will produce line pipe up to 24 

inches OD at an annual capacity of 400,000 short tons. 

Source: American Metal Market, Metal Market Bulletin and Preston Pipe & Tube Report news articles. 

                                                      

4 Preston Pipe and Tube Report, “Domestic Mill Activity”, June 2014, p. 18. The Bellville, Texas facility

***. Staff telephone interview with ***.
III‐4

U.S. PRODUCTION, CAPACITY, AND CAPACITY UTILIZATION

Table III‐3 presents U.S. producers’ overall welded pipe production, capacity, and

capacity utilization, by type of production process. As discussed in Part I, there are three

different production processes for producing welded line pipe. Four producers provided

capacity and production data for their HSAW mills.5

  *** the HSAW process to produce certain

welded line pipe. Much of what is produced using the HSAW process is for welded line pipe

greater than 24 inches in outside diameter.6 One firm, Berg, reported having LSAW capacity.

Berg produced *** of certain welded line pipe using the LSAW production process. Most of

what is produced using the LSAW production process is welded line pipe greater than 24 inches

in outside diameter. The ERW production process accounts for virtually all production of certain

welded line pipe. ERW mills do, however, produce more of other products (including OCTG)

than they do of certain welded line pipe.7

Table III-3 

Certain welded line pipe: Overall U.S. producers’ welded pipe capacity, production, and capacity 

utilization, by production process, 2011-13, January-June 2013, and January-June 2014 

Item 

Calendar year January to June

2011 2012 2013 2013 2014

 Quantity (short tons)

HSAW mills: 

 Overall capacity *** *** *** *** ***

Production: 

 Welded line pipe <= 24" *** *** *** *** ***

Welded line pipe > 24" *** *** *** *** ***

Other HSAW products *** *** *** *** ***

Total production *** *** *** *** ***

 Table continued on next page. 

                                                      

5 These firms are United Spiral, Stupp, Welspun, and Evraz.

6 The *** capacity utilization rate for HSAW mills is largely affected by data provided by *** which

reported annual HSAW capacity of *** short tons for each year during 2011‐13 but reported production

of ***. ***. Its production was *** short tons in January‐June 2013 and *** short tons in January‐June

2014. 7 Other products include OCTG as well as standard and structural pipe and tube.
III‐5

Table III-3--Continued

Certain welded line pipe: Overall U.S. producers’ welded pipe capacity, production, and capacity 

utilization, by production process, 2011-13, January-June 2013, and January-June 2014 

Item 

Calendar year January to June

2011 2012 2013 2013 2014

 Quantity (short tons)

LSAW mills: 

 Overall capacity *** *** *** *** ***

Production: 

 Welded line pipe <= 24" *** *** *** *** ***

Welded line pipe > 24" *** *** *** *** ***

Other LSAW products *** *** *** *** ***

Total production *** *** *** *** ***

ERW mills: 

 Overall capacity 5,541,994 5,670,025 5,997,172 3,028,560 3,021,857

Production: 

 Welded line pipe <= 24" 1,446,966 1,616,295 1,306,275 699,229 686,143

Welded line pipe > 24" 0 0 0 0 0

Oil country tubular goods 1,674,556 1,745,416 2,056,533 1,043,157 993,385

Other ERW products 543,907 506,085 551,190 266,493 252,870

Total production 3,665,429 3,867,796 3,913,998 2,008,879 1,932,398

Total overall capacity 6,687,994 6,821,025 7,195,172 3,609,846 3,644,857

Overall production: 

 Welded line pipe <= 24" 1,450,900 1,623,203 1,307,286 699,735 686,723

Welded line pipe > 24" 349,400 272,365 635,573 354,690 190,638

Other products 2,231,760 2,317,422 2,615,533 1,316,110 1,249,805

Total overall production 4,032,060 4,212,990 4,558,392 2,370,535 2,127,166

 Capacity utilization (percent) 

HSAW mills *** *** *** *** ***

LSAW mills *** *** *** *** ***

ERW mills *** *** *** *** ***

All mills combined 60.3 61.8 63.4 65.7 58.4

 Ratio to overall production (percent) 

Overall production: 

 Welded line pipe <= 24" 36.0 38.5 28.7 29.5 32.3

Welded line pipe > 24" 8.7 6.5 13.9 15.0 9.0

Other products 55.4 55.0 57.4 55.5 58.8

Total production 100.0 100.0 100.0 100.0 100.0

 Source: Compiled from data submitted in response to Commission questionnaires. 

Table III‐4 presents data regarding U.S. producers’ production, capacity, and capacity

utilization. U.S. capacity of certain welded line pipe increased by 7.7 percent (approximately

167,000 short tons) from 2011 to 2013. Capacity was 1.4 percent (approximately 17,000 short

tons less in January‐June 2014 than in January‐June 2013.  

The increase in capacity from 2012 to 2013 is due to the combination of Welspun’s new

ERW mill coming online, along with *** investments in new capacity expanding equipment. ***
III‐6

also reporting increasing capacity, but its increase was due to changes in product mix which

affected allocated capacity.8 These combined increases in reported capacity offset the ***

short tons of declining capacity reported by *** and *** short tons of declining capacity

reported by ***. The declines reported by *** reflect the reduction of operations at its ***

facility as less capacity was allocated to welded line pipe as its output of that product declined.9

*** reported decline in capacity reflects ***.10

Table III-4 

Certain welded line pipe: U.S. producers’ production, capacity, and capacity utilization of certain 

welded line pipe, 2011-13, January-June 2013, and January-June 2014 

Item 

Calendar year January to June 

2011 2012 2013 2013 2014 

 Quantity (short tons) 

Capacity 2,188,400 2,291,751 2,342,745 1,206,866 1,189,582

Production 1,446,966 1,616,295 1,306,275 699,265 686,143

 Ratio (percent) 

Capacity utilization 66.1 70.5 55.8 57.9 57.7

 Source: Compiled from data submitted in response to Commission questionnaires. 

Production fluctuated during 2011‐13. Production increased by 11.7 percent from 2011

to 2012, but decreased by 19.2 percent from 2012 to 2013, for an overall decrease of 9.7

percent from 2011 to 2013. Production was 1.9 percent lower in January‐June 2014 than in

January‐June 2013.

Capacity utilization rates also fluctuated during 2011‐13. The increase in production

from 2011 to 2012 outpaced the increase in capacity, resulting in a 4.4 percentage point

increase in capacity utilization. Capacity utilization, however, declined by 14.8 percentage

points from 2012 to 2013. The decrease in production from 2012 to 2013 largely accounts for

the lower utilization rate. Capacity utilization in January‐June 2014 was virtually the same as it

was in January‐June 2013.  

U.S. PRODUCERS’ U.S. SHIPMENTS AND EXPORTS

Table III‐5 presents U.S. producers’ U.S. shipments, export shipments, and total

shipments.11 The quantity of U.S. producers’ U.S. shipments increased by 12.9 percent from

2011 to 2012, but decreased by 21.7 percent from 2012 to 2013, resulting in an overall

decrease of 11.6 percent for 2011‐13. U.S. producers’ U.S. shipments were 6.9 percent lower in

January‐June 2014 compared to January‐June 2013. U.S. producers’ export shipments more

than doubled during 2011‐13, and were higher in January‐June 2014 than in January‐June 2013,

                                                      

8 E‐mail from ***, November 17, 2014.

9 E‐mail from ***, November 17, 2014.

10 E‐mail from ***, November 17, 2014. 11 No U.S. producer reported any internal consumption or transfers to related firms.
III‐7

but did not represent more than 5.8 percent of total shipments during any full or partial year

period. The average unit values of U.S. producers’ U.S. shipments increased by 1.3 percent from

2011 to 2012, but decreased by 14.6 percent from 2012 to 2013, resulting in an overall

decrease of 13.5 percent from 2011 to 2013. The average unit values of U.S. producers’ U.S.

shipments were 9.4 percent lower in January‐June 2014 compared to January‐June 2013.

Table III-5 

Certain welded line pipe: U.S. producers’ U.S. shipments, exports shipments, and total shipments, 

2011-13, January-June 2013, and January-June 2014 

Item 

Calendar year January to June 

2011 2012 2013 2013 2014 

 Quantity (short tons) 

U.S. shipments 1,385,741 1,563,874 1,224,466 639,964 595,675

Export shipments 32,797 38,089 69,232 17,795 36,349

Total shipments 1,418,538 1,601,963 1,293,698 657,759 632,024

 Value (1,000 dollars) 

U.S. shipments 1,813,926 2,073,429 1,386,324 754,222 636,236

Export shipments 40,696 267,709 68,824 18,370 36,405

Total shipments 1,854,622 2,341,138 1,455,148 772,592 672,641

 Unit value (dollars per short ton) 

U.S. shipments 1,309 1,326 1,132 1,179 1,068

Export shipments 1,241 7,029 994 1,032 1,002

Total shipments 1,307 1,461 1,125 1,175 1,064

 Share of quantity (percent) 

U.S. shipments 97.7 97.6 94.6 97.3 94.2

Export shipments 2.3 2.4 5.4 2.7 5.8

Total shipments 100.0 100.0 100.0 100.0 100.0

 Share of value (percent) 

U.S. shipments 97.8 88.6 95.3 97.6 94.6

Export shipments 2.2 11.4 4.7 2.4 5.4

Total shipments 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires. 
III‐8

U.S. PRODUCERS’ INVENTORIES

Table III‐6 presents U.S. producers’ end‐of‐period inventories and the ratio of these

inventories to U.S. producers’ production, U.S. shipments, and total shipments.

Table III-6 

Certain welded line pipe: U.S. producers’ inventories, 2011-13, January-June 2013, and JanuaryJune 2014 

Item 

Calendar year January to June 

2011 2012 2013 2013 2014 

 Quantity (short tons) 

U.S. producers' end-of-period 

inventories 92,457 102,614 108,518 143,575 161,243

 Ratio (percent) 

Ratio of inventories to.-- 

 U.S. production 6.4 6.3 8.3 10.3 11.7

U.S. shipments 6.7 6.6 8.9 11.2 13.5

Total shipments 6.5 6.4 8.4 10.9 12.8

Source: Compiled from data submitted in response to Commission questionnaires. 

U.S. PRODUCERS’ IMPORTS AND PURCHASES

No U.S. producer imported subject merchandise or purchased subject imports from an

importer.

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

Table III‐7 shows U.S. producers’ employment‐related data during the period examined.

The number of production and related workers increased by 19.4 percent from 2011 to 2012,

but decreased by 14.0 percent from 2012 to 2013, resulting in an overall increase of 2.7 percent

during 2011‐13. The number of production and related workers was 2.7 percent higher in

January‐June 2013 compared to January to June 2014. Production and related workers’ hours

worked and wages paid exhibited the same changes as number of production and related

workers. Productivity, however, decreased steadily during 2011‐13, and was lower in January‐

June 2014 compared to January‐June 2013. Likewise, unit labor costs increased steadily during

2011‐13, and was $4.49 per short ton higher in January‐June 2014 compared to January‐June

2013.
III‐9

Table III-7 

Certain welded line pipe: Average number of production and related workers, hours worked, 

wages paid to such employees, hourly wages, productivity, and unit labor costs, 2011-13, 

January-June 2013, and January-June 2014 

Item 

Calendar year January to June 

2011 2012 2013 2013 2014 

Production-related workers (PRWs) 

(number) 1,815 2,167 1,864 1,960 2,012

Total hours worked (1,000 hours) 3,852 4,495 3,745 1,927 2,006

Hours worked per PRW (hours) 2,122 2,074 2,009 983 997

Wages paid ($1,000 dollars) 93,068 115,408 98,504 49,622 51,769

Hourly wages (dollars per hour) 24.16 25.67 26.30 25.75 25.81

Productivity (short tons per 1,000 

hours) 371.8 359.6 348.8 362.9 342.0

Unit labor costs (dollars per short 

tons) 64.98 71.41 75.41 70.96 75.45

 Source: Compiled from data submitted in response to Commission questionnaires. 

IV‐1

PART IV: U.S. IMPORTS, APPARENT U.S. CONSUMPTION, AND MARKET

SHARES

U.S. IMPORTERS

The Commission issued importer questionnaires to 30 firms believed to be importers of

certain welded line pipe, as well as to all U.S. producers of certain welded line pipe.1 Usable

questionnaire responses were received from 23 companies, representing 96.2 percent of

imports from Korea, 88.5 percent of imports from Turkey, and 50.6 percent of imports from all

other sources in 2013.2 Table IV‐1 lists all responding U.S. importers of certain welded line pipe

from Korea, Turkey, and other sources, their locations, and their shares of U.S. imports, in 2013.   

Table IV-1 

Certain welded line pipe: U.S. importers by source, and share of imports by source, 2013 

Firm Headquarters 

Share of imports by source (percent) 

Korea Turkey 

All other 

sources 

Borusan Houston, TX *** *** ***

C&F International Houston, TX *** *** ***

CMC Irving, TX *** *** ***

CPW America Houston, TX *** *** ***

Daewoo Teaneck, NJ *** *** ***

Dongbu Torrance , CA *** *** ***

Evraz Chicago, IL *** *** ***

Husteel Houston, TX *** *** ***

Hyundai Corp. Torrance, CA *** *** ***

Hyundai HYSCO Houston, TX *** *** ***

Kurt Orban Burlingame, CA *** *** ***

MC Tubular Houston, TX *** *** ***

SeAH Santa Fe Springs, CA *** *** ***

Sumitomo Houston, TX *** *** ***

Sunbelt Group L.P. Houston, TX *** *** ***

Table continued on next page.

 

1 The Commission issued questionnaires to those firms identified in the petition, along with firms

that, based on a review of data ***, may have imported certain welded line pipe.   2 U.S. imports are based on official import statistics for the following seven statistical reporting

numbers from the HTSUS: 7305.11.1030, 7305.12.1030, 7305.19.1030, 7306.19.1010, 7306.19.1050,

7306.19.5110, and 7306.19.5150. (See Part I for a discussion of the use of these statistical reporting

numbers).
IV‐2

Table IV-1--Continued 

Certain welded line pipe: U.S. importers by source, and share of imports by source, 2013 

Firm Headquarters 

Share of imports by source (percent) 

Korea Turkey 

All other 

sources 

TATA International Schaumburg, IL *** *** ***

TATA Steel International Schaumburg, IL *** *** ***

Ternium Houston, TX *** *** ***

TMK IPSCO Houston, TX *** *** ***

Toyota Tsusho Georgetown, KY *** *** ***

Marubeni-Itochu Houston, TX *** *** ***

Salzgitter Mannesmann 

International (USA), Inc. Houston, TX *** *** ***

Tosyali Dis Ticaret A.S. Hatay, Turkey *** *** ***

Total *** *** ***

 Source: Compiled from data submitted in response to Commission questionnaires. 

