U.S. International Trade Commission

Publication 4495 October 2014

Washington, DC 20436

Boltless Steel Shelving Units 

Prepackaged for Sale from China

Investigation Nos. 701-TA-523 and 731-TA-1259 (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

Mary Messer, Investigator 

Dennis Fravel, Industry Analyst 

Tana Farrington, Economist 

Justin Jee, Accountant 

Waleed Navarro, Statistician 

Lita David-Harris, Statistician 

Darlene Smith, Statistical Assistant 

Mary Jane Alves, Attorney 

Elizabeth Haines, Supervisory Investigator
U.S. International Trade Commission

Washington, DC 20436 

www.usitc.gov

Publication 4495 October 2014

Boltless Steel Shelving Units 

Prepackaged for Sale from China

Investigation Nos. 701-TA-523 and 731-TA-1259 (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‐3

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

Nature and extent of alleged subsidies and sales at LTFV........................................................ I‐4

Alleged subsidies................................................................................................................... I‐4

Alleged sales at LTFV ............................................................................................................. I‐5

The subject merchandise .......................................................................................................... I‐6

Commerce’s scope ................................................................................................................ I‐6

Tariff treatment..................................................................................................................... I‐7

The product............................................................................................................................... I‐8

Description and applications................................................................................................. I‐8

Manufacturing process........................................................................................................ I‐10

Domestic like product issues................................................................................................... I‐12

Physical characteristics and uses......................................................................................... I‐13

Manufacturing facilities and production employees.......................................................... I‐13

Interchangeability................................................................................................................ I‐14

Customer and producer perceptions.................................................................................. I‐14

Channels of distribution ...................................................................................................... I‐15

Price..................................................................................................................................... I‐15
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‐2

U.S. supply ............................................................................................................................ II‐2

U.S. demand ......................................................................................................................... II‐5

Substitutability issues............................................................................................................... II‐7

Lead times ............................................................................................................................ II‐7

Comparison of U.S.‐produced and imported boltless steel shelving................................... II‐7

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

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

U.S. production, capacity, and capacity utilization................................................................. III‐2

Boltless steel shelving.......................................................................................................... III‐2

Overall capacity and production ......................................................................................... III‐3

U.S. producers’ U.S. shipments and exports........................................................................... III‐4

U.S. producers’ inventories..................................................................................................... III‐5

U.S. producers’ imports and purchases.................................................................................. III‐5

U.S. employment, wages, and productivity ............................................................................ III‐6

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‐3

Apparent U.S. consumption and U.S. market shares..............................................................IV‐4
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‐3

Price trends...........................................................................................................................V‐7

Price comparisons ................................................................................................................V‐8

Lost sales and lost revenue ......................................................................................................V‐8

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

Background..............................................................................................................................VI‐1

Operations on boltless steel shelving .....................................................................................VI‐1

Capital expenditures and research and development expenses............................................VI‐3

Assets and return on assets....................................................................................................VI‐4

Capital and investment ...........................................................................................................VI‐4

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

The industry in China..............................................................................................................VII‐3

Background.........................................................................................................................VII‐3

Operations on boltless steel shelving.................................................................................VII‐3

Alternative products...........................................................................................................VII‐7

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

U.S. importers’ outstanding orders........................................................................................VII‐8

Antidumping or countervailing duty orders in third‐country markets..................................VII‐8

Information on nonsubject countries....................................................................................VII‐9

Appendixes

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

B. Calendar of the public staff conference ........................................................................... B‐1

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

D. Quarterly domestic price and import cost data................................................................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.

1 

UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation Nos. 701‐TA‐523 and 731‐TA‐1259 (Preliminary)

BOLTLESS STEEL SHELVING UNITS PREPACKAGED FOR SALE FROM CHINA

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 China of boltless steel shelving units prepackaged for sale (“boltless steel

shelving”), provided for in subheadings 9403.10.00 and 9403.20.00 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 Government of China.

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.

   

 

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

(19 CFR § 207.2(f)).
2 

BACKGROUND

On August 26, 2014, petitions were filed with the Commission and Commerce by Edsal

Manufacturing Co., Inc., Chicago, Illinois, alleging that an industry in the United States is

materially injured or threatened with material injury by reason of LTFV and subsidized imports

of boltless steel shelving from China. Accordingly, effective August 26, 2014, the Commission

instituted countervailing duty investigation No. 701‐TA‐523 and antidumping duty investigation

No. 731‐TA‐1259 (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 September 2, 2014 (79 FR 52040). The conference was held in

Washington, DC, on September 16, 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 boltless steel shelving units prepackaged for sale (“boltless steel shelving”) from

China that are allegedly sold in the United States at less than fair value and subsidized by the

Government of China.

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

On August 26, 2014, Edsal Manufacturing Co. Inc. (“Edsal”), the largest U.S. boltless steel

shelving producer, filed antidumping and countervailing duty petitions regarding imports of this

product from China.3  In addition to Edsal,4 several respondent entities participated in these

investigations, including several importers of subject merchandise (Whalen LLC (“Whalen”),

                                                      

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 reason of the

allegedly unfairly traded imports. 2 American Lamb, 785 F.2d at 1001; see also Texas Crushed Stone Co. v. United States, 35 F.3d

1535, 1543 (Fed. Cir. 1994).

3 The other firms producing boltless steel shelving in the United States are Hallowell a k a List

Industries Inc. (“Hallowell”), Hirsh Industries LLC (“Hirsh”), and Tennsco Corp. (“Tennsco”).  Confidential

Report, Memorandum INV‐MM‐098 (Oct. 3, 2014), as amended by Memorandum INV‐MM‐099 (Oct. 7,

2014) (“CR”) at III‐1; Public Report, Boltless Steel Shelving Units Prepackaged for Sale from China, Inv.

Nos. 701‐TA‐523 and 731‐TA‐1259 (Preliminary), USITC Pub. 4495 (Oct. 2014) (“PR”) at III‐1; Petitions,

Vol. I at 2‐3. 4 Edsal appeared at the conference and submitted a postconference brief.
4

W.W. Grainger, Inc. and Grainger International, Inc. (collectively “Grainger”), Sears Holding

Management Corp., and Whirlpool Corp.); subject foreign producer/exporter Guangdong

Guanyu Metal Products Co. Ltd. (“GGMPC”); and subject importer/exporter Meridian

International Co., Ltd.5

III. Domestic Like Product

A. Background

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.”6

  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.”7

  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.”8

  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 “most similar in characteristics and

uses” on a case‐by‐case basis.9  No single factor is dispositive, and the Commission may

consider other factors it deems relevant based on the facts of a particular investigation.10  The

Commission looks for clear dividing lines among possible like products and disregards minor

                                                      

5 Each of these respondents entered an appearance and became subject to the administrative

protective order.  Whalen participated in the conference and submitted a postconference brief, and

GGMPC submitted a written statement.

6 19 U.S.C. § 1677(4)(A). 7 19 U.S.C. § 1677(10).

8 19 U.S.C. § 1677(4)(A).

9 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).

10 See, e.g., S. Rep. No. 96‐249 at 90‐91 (1979).
5

variations.11  Although the Commission must accept Commerce’s determination as to the scope

of the subsidized and/or dumped imported merchandise,12 the Commission determines what

domestic product is like the imported articles Commerce has identified.13

In its notices of initiation, Commerce defined the imported merchandise within the

scope of these investigations as follows:

Boltless steel shelving units prepackaged for sale, with or without decks

(“boltless steel shelving”).  The term “prepackaged for sale” means that, at a

minimum, the steel vertical supports (i.e., uprights and posts) and steel

horizontal supports (i.e., beams, braces) necessary to assemble a completed

shelving unit (with or without decks) are packaged together for ultimate

purchase by the end user.  The scope also includes add‐on kits.  Add‐on kits

include, but are not limited to, kits that allow the end user to add an extension

shelving unit onto an existing boltless steel shelving unit such that the extension

and the original unit will share common frame elements (e.g., two posts).  The

term “boltless” refers to steel shelving in which the vertical and horizontal

supports forming the frame are assembled primarily without the use of nuts and

bolts or screws.  The vertical and horizontal support members for boltless steel

shelving are assembled by methods such as, but not limited to, fitting a rivet,

punched or cut tab or other similar connector on one support into a hole, slot or

similar receptacle on another support.  The supports lock together to form the

frame for the shelving unit, and provide the structural integrity of the shelving

unit separate from the inclusion of any decking.  The incidental use of nuts and

bolts or screws to add accessories, wall anchors, tie‐bars or shelf supports does

not remove the product from the scope.  Boltless steel shelving units may also

                                                      

11 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.”). 12 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).

13 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

come packaged as partially assembled, such as when two upright supports are

welded together with front‐to‐back supports, or are otherwise connected, to

form an end unit for the frame.  The boltless steel shelving covered by these

investigations may be commonly described as rivet shelving, welded frame

shelving, slot and tab shelving, and punched rivet (quasi‐rivet) shelving as well as

by other trade names.  The term “deck” refers to the shelf that sits on or fits into

the horizontal supports (beams or braces) to provide the horizontal storage

surface of the shelving unit.

The scope includes all boltless steel shelving meeting the description

above, regardless of (1) vertical support or post type (including but not limited to

open post, close post and tubing); (2) horizontal support or beam/brace profile

(including but not limited to Z‐beam, C‐beam, L‐beam, step beam, and cargo

rack); (3) number of supports; (4) surface coating (including but not limited to

paint, epoxy, powder coating, zinc and other metallic coating); (5) number of

levels; (6) weight capacity; (7) shape (including but not limited to rectangular,

square, and corner units); (8) decking material (including but not limited to wire

decking, particle board, laminated board or no deck at all); or (9) the boltless

method by which vertical and horizontal supports connect (including but not

limited to keyhole and rivet, slot and tab, welded frame, punched rivet and

clip).14

Pre‐packaged boltless steel shelving is a product that consumers assemble quickly and

easily without using tools.  Boltless steel shelving provides a sturdy (typically riveted or welded)

frame for functional, non‐aesthetic storage in garages, basements, and similar locations.15

                                                      

14 Commerce specifically excluded several products from the scope of these investigations:  

(1) wall‐mounted shelving, defined as shelving that is hung on the wall and does not stand on, or

transfer load to, the floor (but the addition of a wall bracket or other device to attach otherwise

freestanding subject merchandise to a wall does not meet the terms of this exclusion); (2) wire shelving

units, which consist of shelves made from wire that incorporates both a wire deck and wire horizontal

supports (taking the place of the horizontal beams and braces) into a single piece with tubular collars

that slide over the posts and onto plastic sleeves snapped on the posts to create the finished shelving

unit; (3) bulk‐packed parts or components of boltless steel shelving units; and (4) made‐to‐order

shelving systems.  Subject boltless steel shelving enters the United States through Harmonized Tariff

Schedule of the United States (“HTSUS”) statistical reporting numbers 9403.20.0018 and 9403.20.0020,

but may also enter through HTSUS 9403.10.0040.  Although it identified these HTSUS reporting numbers

for convenience and Customs purposes, Commerce noted that the written scope of the investigations is

dispositive.  79 Fed. Reg. 56562, 56567 (Sept. 22, 2014) (initiation of antidumping duty investigation);

79 Fed. Reg. 56567, 56570‐71 (Sept. 22, 2014) (initiation of countervailing duty investigation).

15 CR at I‐10 to I‐15; PR at I‐8 to I‐11.
7

The parties disagree on how to define the domestic like product.  Edsal proposes a

definition encompassing what it describes as the continuum of boltless steel shelving in

prepackaged units that corresponds to the scope.16  Whalen did not initially disagree,17 but it

ultimately asked the Commission to define the domestic like product as boltless steel shelving

with a capacity above “approximately 500 pounds per shelf.”18

B. Analysis and Conclusion

As previously stated, 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.”19  As also indicated above, the Commission accepts Commerce’s definition

of the scope of the investigation, i.e., the articles under investigation,20 and the Commission

defines the domestic like product by determining what U.S. products are “like” the imported

articles included in Commerce’s scope.21  In this case, the imported articles under investigation

include boltless steel shelving meeting the scope description “regardless of ... (6) weight

                                                      

16 Edsal argues that all boltless steel shelving is perceived to be the same, even though it is

produced in a range of features and sold for a range of prices, because all share the same general

physical characteristics and uses, having been produced in the same facilities using similar production

processes.  It argues that resin, wire, and wood shelving and shelving components are generally made by

different firms and distributed in different channels for different uses because their different physical

characteristics limit their interchangeability for use as consumer‐friendly, easy‐to‐assemble, functional,

storage.  Petitioner’s Postconf. Brief at 5‐11, Exhibit 1 at 2‐3; Confer. Tr. at 13‐18 (Liss), 29‐31 (Cannon). 17 During the conference, Whalen initially did not have “any quarrel with the definition of the

domestic like product,” asserting that boltless steel shelving does not encompass wire or resin shelving

products that do not support high per‐shelf capacities.  Confer. Tr. at 99‐100 (Herlach, Whalen).  

Subsequently, Whalen differentiated between low‐ and high‐capacity boltless steel shelving and argued

that the domestic like product should not include the former since it is not imported from China.  When

pressed for a definition, Whalen reported that low‐capacity shelving included resin and wire shelving

and shelving with bolts, id. at 107‐22 (Whalen), none of which is within the scope.

18 In support of its proposed definition of the domestic like product, Whalen argues that it is not

cost‐effective to import low‐capacity commoditized boltless steel shelving into what it characterizes as

the low‐margin U.S. market, so the domestic like product should not include items for which there is no

import competition.  It also argues that customers do not perceive 300‐ and 2,000‐pound boltless steel

shelving as interchangeable, but it does not address any of the other domestic like product factors.  

Whalen’s Postconference Brief at 3‐5.

19 19 U.S.C. § 1677(10); see, e.g., Cleo, 501 F.3d at 1299; NEC, 36 F. Supp. 2d at 383; Nippon,

19 CIT at 455; Timken, 913 F. Supp. at 584; Torrington, 747 F. Supp. at 748‐49; see also S. Rep. No. 249,

96th Cong., 1st Sess. 90‐91 (1979).

20 E.g., Hosiden, 85 F.3d at 1567‐69. 21 See Torrington, 747 F. Supp. at 749; Cleo, 30 CIT at 1383‐89.
8

capacity, ... .”22  Thus, there is no legal basis for the Commission to exclude from the domestic

like product boltless steel shelving with a capacity of less than 500 pounds by defining the

domestic like product as only high‐capacity boltless steel shelving, even if there are no subject

imports of low‐capacity boltless steel shelving, a point on which the record is inconclusive.23

No party advocates defining the domestic like product more broadly than the scope to

include other forms of shelving, and, as indicated below, the record does not support such a

finding.  Even though Whalen did not squarely ask the Commission to consider whether to

define two domestic like products (low‐ and high‐capacity boltless steel shelving corresponding

to the scope), we also analyze that issue. Based on the record, we define the domestic like

product as boltless steel shelving corresponding to the investigations’ scope.  As the

Commission has previously found in investigations where the scope includes various similar

products, a lack of interchangeability between specific products is not inconsistent with finding

a single domestic like product.24

Physical Characteristics and Uses.  All boltless steel shelving units prepackaged for sale

consist of three basic components:  vertical posts with pre‐made holes or slots; horizontal

beams or braces that fit into built‐in receptacles in the posts without nuts, bolts, or screws to

form a strong, stable steel frame; and flat‐surfaced “decking” that sits on the beams.25  The

majority of boltless steel shelving falls within several common sizes that vary by depth, width,

number of decks, and capacity.26  Other features depend on the characteristics of the posts

                                                      

22 79 Fed. Reg. at 56567, 56570‐71.

23 For example, the pricing products in the preliminary phase of these investigations do not

cleanly cover Whalen’s proposed definition of low‐capacity boltless steel shelving, but the reported data

indicate that there are imports from China of products whose capacity ranges of 250 to 1,000 pounds

per level overlap with what Whalen considers low‐capacity boltless steel shelving.  See, e.g., CR/PR at

Tables V‐5 to V‐7 (pricing products 3, 4, and 5).

24 See, e.g., Certain Seamless Carbon and Alloy Steel Standard, Line, and Pressure Pipe from

China, Inv. Nos. 701‐TA‐469 and 731‐TA‐1168 (Final), USITC Pub. 4190 at 8 n.45 (Nov. 2010); Certain Off‐

the‐Road Tires from China, Inv. Nos. 701‐TA‐448 and 731‐TA‐1117 (Final), USITC Pub. 4031 at 9 (Aug.

2008); Citric Acid and Certain Citrate Salts from Canada and China, Inv. Nos. 701‐TA‐456 and

731‐TA‐1151 to 1152 (Preliminary), USITC Pub. 4008 at 11 (June 2008); Carbon and Certain Alloy Steel

Wire Rod from China, Germany, and Turkey, Inv. Nos. 731‐TA‐1099‐1101 (Preliminary), USITC Pub. 3832

at 10 (Jan. 2006); Outboard Engines from Japan, Inv. No. 731‐TA‐1069 (Preliminary), USITC Pub. 3673 at

8 n.40 (Mar. 2004).

25 CR at I‐17; PR at I‐13; Petitioner’s Postconf. Brief at 6‐7; Confer. Tr. at 13‐15 (Liss) ; Petitions,

Vol. I at 4‐6.