U.S. IMPORTS  

Table IV‐2 presents data for U.S. imports of certain welded line pipe from Korea, Turkey,

and major nonsubject sources.3 Table IV‐2 also presents data for the ratio of imports to U.S.

production. U.S. imports from Korea increased by 36.0 percent from 2011 to 2012, but

decreased by 3.5 percent from 2012 to 2013. U.S. imports from Korea were 16.9 percent lower

in January‐June 2014 than in January‐June 2013. U.S. imports from Turkey increased by 192.6

percent from 2011 to 2012, but decreased by 0.7 percent from 2012 to 2013. U.S. imports from

Turkey were 18.8 percent lower in January‐June 2014 than in January‐June 2013. Imports from

nonsubject sources exhibited the same trend as subject imports, increasing from 2011 to 2012,

but decreasing from 2012 to 2013, and lower in January‐June 2014 compared to January‐June

2014. The increase in imports from nonsubject sources (led by Germany and the United

Kingdom) from 2011 to 2012 (338,538 short tons) was greater than the increase in imports

from subject sources (215,493 short tons). The decrease in imports from nonsubject sources

from 2012 to 2013 (388,690 short tons) was also greater than the decrease in imports from

subject sources (26,583 short tons). The average unit value of imports from nonsubject sources

was greater than the average unit value of imports from subject sources throughout 2011‐June

2014, by $110 per short ton to $286 per short ton.

 

3 Additional summary data, including import statistics, are provided in appendix C. Table C‐2 provides

data for welded line pipe not more than 16 inches in outside diameter and table C‐3 provides data for

welded line pipe greater than 16 inches in outside diameter and less than or equal to 24 inches.
IV‐3

Table IV-2 

Certain welded line pipe: U.S. imports by source, 2011-13, January-June 2013, and January-June 

2014 

Item 

Calendar year January to June 

2011 2012 2013 2013 2014 

 Quantity (short tons) 

U.S. imports from.-- 

 Korea 550,707 749,029 722,892 419,982 348,849

Turkey 22,717 66,472 66,025 36,726 29,828

Subject 573,425 815,501 788,917 456,707 378,677

Canada 18,138 38,732 46,791 12,496 18,558

Germany 18,001 138,439 32,448 21,548 42,144

Greece 48,840 116,718 51,098 28,738 5,064

Japan 144,123 209,002 92,515 44,490 20,041

Mexico 140,762 115,958 120,822 73,808 62,179

United Kingdom 23,801 145,100 57,307 55,342 5,245

All other sources 168,940 137,193 111,472 56,311 62,132

Nonsubject total 562,605 901,143 512,453 292,733 215,364

Total 1,136,029 1,716,644 1,301,370 749,440 594,041

 Value (1,000 dollars) 

U.S. imports from.-- 

 Korea 515,789 711,513 602,585 357,292 266,643

Turkey 19,856 57,744 51,901 29,246 31,109

Subject 535,644 769,257 654,486 386,537 297,752

Canada 26,825 52,048 46,230 12,927 19,397

Germany 26,609 170,555 38,666 27,111 37,086

Greece 54,448 143,774 57,530 31,708 5,595

Japan 167,954 258,730 106,504 50,547 22,050

Mexico 165,857 130,139 118,272 73,297 57,578

United Kingdom 23,729 228,941 89,985 88,098 3,973

All other sources 153,178 122,980 94,167 46,938 47,377

Nonsubject total 618,600 1,107,167 551,354 330,626 193,055

Total 1,154,245 1,876,424 1,205,840 717,164 490,807

Table continued on next page. 
IV‐4

Table IV-2--Continued

Certain welded line pipe: U.S. imports by source, 2011-13, January-June 2013, and January-June 

2014 

Item 

Calendar year January to June 

2011 2012 2013 2013 2014 

 Unit value (dollars per short ton) 

U.S. imports from.-- 

 Korea 937 950 834 851 764

Turkey 874 869 786 796 1,043

Subject 934 943 830 846 786

Canada 1,479 1,344 988 1,034 1,045

Germany 1,478 1,232 1,192 1,258 880

Greece 1,115 1,232 1,126 1,103 1,105

Japan 1,165 1,238 1,151 1,136 1,100

Mexico 1,178 1,122 979 993 926

United Kingdom 997 1,578 1,570 1,592 757

All other sources 907 896 845 834 763

Nonsubject total 1,100 1,229 1,076 1,129 896

Total 1,016 1,093 927 957 826

 Share of quantity (percent) 

U.S. imports from.-- 

 Korea 48.5 43.6 55.5 56.0 58.7

Turkey 2.0 3.9 5.1 4.9 5.0

Subject 50.5 47.5 60.6 60.9 63.7

Canada 1.6 2.3 3.6 1.7 3.1

Germany 1.6 8.1 2.5 2.9 7.1

Greece 4.3 6.8 3.9 3.8 0.9

Japan 12.7 12.2 7.1 5.9 3.4

Mexico 12.4 6.8 9.3 9.8 10.5

United Kingdom 2.1 8.5 4.4 7.4 0.9

All other sources 14.9 8.0 8.6 7.5 10.5

Nonsubject total 49.5 52.5 39.4 39.1 36.3

Total 100.0 100.0 100.0 100.0 100.0

Table continued on next page. 
IV‐5

Table IV-2--Continued

Certain welded line pipe: U.S. imports by source, 2011-13, January-June 2013, and January-June 

2014 

Item 

Calendar year January to June 

2011 2012 2013 2013 2014 

 Share of value (percent) 

U.S. imports from.-- 

 Korea 44.7 37.9 50.0 49.8 54.3

Turkey 1.7 3.1 4.3 4.1 6.3

Subject 46.4 41.0 54.3 53.9 60.7

Canada 2.3 2.8 3.8 1.8 4.0

Germany 2.3 9.1 3.2 3.8 7.6

Greece 4.7 7.7 4.8 4.4 1.1

Japan 14.6 13.8 8.8 7.0 4.5

Mexico 14.4 6.9 9.8 10.2 11.7

United Kingdom 2.1 12.2 7.5 12.3 0.8

All other sources 13.3 6.6 7.8 6.5 9.7

Nonsubject total 53.6 59.0 45.7 46.1 39.3

Total 100.0 100.0 100.0 100.0 100.0

 Ratio to U.S. production (percent) 

U.S. imports from.-- 

 Korea 38.1 46.3 55.3 60.1 50.8

Turkey 1.6 4.1 5.1 5.3 4.3

Subject 39.6 50.5 60.4 65.3 55.2

Canada 1.3 2.4 3.6 1.8 2.7

Germany 1.2 8.6 2.5 3.1 6.1

Greece 3.4 7.2 3.9 4.1 0.7

Japan 10.0 12.9 7.1 6.4 2.9

Mexico 9.7 7.2 9.2 10.6 9.1

United Kingdom 1.6 9.0 4.4 7.9 0.8

All other sources 11.7 8.5 8.5 8.1 9.1

Nonsubject total 38.9 55.8 39.2 41.9 31.4

Total 78.5 106.2 99.6 107.2 86.6

Note.—Line pipe not more than 16 inches in outside diameter from China is subject to antidumping and 

countervailing duty orders (Circular Welded Carbon Quality Steel Line Pipe From the People’s Republic 

of China: Continuation of Antidumping and Countervailing Duty Orders, 79 FR 28894, May 20, 2014) and 

line pipe line pipe greater than 16 inches in outside diameter and less than or equal to 24 inches from 

Japan is subject to an antidumping duty order (Welded Large Diameter Line Pipe From Japan: 

Continuation of Antidumping Duty Order, 78 FR 64477, October 29, 2013). 

Source: Compiled from official Commerce statistics. 
IV‐6

NEGLIGIBILITY

The statute requires that an investigation be terminated without an injury

determination if imports of the subject merchandise are found to be negligible.4 Negligible

imports are generally defined in the Tariff Act of 1930, as amended, as imports from a country

of merchandise corresponding to a domestic like product where such imports account for less

than 3 percent of the volume of all such merchandise imported into the United States in the

most recent 12‐month period for which data are available that precedes the filing of the

petition or the initiation of the investigation. However, if there are imports of such merchandise

from a number of countries subject to investigations initiated on the same day that individually

account for less than 3 percent of the total volume of the subject merchandise, and if the

imports from those countries collectively account for more than 7 percent of the volume of all

such merchandise imported into the United States during the applicable 12‐month period, then

imports from such countries are deemed not to be negligible.5 Table IV‐3 presents data for

imports during October 2013‐September 2014 for Turkey and Korea and their individual shares

of total imports. Imports from Korea accounted for 57.2 percent of total imports of certain

welded line pipe and imports from Turkey accounted for 5.6 percent.6

 

4 Sections 703(a)(1), 705(b)(1), 733(a)(1), and 735(b)(1) of the Act (19 U.S.C. §§ 1671b(a)(1),

1671d(b)(1), 1673b(a)(1), and 1673d(b)(1)). 5 Section 771 (24) of the Act (19 U.S.C § 1677(24)).

6 During October 2013‐September 2014, Korea accounted for 58.6 percent of total imports of welded

line pipe not more than 16 inches in outside diameter. Imports from Turkey accounted for 7.5 percent of

total imports in this size range. During October 2013‐September 2014, Korea accounted for 53.1 percent

of total imports of welded line pipe greater than 16 inches in outside diameter and less than or equal to

24 inches. There were no imports from Turkey in this size range.  
IV‐7

Table IV-3 

Certain welded line pipe: U.S. imports by source and share of imports, October 2013-September 

2014 

Month 

Quantity (short tons) 

Korea Turkey All other sources 

2013 -- 

 October 46,121 2,657 34,254

November 24,826 8,517 28,052

December 39,667 5,959 42,715

2014 -- 

 January 66,932 0 28,297

February 47,220 11,420 35,311

March 32,405 531 44,949

April 62,056 4,741 51,360

May 88,666 10,057 36,041

June 51,570 3,079 19,406

July 65,034 8,476 48,561

August 99,348 613 29,983

September 51,137 10,251 39,269

Total 674,982 66,300 438,198

Share of total imports 

 Oct. 2013-Sept. 2014 57.2 5.6 37.2

Source: Compiled from official Commerce statistics. 

CUMULATION CONSIDERATIONS

In assessing whether imports should be cumulated, the Commission determines

whether U.S. imports from the subject countries compete with each other and with the

domestic like product and has generally considered four factors: (1) fungibility, (2) presence of

sales or offers to sell in the same geographical markets, (3) common or similar channels of

distribution, and (4) simultaneous presence in the market. Additional information concerning

fungibility, geographical markets, and simultaneous presence in the market is presented below.

Fungibility

Table IV‐4 presents data for U.S. producers’ U.S. shipments and importers’ imports of

certain welded line pipe by size ranges. U.S. producers and importers from Korea supplied

certain welded line pipe in both size ranges. Importers from Turkey did not supply any certain

welded line pipe greater than 16 inches in outside diameter and less than or equal to 24 inches.
IV‐8

Table IV-4 

Certain welded line pipe: U.S. producers' U.S. shipments by size and imports by size, 2011-13, 

January-June 2013, and January-June 2014 

Item 

Calendar year January-June 

2011 2012 2013 2013 2014 

 Quantity (short tons) 

U.S. producers' U.S. shipments

 <=16 inches 914,411 1,019,486 837,769 471,729 394,916

> 16 inches <= 24 inches 461,670 551,170 386,697 168,235 200,759

Total 1,376,081 1,570,656 1,224,466 639,964 595,675

U.S. imports from: 

 Korea

 <=16 inches 485,551 597,204 570,876 353,290 274,526

> 16 inches <= 24 inches 65,156 151,825 152,016 66,692 74,323

Total 550,707 749,029 722,892 419,982 348,849

Turkey

 <=16 inches 22,717 66,472 66,025 36,726 29,828

> 16 inches <= 24 inches 0 0 0 0 0

Total 22,717 66,472 66,025 36,726 29,828

All other sources

 <=16 inches 357,022 446,733 296,836 166,121 155,689

> 16 inches <= 24 inches 205,582 454,409 215,616 126,612 59,675

Total 562,605 901,143 512,453 292,733 215,364

Source: Compiled from data submitted in response to Commission questionnaires and from official 

Commerce statistics. 

Presence in the market

Official Commerce data for U.S. imports were used to evaluate subject import presence

in the market. Table IV‐5 summarizes the number of months during January 2011‐September

2014 in which imports were present from Korea and Turkey, by size range. Imports of certain

welded line pipe from Korea were present in all 45 months during January 2011‐September

2014. Imports from Korea of welded line pipe greater than 16 inches in outside diameter and

less than or equal to 24 inches and imports from Korea of welded line pipe not more than 16

inches in outside diameter were each also present in all 45 months during January 2011‐

September 2014. August 2014 represented the largest quantity of imports from Korea entered

during a single month, with 99,348 short tons.

Imports of certain welded line pipe from Turkey were present in 37 months during

January 2011‐September 2014 (eight months during 2011, eleven months during 2012, ten

months during 2013, and eight months during January‐September 2014). Imports from Turkey

were exclusively for welded line pipe not more than 16 inches in outside diameter. October

2012 represented the largest quantity of imports from Turkey entered during a single month,

with 15,799 short tons.
IV‐9

Imports of certain welded line pipe from all other sources were present in all 45 months

during January 2011‐September 2014. Imports from all other sources of welded line pipe

greater than 16 inches in outside diameter and less than or equal to 24 inches and imports from

all other sources of welded line pipe not more than 16 inches in outside diameter were each

also present in all 45 months during January 2011‐September 2014. March 2012 represented

the largest quantity of imports from all other sources entered during a single month, with

130,172 short tons.

Table IV-5 

Certain welded line pipe: Monthly U.S. imports, by source, 2011-13, and January-September 2014 

Month 

Period 

2011 2012 2013 2014 

 Quantity (short tons) 

U.S. imports from Korea -- 

 January 58,061 79,476 78,728 66,932

February 35,468 40,176 49,178 47,220

March 36,890 66,466 80,155 32,405

April 60,079 68,121 63,622 62,056

May 33,124 70,849 58,135 88,666

June 64,161 42,374 90,164 51,570

July 52,063 82,363 55,717 65,034

August 50,780 62,080 66,019 99,348

September 47,595 47,228 70,561 51,137

October 39,721 83,268 46,121 

 

November 37,962 68,913 24,826 

December 34,803 37,716 39,667 

Total 550,707 749,029 722,892 564,369

U.S. imports from Turkey -- 

 January 5,016 0 526 0

February 278 6,782 14,342 11,420

March 0 8,424 1,256 531

April 3,933 90 2,073 4,741

May 1,621 5,976 4,458 10,057

June 0 202 14,070 3,079

July 0 5,817 12,167 8,476

August 5,062 11,313 0 613

September 1,699 518 0 10,251

October 1,089 15,799 2,657 

 

November 0 11,243 8,517 

December 4,020 309 5,959 

Total 22,717 66,472 66,025 49,167

Table continued on next page. 
IV‐10

Table IV-5--Continued 

Certain welded line pipe: Monthly U.S. imports, by source, 2011-13, and January-September 2014 

Month 

Period 

2011 2012 2013 2014 

 Quantity (short tons) 

 U.S. imports from all other 

sources -- 

 January 30,223 47,360 56,688 28,297

February 33,856 47,975 49,036 35,311

March 66,483 130,172 57,086 44,949

April 69,304 105,028 43,084 51,360

May 52,359 65,135 48,811 36,041

June 37,707 99,592 38,028 19,406

July 35,564 118,246 29,187 48,561

August 41,309 70,836 40,663 29,983

September 47,436 46,436 44,849 39,269

October 60,320 62,569 34,254 

 

November 34,207 75,319 28,052 

December 53,836 32,475 42,715 

Total 562,605 901,143 512,453 333,177

Source: Compiled from official Commerce statistics. 