26 CR at I‐13 (noting a weight capacity per shelf range of hundreds of pounds to over 1,000

pounds), I‐17 to I‐18; PR at I‐10, I‐13; Petitioner’s Postconf. Brief at 8, 11, Exhibit 5 (list of common

shelving size and deck level combinations); Confer. Tr. at 16‐17, 77‐78 (Liss).
9

(steel gauge, profile, hole/slot type and number, coating, finish), beams (steel gauge, profile,

coating/finish), and decking (e.g., particle board, laminated particle board, or wire decking).27

All forms of boltless steel shelving are convenient, easy‐to‐assemble, consumer

products that are constructed from steel and intended for functional, non‐aesthetic storage in

garages and basements, whereas wood shelving is used to display items in living rooms,

kitchens, or commercial display areas.  Wood, resin, and wire shelving tend to have lower

shelving capacities and are typically smaller in size than boltless steel shelving, which is

designed to hold hundreds or even over 1,000 pounds per level.28

Manufacturing Facilities, Production Processes and Employees.  Edsal produces all

varieties of boltless steel shelving using the same equipment, employees, and six basic

manufacturing processes.29  Edsal does not use boltless steel shelving manufacturing

equipment to produce shelving components that are sold to distributors for use in large‐scale

custom projects, because those components require different steel thicknesses and profiles.30  

Edsal does not manufacture any other types of shelving.  ***.31

Channels of Distribution.  All varieties of boltless steel shelving are prepackaged as a kit

and sold to big box stores, home improvement stores, club retailers, department stores, office

supply stores, and online retailers for ultimate use by consumers.32  Other types of steel

shelving components are sold as bulk product in hundreds of sizes and configurations, generally

to industrial purchasers through distributors in the material handling industry (rather than at

retail); such steel shelving is not prepackaged in single unit kits but instead is shipped on large

pallets and assembled as part of a made‐to‐order commercial or industrial package that

includes design, engineering, and installation services.33

Interchangeability.  For boltless steel shelving, the necessary pieces come packaged

together in a single kit; boltless steel shelving is not interchangeable with made‐to‐order

shelving systems for which customers purchase the pieces tailored for their specific project.34  

                                                      

27 CR at I‐10 to I‐13, I‐17 to I‐18; PR at I‐8 to I‐10, I‐13; Confer. Tr. at 13‐15 (Liss), 41 (Liss) (noting

that L‐shaped posts comprise the majority of the market).  The two most common types of boltless steel

shelving are rivet shelving where the beams fit through the sides and welded frame shelving where the

beam slides into a welded upright.  Confer. Tr. at 15 (Liss).

28 CR at I‐13 to I‐14, I‐18; PR at I‐10, I‐13; Petitioner’s Postconf. Brief at 7; Confer. Tr. at 15 (Liss),

17‐18 (Liss), 30 (Cannon), 76 (Liss).  Boltless steel shelving is usually stationary, whereas casters typically

provide mobility to wire shelving.  CR at I‐18; PR at I‐13; Confer Tr. at 30 (Cannon).

29 CR at I‐14 to I‐15, I‐18; PR at I‐10 to I‐11, I‐13; Petitioner’s Postconf. Brief at 10.

30 CR at I‐18 to I‐19; PR at I‐13 to I‐14; Petitioner’s Postconf. Brief at 10.

31 CR at III‐8; PR at III‐4; CR/PR at Table III‐4 (production of (***) represented *** percent of

overall facility production in 2013); Petitioner’s Postconf. Brief at 10; Confer. Tr. at 17, 31 (Liss).

32 CR at I‐18, I‐21; PR at I‐10, I‐15; Confer. Tr. at 17 (Liss).

33 CR at I‐21; PR at I‐15; Petitioner’s Postconf. Brief at 9‐10; Confer. Tr. at 17, 39‐40 (Liss).

34 CR at I‐19 to I‐22; PR at I‐14 to I‐15; Petitioner’s Postconf. Brief at 8‐9; Confer. Tr. at 15‐16

(Liss), 31 (Cannon).
10

Boltless steel shelving, which is designed to be user‐friendly, requires no tools, bolts, or screws

and can be quickly assembled by the ultimate consumer, so it is not interchangeable with

shelving that requires screws, bolts, nuts, and tools for assembly.35  Twelve of seventeen

responding importers reported that there are no substitutes for boltless steel shelving.36

Producer and Customer Perceptions.  Edsal argues that domestic producers and

customers perceive boltless steel shelving as a convenient and sturdy consumer product that

differs from made‐to‐order shelving, commercial or industrial shelving sold in pieces, resin,

wire, or wood shelving, or shelving that requires tools, nuts, and bolts to assemble.  It argues

that most market participants reported no substitutes for boltless steel shelving.37  The record

indicates retailers display other shelving products in furniture (wood shelving) or building

materials departments (shelving components) instead of in home organization or hardware

departments, where they display boltless steel shelving.38

Price.  The price of boltless steel shelving falls within a range depending on the product’s

features and size.  Plastic or resin shelving is typically lower priced than boltless steel shelving,

whereas wooden shelving is generally more expensive.  A large volume of wire shelving is also

lower priced than boltless steel shelving, but certain prepackaged heavy chrome wire shelving

might be priced similarly to boltless steel shelving.39

Conclusion.  Differences in physical characteristics (including ease of assembly,

functional appearance, and higher deck capacity) limit the interchangeability of boltless steel

shelving with other types of shelving.  Some of the other types of shelving are sold in different

channels of distribution (distributors) than boltless steel shelving (retailers).  Responding

producers and importers generally reported that boltless steel shelving differs from other forms

of shelving.  Edsal, *** the largest U.S. boltless steel shelving producer, uses different

machinery to produce shelving components sold for material handling applications, although

***.  Boltless steel shelving is generally priced higher than resin shelving and lower than wood

shelving, but may overlap with limited higher priced wire shelving.  For these reasons, we find a

clear dividing line between boltless steel shelving and other forms of shelving.

By contrast, we do not find a clear dividing line between what Whalen refers to as low‐ 

and high‐capacity boltless steel shelving, a division that it concedes is not supported by any

industry definition.40  All boltless steel shelving products share similar physical characteristics

because all are manufactured using similar production facilities, processes, and employees.  

                                                      

35 CR at I‐19 to I‐22; PR at I‐14 to I‐15; Petitioner’s Postconf. Brief at 8‐9; Confer. Tr. at 15‐16

(Liss), 31 (Cannon).

36 CR at I‐20; PR at I‐14; Petitioner’s Postconf. Brief at 9.

37 CR at I‐20 to I‐21; PR at I‐14 to I‐15; Petitioner’s Postconf. Brief at 9‐10; Confer. Tr. at 15‐16

(Liss), 31 (Cannon).

38 CR at I‐21; PR at I‐15; Confer. Tr. at 31 (Cannon), 72‐73 (Liss).

39 CR at I‐22; PR at I‐15; Petitioner’s Postconf. Brief at 11; Confer. Tr. at 40‐41 (Cannon, Liss).

40 Whalen’s Postconference Brief at 4.
11

Even though customers may not perceive all boltless steel shelving products to be completely

interchangeable, particularly those with dramatically different capacity, all boltless steel

shelving is used for convenient, easy‐to‐assemble, functional, and non‐aesthetic storage in

locations like garages and basements, and is priced accordingly.

Therefore, we define the domestic like product as encompassing those boltless steel

shelving products described in the scope definition.

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.”41  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.  Four firms produce boltless steel shelving in the United States:  

Edsal, Hallowell, Hirsh, and Tennsco.42

These investigations raise one domestic industry issue – whether appropriate

circumstances exist to exclude a producer 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 or which are themselves importers.43  Exclusion of such a

producer is within the Commission’s discretion based upon the facts presented in each

investigation.44

                                                      

41 19 U.S.C. § 1677(4)(A).

42 CR at III‐1; PR at III‐1; Petitions, Vol. I at 2‐3.

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

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). 44 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‐à‐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, 790 F. Supp. at 1168.
12

Petitioner Edsal, which began producing boltless steel shelving in 1985, accounted for

the overwhelming share (*** percent) of U.S. production in 2013.45  About a decade ago, Edsal

established a *** boltless steel shelving production facility in China (Edsal Sandusky Corp.

Zhongshan or “Edsal Sandusky”), primarily to serve anticipated demand in China, which

apparently never materialized.46  Edsal and Whalen dispute the motivation behind Edsal’s

growing and sizable importing activities.47  They agree that Edsal qualifies as a related party as

an importer of subject merchandise with ownership interest in a producer of subject

merchandise in China, but they disagree whether it is appropriate to exclude Edsal from the

domestic industry.48

Edsal ***.49  ***.50  During the January 2011‐June 2014 period of investigation (“POI”),

Edsal’s direct imports of subject merchandise from Edsal Sandusky rose both absolutely and

relative to its U.S. production.51  The imports that Edsal arranged for *** also progressively rose

over the POI.52  As a ratio to its U.S. production, Edsal’s direct imports were *** increasing from

*** percent in 2011 to *** percent in 2013, and they were higher in interim 2014 (*** percent)

                                                      

45 CR at III‐2; PR at III‐1; CR/PR at Table III‐1.

46 CR at III‐2; PR at III‐1; Confer. Tr. at 19‐21 (Liss). 47 Edsal argues that it has been forced to import limited volumes of subject merchandise as a

defensive measure since *** to remain competitive with other low‐priced imports from China and to

preserve business relationships with U.S. purchasers demanding competitive prices.  Edsal maintains its

imports in a separate inventory, clearly labeling them as “made in China.”  CR at III‐3; PR at III‐2;

Petitioner’s Postconf. Brief at 13, Exhibit 1 at 6; Confer. Tr. at 19‐21, 46, 68 (Liss), 74‐75 (Rosenthal).  

Whalen asserts that Edsal made a “calculated decision” to benefit financially from imports, given that

Edsal opened its factory in China “approximately six years before Petitioner claims Chinese imports

began injuring the domestic market.”  Whalen’s Postconf. Brief at 2, 6‐10.