Geographical markets

According to Commerce statistics, 75.6 percent of U.S. imports of certain welded line

pipe from Korea entered the United States through the Houston‐Galveston, Texas, customs

district in 2013. The second largest point of entry for subject imports from Korea, representing

11.2 percent of imports, was the Los Angeles, California, customs district. No other customs

district accounted for more than 3.5 percent of subject imports from Korea. Subject imports

from Turkey were more concentrated, with 99.6 percent entering through the Houston‐

Galveston, Texas, customs district in 2013. Entries of imports from all other sources were

concentrated in three customs districts: Houston‐Galveston, Texas (40.1 percent), New Orleans,

Louisiana (16.8 percent), and Laredo, Texas (23.6 percent).

In 2013, imports of welded line pipe not more than 16 inches in outside diameter from

Korea primarily entered through the Houston‐Galveston, Texas customs district (73.4 percent).

The Los Angeles, California customs district was the second largest point of entry (12.8

percent). As discussed above, there were no imports from Turkey of welded line pipe greater

than 16 inches in diameter. Accordingly, entries by customs district of welded line pipe not

more than 16 inches in outside diameter is the same as entries of all subject merchandise from

Turkey—99.6 percent through the Houston‐Galveston, Texas customs district.  Nearly 75

percent of imports from all other sources entered through the customs districts of New

Orleans, Louisiana (40.5 percent) and Houston‐Galveston, Texas (33.9 percent).
IV‐11

Imports of welded line pipe greater than 16 inches in outside diameter and less than or

equal to 24 inches from Korea primarily entered through the Houston‐Galveston, Texas

customs district, representing 83.9 percent of entries in 2013. There were no imports from

Turkey of welded line pipe in this size range. Imports from all other sources in this size range

entered mainly through the customs districts Houston‐Galveston, Texas (48.6 percent) or

Laredo, Texas (37.5 percent); no other customs district accounted for more than 6 percent of

entries.  

APPARENT U.S. CONSUMPTION  

Table IV‐6 presents data on apparent U.S. consumption and U.S. market shares for

certain welded line pipe.

Table IV-6 

Certain welded line pipe: U.S. shipments of domestic product, U.S. imports, and apparent U.S. 

consumption, 2011-13, January-June 2013, and January-June 2014 

Item 

Calendar year January to June

2011 2012 2013 2013 2014

 Quantity (short tons)

U.S. producers' U.S. shipments 1,385,741 1,563,874 1,224,466 639,964 595,675

U.S. imports from.-- 

 Korea 550,707 749,029 722,892 419,982 348,849

Turkey 22,717 66,472 66,025 36,726 29,828

Subject 573,425 815,501 788,917 456,707 378,677

Canada 18,138 38,732 46,791 12,496 18,558

Germany 18,001 138,439 32,448 21,548 42,144

Greece 48,840 116,718 51,098 28,738 5,064

Japan 144,123 209,002 92,515 44,490 20,041

Mexico 140,762 115,958 120,822 73,808 62,179

United Kingdom 23,801 145,100 57,307 55,342 5,245

All other sources 168,940 137,193 111,472 56,311 62,132

Nonsubject total 562,605 901,143 512,453 292,733 215,364

Total 1,136,029 1,716,644 1,301,370 749,440 594,041

Apparent U.S. consumption 2,521,770 3,280,518 2,525,836 1,389,404 1,189,716

Table continued on next page.
IV‐12

Table IV-6--Continued

Certain welded line pipe: U.S. shipments of domestic product, U.S. imports, and apparent U.S. 

consumption, 2011-13, January-June 2013, and January-June 2014 

Item 

Calendar year January to June

2011 2012 2013 2013 2014

 Quantity (short tons)

 Value (1,000 dollars)

U.S. producers' U.S. shipments 1,813,926 2,073,429 1,386,324 754,222 636,236

U.S. imports from.-- 

 Korea 515,789 711,513 602,585 357,292 266,643

Turkey 19,856 57,744 51,901 29,246 31,109

Subject 535,644 769,257 654,486 386,537 297,752

Canada 26,825 52,048 46,230 12,927 19,397

Germany 26,609 170,555 38,666 27,111 37,086

Greece 54,448 143,774 57,530 31,708 5,595

Japan 167,954 258,730 106,504 50,547 22,050

Mexico 165,857 130,139 118,272 73,297 57,578

United Kingdom 23,729 228,941 89,985 88,098 3,973

All other sources 153,178 122,980 94,167 46,938 47,377

Nonsubject total 618,600 1,107,167 551,354 330,626 193,055

Total 1,154,245 1,876,424 1,205,840 717,164 490,807

Apparent U.S. consumption 2,968,171 3,949,853 2,592,164 1,471,386 1,127,043

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce statistics. 

. 
IV‐13

U.S. MARKET SHARES  

U.S. market share data are presented in table IV‐7.

Table IV-7 

Certain welded line pipe: U.S. consumption and market shares, 2011-13, January-June 2013, and 

January-June 2014 

Item 

Calendar year January to June 

2011 2012 2013 2013 2014 

 Share of quantity (percent) 

U.S. producers' U.S. shipments 55.0 47.7 48.5 46.1 50.1

U.S. imports from.-- 

 Korea 21.8 22.8 28.6 30.2 29.3

Turkey 0.9 2.0 2.6 2.6 2.5

Subject 22.7 24.9 31.2 32.9 31.8

Canada 0.7 1.2 1.9 0.9 1.6

Germany 0.7 4.2 1.3 1.6 3.5

Greece 1.9 3.6 2.0 2.1 0.4

Japan 5.7 6.4 3.7 3.2 1.7

Mexico 5.6 3.5 4.8 5.3 5.2

United Kingdom 0.9 4.4 2.3 4.0 0.4

All other sources 6.7 4.2 4.4 4.1 5.2

Nonsubject total 22.3 27.5 20.3 21.1 18.1

Total 45.0 52.3 51.5 53.9 49.9

 Share of value (percent) 

U.S. producers' U.S. shipments 61.1 52.5 53.5 51.3 56.5

U.S. imports from.-- 

 Korea 17.4 18.0 23.2 24.3 23.7

Turkey 0.7 1.5 2.0 2.0 2.8

Subject 18.0 19.5 25.2 26.3 26.4

Canada 0.9 1.3 1.8 0.9 1.7

Germany 0.9 4.3 1.5 1.8 3.3

Greece 1.8 3.6 2.2 2.2 0.5

Japan 5.7 6.6 4.1 3.4 2.0

Mexico 5.6 3.3 4.6 5.0 5.1

United Kingdom 0.8 5.8 3.5 6.0 0.4

All other sources 5.2 3.1 3.6 3.2 4.2

Nonsubject total 20.8 28.0 21.3 22.5 17.1

Total 38.9 47.5 46.5 48.7 43.5

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce 

statistics. 

PART V: PRICING DATA

FACTORS AFFECTING PRICES

Raw material costs

Certain welded line pipe is primarily made from hot-rolled steel in coils. Raw materials 

were 65.8 percent of U.S. producers’ net sales in 2011 and increased to 71.0 percent in 2013. 

Published U.S. prices for hot-rolled sheet reached $887 per short ton in 2011, then declined 

irregularly through mid-2013, before generally increasing through the remainder of 2013 and 

into 2014. Published U.S. prices for hot-rolled sheet averaged $660 per short ton in 2012, $631 

per short ton in 2013, and $666 per short ton in the first half of 2014. Hot-rolled sheet prices 

averaged $669 per short ton in the third quarter of 2014 (figure V-1).

1

According to Petitioners, certain welded line pipe is made to particular quality 

specifications provided by API-5L and grade specifications (e.g., X-42, X52, X60, X70); as a result, 

hot-rolled steel purchases reflect a premium.

2 *** estimates these specifications increase the 

raw material cost of certain welded line pipe by $*** per short ton based on grade ***

requirements and a base price reported by ***.

3 Maverick reportedly paid $*** to $*** extra 

for API 5L grade hot-rolled steel.4 Petitioners provided comparisons of AMM prices to purchase 

costs of welded line pipe, (including dates between *** and ***, covering various suppliers and 

purchasers, and grades X42 to X70), that ranged in additional costs from $*** per short ton to 

$*** per short ton.5 Petitioners also indicated that the price of line pipe is set by competitive 

pressures and not necessarily reflective of changes in raw material costs.6

1 American Metal Market, www.amm.com, retrieved November 2014. 2 Conference transcript, p. 58 (DuBreuil).

3 U.S. Steel postconference brief, exhibit 1.

4 Petitioner Maverick’s postconference brief, exhibit 1 pp.14. 

5 Petitioner ACIPCO et al. postconference brief, exhibit 9.

6 Conference transcript, p. 75 (Schagrin); Petitioner ACIPCO et al. postconference brief, p. 28. 

V-1

 
Figure V-1 

Average hot-rolled steel sheet prices (Midwest), monthly, January 2011-September 2014

Source: American Metal Market, www.amm.com, retrieved November 2014.

U.S. inland transportation costs

Eleven responding U.S. producers and eight responding importers reported that they 

typically arrange transportation to their customers. U.S. producers reported that their U.S. 

inland transportation costs ranged from 1.0 percent to 10.0 percent while importers reported 

costs of 2.0 percent to 10.0 percent.

PRICING PRACTICES

Pricing methods

U.S. producers and importers reported using primarily transaction-by-transaction 

negotiations, with more limited use of contracts, price lists, and other methods (table V-1).

V-2
Table V-1

Certain welded line pipe: U.S. producers and importers reported price setting methods, by number 

of responding firms1

Method U.S. producers Importers

Transaction-by-transaction 12 21

Contract *** ***

Set price list *** ***

Other *** *** 1 The sum of responses down may not add up to the total number of responding firms as each firm was 

instructed to check all applicable price setting methods employed.

Source: Compiled from data submitted in response to Commission questionnaires.

U.S. producers reported selling most of their certain welded line pipe in the spot market

while importers of Korean line pipe reported selling primarily under short-term contracts and 

importers of Turkish line pipe reported selling *** in the spot market (table V-2).

Table V-2

Certain welded line pipe: U.S. producers’ and importers’ shares of U.S. commercial shipments by 

type of sale, 2013

Type of sale U.S. producers

Importers

Korea Turkey

Long-term contracts 0.0 0.0 ***

One year contracts 0.0 0.0 ***

Short-term contracts 30.4 96.0 ***

Spot sales 69.6 4.0 ***

Total 100.0 100.0 100.0

Note.--Because of rounding, figures may not add to the totals shown. 

Source: Compiled from data submitted in response to Commission questionnaires.

Sales terms and discounts

U.S. producers and importers typically quote prices on an f.o.b. basis. Most U.S. 

producers do not offer discounts, although *** offers quantity and total volume discounts and 

*** producers indicated other discount policies, including *** and ***. Seven of twelve 

responding producers reported sales terms of net 30 days, four reported sales terms of 2/10 

net 30 days, and four reported other sales terms. Most importers reported that they did not 

offer discounts; *** offers a discount based on early payment. The majority of importers (12 of 

13) reported sales terms of net 30 days.

Approved manufacturer’s lists (AMLs) can also affect sales. End users use AMLs as a 

quality control device to evaluate potential suppliers.

7 Most U.S. producers are on these AMLs, 

7 Conference transcript, pp. 100-101 (Snow). 

V-3

 
as well as most Korean producers.8 Turkish respondent, Tosçelik, contends that it is not on end 

user AMLs.9

PRICE DATA

The Commission requested U.S. producers and importers to provide quarterly data for 

the total quantity and f.o.b. value of the following certain welded line pipe products shipped to 

unrelated U.S. customers from January 2011 to June 2014.

Product 1.-- API 5L Grade B/X42 welded pipe, 6-inch nominal size (6.625 inch O.D.), 

plain end, with a wall thickness of 0.280 inch.

Product 2.-- API 5L Grade B/X42 welded pipe, 8-inch nominal size (8.625 inch O.D.), 

plain end, with wall thickness of 0.322 inch.

Product 3.-- API 5L Grade B/X42 welded pipe, 12-inch nominal size (12.75 inch O.D.), 

plain end, with a wall thickness of 0.375 inch.

Product 4.-- API 5L Grade B/X60 welded pipe, 24-inch nominal size (24 inch O.D.), plain 

end, with a wall thickness of 0.375 inch.

Eleven U.S. producers and ten importers provided usable pricing data for sales of the 

requested products, although not all firms reported pricing for all products for all quarters. 

Pricing data reported by these firms accounted for approximately 5.2 percent of U.S. producers’ 

shipments of product, 6.3 percent of U.S. shipments of subject imports from Korea, and ***

percent of U.S. shipments of subject imports from Turkey in 2013. Staff received usable pricing 

data for 14 quarters of products 1, 2, and 3, and received 8 quarters of pricing data for product 

4 from U.S. producers. Staff received useable pricing data for 14 quarters for all four pricing 

products imported from Korea but received only one quarter of pricing data for products 1 and 

3, three quarters for product 2, and no pricing data for product 4 for imports from Turkey.10

8 Conference transcript, pp. 100-101 (Snow). Ms. Snow, testifying for Korean Respondents, also 

stated that many end users do not accept imports on the AMLs in reality.

9 Conference transcript, p. 133 (Simon).

10 Turkish importer, ***, did not report pricing data as requested by staff. *** imports certain welded 

line pipe from Turkish producer ***, who produces ***. According to ***, line pipe produced at *** do 

not require mill test certificates and, therefore, cannot be used in oil and gas pipeline systems. ***

believes this material does not sell head-to-head with domestic industry products, and is not used in the 

usage of oil and gas fields or oil and gas pipelines. Email with ***, Counsel to ***, November 20, 2014.

V-4

 
Price data for products 1-4 are presented in tables V-3 to V-6 and figures V-2 to V-5. 

Nonsubject country prices are presented in Appendix D.

Table V-3

Certain welded line pipe: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 11 and margins of underselling/(overselling), by quarters, January 2011-June 2014

Period

United States Korea Turkey

Price

(per short 

ton)

Quantity

(short 

tons)

Price

(per 

short 

ton)

Quantity

(short 

tons)

Margin

(percent)

Price

(per short 

ton)

Quantity

(short 

tons)

Margin

(percent)

2011:

Jan.-Mar. $1,189.49 7,197 $899.98 5,398 24.3 -- 0 --

Apr.-June 1,335.14 6,493 892.10 3,838 33.2 -- 0 --

July-Sept. 1,298.75 5,863 1,040.33 4,322 19.9 -- 0 --

Oct.-Dec. 1,247.45 3,746 997.56 2,949 20.0 $*** *** ***

2012:

Jan.-Mar. 1,281.06 6,604 963.60 3,786 24.8 -- 0 --

Apr.-June 1,260.32 6,686 944.27 5,440 25.1 -- 0 --

July-Sept. 1,180.11 4,815 979.06 7,767 17.0 -- 0 --

Oct.-Dec. 1,175.81 9,005 916.35 3,407 22.1 -- 0 --

2013:

Jan.-Mar. 1,042.04 4,141 886.16 4,179 15.0 -- 0 --

Apr.-June 972.53 7,718 853.91 4,145 12.2 -- 0 --

July-Sept. 1,001.18 5,319 817.94 4,137 18.3 -- 0 --

Oct.-Dec. 954.84 4,878 772.94 1,914 19.1 -- 0 --

2014:

Jan.-Mar. *** *** 770.81 3,831 *** -- 0 --

Apr.-June *** *** 777.48 7,098 *** -- 0 -- 1 Product 1: API 5L Grade B/X42 welded pipe, 6-inch nominal size (6.625 inch O.D.), plain end, with a 

wall thickness of 0.280 inch.