48 Edsal asserts that its imports are limited, its interests lie in domestic production, it only

imported as a defensive measure, ***, and its exclusion would substantially skew the domestic

industry’s data.  Petitioner’s Postconf. Brief at 12‐13, Exhibit 1 at 3; Confer. Tr. at 19‐21, 46, 68 (Liss), 74‐

75 (Rosenthal).  Whalen argues against placing undue weight on the risk of skewing the domestic

industry data by excluding Edsal.  It argues that Edsal has accrued a “substantial interest” ***.  Whalen

also claims that Edsal directs its imports to avoid competing with its U.S. operations.  Whalen’s Postconf.

Brief at 2, 6‐10.

49 CR at III‐13; PR at III‐5; CR/PR at Table III‐7; Petitioner’s Postconf. Brief at Exhibit 1 at 3, 5

(***); Confer. Tr. at 46‐48 (Liss).

50 CR at III‐13; PR at III‐5; CR/PR at Table III‐7.

51 Edsal’s direct imports were *** units in 2011, *** units in 2013, *** units in the first six

months of 2013 (“interim 2013”) and *** units in the first six months of 2014 (“interim 2014”),

compared to U.S. production of *** units in 2011, *** units in 2013, *** units in interim 2013, and ***

units in interim 2014.  CR/PR at Table III‐7.

52 Edsal’s arranged imports of boltless steel shelving *** were *** units in 2011, *** units in

2013, *** units in interim 2013, and *** units in interim 2014.  CR/PR at Table III‐7 & n.2.
13

than in interim 2013 (*** percent).53  When combined with its arranged imports, Edsal’s

increasing import activities are ***; at the same time, Edsal’s domestic production is *** than

the sum of its direct and arranged imports.54  Moreover, Edsal is the petitioning firm, and its

U.S. operations experienced *** financial performance over the POI.55 56  Additionally, the

Commission does not ordinarily exclude a producer that accounts for the vast majority of U.S.

production as a related party because such an exclusion would result in a skewed depiction of

the domestic industry.57  Accordingly, we find that appropriate circumstances do not exist to

exclude Edsal from the domestic industry as a related party.  We define the domestic industry

as all U.S. producers of the domestic like product.58   

V. Reasonable Indication of Material Injury by Reason of Subject Imports59

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

                                                      

53 CR/PR at Table III‐7.

54 As a share of domestic production, Edsal’s direct and arranged imports of subject

merchandise represented *** percent in 2011, *** percent in 2013, *** percent in interim 2013, and

*** percent in interim 2014.  CR/PR at Table III‐7. 55 Edsal’s operating income as a ratio to net sales ***.  CR/PR at Table VI‐2.

56 Vice Chairman Pinkert does not rely upon Edsal’s financial performance as a factor in

determining whether there are appropriate circumstances to exclude Edsal from the domestic industry,

as it is unclear the extent to which Edsal has derived a specific financial benefit from its status as a

related party.  See Allied Mineral Products v. United States, 28 CIT 1861, 1865‐67 (2004).  He encourages

parties to comment on this issue in any final phase of these investigations. 57 See, e.g., Certain Activated Carbon from China, Inv. No. 731‐TA‐1103 (Review), USITC Pub.

4381 at 7 n.22 (Feb. 2013); Narrow Woven Ribbons with Woven Selvedge from China and Taiwan, Inv.

Nos. 701‐TA‐467 and 731‐TA‐1164 to 1165 (Final), USITC Pub. 4180 at 9‐10, 21 (Aug. 2010).   58 U.S. industry data are based on questionnaire responses of four firms that accounted for all

U.S. boltless steel shelving production in 2013.  CR at I‐5, III‐1; PR at I‐3, III‐1.

59 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.  19 U.S.C. §§ 1671b(a), 1673b(a),

1677(24)(A)(i), 1677(24)(B).  Subject imports from China accounted for *** (*** percent) U.S. imports of

boltless steel shelving, by quantity, from July 1, 2013 to June 30, 2014, the most recent twelve‐month

period prior to the filing of the petitions for which data are available.  Derived from CR/PR at Table IV‐2.  

Thus, we find that subject imports from China are not negligible.
14

investigation.60  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.61  The statute defines “material injury” as “harm which is not inconsequential,

immaterial, or unimportant.”62  In assessing whether there is a reasonable indication that the

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

economic factors that bear on the state of the industry in the United States.63  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.”64

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,65 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.66  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.67

                                                      

60 19 U.S.C. §§ 1671b(a), 1673b(a).

61 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).

62 19 U.S.C. § 1677(7)(A).

63 19 U.S.C. § 1677(7)(C)(iii).

64 19 U.S.C. § 1677(7)(C)(iii).

65 19 U.S.C. §§ 1671b(a), 1673b(a).

66 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).

67 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).
15

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.68  In performing its examination, however, the Commission need not isolate

the injury caused by other factors from injury caused by unfairly traded imports.69  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.70  It is clear

                                                      

68 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

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, 542 F.3d at 877.

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

injury caused by unfair imports.”); Taiwan Semiconductor, 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.”).

70 S. Rep. 96‐249 at 74‐75; H.R. Rep. 96‐317 at 47.
16

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

determination.71

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.”72 73  Indeed, the Federal Circuit has examined and affirmed various

Commission methodologies and has disavowed “rigid adherence to a specific formula.”74

The Federal Circuit’s decisions in Gerald Metals, Bratsk, and Mittal 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.75  The additional “replacement/benefit” test

                                                      

71 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.”).

72 Mittal, 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.   73 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, held that the Commission is

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

kind of analysis of nonsubject imports, albeit without reliance upon presumptions or rigid formulas.  

Mittal explains as follows:

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

traded, price competitive, nonsubject 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 nonsubject 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.    74 Nucor Corp. v. United States, 414 F.3d 1331, 1336, 1341 (Fed. Cir. 2005); see also Mittal, 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.”). 75 Mittal, 542 F.3d at 875‐79.
17

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 litigation.

Mittal 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.76  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 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.77

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.78  Congress has delegated this factual finding to the Commission because of

the agency’s institutional expertise in resolving injury issues.79

                                                      

76 Mittal, 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). 77 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

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.

78 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.

79 Mittal, 542 F.3d at 873; Nippon, 458 F.3d at 1350, citing U.S. Steel, 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.”).
18

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

Boltless steel shelving is a final good that is sold prepackaged in a kit, ready for assembly

and installation by the consumer for storage use in basements, garages, and similar locations.80  

Most U.S. producers and importers reported that there are no substitutes for boltless steel

shelving, particularly given its boltless design and high‐load capacity.81  As an end‐use good,

boltless steel shelving is likely to experience moderate to large changes in quantity demanded

in response to changes in price.82

During the conference, Edsal and Whalen disputed whether U.S. demand for boltless

steel shelving is increasing or decreasing.83  Questionnaire respondents also disagreed about

demand trends during the POI.84  Based on the record, demand, as measured by apparent U.S.

consumption of boltless steel shelving, increased each year between 2011 and 2013, and was

lower in interim 2014 than in interim 2013.85

                                                      

80 CR at II‐8; PR at II‐5.

81 CR at II‐10; PR at II‐6 to II‐7 (noting that the few questionnaire respondents identifying

possible substitutes for boltless steel shelving referred to wire, plastic, resin, or bolted steel shelving;

shelving sold as components; and bulk‐packaged boltless steel shelving).

82 CR at II‐8; PR at II‐5.

83 Edsal argues that U.S. demand for boltless steel shelving is strong and increasing.  Petitioner’s

Postconf. Brief at 13‐14; Confer. Tr. at 18‐19 (Liss).  Whalen argues that U.S. boltless steel shelving

demand is declining.  It maintains that heavy discounting and promotions that began for boltless steel

shelving about three years ago initially resulted in higher sales but the regularity of the promotions has

led to “customer fatigue” and lower volumes in recent periods.  Whalen’s Postconf. Brief at 2, 17‐18;

Confer. Tr. at 93‐94 (Whalen).

84 CR/PR at Table II‐3; CR at II‐9; PR at II‐6 (noting that one U.S. producer reported increasing

demand, one reported decreasing demand, and two reported fluctuating demand and that nearly half of

responding importers (***) reported no change in U.S. demand for boltless steel shelving).