Source: Compiled from data submitted in response to Commission questionnaires.

V-5
Table V-4

Certain welded line pipe: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 21 and margins of underselling/(overselling), by quarters, January 2011-June 2014

Period

United States Korea Turkey

Price

(per short 

ton)

Quantity

(short 

tons)

Price

(per 

short 

ton)

Quantity

(short 

tons)

Margin

(percent)

Price

(per short 

ton)

Quantity

(short 

tons)

Margin

(percent)

2011:

Jan.-Mar. $1,193.85 4,093 $895.94 6,988 25.0 -- 0 --

Apr.-June 1,344.69 5,538 878.08 3,462 34.7 -- 0 --

July-Sept. 1,310.32 8,016 1,027.98 4,745 21.5 -- 0 --

Oct.-Dec. 1,300.09 8,454 988.46 2,578 24.0 -- 0 --

2012:

Jan.-Mar. 1,316.14 7,713 909.31 4,715 30.9 -- 0 --

Apr.-June 1,301.60 11,321 924.16 5,221 29.0 -- 0 --

July-Sept. 1,247.53 8,217 913.52 5,216 26.8 -- 0 --

Oct.-Dec. 1,125.74 3,939 919.77 3,653 18.3 -- 0 --

2013:

Jan.-Mar. 1,063.99 5,400 853.73 3,933 19.8 $*** *** ***

Apr.-June 1,063.31 5,700 814.08 4,927 23.4 *** *** ***

July-Sept. 1,084.22 3,804 817.99 3,680 24.6 *** *** ***

Oct.-Dec. 1,038.25 2,808 775.86 1,700 25.3 -- 0 --

2014:

Jan.-Mar. 1,027.65 3,371 769.26 4,005 25.1 -- 0 --

Apr.-June 977.82 3,394 776.22 6,953 20.6 -- 0 -- 1 Product 2: API 5L Grade B/X42 welded pipe, 8-inch nominal size (8.625 inch O.D.), plain end, with wall 

thickness of 0.322 inch.

Source: Compiled from data submitted in response to Commission questionnaires.

V-6
Table V-5

Certain welded line pipe: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 31 and margins of underselling/(overselling), by quarters, January 2011-June 2014

Period

United States Korea Turkey

Price

(per short 

ton)

Quantity

(short 

tons)

Price

(per 

short 

ton)

Quantity

(short 

tons)

Margin

(percent)

Price

(per short 

ton)

Quantity

(short 

tons)

Margin

(percent)

2011:

Jan.-Mar. $*** *** $893.35 5,719 *** -- 0 --

Apr.-June 1,342.80 11,422 893.12 5,774 33.5 -- 0 --

July-Sept. 1,316.66 6,660 1,019.37 4,372 22.6 -- 0 --

Oct.-Dec. 1,285.71 6,763 1,013.56 3,401 21.2 -- 0 --

2012:

Jan.-Mar. 1,378.64 10,375 892.63 6,766 35.3 -- 0 --

Apr.-June 1,308.59 11,343 860.61 6,195 34.2 -- 0 --

July-Sept. *** *** 940.70 5,290 *** -- 0 --

Oct.-Dec. 1,058.83 6,016 847.08 4,547 20.0 -- 0 --

2013:

Jan.-Mar. 1,072.91 5,906 877.76 3,748 18.2 -- 0 --

Apr.-June 1,059.30 5,177 836.47 4,280 21.0 $*** *** ***

July-Sept. *** *** 779.72 3,984 *** -- 0 --

Oct.-Dec. *** *** 803.18 1,253 *** -- 0 --

2014:

Jan.-Mar. *** *** 761.96 7,649 *** -- 0 --

Apr.-June 984.25 5,931 782.88 6,942 20.5 -- 0 -- 1 Product 3: API 5L Grade B/X42 welded pipe, 12-inch nominal size (12.75 inch O.D.), plain end, with a 

wall thickness of 0.375 inch.

Source: Compiled from data submitted in response to Commission questionnaires.

V-7
Table V-6

Certain welded line pipe: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 41 and margins of underselling/(overselling), by quarters, January 2011-June 2014

Period

United States Korea Turkey

Price

(per short 

ton)

Quantity

(short 

tons)

Price

(per short 

ton)

Quantity

(short 

tons)

Margin

(percent)

Price

(per 

short 

ton)

Quantity

(short 

tons)

Margin

(percent)

2011:

Jan.-Mar. $*** *** $915.20 682 *** -- 0 --

Apr.-June *** *** 896.29 538 *** -- 0 --

July-Sept. *** *** *** *** *** -- 0 --

Oct.-Dec. *** *** *** *** *** -- 0 --

2012:

Jan.-Mar. -- 0 990.90 1,272 -- -- 0 --

Apr.-June *** *** 981.48 1,192 *** -- 0 --

July-Sept. -- 0 992.10 2,412 -- -- 0 --

Oct.-Dec. *** *** *** *** *** -- 0 --

2013:

Jan.-Mar. -- 0 *** *** -- -- 0 --

Apr.-June -- 0 *** *** -- -- 0 --

July-Sept. -- 0 *** *** -- -- 0 --

Oct.-Dec. -- 0 *** *** -- -- 0 --

2014:

Jan.-Mar. *** *** *** *** *** -- 0 --

Apr.-June *** *** *** *** *** -- 0 -- 1 Product 4: API 5L Grade B/X60 welded pipe, 24-inch nominal size (24 inch O.D.), plain end, with a wall 

thickness of 0.375 inch.

Source: Compiled from data submitted in response to Commission questionnaires.

Figure V-2

Certain welded line pipe: Weighted-average prices and quantities of domestic and imported 

product 1, by quarters, January 2011-June 2014

* * * * * * *

Figure V-3

Certain welded line pipe: Weighted-average prices and quantities of domestic and imported 

product 2, by quarters, January 2011-June 2014

* * * * * * *

Figure V-4

Certain welded line pipe: Weighted-average prices and quantities of domestic and imported 

product 3, by quarters, January 2011-June 2014

* * * * * * *

V-8
Figure V-5

Certain welded line pipe: Weighted-average prices and quantities of domestic and imported 

product 4, by quarters, January 2011-June 2014

* * * * * * *

Price trends

Prices generally decreased from 2011 through the first half of 2014. Table V-6

summarizes the price trends, by country and by product. As shown in the table, domestic price 

decreases for products 1, 2, and 3 ranged from *** to *** percent from the first quarter of 

2011 to the second quarter of 2014 while prices for product 4 increased *** percent. Korean 

import price decreases across all products ranged from *** to *** percent. Due to limited data 

points and coverage, price trend data was unavailable for Turkey.

Table V-6

Certain welded line pipe: Summary of weighted-average f.o.b. prices for products 1-4 from the 

United States, Korea, and Turkey

* * * * * * *

Price comparisons

As shown in table V-7, prices for certain welded line pipe imported from Korea were 

below those for U.S.-produced product in 50 of 50 instances; margins of underselling ranged 

from *** to *** percent. Prices for certain welded line pipe imported from Turkey were below 

those for U.S.-produced product in 5 of 5 instances; margins of underselling ranged from *** to 

*** percent.

V-9
Table V-7

Certain welded line pipe: Instances of underselling/overselling and the range and average of 

margins, by product, January 2011-June 2014

Source

Underselling

Number of 

quarters

Quantity1

(short tons)

Average 

margin 

(percent)

Margin range (percent)

Min Max

Korea 50 *** *** *** ***

Turkey 5 *** *** *** ***

Total 55 208,389 23.6 12.0 35.3

Source

(Overselling)

Number of 

quarters

Quantity1

(short tons)

Average 

margin 

(percent)

Margin range (percent)

Min Max

Korea 0 0 0 0 0

Turkey 0 0 0 0 0

Total 0 0 0 0 0

1 These data include only quarters in which there is a comparison between the U.S. and subject product.

There were no comparisons made for *** quarters for which there were sales of certain welded line pipe 

from Korea. U.S. producers did not report pricing data for product 4 in ***.

Source: Compiled from data submitted in response to Commission questionnaires.

LOST SALES AND LOST REVENUE

The Commission requested U.S. producers of certain welded line pipe to report any 

instances of lost sales or revenue they experienced due to competition from imports of certain 

welded line pipe from Korea or Turkey since January 1, 2011. All 12 responding U.S. producers

reported that they had to either reduce prices or roll back announced price increases. Four 

producers provided 35 lost sales allegations which totaled $*** and involved *** short tons of 

certain welded line pipe and a lost revenue allegation that totaled $*** and involved *** short 

tons of certain welded line pipe.11 Staff contacted *** purchasers and a summary of the 

information obtained follows (tables V-8 and V-9).

12 13 Purchasers agreed to *** of the *** lost 

11 Seven of the 12 producers that indicated lost sales did not report specific lost sales or lost revenue 

allegations. *** reported that they do not have the data available to provide the level of detail for 

specific allegations because they sell to distributors. *** do not have the documentation or data. *** 

did not report lost sales allegations to preserve customer confidentiality. 12 Staff was unable to verify the contact information of *** lost sales allegations provided by *** and 

***. These allegations totaled $*** and involved *** short tons. These allegations are not included in 

table V-8. 

13 Two petitioning companies, *** and ***, provided additional allegations subsequent to the filing 

of the petition. *** submitted *** new lost sales allegations on ***, two weeks after the petition was 

filed. *** submitted *** new lost sale allegation, *** new lost revenue allegation, and *** updated 

V-10

 

(continued...)
sale and lost revenue allegations. *** allegations reportedly involved Turkey, *** of which were 

confirmed by purchasers. The remaining *** allegations reportedly involved Korea, *** of 

which were confirmed by purchasers.

Table V-8 

Certain welded line pipe: U.S. producers’ lost sales allegations

* * * * * * *

Table V-9 

Certain welded line pipe: U.S. producers’ lost revenue allegations

* * * * * * *

*** stated that “the primary reason for the rejection of the domestic offering was due 

to manufacturing process. We were offered two domestic offerings one a DSAW and the other 

an LSAW product. Our Engineering rejected both processes for this project.”

*** stated that “The line pipe sale was awarded to a distributor, *** and they quoted 

line pipe manufactured by ***. We did not go to any mills for quotes. Only distribution.”

*** stated that “we have a purchase activity during that period but bids were received 

from pipe distributors and I do not have any idea what mark-ups the distributors applied to 

quotes that they received from their perspective mills. Distributors could apply markups as high 

as 25%. Our purchase requirement involved pipe coating which could have impacted logistics 

costs on the overall pipe order.”

*** responded “No answer/don’t know” to the survey. However, a representative from 

*** stated that “the quantity says *** tons but only *** tons were from Korea” in a phone 

interview. 

Purchasers responding to the lost sales allegations also were asked whether they shifted 

their purchases of certain welded line pipe from U.S. producers to suppliers from Korea or 

Turkey since 2011 (table V-10). In addition, they were asked whether U.S. producers reduced 

their prices in order to compete with suppliers of certain welded line pipe from Korea or 

Turkey. Four of the ten responding purchasers reported that they had shifted purchases of 

certain welded line pipe from U.S. producers to subject imports since 2011; all four indicated

that price was the reason for the shift. The same four purchasers reported that U.S. producers 

had reduced their prices in order to compete with the prices of subject imports since 2011.

allegations on ***, more than two weeks after the petition was filed. The *** new lost sales allegations 

totaled $*** and accounted for *** short tons. Staff was only able to give identified purchasers in the 

*** new allegations three business days to reply to these allegations, rather than the full week given to 

the allegations identified in the petition. *** were the only purchasers to respond to these secondary 

allegations. The new allegations are included in table V-8; ***’s revised allegations were not 

resubmitted to the purchasers and are not revised and included in the table.

V-11

 

(...continued)
Table V-10

Certain welded line pipe: Purchasers’ responses regarding shifting supply and price reductions

* * * * * * *

*** stated that U.S. producers “often reduce prices by *** percent.” Another ***

representative stated that “U.S. producers reduced their prices often, sometimes by as much as 

***%.”

An *** representative stated that “U.S. producers have been constantly chasing the 

Korean numbers that have ranged *** NT lower than domestics.” Another stated that “The 

pricing difference between Korean and domestic is $***/NT depending on market conditions.

The domestic mills haven't ever been able to match any Korean pricing.

V-12
VI‐1

PART VI: FINANCIAL EXPERIENCE OF U.S. PRODUCERS

INTRODUCTION

Twelve U.S. producers (ACIPCO, Boomerang, CSI, EnergeX, Maverick, Northwest Pipe,

Paragon, Stupp, TMK IPSCO, Tex‐Tube, U.S. Steel, and Welspun) provided financial data on their

operations on certain welded line pipe.  These data are believed to account for nearly all U.S.

production of certain welded line pipe in 2013.  *** to report sales other than commercial

sales.  *** reported transfers to related firms *** that accounted for *** percent of total net

sales between January 2011 and June 2014, and are not shown separately in this section of the

report.  EnergeX and Welspun reported fiscal year ends of September 30 and March 31,

respectively.  All other firms reported a fiscal year end of December 31.

As previously discussed in this report, some firms have made substantial capital

investments related to the production of certain welded line pipe since 2011, including the new

ERW plant and onset of production by Welspun in 2013.  In addition, some firms cut back

production of the subject product, including U.S. Steel which indefinitely idled its McKeesport

facility in August 2014.  

OPERATIONS ON CERTAIN WELDED LINE PIPE

Income‐and‐loss data for U.S. producers of certain welded line pipe are presented in

table VI‐1, while selected financial data, by firm, are presented in table VI‐2.  The reported

profitability of the U.S. industry declined from 2011‐13.  The reported aggregate net sales

quantity declined by 7.5 percent from 2011‐13, while the aggregate net sales value declined by

20.5 percent during this time.  Collectively, the aggregate cost of goods sold (“COGS”) and

selling, general, and administrative (“SG&A”) expenses declined by 8.7 percent during this time.  

As a result of the larger decline in revenue as compared to operating costs and expenses,

aggregate operating income declined from 2011‐13.

Similar to the full year data, net sales and operating income were lower in January‐June

2014 as compared to January‐June 2013.  The reported aggregate net sales quantity and value

were lower by 3.9 and 12.9 percent, respectively.  Collectively, operating costs and expenses

were 8.4 percent lower in interim 2014 as compared to interim 2013.  As a result of the larger

decline in revenue as compared to operating costs and expenses, aggregate operating income

was lower in January‐June 2014 than in January‐June 2013.

On a per short ton basis, raw material costs decreased from 2011‐13, and were also

lower in interim 2014 as compared to interim 2013.  Direct labor, other factory costs, and SG&A

expenses all increased on a per short ton basis from 2011‐13.  In January‐June 2014 as

compared to January‐June 2013, other factory costs and SG&A expenses declined on a per

short ton basis, while direct labor increased.  As a ratio to net sales, operating costs and

expenses were higher in each successive full and partial year, while operating income was

lower.
VI‐2

Table VI-1 

Certain welded line pipe: Results of operations of U.S. producers, 2011-13, January-June 2013, 

and January-June 2014 

Item 

Fiscal year January-June

2011 2012 2013 2013 2014

Quantity (short tons)

Total net sales 1,413,085 1,602,650 1,306,408 657,759 632,025

Value ($1,000)

Total net sales 1,846,887 2,115,958 1,468,441 772,502 672,641

Cost of goods sold 1,508,130 1,746,340 1,363,032 689,683 636,616

Gross profit or (loss) 338,757 369,618 105,409 82,819 36,025 

SG&A expense 80,004 93,021 86,768 45,378 37,059

Operating income or (loss) 258,753 276,597 18,641 37,441 (1,034)

Other income or (expense), net (15,947) (17,480) (12,295) (7,645) (8,431)

Net income or (loss) 242,806 259,117 6,346 29,796 (9,465)

Depreciation 31,258 30,966 33,382 15,077 20,211

Cash flow 274,064 290,083 39,728 44,873 10,746 

Ratio to net sales (percent) 

Cost of goods sold.-- 

Raw materials 65.8 64.9 71.0 68.7 74.6 

Direct labor 4.0 4.5 5.6 5.3 6.4 

Other factory costs 11.8 13.1 16.2 15.3 13.7 

Average COGS 81.7 82.5 92.8 89.3 94.6 

Gross profit or (loss) 18.3 17.5 7.2 10.7 5.4 

SG&A expense 4.3 4.4 5.9 5.9 5.5 

Operating income or (loss) 14.0 13.1 1.3 4.8 (0.2)

Unit value (per short ton) 

Total net sales $1,307 $1,320 $1,124 $1,174 $1,064

Cost of goods sold.-- 

Raw materials 860 857 798 807 794

Direct labor 53 60 63 62 68

Other factory costs 155 173 182 180 145

Average COGS 1,067 1,090 1,043 1,049 1,007

Gross profit or (loss) 240 231 81 126 57 

SG&A expense 57 58 66 69 59 

Operating income or (loss) 183 173 14 57 (2)

Number of firms reporting 

Operating losses 0 0 5 5 7

Data 11 11 12 12 12

Source: Compiled from data submitted in response to Commission questionnaires. 
VI‐3

Table VI-2 

Certain welded line pipe: Selected results of operations of U.S. producers, by firm, 2011-13, 

January-June 2013, and January-June 2014 

*            *            *            *            *            *            *

Raw material costs accounted for an average 78.7 percent of total COGS for the

reporting period, and had the greatest impact on the increase or decrease in COGS during this

time.   Respondents argue that certain U.S. producers’ reported raw material costs are

unusually high, and inhibit profitability unless demand and pricing are very strong.  

Respondents also argue that these firms’ data result in per short ton raw material costs that are

incongruous with publicly available price data for hot‐rolled steel.1  In response to these

allegations, U.S. producers stated that the hot‐rolled steel purchased to produce the subject

line pipe is more expensive than publicly available base prices due to surcharges for higher

grades of steel and freight costs.2

Certain U.S. producers reported relatively greater profitability as compared to the

average results for all firms, including ***.  According to ***.3  According to ***.4

While the U.S. industry overall reported a decline in profitability, *** reported financial

performance in 2013 was *** as compared to other reporting firms.  According to ***. 5 6  

According to ***.7 8

   

 

1 Postconference brief of Korean producers, pp. 23‐29.  Respondents particularly focus on the raw

material costs reported by ***.  E‐mail from ***, November 17, 2014.  ***.  E‐mails from ***,

November 10, 2014 and November 17, 2014.  *** raw material costs are discussed above.     2 ***.  Postconference brief of U.S. Steel, exhibit 1.  ***.  Postconference brief of Maverick, pp. 14‐

15.  In petitioners’ postconference brief, ***.  Postconference brief of petitioners, exhibit 9.

3 E‐mails from ***, November 3, 2014, and November 4, 2014. 4 E‐mail from ***, November 4, 2014.  In its U.S. producer questionnaire response, ***. 5 E‐mails from ***, November 4, 2014, and November 13, 2014.  ***.  Ibid.

6 ***.  Postconference brief of U.S. Steel, pp. 2‐3. 7 E‐mail from ***, November 14, 2014.  ***.  Ibid.  These other raw materials account for about ***

percent of ***’s total raw materials cost for the subject line pipe.  E‐mail from ***, November 16, 2014.

8 The decline in operating income observed in the reported data is impacted by ***.
VI‐4

Variance analysis

 The variance analysis presented in table VI‐3 is based on the data in table VI‐1.9  The

analysis shows that the decline in operating income from 2011 to 2013, as well as from  

January‐June 2013 to January‐June 2014, is primarily attributable to a higher unfavorable price

variance despite a favorable net cost/expense variance (that is, prices declined more than costs

and expenses.

Table VI-3 

Certain welded line pipe: Variance analysis on the operations of U.S. producers, 2011-13, and 

January-June 2013-14 

Item 

Fiscal year January-June 

2011-13 2011-12 2012-13 2013-14 

Value ($1,000) 

Total net sales: 

Price variance (239,020) 21,312 (256,393) (69,638)

Volume variance (139,426) 247,759 (391,124) (30,223)

Total net sales variance (378,446) 269,071 (647,517) (99,861)

Cost of sales: 

Cost variance 31,246 (35,895) 60,506 26,084 

Volume variance 113,852 (202,315) 322,802 26,983 

Total cost variance 145,098 (238,210) 383,308 53,067 

Gross profit variance (233,348) 30,861 (264,209) (46,794)

SG&A expenses: 

Expense variance (12,804) (2,284) (10,941) 6,544 

Volume variance 6,040 (10,733) 17,194 1,775 

Total SG&A variance (6,764) (13,017) 6,253 8,319 

Operating income variance (240,112) 17,844 (257,956) (38,475)

Summarized as: 

Price variance (239,020) 21,312 (256,393) (69,638)

Net cost/expense variance 18,442 (38,179) 49,564 32,628 

Net volume variance (19,534) 34,712 (51,128) (1,465)

Note.--Unfavorable variances are shown in parenthesis; all others are favorable. 

Source: Compiled from data submitted in response to Commission questionnaires. 

 

9 The Commission’s variance analysis is calculated in three parts:  sales variance, cost of sales

variance (COGS variance), and SG&A expense variance.  Each part consists of a price variance (in the

case of the sales variance) or a cost variance (in the case of the COGS and SG&A expense variance), and

a volume variance.  The sales or cost variance is calculated as the change in unit price or unit

cost/expense times the new volume, while the volume variance is calculated as the change in volume

times the old unit price or unit cost.  Summarized at the bottom of the table, the price variance is from

sales; the cost/expense variance is the sum of those items from COGS and SG&A variances, respectively,

and the volume variance is the sum of the volume components of the net sales, COGS, and SG&A

expense variances.  
VI‐5

Capital expenditures, research and development expenses, and total assets

The responding firms’ aggregate data on capital expenditures, research and

development (“R&D”) expenses, and total assets are shown in table VI‐4.  Eleven firms reported

capital expenditure data, and three firms reported research and development (“R&D”)

expenses.  Aggregate capital expenditures increased notably from 2011 to 2013, with the

majority of reported capital expenditures in 2013 reflecting ***.  The total assets utilized in the

production, warehousing, and sale of certain welded line pipe decreased from $1.9 billion in

2011 to $1.7 billion in 2013.

Table VI-4 

Certain welded line pipe: Capital expenditures, R&D expenses, and total assets of U.S. producers, 

2011-13, January-June 2013, and January-June 2014 

Item 

Fiscal year January-June 

2011 2012 2013 2013 2014 

Value ($1,000) 

Capital expenditures *** *** *** *** ***

R&D expenses *** *** *** *** ***

Total assets 1,924,222 1,910,321 1,729,177

Note.—***. 

Source: Compiled from data submitted in response to Commission questionnaires.

Capital and investment

The Commission requested U.S. producers of certain welded line pipe to describe any

actual or potential negative effects of imports of certain welded line pipe from the subject

countries on their firms’ growth, investment, ability to raise capital, development and

production efforts, or the scale of capital investments.  Responses by U.S. producers follow.

Actual Negative Effects:

*            *            *            *            *            *            *

Potential Negative Effects:

*            *            *            *            *            *            *

 

VII‐1

PART VII: THREAT CONSIDERATIONS AND INFORMATION ON

NONSUBJECT COUNTRIES

Section 771(7)(F)(i) of the Act (19 U.S.C. § 1677(7)(F)(i)) provides that—

In determining whether an industry in the United States is threatened

with material injury by reason of imports (or sales for importation) of the

subject merchandise, the Commission shall consider, among other

relevant economic factors1

‐‐ 

(I) if a countervailable subsidy is involved, such information as may be

presented to it by the administering authority as to the nature of

the subsidy (particularly as to whether the countervailable subsidy

is a subsidy described in Article 3 or 6.1 of the Subsidies

Agreement), and whether imports of the subject merchandise are

likely to increase,

(II) any existing unused production capacity or imminent, substantial

increase in production capacity in the exporting country indicating

the likelihood of substantially increased imports of the subject

merchandise into the United States, taking into account the

availability of other export markets to absorb any additional

exports,

(III) a significant rate of increase of the volume or market penetration of

imports of the subject merchandise indicating the likelihood of

substantially increased imports,

(IV)whether imports of the subject merchandise are entering at prices

that are likely to have a significant depressing or suppressing

effect on domestic prices, and are likely to increase demand for

further imports,

(V) inventories of the subject merchandise,

                                                            

1 Section 771(7)(F)(ii) of the Act (19 U.S.C. § 1677(7)(F)(ii)) provides that “The Commission shall

consider {these factors} . . . as a whole in making a determination of whether further dumped or

subsidized imports are imminent and whether material injury by reason of imports would occur unless

an order is issued or a suspension agreement is accepted under this title. The presence or absence of

any factor which the Commission is required to consider . . . shall not necessarily give decisive guidance

with respect to the determination. Such a determination may not be made on the basis of mere

conjecture or supposition.”
VII‐2

(VI)the potential for product‐shifting if production facilities in the foreign

country, which can be used to produce the subject merchandise,

are currently being used to produce other products,

(VII) in any investigation under this title which involves imports of both

a raw agricultural product (within the meaning of paragraph

(4)(E)(iv)) and any product processed from such raw agricultural

product, the likelihood that there will be increased imports, by

reason of product shifting, if there is an affirmative determination

by the Commission under section 705(b)(1) or 735(b)(1) with

respect to either the raw agricultural product or the processed

agricultural product (but not both),

(VIII) the actual and potential negative effects on the existing

development and production efforts of the domestic industry,

including efforts to develop a derivative or more advanced version

of the domestic like product, and

(IX)any other demonstrable adverse trends that indicate the probability

that there is likely to be material injury by reason of imports (or

sale for importation) of the subject merchandise (whether or not it

is actually being imported at the time).2

Information on the nature of the alleged subsidies was presented earlier in this report;

information on the volume and pricing of imports of the subject merchandise is presented in

Parts IV and V; and information on the effects of imports of the subject merchandise on U.S.

producers’ existing development and production efforts is presented in Part VI. Information on

inventories of the subject merchandise; foreign producers’ operations, including the potential

for “product‐shifting;” any other threat indicators, if applicable; and any dumping in third‐

country markets, follows. Also presented in this section of the report is information obtained

for consideration by the Commission on nonsubject countries.  

                                                            

2 Section 771(7)(F)(iii) of the Act (19 U.S.C. § 1677(7)(F)(iii)) further provides that, in antidumping

investigations, “. . . the Commission shall consider whether dumping in the markets of foreign countries

(as evidenced by dumping findings or antidumping remedies in other WTO member markets against the

same class or kind of merchandise manufactured or exported by the same party as under investigation)

suggests a threat of material injury to the domestic industry.”
VII‐3

THE INDUSTRY IN KOREA

The petition in these investigations identified 13 producers and/or exporters of certain

welded line pipe in Korea. The Commission issued foreign producers’/exporters’ questionnaires

to these firms and received a completed response from four producers:  Husteel, Hyundai

HYSCO, NEXTEEL, and SeAH.3 A comparison of the responding firms’ export data to official

Commerce import statistics shows that in 2013 they accounted for *** percent of U.S. imports

from Korea. According to estimates requested of the responding Korean producers, the

production of certain welded line pipe in Korea reported in Part VII accounts for approximately

all production of certain welded line pipe in Korea. Husteel reported that *** percent of its

sales in the most recent year were sales of certain welded line pipe. Hyundai HYSCO reported

that *** percent of its sales in the most recent year were sales of certain welded line pipe.

NEXTEEL reported that *** percent of its sales in the most recent year were sales of certain

welded line pipe. SeAH reported that *** percent of its sales in the most recent year were sales

of certain welded line pipe.

Overall capacity and production of welded tubular products

Table VII‐1 presents information on the total welded tubular capacity and production of

the four responding producers in Korea.

Table VII-1 

Certain welded line pipe: Overall Korean welded pipe capacity, production, and capacity 

utilization, by production process, 2011-13, January-June 2013, and January-June 2014 

 

* * * * * * * 

Operations on certain welded line pipe

Table VII‐2 presents information on the certain welded line pipe operations of the four

responding producers and exporters in Korea. Reported capacity fluctuated slightly from 2011

to 2013. Capacity is expected to remain at the 2013 level through 2015. Production increased

by *** percent from 2011 to 2013 but was *** percent lower in January‐June 2014 than in

January‐June 2013. Production is projected to be *** percent lower in 2014 than in 2013, and

to not change from 2014 to 2015. Capacity utilization increased from *** percent in 2011 to

*** percent in 2012 but declined to *** percent in 2013. Capacity utilization was over ***

percent in January‐June 2013 and January‐June 2014.  

                                                            

3 ***.
VII‐4

Table VII-2 

Certain welded line pipe: Korean operations for certain welded line pipe, 2011-13, January-June 

2013, January-June 2014, and projected 2014 and 2015 

* * * * * * * 

Total shipments of Korean certain welded line pipe increased during 2011‐13. Exports to

the United States accounted for most of the increase, as exports to all other markets grew

slightly and Korean home market shipments declined during 2011‐13. Exports of certain welded

line pipe from Korea to the United States increased by *** percent from 2011‐13. In 2013, ***

percent of total shipments of certain welded line pipe from Korea were exported to the United

States, and *** percent were exported to other markets.  

Operations on welded line pipe not more than sixteen inches in outside diameter

Table VII‐3 presents information on the Korean operations for welded line pipe not

more than 16 inches in outside diameter.

Table VII-3 

Certain welded line pipe: Korean production of welded line <= 16 inches, 2011-13, January-June 

2013, January-June 2014, and projected 2014 and 2015 

* * * * * * * 

Operations on welded line pipe greater than sixteen inches

in outside diameter and less than or equal to twenty four inches

Table VII‐4 presents information on the Korean operations for welded line pipe greater

than 16 inches in outside diameter and less than or equal to 24 inches.