85 Apparent U.S. consumption of boltless steel shelving was *** units in 2011, *** units in 2012,

*** units in 2013, *** units in interim 2013, and *** units in interim 2014.  CR/PR at Table IV‐3, Table C‐

1.
19

2. Supply Conditions

During the POI, the U.S. market was supplied by the domestic industry, subject imports

from China, and imports from nonsubject countries.86

The domestic industry held the *** share of the U.S. market during the POI (between

*** and *** percent on an annual basis).87  As the largest U.S. producer of boltless steel

shelving, Edsal accounted for *** percent of domestic production in 2013.88  The domestic

industry progressively increased its boltless steel shelving production capacity, ***.89  The

domestic industry did not operate at full capacity at any point during the POI.90

Subject imports from China held the *** share of the U.S. market during the POI

(between *** and *** percent).91  The industry producing subject merchandise in China

includes approximately 32 boltless steel shelving producers.92  Of the 25 firms issued foreign

producer/exporter questionnaires, only four submitted responses (Edsal Sandusky;93 HoiFat

(Ningbo) Office Facilities Co., Ltd.; Intradin; and GGMPC).94  They reported combined exports to

the United States equivalent to *** percent of reported subject imports from China in 2013.95  

The responding Chinese boltless steel shelving producers reported increasing their collective

production capacity over the POI, the entry of new producer (GGMPC) at the end of the POI,

and increasing projected production capacity in 2014 and 2015.96  As the production capacity of

the responding producers in China expanded, their capacity utilization declined.97

As discussed above, Edsal imported subject merchandise from its affiliate Edsal

Sandusky in China ***, and it arranged for other importers of record to import additional

                                                      

86 CR/PR at Table IV‐3.

87 CR/PR at Table IV‐3, Table C‐1.

88 CR/PR at Table III‐1.

89 Derived from CR/PR at Table C‐1.

90 The domestic industry’s capacity utilization was *** percent in 2011, *** percent in 2012, ***

percent in 2013, *** percent in interim 2013, and *** percent in interim 2014.  CR/PR at Table III‐3.

91 CR/PR at Table IV‐3, Table C‐1.

92 CR at VII‐3; PR at VII‐3.

93 Whalen disputes Edsal’s ***.  Whalen’s Postconf. Brief at 1.  The record reflects that Edsal

Sandusky ***.  CR at VII‐10 to VII‐11; PR at VII‐6; CR/PR at Table VII‐3.

94 CR at VII‐4; PR at VII‐3.  According to Edsal, the five largest subject producers in China are ***.  

Petitions at Exhibit GEN‐2 at 5.  None of these firms submitted questionnaire responses in the

preliminary phase of these investigations.  CR at VII‐4; PR at VII‐3.    95 CR at VII‐4; PR at VII‐3.  In any final phase of these investigations, we encourage additional

foreign producers/exporters in China to submit data concerning their boltless steel shelving operations.

96 The United States represented the largest market for the responding subject producers

throughout the POI.  CR/PR at Table VII‐1; CR at VII‐3 to VII‐5, VII‐11; PR at VII‐3 to VII‐4, VII‐6.

97 CR/PR at Table VII‐1.
20

volumes of boltless steel shelving from China.  Collectively, these direct and arranged imports

accounted for a *** and increasing share of subject imports and apparent U.S. consumption.98

Nonsubject imports held the smallest share of the U.S. market during the POI (between

*** and *** percent).99  Edsal reports the existence of boltless steel shelving manufacturers in

Mexico, Canada, Poland, and Australia, but is unaware of any current U.S. imports of boltless

steel shelving from nonsubject countries; Whalen reports knowledge of boltless steel shelving

imports from Mexico that entered about a decade ago.100  *** reported importing a ***

volume of boltless steel shelving from *** during the POI.101

3. Substitutability and Sales Process

All U.S. producers and *** of *** responding U.S. importers reported that boltless steel

shelving manufactured in the United States is at least frequently interchangeable with boltless

steel shelving imported from China.102  The current record suggests a high degree of

substitutability between boltless steel shelving made in the United States and imported from

China.103   

Edsal and Whalen agree that price is the most important factor in U.S. boltless steel

shelving sales, although Whalen asserts that decking capacity and other factors are also

important.104  All U.S. producers reported that non‐price factors are “never” a significant

difference between boltless steel shelving sourced from the United States and China, whereas

U.S. importers of subject merchandise from China generally reported that there are

                                                      

98 Subject merchandise that Edsal imported directly or arranged for importation accounted for

*** percent of total imports from China in 2011, *** percent in 2012, *** percent in 2013, *** percent

in interim 2013, and *** percent in interim 2014.  CR/PR at Table IV‐4.  In terms of apparent U.S.

consumption, they were equivalent to *** percent of the U.S. market in 2011, *** percent in 2012, ***

percent in 2013, *** percent in interim 2013, and *** percent in interim 2014.  CR/PR at Table IV‐4.  We

intend to examine these transactions in any final phase of these investigations in order to analyze the

relationships at issue, Edsal’s reliance on them, and the impact of these imports on the U.S. market.

99 CR/PR at Table IV‐3, Table C‐1.

100 Petitioner’s Postconf. Brief at 14‐15, Exhibit 1 at 2; Confer. Tr. at 19, 43‐44 (Liss), 112

(Whalen).   

101 CR at IV‐6 & n.7; PR at IV‐3 & n.7.

102 *** U.S. producers reported that boltless steel shelving manufactured in the United States is

always interchangeable with boltless steel shelving imported from China, and *** reported they are

frequently interchangeable.  *** U.S. importers reported that boltless steel shelving manufactured in

the United States is always interchangeable with subject merchandise from China, and *** reported

they are frequently interchangeable.  CR/PR at Table II‐4.

103 CR at II‐11; PR at II‐7.

104 Petitioner’s Postconf. Brief at 15‐16, 39, Exhibit 16; Confer. Tr. at 26‐29 (Quick); Confer. Tr. at

115 (Whalen).
21

“sometimes” or “frequently” non‐price differences between the two.105  The domestic industry

and importers of subject merchandise from China reported selling boltless steel shelving to all

regions in the U.S. market,106 and both sources sold primarily to end users.107

The parties agreed that five big box store operators (Home Depot, Lowe’s, Menards,

Costco, and Sam’s Club/Walmart) accounted for a substantial share of the U.S. market during

the POI.  Edsal estimated that these big box store operators represented “roughly *** percent”

of its U.S. boltless steel shelving sales in 2013, and Whalen estimated that they accounted for

more than 80 percent of the U.S. market.108  Other purchasers include department stores,

office supply stores, and online retailers.109  According to Edsal, some purchasers have decided

to purchase boltless steel shelving directly from the U.S. or foreign factories instead of using an

intermediary.110  Whalen, however, asserts that some purchasers still use sales agents or other

intermediaries like Whalen that reduce purchasers’ compliance, regulatory, and reputational

risks by providing valuable services, such as ***.111  The parties disagree about the extent to

which purchasers use global sourcing teams that conduct line reviews in China for their boltless

steel shelving purchases for the U.S. market.112

U.S. producers and importers typically quote prices on a free on board (“F.O.B.”) basis;

some purchasers are large procurers of freight that make their own freight arrangements.113  

Boltless steel shelving sales usually involve short‐term contracts or spot sales.114  Half of U.S.

producers offer quantity and total volume discounts, while half of U.S. producers and the

majority of U.S. importers offer no discount.115  According to Edsal and Whalen, some retailers

offer periods of promotions or discounts to consumers and expect their suppliers to help offset

                                                      

105 CR/PR at Table II‐5.  Quality, product diversity, and logistical support were some of the most

frequently cited differences, with a number of importers noting that the subject merchandise from

China was superior with respect to these factors.  CR at II‐12 to II‐13, PR at II‐8 to II‐9.  In any final phase

of these investigations, we will seek additional information on whether non‐price factors affect

substitutability between subject imports and the domestic like product.

106 CR/PR at Table II‐2.

107 CR/PR at Table II‐1.

108 Whalen’s Postconf. Brief at 5‐6; Confer. Tr. at 11 (Herlach), 51 (Liss), 85, 109, 119‐22

(Whalen); Petitioner’s Postconf. Brief at 25, Exhibit 1 at 3.

109 CR at II‐1; PR at II‐1.  Responding U.S. importers included ***.  CR/PR at Table IV‐1.

110 Confer. Tr. at 25 (Quick). 111 Whalen’s Postconf. Brief at 10‐12; Confer. Tr. at 91 (Whalen). 112 Petitioner’s Postconf. Brief at 25, 30‐31, Exhibit 2, Exhibit 13; Confer. Tr. at 23 (Quick), 91‐92

(Whalen).  We intend to explore further the nature and extent of any direct importing practices in any

final phase of these investigations.

113 Confer. Tr. at 25 (Quick), 55 (Liss); CR at V‐2, V‐4; PR at V‐2, V‐3. 114 CR/PR at Table V‐2.

115 CR at V‐4; PR at V‐3.
22

these promotional and discounted periods, such as for “Black Friday” sales around

Thanksgiving.116

4. Raw Materials

Edsal procures the majority of its main raw material, hot‐rolled steel, within a 500‐mile

radius of its facility in Chicago, and it also obtains its wire and particle board decking materials

locally.  The firm does not enter into long‐term contracts for these raw materials.117  The price

for domestic hot‐rolled sheet generally declined over the POI.118  The domestic industry’s

reported cost of goods sold (“COGS”) increased during this period, primarily due to increased

raw material costs and changes in product mix.119

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.”120

Subject imports from China had a *** presence in the U.S. market during the POI, and

their absolute volume increased overall during this period.121  The volume of subject imports

from China was also *** relative to domestic production during the POI.122

                                                      

116 Confer. Tr. at 63 (Liss), 115 (Whalen) (agreeing that discounts are “an unfortunate part of the

business the way it has evolved.”); CR at V‐4; PR at V‐3. 117 Confer. Tr. at 69‐70 (Liss).