Table VII-4 

Certain welded line pipe: Korean production of welded line pipe > 16 inches <= 24 inches, 2011-13, 

January-June 2013, January-June 2014, and projected 2014 and 2015 

* * * * * * * 

THE INDUSTRY IN TURKEY

The petition in these investigations identified 13 potential producers and/or exporters

of certain welded line pipe in Turkey. The Commission issued foreign producers’/exporters’

questionnaires to these firms and received a completed response from three producers:

Cayirova Boru Sanayi, Toscelik, and Borusan.4 A comparison of the responding firms’ export

data to official Commerce import statistics shows that in 2013 they accounted for *** percent

                                                            

4 ***.
VII‐5

of U.S. imports from Turkey. Responding Turkish producers did not provide estimates of their

share of the production of certain welded line pipe in Turkey, but Counsel for Respondent

Turkish Exporters characterized questionnaire responses as accounting for the vast majority of

the Turkish industry.5 Cayirova Boru Sanayi reported that *** percent of its sales in the most

recent fiscal year were sales of certain welded line pipe. Toscelik reported that *** percent of

its sales in the most recent fiscal year were sales of certain welded line pipe. Borusan reported

that *** percent of its sales in the most recent fiscal year were sales of certain welded line

pipe.

Overall capacity and production of welded tubular products

Table VII‐5 presents information on the total welded tubular capacity and production of

the three responding producers in Turkey.

Table VII-5 

Certain welded line pipe: Overall Turkish welded pipe capacity, production, and capacity 

utilization, by production process, 2011-13, January-June 2013, and January-June 2014 

* * * * * * * 

Operations on certain welded line pipe

Table VII‐6 presents information on the certain welded line pipe operations of the three

responding producers and exporters in Turkey. Reported capacity increased steadily during

2011‐13, resulting in an overall increase of *** percent from 2011 to 2013. Capacity is

projected to be *** percent lower in 2014 compared to 2013, and to not change from 2014 to

2015. Production increased from by *** percent from 2011 to 2012 but decreased by ***

percent from 2012 to 2013, resulting in an overall increase of *** percent from 2011 to 2013.

Production was *** percent lower in January‐June 2014 than in January‐June 2013. Production

is projected to be *** percent lower in 2014 compared to 2013, and is projected to be ***

percent lower in 2015 compared to 2013. Capacity utilization increased by *** percentage

points from 2011 to 2012 (from *** percent to *** percent), but the combination of increasing

capacity and decreasing production resulted in a *** percentage point decrease from 2012 to

2013. Capacity utilization is projected to decrease further in 2014 and 2015, reaching ***

percent in 2015.

Table VII-6 

Certain welded line pipe: Turkish operations for certain welded line pipe, 2011-13, January-June 

2013, January-June 2014, and projected 2014 and 2015 

* * * * * * * 

                                                            

5 Conference transcript, p. 128 (Nolan).
VII‐6

Total shipments of Turkish certain welded line pipe increased by *** percent from 2011‐

13. During this period, home market shipments increased by *** percent and exports by ***

percent. During 2011‐12, exports to the United States increased by *** percent whereas

exports to all other markets decreased by *** percent. In 2013, *** percent of total shipments

of certain welded line pipe from Turkey were exported to the United States, and *** were

exported to other markets.

Operations on welded line pipe not more than sixteen inches in outside diameter

Table VII‐7 presents information on the Turkish operations for welded line pipe not

more than 16 inches in outside diameter.

Table VII-7 

Certain welded line pipe: Turkish production of welded line <= 16 inches, 2011-13, January-June 

2013, January-June 2014, and projected 2014 and 2015 

* * * * * * * 

Operations on welded line pipe greater than sixteen inches

in outside diameter and less than or equal to twenty four inches

Table VII‐8 presents information on the Turkish operations for welded line pipe greater

than 16 inches in outside diameter and less than or equal to 24 inches.

Table VII-8 

Certain welded line pipe: Turkish production of welded line pipe > 16 inches <= 24 inches, 2011-

13, January-June 2013, January-June 2014, and projected 2014 and 2015 

* * * * * * * 

SUBJECT COUNTRIES COMBINED

Table VII‐9 presents information on the overall welded pipe operations of the

responding producers and exporters in the subject countries.  

Table VII-9 

Certain welded line pipe: Overall subject producers’ welded pipe capacity, production, and 

capacity utilization, by production process, 2011-13, January-June 2013, and January-June 2014 

* * * * * * * 

Table VII‐10 presents information on certain welded line pipe operations of the

reporting producers and exporters in the subject countries.  
VII‐7

Table VII-10 

Certain welded line pipe: Subject producers’ operations for certain welded line pipe, 2011-13, 

January-June 2013, January-June 2014, and projected 2014 and 2015 

* * * * * * * 

Table VII‐11 presents information on subject producers’ operations combined for

welded line pipe not more than 16 inches in outside diameter.

Table VII-11 

Certain welded line pipe: Subject producers’ combined production of welded line <= 16 inches, 

2011-13, January-June 2013, January-June 2014, and projected 2014 and 2015 

* * * * * * * 

Table VII‐12 presents information on subject producers’ combined operations for

welded line pipe greater than 16 inches in outside diameter and less than or equal to 24 inches

in the subject countries.

Table VII-12 

Certain welded line pipe: Subject producers’ production of welded line pipe > 16 inches <= 24 

inches, 2011-13, January-June 2013, January-June 2014, and projected 2014 and 2015 

* * * * * * * 

U.S. INVENTORIES OF IMPORTED MERCHANDISE

Table VII‐13 presents data on U.S. importers’ reported inventories of certain welded line

pipe.6

  

Table VII-13 

Certain welded line pipe: U.S. importers’ inventories, 2011-13, January-June 2013, and JanuaryJune 2014 

* * * * * * * 

U.S. IMPORTERS’ OUTSTANDING ORDERS

The Commission requested importers to indicate whether they imported or arranged for

the importation of certain welded line pipe from Korea and Turkey after June 30, 2014. These

imports are presented in table VII‐14.

                                                            

6 U.S. importers’ reported inventories of welded line pipe not more than 16 inches in outside

diameter is presented in table C‐2 and U.S. importers’ reported inventories of welded line pipe greater

than 16 inches in outside diameter and less than or equal to 24 inches is presented in table C‐3.
VII‐8

Table VII-14 

Certain welded line pipe: U.S. importers’ arranged imports, July 2014 – June 2015 

* * * * * * * 

TRADE REMEDY ACTIONS IN THIRD‐COUNTRY MARKETS

There are no known trade remedy actions in third‐country markets covering certain

welded line pipe.

INFORMATION ON NONSUBJECT COUNTRIES

Welded line pipe is produced in substantial quantities by pipe and tube producers

throughout the world. The World Steel Association publishes data on the broader product

grouping of all welded tubes. Global welded tube production increased by 46 percent from

2009 to 2013, following the global economic recession. Global welded tube production reached

its highest levels in 2013 with 870.2 million short tons produced that year. Most of this growth

was attributed to China, which accounted for 64 percent of all global welded tube production in

2013.7  

Official Commerce statistics indicate that Mexico was the second‐largest source of U.S.

imports of line pipe of up to 24 inches after Korea, and accounted for 9.3 percent of all such

U.S. imports in 2013. Imports from Japan of line pipe up to 24 inches fell slightly under Mexico’s

levels, but also accounted for 7.1 percent of all U.S. imports in 2013. However, from 2011 to

2013, welded line pipe imports from Mexico decreased by 14.2 percent and imports from Japan

decreased by 35.8 percent.

Mexico

Mexico’s domestic oil and gas industry, as well as pipeline projects in the United States,  

drives demand for Mexican welded line pipe. Despite recent declines in oil production, Mexico

remains one of the world’s top ten largest oil producers. Further, substantial, new off‐shore and

on‐shore oil discoveries have been reported, and Mexico is estimated to be one of the largest

shale gas resource bases.  However, extraction of these resources is developing slowly. In the

meantime, Mexico expects to expand its natural gas pipeline from the United States to meet

Mexican demand for energy. Mexico currently has 13 natural gas pipeline connections and

plans to add two additional connections.8

  According to the World Steel Association, Mexico

was not a top‐ten global producer of all welded tubes in 2011 and 2012. Mexico’s welded tube

                                                            

7 World Steel Association, Steel Statistical Yearbook, 2014, table 28, p. 52.   8 U.S. Energy Information Administration, Country Analysis Brief, Mexico, last modified April 24,

2014.
VII‐9

production was 570,000 metric tons in 2013. However, according to Global Trade Atlas, Mexico

was the fourth‐largest supplier of all diameters of welded line pipe to the United States from

2011‐2013, by quantity (table VII‐15).9 From 2011 to 2013, Mexico’s global exports of welded

line pipe decreased by 15.0 percent, and its exports to the United States decreased by 12.3

percent.  

Table VII-15 

Welded line pipe: Mexico’s reported exports, 2011-13 

Country 

Calendar year 

2011 2012 2013 

Quantity (short tons) 

World 135,299 144,351 115,069

United States 130,425 107,743 114,422

Guatemala 635 856 508

Belize 0 2 71

Italy 0 22 20

Nicaragua 0 0 19

Costa Rica 12 0 17

El Salvador 40 60 10

Nigeria 0 0 3

Cuba 1 0 0

Canada 0 3 0

Colombia 3,102 172 0

Peru 0 4 0

Singapore 0 12 0

Thailand 0 2 0

Korea South 13 4 0

Uruguay 64 24 0

Venezuela 1,006 25,369 0

Barbados 0 10,074 0

All others 1 4 0

Note.— Original data were published in metric tons, which were converted to short tons by multiplying by 

1.102311. Because of rounding, figures may not add to the totals shown. The HTS subheadings used to 

gather information on welded line pipe are broader than the HTS statistical reporting numbers in the 

scope of this investigation. 

Source: Global Trade Atlas, 2014 HS Subheadings 730511, 730512, 730519, and 730619. 

In terms of line pipe of up to 16 inches in outside diameter, Mexico was the second‐

largest importer to the United States by quantity (after Korea) and accounted for about 13

percent of the total from 2011‐14.10  However, in terms of line pipe greater than 16 inches up

to 24 inches, Mexico accounted for less than 1 percent of U.S. imports from 2011‐14.  

                                                            

9 Global Trade Atlas, U.S. Import Statistics, 2014, HS Subheadings 7305.11, 7305.12, 7305.19,

7306.19.

10 Official Commerce statistics, 2014; HTS numbers 7305.11.1030, 7305.12.1030, 7305.19.1030,

7306.19.1010, 7306.19.1050, 7306.19.5110, and 7306.19.5150.
VII‐10

There are thirteen known Mexican welded line pipe producers that produce to API 5L  

standards: ArcelorMittal Productura Mexicana de Tuberia, Forza Steel, Procarsa, Pytco, Talleres

Acerorey, Tenaris TAMSA, Ternium Hysla, Tubac, Tubacero, Tuberia Laguna (Tysla), Tubesa,

Tumex, and Tuberia National (Villacero).11 In 2011, Carso Infraestructura y Construccion (CICSA)

sold its carbon steel pipes subsidiary, Operadora CICSA, to Tubacero, a Mexican pipe and tube

manufacturer. The facility acquired from CICSA is located in Veracruz and produces welded line

pipe to API 5L specifications.12 In 2013, Tubacero also completed the addition of 243,000 short

tons of capacity to produce welded line pipe ranging from 6 inches to 96 inches outside

diameter at its Monterrey Interport facility (Salinas Victoria, Nuevo León).13 According to

Simdex, Tubacero’s Monterrey facility has the capacity to make 425,000 short tons of OCTG and

welded line pipe with outside diameter ranges of 6.625 inches to 48 inches.14  In October 2014,

Tenaris TAMSA announced that its Veracruz facility currently has an annual production capacity

of 1.1 million short tons per year focused on seamless and welded line pipes for offshore and

onshore oil and gas applications.15

Japan

Since Japan’s oil resources are very limited, the country relies almost solely on imports

to meet its oil consumption needs, making the country the third largest net oil importer. Japan

is the world’s largest liquefied natural gas (LNG) importer because it depends on LNG imports

for virtually all of its natural gas demand. Due to lack of domestic oil and gas reserves, Japanese

energy companies have actively pursued upstream oil and natural gas projects abroad, and

provide construction for energy projects worldwide. Japan is a major exporter of energy‐sector

capital equipment.16  

According to the World Steel Association, Japan was the world’s fourth‐largest producer

of all welded tube in 2012, after China, Russia, and Korea.17 Japan’s welded tube production in

2013 was 5.1 million tons in 2013. According to Global Trade Atlas, Malaysia was the leading

market for Japan’s exports of welded line pipe in 2013, accounting for approximately 42

percent of the Japan’s total exports (table VII‐16). From 2011 to 2013, Japan’s exports of

welded line pipe decreased by 1.6 percent. The United States was the second‐largest export

destination for Japanese welded line pipe from 2011 to 2013.

                                                            

11 The Simdex Steel Tube Manufacturers Worldwide Guide, 2014. 12 CNNExpansion, “Slim Deja Negocio de Tubos de Acero”, April 27, 2011; Grupo Carso, “Significant

Events”, Annual Report, 2012    13 Tubacero, “Investment in New Plant Located in Salinas Victoria”, April 1, 2013 14 The Simdex Steel Tube Manufacturers Worldwide Guide, Tubacero, 2014.

15 Preston Pipe and Tube Report, October 2014, 19, and Tenaris, “Offshore and Onshore Pipeline

Solutions,” July 2012, accessed on November 20, 2014.

16 U.S. Energy Information Administration, Japan, Country Analysis, last modified May 30, 2013.

http://www.eia.gov/countries/country‐data.cfm?fips=ja (accessed on November 4, 2014).   17 World Steel Association, Steel Statistical Yearbook, 2014, table 28, p. 52.
VII‐11

Table VII-16 

Welded line pipe: Japan’s reported exports, 2011-13 

Country 

Calendar year 

2011 2012 2013 

Quantity (short tons) 

World 1,138,654 1,373,168 1,120,581

Malaysia 369,305 355,289 474,569

United States 210,808 242,190 155,473

United Arab Emirates 36,590 92,103 113,135

Singapore 93,580 109,847 65,295

Saudi Arabia 87,807 203,718 61,770

Indonesia 54,884 133,093 60,173

Canada 38,451 72,508 41,112

Thailand 24,105 23,753 29,033

France 30,812 3,800 24,625

Mozambique 0 8,303 17,116

United Kingdom 94 8,952 15,343

All others 115,916 102,448 62,935

Note.— Original data were published in metric tons, which were converted to short tons by multiplying by 

1.102311. Because of rounding, figures may not add to the totals shown. The HTS subheadings used to 

gather information on welded line pipe are broader than the HTS statistical reporting numbers in the 

scope of this investigation. 

 

Source: Global Trade Atlas, 2014 HS Subheadings 730511, 730512, 730519, and 730619. 