118 CR at V‐1; PR at V‐1; CR/PR at Figure V‐1.

119 For example, ***.  CR at VI‐4, VI‐8; PR at VI‐2; CR/PR at Table VI‐3.

120 19 U.S.C. § 1677(7)(C)(i). 121 The volume of subject imports was *** units in 2011, *** units in 2012, *** units in 2013,

*** units in interim 2013, and *** units in interim 2014.  CR/PR at Table IV‐3.  We note that official

import statistics greatly exaggerate the volume of U.S. imports because the relevant tariff statistical

reporting numbers correspond to basket categories that include a number of non‐boltless steel shelving

products.  CR at I‐9, IV‐2 n.5; PR at I‐7, IV‐2 n.5; Petitions, Vol. I at 9‐10; Petitioner’s Postconf. Brief at 3,

13, 17, Exhibit 1 at 1; Confer. Tr. at 35‐38 (Cannon).  Consequently, U.S. import data are based on

questionnaire responses of 17 firms that are believed to have accounted for the vast majority of U.S.

boltless steel shelving imports from China in 2013.  CR at I‐5, IV‐1 to IV‐2; PR at I‐4, IV‐1 to IV‐2.  Edsal’s

arguments concerning importer coverage, Petitioner’s Postconf. Brief at 1‐2, 20, do not reflect more

recent information obtained by staff.  See, e.g., CR at IV‐1 to IV‐2; PR at IV‐1. 122 The volume of subject imports was equivalent to *** percent of U.S. production in 2011, ***

percent in 2012, *** percent in 2013, *** percent in interim 2013, and *** percent in interim 2014.  

CR/PR at Table IV‐2.
23

Between 2011 and 2013, as apparent U.S. consumption rose *** percent, subject

imports from China maintained a substantial share of the U.S. market, which fluctuated on an

annual basis.123  The domestic industry’s market share fluctuated inversely with subject

imports’ market share.124   

We find for purposes of the preliminary phase of these investigations that the volume of

subject imports is significant both in absolute terms and relative to consumption and

production in the United States.  We observe that imports that Edsal imported or arranged

accounted for a substantial share of subject imports.125  We will explore this further in any final

phase investigations and invite the parties to brief the implications, if any, this fact should have

on our analysis of material injury by reason of subject imports.

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  

(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.126

As stated above, the current record suggests a high degree of substitutability between

subject imports from China and the domestic like product, and that price is an important

                                                      

123 Subject imports’ share of apparent U.S. consumption rose from *** percent in 2011 to ***

percent in 2012 and then declined to *** percent in 2013.  Their market share was higher in interim

2014 than in interim 2013.  It was *** percent in interim 2013, and *** percent in interim 2014.  CR/PR

at Table IV‐3, Table C‐1.

124 The domestic industry’s share of apparent U.S. consumption declined from *** percent in

2011 to *** percent in 2012 and then rose to *** percent in 2013.  It was *** percent in interim 2013

and *** percent in interim 2014.  By contrast, nonsubject imports’ market share remained small and

relatively stable, at *** percent in 2011 and 2012 and *** percent in 2013, interim 2013, and interim

2014.  CR/PR at Table IV‐3, Table C‐1.

125 By interim 2014, the volume of Edsal’s direct and arranged imports of subject merchandise

from China accounted for *** percent of total boltless steel shelving imports from China and ***

percent of apparent U.S. consumption.  CR/PR at Table IV‐4.

126 19 U.S.C. § 1677(7)(C)(ii).
24

consideration in purchasing decisions.127  Thus, competition in the U.S. market appears to

depend largely on price.

In the preliminary phase of these investigations, the Commission collected quarterly

weighted‐average sales price data for the POI for both U.S. and subject Chinese boltless steel

shelving, and it requested importers to provide quarterly purchase cost data for their imports

that were sold directly to retail customers.128  Three domestic producers and 13 importers

submitted data regarding five boltless steel shelving products.129  According to the pricing

comparisons, subject imports undersold the domestic like product in *** out of 68 possible

quarterly comparisons and oversold it in the remaining *** comparisons.130  Based on a

comparison of domestic prices to import costs, subject imports were lower in 26 of 69 instances

and higher in the remaining 43 instances.131  We cannot conclude based on the current record

that subject imports undersold the domestic like product to a significant degree.

                                                      

127 As also stated above, we will consider the issue of substitutability further in any final phase of

these investigations.

128 CR at V‐4; PR at V‐4.  The pricing data reported by domestic producers accounted for

approximately *** percent of the domestic industry’s U.S. shipments of boltless steel shelving during

the POI and *** percent of U.S. shipments of subject imports from China in the same period; the cost

data reported by importers accounted for *** percent of U.S. shipments of subject imports during the

POI.  CR at V‐5; PR at V‐4.

In their comments on the draft final phase questionnaires, we invite the parties to comment on

the utility and appropriate method of analysis of purchase cost data in these investigations, particularly

given Edsal’s request that we adjust any such data for freight and logistics and Whalen’s suggestion that

sales agents provide value‐added services to purchasers.  See, e.g., Petitioner’s Postconf. Brief at 24‐28,

Exhibit 1 at 4, Exhibit 13; Confer. Tr. at 31‐34 (Cannon), 55 (Liss), 91 (Whalen); Whalen’s Postconf. Brief

at 10‐12.

129 The pricing products include the following:  (1) 77” width x 24” depth x 72” to 78” height, 4‐

level rack with steel wire decking, with load capacity of 1,000 to 2,500 pounds per level; (2) 77” width x

24” depth x 72” height, 3‐level rack with steel wire decking, with load capacity of 1,000 to 2,500 pounds

per level; (3) 36” width x 18” depth x 72” height, 5‐level boltless/rivet steel shelving with particle board

deck, with load capacity of 250 to 1,000 pounds per level; (4) 48” width x 24” depth x 72” height, 5‐level

boltless/rivet steel shelving with particle board deck, with load capacity of 250 to 1,000 pounds per

level; and (5) 34” to 36” width x between 15” and 18” depth x 60” height, 4‐level boltless/rivet steel

shelving with particle board deck, with load capacity of 250 to 1,000 pounds per level.  CR at V‐5; PR at

V‐4.

130 Subject imports’ margins of underselling ranged from *** to *** percent during the POI.  

CR/PR at Table V‐9.

131 In those instances where import costs were lower than the reported price of the domestic

like product, the differential ranged from *** percent to *** percent.  Derived from CR/PR at Tables V‐3

to V‐7.  Some of the large margins observed may indicate differences in comparability between

domestic and imported products.  When reviewing the draft questionnaires in the final phase of these

investigations, we invite the parties to comment on how pricing products may be defined to ensure

(Continued...)
25

*** reported having to reduce prices or roll back announced price increases in response

to subject imports from China.132  The domestic industry alleged *** lost sales totaling $***

and involving *** units of boltless steel shelving, and it alleged *** instances of lost revenue

totaling $*** and involving *** units of boltless steel shelving.133  Purchasers either did not

answer, did not know, or disagreed with the alleged lost sales and lost revenue claims.134  

Nonetheless, *** purchasers (***) reported switching purchases from U.S. producers to

suppliers of boltless steel shelving from China, *** of them (***) reported that price was the

reason for the shift, and *** of them (***) reported that U.S. producers reduced their prices in

order to compete with prices of boltless steel shelving imported from China.135

With respect to whether subject imports depressed prices to a significant degree, we

considered changes in U.S. and subject import prices over the POI.  According to questionnaire

data, the domestic industry’s weighted‐average prices for all five pricing products decreased

overall between January 2011 and June 2014.136  Reported weighted‐average prices for three of

the pricing products imported from China (products 1, 4, and 5) also decreased overall during

the POI.137  Prices of boltless steel shelving from China declined more than domestic prices for

                                                                                                                                                                              

(...Continued)

comparability.  The parties may also wish to consider whether to modify the pricing products to address

what some questionnaire respondents reported were non‐price differences between the domestic like

product and boltless steel shelving imported from China.  CR at II‐13 at n.13; PR at II‐8 at n.13.

132 CR at V‐17; PR at V‐8.

133 CR at V‐17 to V‐18; PR at V‐8; CR/PR at Table V‐10, Table V‐11.  We note that some of the

information about lost sales/lost revenue allegations provided in the petitions and summarized in CR/PR

at Table V‐10 and Table V‐11 does not match the information Edsal included in its postconference brief

at Exhibit 2.  This latter material contained some new allegations and suggested that ***.

134 CR/PR at Table V‐10, Table V‐11.

135 CR/PR at Table V‐12.

136 The domestic industry’s price for product 1 decreased irregularly from $*** per unit in the

first quarter of 2011 to $*** per unit in the second quarter of 2014.  CR/PR at Table V‐3.  Its price for

product 2 decreased irregularly from $*** per unit in the first quarter of 2011 to $*** per unit in the

second quarter of 2014.  CR/PR at Table V‐4.  Its price for product 3 decreased irregularly from $*** per

unit in the first quarter to 2011 to $*** per unit in the second quarter of 2014.  CR/PR at Table V‐5.  Its

price for product 4 decreased irregularly from $*** per unit in the first quarter of 2011 to $*** per unit

in the second quarter of 2014.  CR/PR at Table V‐6.  Its price for product 5 decreased irregularly from

$*** per unit in the first quarter of 2011 to $*** in the second quarter of 2014.  CR/PR at Table V‐7.

137 The reported quarterly weighted‐average price for product 1 imported from China decreased

irregularly from $*** per unit in the first quarter of 2011 to $*** per unit in the second quarter of 2014.  

CR/PR at Table V‐3.  The quarterly weighted‐average price for product 4 imported from China decreased

irregularly from $*** per unit in the first quarter of 2011 to $*** per unit in the second quarter of 2014.  

CR/PR at Table V‐6.  The quarterly weighted‐average price for product 5 imported from China decreased

(Continued...)
26

two of these products (products 4 and 5).138  We intend to explore the reason for any price

declines in any final phase of these investigations.

We also examined whether subject imports prevented price increases, which would

have otherwise occurred, to a significant degree during the POI.  As discussed above, apparent

U.S. consumption increased *** percent from 2011 to 2013 and was *** percent lower in

interim 2014 than in interim 2013.139  During that time, the domestic industry’s average unit

net sales value fluctuated on an annual basis.  It was $*** in 2011, $*** in 2012, $*** in 2013,

$*** in interim 2013, and $*** in interim 2013.140  By comparison, the domestic industry’s unit

COGS rose irregularly during the POI.  Unit COGS was $*** in 2011, $*** in 2012, $*** in 2013,

$*** in interim 2013, and $*** in interim 2014.141  The domestic industry’s COGS as a ratio to

net sales increased steadily, and was *** percent in 2011, *** percent in 2012, *** percent in

2013, *** percent in interim 2013, and *** percent in interim 2014.142  Consequently, the

domestic industry was increasingly unable to price its boltless steel shelving at levels that

permitted it to cover its costs during a period of overall increasing apparent U.S.

consumption.143

Thus, the record shows that U.S. prices declined and that the domestic industry

experienced an increase in its COGS to net sales ratio.  In any final phase of these investigations,

we intend to explore further the role of subject imports as well as other market factors in both

of these trends.

                                                                                                                                                                              

(...Continued)

irregularly from $*** per unit in the first quarter of 2011 to $*** per unit in the second quarter of 2014.  

CR/PR at Table V‐7.

138 Quarterly weighted‐average U.S. prices for product 4 declined *** percent over the POI,

whereas quarterly weighted‐average prices for imports from China of product 4 declined *** percent

during this period.  Quarterly weighted‐average U.S. prices for product 5 declined *** percent over the

POI, whereas quarterly weighted‐average U.S. prices for imports from China of product 5 declined ***

percent during this period.  CR/PR at Table V‐8.

139 CR/PR at Table C‐1.

140 CR/PR at Table VI‐1, Table C‐1. 141 CR/PR at Table VI‐1, Table C‐1.

142 CR/PR at Table VI‐1, Table C‐1.

143 CR/PR at Table IV‐3, Table VI‐1, Table C‐1.  In any final phase of these investigations, we invite

the parties to discuss the role of *** in any cost‐price squeeze that the domestic industry experienced.  

CR at VI‐4; PR at VI‐1 to VI‐2.
27

E. Impact of the Subject Imports144

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

“within the context of the business cycle and conditions of competition that are distinctive to

the affected industry.”

During a period of overall increases in apparent U.S. consumption, the domestic

industry’s performance indicators were mixed.145  The domestic industry increased production

capacity throughout the POI.146  Its U.S. shipments, net sales, and production increased overall

during the POI.147  Employment‐related factors increased as well.148  The domestic industry’s

capacity utilization declined.149

The domestic industry’s financial performance deteriorated during the POI.  Sales

revenues increased from 2011 to 2013, and were *** lower in interim 2014 than in interim

                                                      

144 In its notice initiating the antidumping duty investigation of boltless steel shelving from

China, Commerce estimated antidumping duty margins of 40 to 211 percent.  79 Fed. Reg. 56562, 56565

(Sept. 22, 2014).   145 As discussed above, apparent U.S. consumption increased *** percent between 2011 and

2013.  CR/PR at Table IV‐3, Table C‐1.

146 Average production capacity was *** units in 2011, *** units in 2012, *** units in 2013, ***

units in interim 2013, and *** units in interim 2014. 147 The domestic industry’s U.S. shipments were *** units in 2011, *** units in 2012, *** units in

2013, *** units in interim 2013, and *** units in interim 2014.  Its net sales were *** units in 2011, ***

units in 2012, *** units in 2013, *** units in interim 2013, and *** units in interim 2014.  The domestic

industry’s production was *** units in 2011, *** units in 2012, *** units in 2013, *** units in interim

2013, and *** units in interim 2014.  Its inventories were *** during the POI.  CR/PR at Table III‐3, Table

III‐5, Table VI‐1, Table C‐1.

148 Production‐related workers, hours worked, wages and productivity increased over the POI.  

CR/PR at Table III‐3, Table III‐8, Table C‐1.  At the same time, Edsal reported that it had to shut down a

particular machine, lay off 150 workers, and reduce its remaining workers’ hours after losing a Black

Friday sale *** involving approximately $5 million of boltless steel shelving sales at the end of the POI.  

Petitioner’s Postconf. Brief at 34‐38; Confer. Tr. at 70‐71 (Liss).

149 The domestic industry’s capacity utilization was *** percent in 2011, *** percent in 2012,

*** percent in 2013, *** percent in interim 2013, and *** percent in interim 2014.  CR/PR at Table III‐3,

Table C‐1.
28

2013.150  The domestic industry’s ratio of COGS to net sales ratio rose throughout the POI,151

and its ratio of operating income to net sales declined.152  Operating income declined from

$*** in 2011 to $*** in 2012 and then to $*** in 2013.153  The decline in the domestic

industry’s operating income was the result of the increased unit costs outstripping the

increases in unit sales values, and we intend to explore the role of subject imports in these

trends in any final phase of these investigations.154

The POI was characterized by significant volumes of subject imports that were good

substitutes for the domestic like product.  Two significant purchasers also reported that

domestic producers reduced prices in the face of competition from subject imports from China.  

In light of these considerations and the record as a whole of the preliminary phase of these

investigations, we cannot find that the declines in the domestic industry’s financial

performance were unrelated to subject imports.

In reaching this conclusion, we have considered whether there are factors other than

subject imports from China that may have had an adverse impact on the domestic industry

during the POI to ensure that we are not attributing any injury from other such factors to the

subject imports.  As discussed above, apparent U.S. consumption generally increased during the

POI,155 and imports from nonsubject countries had a nominal and steady presence in the U.S.

market throughout this period.156 157  Therefore, neither demand conditions nor nonsubject

imports appear to explain the domestic industry’s deteriorating financial performance during

the POI.

                                                      

150 The domestic industry’s sales revenues increased from $*** in 2011 to $*** in 2012 and

$*** in 2013, and were $*** in interim 2013 and $*** in interim 2014.  CR/PR at Table VI‐1, Table C‐1.

151 The domestic industry’s COGS as a ratio to net sales increased steadily, and was *** percent

in 2011, *** percent in 2012, *** percent in 2013, *** percent in interim 2013, and *** percent in

interim 2014.  CR/PR at Table VI‐1, Table C‐1.

152 The domestic industry’s operating income margin declined from *** percent in 2011 to ***

percent in 2012 and *** percent in 2013, and it had an operating income margin of *** percent in

interim 2013 and an operating *** percent in interim 2014.  CR/PR at Table VI‐1, Table C‐1.

153 The domestic industry had operating income of $*** in interim 2013 and an operating loss of

$*** in interim 2014.  CR/PR at Table VI‐1, Table C‐1.  The domestic industry’s capital expenditures

declined from 2011 to 2013 and were lower in interim 2014 than in interim 2013.  CR/PR at Table VI‐5.  

It *** research and development expenses.  CR/PR at Table VI‐6.

154 CR/PR at Table VI‐4.

155 Apparent U.S. consumption of boltless steel shelving was *** units in 2011, *** units in 2012,

*** units in 2013, *** units in interim 2013, and *** units in interim 2014.  CR/PR at Table IV‐3, Table C‐

1.

156 Nonsubject imports’ market share was *** percent in 2011 and 2012 and *** percent in

2013, interim 2013, and interim 2014.  CR/PR at Table IV‐3.

157 Vice Chairman Pinkert does not undertake a Bratsk/Mittal Steel analysis in these

investigations as he does not find that nonsubject imports were a significant factor in the U.S. market.
29

As another potential source of any injury, Whalen points to Edsal’s aggressive pricing

behavior and Edsal’s own *** importing activities.158  As indicated above, we invite party

comments on this issue and we intend to revisit this issue in any final phase of these

investigations.   

Based on the  record as a whole in the preliminary phase of these investigations, we do

not find clear and convincing evidence that the domestic industry is not materially injured by

reason of subject imports or that there is no likelihood that evidence will arise in any final

phase of these investigations that will affect our resolution of this issue.  Accordingly, we have

made affirmative determinations in the preliminary phase of these investigations.

VI. 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 boltless steel

shelving from China that are allegedly sold in the United States at less than fair value and

subsidized by the Government of China.