During 2011 to 2013, Japan was the third‐largest exporter of welded line pipe to the

United States (12.3 percent of U.S. imports of welded pipe in 2013), after Korea and Canada.18

In terms of line pipe of up to 16 inches in outside diameter, Japan was the fifth‐ largest supplier

to the United States (after Korea, Mexico, Turkey, and Canada), and accounted for 5.0 percent

of U.S. imports in the product category from 2011 to June 2014. However, in terms of line pipe

greater than 16 inches up to 24 inches, Japan was the second‐largest exporter to the United

States after Korea, and accounted for 21.5 percent of U.S. imports in the product category from

2011 to June 2014.19  

The eight known Japanese welded line pipe producers that produce to the API 5L and

ASTM A‐53 standards are JFE Steel Corporation (“JFE Steel”), Nippon Steel and Sumitomo Metal

Corporation (“NSSMC”), Maruichi Steel Tube, Araya Industrial, Nishimura Koki, Osaka Tokushu

                                                            

18 Global Trade Atlas, HTS numbers 730511, 730512, 730519, and 730619 (accessed on November 4,

2014).   19 Official Commerce Import Statistics, 2014; HTS numbers 7305.11.1030, 7305.12.1030,

7305.19.1030, 7306.19.1010, 7306.19.1050, 7306.19.5110, and 7306.19.5150.  
VII‐12

Kokan, Toa Gaigyo, and Usui Kokosai Sangyo Kaisha.20  In October 2012, NSSMC was created as

a result of a merger between Nippon Steel Corporation and Sumitomo Metal Industries.21

According to Simdex, the Nippon Steel facilities have the capacity to make 3.9 million metric

tons of tubes annually and Sumitomo Metal Industries facilities have the capacity to make 3

million metric tons of pipe and tube annually.  These companies focus their production on

circular welded carbon or low alloy pipes. In December 2011, JFE Steel announced its intention

to increase capacity of high grade pipe to 330,000 tons per year as a result of welding and crane

upgrades.22 According to its website, JFE Steel has the ability to make 1.32 million metric tons

annually of submerged arc welded pipe, 940,000 metric tons of high‐frequency welded tubular

products, and 360,000 metric tons of butt‐welded pipe.23 Simdex states that Mariuchi Steel

Tube Ltd. has the capacity to produce 1.2 million metric tons of pipes and tubes annually.24 On

its website, Japanese welded line pipe producer, Nishimura Koki, states that it makes line pipe

for oil and gas applications and produces 36,000 metric tons annually.25

                                                            

20 The Simdex Steel Tube Manufacturers Worldwide Guide, 2014.   21 Nippon Steel and Sumitomo Metal website, Who We Are,

http://www.nssmc.com/en/company/whoweare/index.html (accessed on November 10, 2014).   22 Preston Pipe and Tube Report, December 2011, vol. 29 no. 12.

23 JFE Steel Website, JFE Line Pipe, http://www.jfe‐steel.co.jp/en/products/pipes/linepipe/facts.html

(accessed on November 13, 2014).   24 The Simdex Steel Tube Manufacturers Worldwide Guide, Maruichi Steel Tube Ltd., 2014.

25 Nishimura Koki, Profile,  http://www.nishimura‐koki.co.jp/en/profile/index.html (accessed on

November 10, 2014).  
APPENDIX A

FEDERAL REGISTER NOTICES 

A-1

The Commission makes available notices relevant to its investigations and reviews on its 

website, www.usitc.gov. In addition, the following tabulation presents, in chronological order, 

Federal Register notices issued by the Commission and Commerce during the current 

proceeding.

Citation Title Link

79 FR 63438

October 23, 2014

Certain Welded Line Pipe From 

Korea and Turkey; Institution of

Antidumping and Countervailing 

Duty Investigations and 

Scheduling of Preliminary Phase

Investigations

https://www.federalregister.gov/ar

ticles/2014/10/23/2014-

25156/certain-welded-line-pipefrom-korea-and-turkey-institutionof-antidumping-andcountervailing-duty

79 FR 67419

November 12, 2014

Initiation of Countervailing Duty 

Investigations

https://www.federalregister.gov/ar

ticles/2014/11/13/2014-

26897/welded-line-pipe-from-therepublic-of-korea-and-the-republicof-turkey-initiation-ofcountervailing

79 FR 68213, 

November 14, 2014 Initiation of Antidumping Duty 

Investigations

https://www.federalregister.gov/ar

ticles/2014/11/14/2014-

26894/welded-line-pipe-from-therepublic-of-korea-and-the-republicof-turkey-initiation-of

Source: https://www.federalregister.gov/

A-3

APPENDIX B

LIST OF CONFERENCE WITNESSES

B-1

CALENDAR OF PUBLIC PRELIMINARY CONFERENCE

Those listed below appeared as witnesses at the United States International Trade 

Commission’s preliminary conference:

Subject: Certain Welded Line Pipe from Korea and Turkey

Inv. Nos.: 701-TA-524-525 and 731-TA-1260-1261 (Preliminary)

Date and Time: November 6, 2014 - 9:30 am

Sessions were held in connection with these preliminary investigations in the ALJ 

Courtroom A (room 100), 500 E Street, S.W., Washington, DC.

OPENING REMARKS:

Petitioners (Roger B. Schagrin, Schagrin Associates)

Respondents (Donald B. Cameron, Morris, Manning & Martin, LLP)

 

 

In Support of the Imposition of

Antidumping and Countervailing Duty Orders:

Schagrin Associates 

Washington, DC

on behalf of

American Cast Iron Pipe Company (“ACIPCO”)

California Steel Industries (“CSI”) 

Energex, a division of JMC Steel Group

Northwest Pipe Company

Stupp Corporation, a division of Stupp Bros., Inc. 

Tex-Tube Company

TMK IPSCO 

Welspun Tubular LLC USA

United Steel, Paper and Forestry, Rubber, 

Manufacturing, Energy, Allied Industrial 

and Service Workers International Union ("USW")

Jon Noland, Division Manager - American Steel Pipe 

Division, ACIPCO

Robert Mahoney, Senior Vice President of Strategy & Business 

Development, Northwest Pipe Company

John Clark, Senior Vice President of Global Sales and Marketing, 

Stupp Corporation

B-3
In Support of the Imposition of

Antidumping and Countervailing Duty Orders (continued):

Michael O'Brien, Vice President of Sales, ACIPCO

Ray Dubreuil, Vice President of Sales, CSI

Raymond Davila, Consultant, Tex-Tube Company

Scott Barnes, Senior Vice President and Chief Commercial 

Officer, TMK IPSCO

Rusty Fisher, Senior Vice President of Marketing and Sales, 

Welspun Tubular LLC USA

Skip Herald, President and CEO, Welspun Americas LLC

Holly Hart, Legislative Director, USW

Roger B. Schagrin ) 

John W. Bohn ) – OF COUNSEL

Paul W. Jameson )

Skadden, Arps, Slate, Meagher & Flom LLP 

Washington, DC

on behalf of

United States Steel Corporation (“U.S. Steel”)

Robert Y. Kopf, General Manager North American 

Flat-Rolled Marketing, U.S. Steel

Jeff Johnson, Director, Commercial – North American Line

& Standard Pipe, United States Steel Tubular Products

Robert C. Upton, Manager Standard and Line Pipe Marketing, 

United States Steel Tubular Products

Stephen P. Vaughn ) – OF COUNSEL

B-4
In Support of the Imposition of

Antidumping and Countervailing Duty Orders (continued):

Wiley Rein LLP 

Washington, DC

on behalf of

Maverick Tube Corporation

Brad Lowe, President, Tenaris Global Services (USA) Inc. and

Commercial Director, Maverick Tube Corporation

Alan H. Price ) 

) – OF COUNSEL

Robert E. DeFrancesco )

In Opposition to the Imposition of

Antidumping 

and Countervailing Duty Orders:

Morris, Manning & Martin, LLP 

Washington, DC

on behalf of

Husteel Co., Ltd.

Hyundai HYSCO

Nextell Co., Ltd.

SeAH Steel Corporation

Hope Snow, Vice President, Trident Steel

Donald B. Cameron )

) – OF COUNSEL

Julie C. Mendoza ) 

Arent Fox, LLP 

Washington, DC

on behalf of

Çelik İhracatçilari Birliği (“ÇİB”)

Matthew M. Nolan ) 

) – OF COUNSEL

B-5
Diana Dimitriuc Quaia )

In Opposition to the Imposition of

Antidumping and Countervailing Duty Orders (continued):

Law Offices of David L. Simon 

Washington, DC

on behalf of

Çayirova Boru Sanayi ve Ticaret A.S. and its affiliated exporter,

Yücel Boru Ithalat-Ihracat ve Pazarlama A.S. (collectively “Yücel”)

Tosçelik Profil ve Sac Endustrisi A.S. and its affiliated exporter,

Tosyali Dis Ticaret A.S. (collectively “Tosçelik”)

David L. Simon ) – OF COUNSEL

REBUTTAL/CLOSING REMARKS:

Petitioners (Roger B. Schagrin, Schagrin Associates and Alan Price,)

Wiley Rein LLP

Respondents (Donald B. Cameron, Morris, Manning & Martin, LLP and

Matthew M. Nolan, Arent Fox, LLP)

-ENDB-6
APPENDIX C

SUMMARY DATA

C-1

Table C-1

Welded line pipe: Summary data concerning the U.S. market, 2011-13, January to June 2013, and January to June 2014

Jan-Jun

2011 2012 2013 2013 2014 2011-13 2011-12 2012-13 2013-14

U.S. consumption quantity:

Amount...................................................................... 2,521,770 3,280,518 2,525,836 1,389,404 1,189,716 0.2 30.1 (23.0) (14.4)

Producers' share (fn1).............................................. 55.0 47.7 48.5 46.1 50.1 (6.5) (7.3) 0.8 4.0

Importers' share (fn1):

Korea..................................................................... 21.8 22.8 28.6 30.2 29.3 6.8 1.0 5.8 (0.9)

Turkey.................................................................... 0.9 2.0 2.6 2.6 2.5 1.7 1.1 0.6 (0.1)

Subject................................................................ 22.7 24.9 31.2 32.9 31.8 8.5 2.1 6.4 (1.0)

All others sources.................................................. 22.3 27.5 20.3 21.1 18.1 (2.0) 5.2 (7.2) (3.0)

Total imports.................................................... 45.0 52.3 51.5 53.9 49.9 6.5 7.3 (0.8) (4.0)

U.S. consumption value:

Amount...................................................................... 2,968,171 3,949,853 2,592,164 1,471,386 1,127,043 (12.7) 33.1 (34.4) (23.4)

Producers' share (fn1).............................................. 61.1 52.5 53.5 51.3 56.5 (7.6) (8.6) 1.0 5.2

Importers' share (fn1):

Korea..................................................................... 17.4 18.0 23.2 24.3 23.7 5.9 0.6 5.2 (0.6)

Turkey.................................................................... 0.7 1.5 2.0 2.0 2.8 1.3 0.8 0.5 0.8

Subject................................................................ 18.0 19.5 25.2 26.3 26.4 7.2 1.4 5.8 0.1

All others sources.................................................. 20.8 28.0 21.3 22.5 17.1 0.4 7.2 (6.8) (5.3)

Total imports.................................................... 38.9 47.5 46.5 48.7 43.5 7.6 8.6 (1.0) (5.2)

U.S. importers' U.S. imports from:

Korea:

Quantity.................................................................. 550,707 749,029 722,892 419,982 348,849 31.3 36.0 (3.5) (16.9)

Value...................................................................... 515,789 711,513 602,585 357,292 266,643 16.8 37.9 (15.3) (25.4)

Unit value............................................................... 937 950 834 851 764 (11.0) 1.4 (12.2) (10.2)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Turkey:

Quantity.................................................................. 22,717 66,472 66,025 36,726 29,828 190.6 192.6 (0.7) (18.8)

Value...................................................................... 19,856 57,744 51,901 29,246 31,109 161.4 190.8 (10.1) 6.4

Unit value............................................................... 874 869 786 796 1,043 (10.1) (0.6) (9.5) 31.0

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Subject:

Quantity.................................................................. 573,425 815,501 788,917 456,707 378,677 37.6 42.2 (3.3) (17.1)

Value...................................................................... 535,644 769,257 654,486 386,537 297,752 22.2 43.6 (14.9) (23.0)

Unit value............................................................... 934 943 830 846 786 (11.2) 1.0 (12.1) (7.1)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

All other sources:

Quantity.................................................................. 562,605 901,143 512,453 292,733 215,364 (8.9) 60.2 (43.1) (26.4)

Value...................................................................... 618,600 1,107,167 551,354 330,626 193,055 (10.9) 79.0 (50.2) (41.6)

Unit value............................................................... 1,100 1,229 1,076 1,129 896 (2.1) 11.7 (12.4) (20.6)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Total imports:

Quantity.................................................................. 1,136,029 1,716,644 1,301,370 749,440 594,041 14.6 51.1 (24.2) (20.7)

Value...................................................................... 1,154,245 1,876,424 1,205,840 717,164 490,807 4.5 62.6 (35.7) (31.6)

Unit value............................................................... 1,016 1,093 927 957 826 (8.8) 7.6 (15.2) (13.7)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

U.S. producers':

Average capacity quantity........................................ 2,188,400 2,291,751 2,342,745 1,206,866 1,189,582 7.1 4.7 2.2 (1.4)

Production quantity................................................... 1,446,966 1,616,295 1,306,275 699,265 686,143 (9.7) 11.7 (19.2) (1.9)

Capacity utilization (fn1)........................................... 66.1 70.5 55.8 57.9 57.7 (10.4) 4.4 (14.8) (0.3)

U.S. shipments:

Quantity.................................................................. 1,385,741 1,563,874 1,224,466 639,964 595,675 (11.6) 12.9 (21.7) (6.9)

Value...................................................................... 1,813,926 2,073,429 1,386,324 754,222 636,236 (23.6) 14.3 (33.1) (15.6)

Unit value............................................................... 1,309 1,326 1,132 1,179 1,068 (13.5) 1.3 (14.6) (9.4)

Export shipments:

Quantity.................................................................. 32,797 38,089 69,232 17,795 36,349 111.1 16.1 81.8 104.3

Value...................................................................... 40,696 267,709 68,824 18,370 36,405 69.1 557.8 (74.3) 98.2

Unit value............................................................... 1,241 7,029 994 1,032 1,002 (19.9) 466.4 (85.9) (3.0)

Ending inventory quantity......................................... 92,457 102,614 108,518 143,575 161,243 17.4 11.0 5.8 12.3

Inventories/total shipments (fn1).............................. 6.5 6.4 8.4 10.9 12.8 1.9 (0.1) 2.0 1.8

Production workers................................................... 1,815 2,167 1,864 1,960 2,012 2.7 19.4 (14.0) 2.7

Hours worked (1,000s)............................................. 3,852 4,495 3,745 1,927 2,006 (2.8) 16.7 (16.7) 4.1

Wages paid ($1,000)................................................ 93,068 115,408 98,504 49,622 51,769 5.8 24.0 (14.6) 4.3

Hourly wages............................................................ 24.16 25.67 26.30 25.75 25.81 8.9 6.3 2.4 0.2

Productivity (short tons per 1,000 hours)................. 375.6 359.6 348.8 362.9 342.0 (7.1) (4.3) (3.0) (5.7)

Unit labor costs......................................................... 64.32 71.40 75.41 70.96 75.45 17.2 11.0 5.6 6.3

Net sales:

Quantity.................................................................. 1,413,085 1,602,650 1,306,408 657,759 632,025 (7.5) 13.4 (18.5) (3.9)

Value...................................................................... 1,846,887 2,115,958 1,468,441 772,502 672,641 (20.5) 14.6 (30.6) (12.9)

Unit value............................................................... 1,307 1,320 1,124 1,174 1,064 (14.0) 1.0 (14.9) (9.4)

Cost of goods sold (COGS)...................................... 1,508,130 1,746,340 1,363,032 689,683 636,616 (9.6) 15.8 (21.9) (7.7)

Gross profit of (loss)................................................. 338,757 369,618 105,409 82,819 36,025 (68.9) 9.1 (71.5) (56.5)

SG&A expenses....................................................... 80,004 93,021 86,768 45,378 37,059 8.5 16.3 (6.7) (18.3)

Operating income or (loss)....................................... 258,753 276,597 18,641 37,441 (1,034) (92.8) 6.9 (93.3) fn2

Capital expenditures................................................. *** *** *** *** *** *** *** *** ***

Unit COGS................................................................ 1,067 1,090 1,043 1,049 1,007 (2.2) 2.1 (4.3) (3.9)

Unit SG&A expenses................................................ 57 58 66 69 59 17.3 2.5 14.4 (15.0)

Unit operating income or (loss)................................ 183 173 14 57 (2) (92.2) (5.7) (91.7) fn2

COGS/sales (fn1)..................................................... 81.7 82.5 92.8 89.3 94.6 11.2 0.9 10.3 5.4

Operating income or (loss)/sales (fn1)..................... 14.0 13.1 1.3 4.8 (0.2) (12.7) (0.9) (11.8) (5.0)

Notes:

fn1.--Reported data are in percent and period changes are in percentage points.

fn2.--Undefined. 

Source: Import data compiled from official U.S. import statistics and data submitted in response to Commission questionnaires.

C-3

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)

Reported data Period changes

Calendar year January to June Calendar year
Table C-2

Welded line pipe: Summary data concerning the U.S. market for welded line pipe <=16", 2011-13, January to June 2013, and January to June 2014

Jan-Jun

2011 2012 2013 2013 2014 2011-13 2011-12 2012-13 2013-14

U.S. consumption quantity:

Amount...................................................................... *** *** *** *** *** *** *** *** ***

Producers' share (fn1).............................................. *** *** *** *** *** *** *** *** ***

Importers' share (fn1):

Korea..................................................................... *** *** *** *** *** *** *** *** ***

Turkey.................................................................... *** *** *** *** *** *** *** *** ***

Subject................................................................ *** *** *** *** *** *** *** *** ***

All others sources.................................................. *** *** *** *** *** *** *** *** ***

Total imports.................................................... *** *** *** *** *** *** *** *** ***

U.S. consumption value:

Amount...................................................................... *** *** *** *** *** *** *** *** ***

Producers' share (fn1).............................................. *** *** *** *** *** *** *** *** ***

Importers' share (fn1):

Korea..................................................................... *** *** *** *** *** *** *** *** ***

Turkey.................................................................... *** *** *** *** *** *** *** *** ***

Subject................................................................ *** *** *** *** *** *** *** *** ***

All others sources.................................................. *** *** *** *** *** *** *** *** ***

Total imports.................................................... *** *** *** *** *** *** *** *** ***

U.S. importers' U.S. imports from:

Korea:

Quantity.................................................................. 485,551 597,204 570,876 353,290 274,526 17.6 23.0 (4.4) (22.3)

Value...................................................................... 454,126 558,321 466,602 295,686 204,558 2.7 22.9 (16.4) (30.8)

Unit value............................................................... 935 935 817 837 745 (12.6) (0.0) (12.6) (11.0)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Turkey:

Quantity.................................................................. 22,717 66,472 66,025 36,726 29,828 190.6 192.6 (0.7) (18.8)

Value...................................................................... 19,856 57,744 51,901 29,246 31,109 161.4 190.8 (10.1) 6.4

Unit value............................................................... 874 869 786 796 1,043 (10.1) (0.6) (9.5) 31.0

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Subject:

Quantity.................................................................. 508,268 663,676 636,901 390,015 304,354 25.3 30.6 (4.0) (22.0)

Value...................................................................... 473,982 616,065 518,503 324,932 235,667 9.4 30.0 (15.8) (27.5)

Unit value............................................................... 933 928 814 833 774 (12.7) (0.5) (12.3) (7.1)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

All other sources:

Quantity.................................................................. 357,022 446,733 296,836 166,121 155,689 (16.9) 25.1 (33.6) (6.3)

Value...................................................................... 389,537 493,211 282,009 161,255 138,351 (27.6) 26.6 (42.8) (14.2)

Unit value............................................................... 1,091 1,104 950 971 889 (12.9) 1.2 (13.9) (8.5)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Total imports:

Quantity.................................................................. 865,291 1,110,409 933,737 556,136 460,042 7.9 28.3 (15.9) (17.3)

Value...................................................................... 863,519 1,109,276 800,512 486,187 374,017 (7.3) 28.5 (27.8) (23.1)

Unit value............................................................... 998 999 857 874 813 (14.1) 0.1 (14.2) (7.0)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

U.S. producers':

Average capacity quantity........................................ *** *** *** *** *** *** *** *** ***

Production quantity................................................... *** *** *** *** *** *** *** *** ***

Capacity utilization (fn1)........................................... *** *** *** *** *** *** *** *** ***

U.S. shipments:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Export shipments:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity......................................... *** *** *** *** *** *** *** *** ***

Inventories/total shipments (fn1).............................. *** *** *** *** *** *** *** *** ***

Production workers................................................... *** *** *** *** *** *** *** *** ***

Hours worked (1,000s)............................................. *** *** *** *** *** *** *** *** ***

Wages paid ($1,000)................................................ *** *** *** *** *** *** *** *** ***

Hourly wages............................................................ *** *** *** *** *** *** *** *** ***

Productivity (short tons per 1,000 hours)................. *** *** *** *** *** *** *** *** ***

Unit labor costs......................................................... *** *** *** *** *** *** *** *** ***

Net Sales:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Cost of goods sold (COGS)...................................... *** *** *** *** *** *** *** *** ***

Gross profit of (loss)................................................. *** *** *** *** *** *** *** *** ***

SG&A expenses....................................................... *** *** *** *** *** *** *** *** ***

Operating income or (loss)....................................... *** *** *** *** *** *** *** *** ***

Capital expenditures................................................. *** *** *** *** *** *** *** *** ***

Unit COGS................................................................ *** *** *** *** *** *** *** *** ***

Unit SG&A expenses................................................ *** *** *** *** *** *** *** *** ***

Unit operating income or (loss)................................ *** *** *** *** *** *** *** *** ***

COGS/sales (fn1)..................................................... *** *** *** *** *** *** *** *** ***

Operating income or (loss)/sales (fn1)..................... *** *** *** *** *** *** *** *** ***

Notes:

fn1.--Reported data are in percent and period changes are in percentage points.

fn2.--Undefined. 

Source: Import data compiled from official U.S. import statistics and data submitted in response to Commission questionnaires.

C-4

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)

Reported data Period changes

Calendar year January to June Calendar year
Table C-3

Welded line pipe: Summary data concerning the U.S. market for welded line pipe >16" and <= 24", 2011-13, January to June 2013, and January to June 2014

Jan-Jun

2011 2012 2013 2013 2014 2011-13 2011-12 2012-13 2013-14

U.S. consumption quantity:

Amount...................................................................... *** *** *** *** *** *** *** *** ***

Producers' share (fn1).............................................. *** *** *** *** *** *** *** *** ***

Importers' share (fn1):

Korea..................................................................... *** *** *** *** *** *** *** *** ***

Turkey.................................................................... *** *** *** *** *** *** *** *** ***

Subject................................................................ *** *** *** *** *** *** *** *** ***

All others sources.................................................. *** *** *** *** *** *** *** *** ***

Total imports.................................................... *** *** *** *** *** *** *** *** ***

U.S. consumption value:

Amount...................................................................... *** *** *** *** *** *** *** *** ***

Producers' share (fn1).............................................. *** *** *** *** *** *** *** *** ***

Importers' share (fn1):

Korea..................................................................... *** *** *** *** *** *** *** *** ***

Turkey.................................................................... *** *** *** *** *** *** *** *** ***

Subject................................................................ *** *** *** *** *** *** *** *** ***

All others sources.................................................. *** *** *** *** *** *** *** *** ***

Total imports.................................................... *** *** *** *** *** *** *** *** ***

U.S. importers' U.S. imports from:

Korea:

Quantity.................................................................. 65,156 151,825 152,016 66,692 74,323 133.3 133.0 0.1 11.4

Value...................................................................... 61,662 153,192 135,983 61,605 62,085 120.5 148.4 (11.2) 0.8

Unit value............................................................... 946 1,009 895 924 835 (5.5) 6.6 (11.3) (9.6)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Turkey:

Quantity.................................................................. 00000 fn2 fn2 fn2 fn2

Value...................................................................... 00000 fn2 fn2 fn2 fn2

Unit value............................................................... fn2 fn2 fn2 fn2 fn2 fn2 fn2 fn2 fn2

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Subject:

Quantity.................................................................. 65,156 151,825 152,016 66,692 74,323 133.3 133.0 0.1 11.4

Value...................................................................... 61,662 153,192 135,983 61,605 62,085 120.5 148.4 (11.2) 0.8

Unit value............................................................... 946 1,009 895 924 835 (5.5) 6.6 (11.3) (9.6)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

All other sources:

Quantity.................................................................. 205,582 454,409 215,616 126,612 59,675 4.9 121.0 (52.6) (52.9)

Value...................................................................... 229,063 613,956 269,345 169,371 54,704 17.6 168.0 (56.1) (67.7)

Unit value............................................................... 1,114 1,351 1,249 1,338 917 12.1 21.3 (7.5) (31.5)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Total imports:

Quantity.................................................................. 270,738 606,235 367,633 193,303 133,998 35.8 123.9 (39.4) (30.7)

Value...................................................................... 290,726 767,148 405,328 230,976 116,789 39.4 163.9 (47.2) (49.4)

Unit value............................................................... 1,074 1,265 1,103 1,195 872 2.7 17.8 (12.9) (27.1)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

U.S. producers':

Average capacity quantity........................................ *** *** *** *** *** *** *** *** ***

Production quantity................................................... *** *** *** *** *** *** *** *** ***

Capacity utilization (fn1)........................................... *** *** *** *** *** *** *** *** ***

U.S. shipments:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Export shipments:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity......................................... *** *** *** *** *** *** *** *** ***

Inventories/total shipments (fn1).............................. *** *** *** *** *** *** *** *** ***

Production workers................................................... *** *** *** *** *** *** *** *** ***

Hours worked (1,000s)............................................. *** *** *** *** *** *** *** *** ***

Wages paid ($1,000)................................................ *** *** *** *** *** *** *** *** ***

Hourly wages............................................................ *** *** *** *** *** *** *** *** ***

Productivity (short tons per 1,000 hours)................. *** *** *** *** *** *** *** *** ***

Unit labor costs......................................................... *** *** *** *** *** *** *** *** ***

Net sales:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Cost of goods sold (COGS)...................................... *** *** *** *** *** *** *** *** ***

Gross profit of (loss)................................................. *** *** *** *** *** *** *** *** ***

SG&A expenses....................................................... *** *** *** *** *** *** *** *** ***

Operating income or (loss)....................................... *** *** *** *** *** *** *** *** ***

Capital expenditures................................................. *** *** *** *** *** *** *** *** ***

Unit COGS................................................................ *** *** *** *** *** *** *** *** ***

Unit SG&A expenses................................................ *** *** *** *** *** *** *** *** ***

Unit operating income or (loss)................................ *** *** *** *** *** *** *** *** ***

COGS/sales (fn1)..................................................... *** *** *** *** *** *** *** *** ***

Operating income or (loss)/sales (fn1)..................... *** *** *** *** *** *** *** *** ***

Notes:

fn1.--Reported data are in percent and period changes are in percentage points.

fn2.--Undefined. 

Source: Import data compiled from official U.S. import statistics and data submitted in response to Commission questionnaires.

C-5

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)

Reported data Period changes

Calendar year January to June Calendar year

APPENDIX D

NONSUBJECT PRICE DATA (JAPAN AND MEXICO)

D-1

Tables D-1 and D-2 and figures D-1 and D-2 present data on nonsubject prices of pricing 

products 1 and 3 described in Part V. Only three quarters of pricing data were provided for 

Japan, and all in product 3. Japan’s prices were lower than the U.S. prices but were higher than 

Korean prices in all quarters with data available. Only five quarters of pricing data were 

provided for Mexico, and all in product 1. Mexico’s prices were lower than the United States

and Turkish prices in all quarters with data available but were higher than Korean prices in 

three of the five quarters. There were no reported imports from nonsubject countries of 

products 2 and 4. 

Table D-1

Certain welded line pipe: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 1,

1 by quarters, January 2011-June 2014

Period

United States Japan Mexico

Price

(per short 

ton)

Quantity

(short tons)

Price

(per short 

ton)

Quantity

(short tons)

Price

(per short 

ton)

Quantity

(short tons)

2011:

Jan.-Mar. $1,189.49 7,197 -- 0 -- 0 

Apr.-June 1,335.14 6,493 -- 0 -- 0 

July-Sept. 1,298.75 5,863 -- 0 *** ***

Oct.-Dec. 1,247.45 3,746 -- 0 *** ***

2012:

Jan.-Mar. 1,281.06 6,604 -- 0 *** ***

Apr.-June 1,260.32 6,686 -- 0 -- 0 

July-Sept. 1,180.11 4,815 -- 0 *** ***

Oct.-Dec. 1,175.81 9,005 -- 0 *** ***

2013:

Jan.-Mar. 1,042.04 4,141 -- 0 -- 0 

Apr.-June 972.53 7,718 -- 0 -- 0 

July-Sept. 1,001.18 5,319 -- 0 -- 0 

Oct.-Dec. 954.84 4,878 -- 0 -- 0 

2014:

Jan.-Mar. *** *** -- 0 -- 0 

Apr.-June *** *** -- 0 -- 0 

1 Product 1: API 5L Grade B/X42 welded pipe, 6-inch nominal size (6.625 inch O.D.), plain end, with a 

wall thickness of 0.280 inch.

Source: Compiled from data submitted in response to Commission questionnaires.

D-3
Table D-2

Certain welded line pipe: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 3,

1 by quarters, January 2011-June 2014

Period

United States Japan Mexico

Price

(per short 

ton)

Quantity

(short tons)

Price

(per short 

ton)

Quantity

(short tons)

Price

(per short 

ton)

Quantity

(short tons)

2011:

Jan.-Mar. *** *** -- 0 -- 0 

Apr.-June $1,342.80 11,422 -- 0 -- 0 

July-Sept. 1,316.66 6,660 *** *** -- 0 

Oct.-Dec. 1,285.71 6,763 -- 0 -- 0 

2012:

Jan.-Mar. 1,378.64 10,375 -- 0 -- 0 

Apr.-June 1,308.59 11,343 -- 0 -- 0 

July-Sept. *** *** *** *** -- 0 

Oct.-Dec. 1,058.83 6,016 -- 0 -- 0 

2013:

Jan.-Mar. 1,072.91 5,906 -- 0 -- 0 

Apr.-June 1,059.30 5,177 -- 0 -- 0 

July-Sept. *** *** -- 0 -- 0 

Oct.-Dec. *** *** -- 0 -- 0 

2014:

Jan.-Mar. *** *** *** *** -- 0 

Apr.-June 984.25 5,931 -- 0 -- 0 

1 Product 3: API 5L Grade B/X42 welded pipe, 12-inch nominal size (12.75 inch O.D.), plain end, with a 

wall thickness of 0.375 inch.

Source: Compiled from data submitted in response to Commission questionnaires.

Figure D-1

Certain welded line pipe: Weighted-average prices and quantities of domestic and imported 

product 1, by quarters, January 2011-June 2014

* * * * * * *

Figure D-2

Certain welded line pipe: Weighted-average prices and quantities of domestic and imported 

product 3, by quarters, January 2011-June 2014

* * * * * * *

D-4