                                                      

158 Whalen’s Postconf. Brief at 1‐3, 6, 16‐17; Confer. Tr. at 85‐90 (Whalen), 129 (Herlach).

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

Edsal Manufacturing Co., Inc. (“Edsal”), Chicago, Illinois, on August 26, 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 boltless steel shelving units

prepackaged for sale (“boltless steel shelving”)1 from China. The following tabulation provides

information relating to the background of these investigations.2 3  

Effective date Action 

August 26, 2014 

Petitions filed with Commerce and the Commission; institution of Commission 

investigations (79 FR 52040, September 2, 2014) 

September 16, 2014 Commission’s conference 

September 22, 2014 

Commerce’s notice of initiation of antidumping investigation (79 FR 56562, 

September 22, 2014) and countervailing duty investigation (79 FR 56567, 

September 22, 2014) 

October 10, 2014 Commission’s vote 

October 10, 2014 Commission’s determinations 

October 20, 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 app. B of this report.
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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
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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 subsidy

and dumping margins, 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

Boltless steel shelving is generally used for storage purposes in homes, garages, offices

and commercial and industrial operations. It is sold through “big box” stores, department

stores, home improvement stores, and other retail, industrial and commercial supply sources,

including on‐line vendors.4 Currently, four firms are known to produce boltless steel shelving in

the United States. The leading U.S. producer of boltless steel shelving is petitioner Edsal. The

five leading producers of boltless steel shelving in China include ***.5 The leading U.S.

importers of boltless steel shelving from China are ***, while the only identified importer of

boltless steel shelving from a nonsubject country was *** (importer of *** from ***).

Apparent U.S. consumption of boltless steel shelving totaled approximately *** units

($***) in 2013. U.S. producers’ U.S. shipments of boltless steel shelving totaled *** units ($***)

in 2013, and accounted for *** percent of apparent U.S. consumption by quantity and ***

percent by value. U.S. imports from China totaled *** units ($***) in 2013 and accounted for

*** percent of apparent U.S. consumption by quantity and *** percent by value. U.S. imports

from nonsubject sources (Vietnam) totaled *** units ($***) in 2013 and accounted for ***

percent of apparent U.S. consumption by quantity and *** percent by value.  

SUMMARY DATA AND DATA SOURCES

A summary of data collected in these investigations is presented in appendix C,  

table C‐1. U.S. industry data are based on questionnaire responses of four firms that accounted

for all U.S. production of boltless steel shelving during 2013. U.S. imports are based on

                                                      

4 Petitions, vol. I, p. 7. 5 Petitions, exh. GEN‐2 (paragraph 17) and GEN‐11.
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questionnaire responses of 17 firms that are believed to have accounted for the vast majority

of U.S. imports of boltless steel shelving from China in 2013.6

PREVIOUS AND RELATED INVESTIGATIONS

Boltless steel shelving has not been the subject of any prior countervailing or

antidumping duty investigations in the United States. The petitioner indicated that boltless

steel shelving has not been the subject of any investigations under section 337 of the Act (19

U.S.C. § 1337, 1671a), section 232 of the Trade Expansion Act of 1962 (19 U.S.C. § 1862), or

under sections 201 and 301 of the Trade Act of 1974 (19 U.S.C. §§ 2251 and 2411).7

NATURE AND EXTENT OF ALLEGED SUBSIDIES AND SALES AT LTFV

Alleged subsidies

On September 22, 2014, Commerce published a notice in the Federal Register of the

initiation of its countervailing duty investigation on boltless steel shelving from China.8

Commerce identified the following government programs in China on which it initiated an

investigation:   

                                                      

6 The HTS statistical reporting numbers under which subject boltless steel shelving enter the United

States are “basket” categories and cannot be used as an accurate measure from which to calculate

importer questionnaire coverage. However, based on individual proprietary Customs entries, staff

believes that *** are the only importers of record that have not provided a response to the Commission

questionnaire. *** indicated that it imported *** subject product from China ***. Staff telephone

interview with ***. *** is estimated to account for approximately *** percent of subject imports from

China during 2013 (based on *** landed, duty‐paid value reported by Customs). Other firms identified

by the petitioner that did not provide a response to the Commission’s questionnaire (***) are not listed

by Customs as importers of items under the applicable HTS numbers for boltless steel shelving. 7 Petitions, vol. I, p. 4.

8 Boltless Steel Shelving Units Prepackaged for Sale From the People’s Republic of China: Initiation of

Countervailing Duty Investigation, 79 FR 56567, September 22, 2014; and Enforcement & Compliance

Office of AD/CVD Operations Countervailing Duty Investigation Initiation Checklist, Boltless Steel

Shelving from the People’s Republic of China (C‐570‐019), September 15, 2014, pp. 7‐22.
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A. Government Provision of Goods and Services for Less Than Adequate Remuneration  

1. Electricity

2. Hot‐Rolled Coiled Steel

B.   Tax Programs

       1.   “Two Free/Three Half” Program for Foreign‐Invested Enterprises (“FIEs”)

       2.   Income Tax Reductions for Export Oriented FIEs

       3.   Income Tax Benefits for FIEs Based on Geographic Location

       4.   Local Income Tax Exemption and Reduction Programs for Productive FIEs

       5.   Income Tax Reduction for High or New Technology Enterprises

       6.   Income Tax Deductions for Research and Development Expenses Under the   

               Enterprise Income Tax Law

       7.   Income Tax Credits on Purchases of Domestically Produced Equipment by  

             Domestically Owned Companies

       8.   Import Tariff and Value‐Added Tax (“VAT”) Reductions for FIES and Certain  

             Domestic Enterprises Using Imported Equipment in Encouraged Industries

       9.   VAT Refunds for FIEs Purchasing Domestically Produced Equipment

C.   Grant Programs

       1.   Government of China (“GOC”) and Sub‐Central Government Subsidies for the  

             Development of Famous brands and China World Top Brands  

       2.  Special Fund for Energy Savings Technology Reform

       3.  International Market Exploration Fund (SME Fund)

       4.  Export Assistance/Outward Expansion Grants in Guangdong Province

       5.  Guangdong Supporting Fund

       6.  Guangdong Province Funds to Support the Adoption of E‐Commerce by Foreign

             Trade Enterprises

       7.  Technology to Improve Trade Research and Development Fund

D.  Loan Programs

      1.   Export Seller’s Credits and Export Buyer’s Credits from the Export‐Import Bank of

             China

Commerce is not initiating an investigation on the alleged program involving Policy Loans in

Guangdong Province.

Alleged sales at LTFV

On September 22, 2014, Commerce published a notice in the Federal Register of the

initiation of its antidumping duty investigation on boltless steel shelving from China.9

Commerce has initiated an antidumping duty investigation based on an estimated dumping

margin of 40 to 211 percent for boltless steel shelving from China.

                                                      

9 Boltless Steel Shelving Units Prepackaged for Sale From the People’s Republic of China: Initiation of

Antidumping Duty Investigation, 79 FR 56562, September 22, 2014.
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THE SUBJECT MERCHANDISE

Commerce’s scope

Commerce has defined the scope of these investigations as follows:

The scope of this investigation covers boltless steel shelving units

prepackaged for sale, with or without decks (‘‘boltless steel shelving’’).

The term ‘‘prepackaged for sale’’ means that, at a minimum, the steel

vertical supports (i.e., uprights and posts) and steel horizontal supports

(i.e., beams, braces) necessary to assemble a completed shelving unit

(with or without decks) are packaged together for ultimate purchase by

the end user. The scope also includes add‐on kits. Add‐on kits include,

but are not limited to, kits that allow the end‐user to add an extension

shelving unit onto an existing boltless steel shelving unit such that the

extension and the original unit will share common frame elements (e.g.,

two posts). The term ‘‘boltless’’ refers to steel shelving in which the

vertical and horizontal supports forming the frame are assembled

primarily without the use of nuts and bolts or screws. The vertical and

horizontal support members for boltless steel shelving are assembled by

methods such as, but not limited to, fitting a rivet, punched or cut tab or

other similar connector on one support into a hole, slot or similar

receptacle on another support. The supports lock together to form the

frame for the shelving unit, and provide the structural integrity of the

shelving unit separate from the inclusion of any decking. The incidental

use of nuts and bolts or screws to add accessories, wall anchors, tie‐bars

or shelf supports does not remove the product from scope. Boltless steel

shelving units may also come packaged as partially assembled, such as

when two upright supports are welded together with front‐to‐back

supports, or are otherwise connected, to form an end unit for the frame.

The boltless steel shelving covered by this investigation may be

commonly described as rivet shelving, welded frame shelving, slot and

tab shelving, and punched rivet (quasi‐rivet) shelving as well as by other

trade names. The term ‘‘deck’’ refers to the shelf that sits on or fits into

the horizontal supports (beams or braces) to provide the horizontal

storage surface of the shelving unit.

The scope includes all boltless steel shelving meeting the description

above regardless of (1) vertical support or post type (including but not

limited to open post, closed post and tubing); (2) horizontal support or

beam/brace profile (including but not limited to Z‐beam, C‐beam, L‐

beam, step beam and cargo rack); (3) number of supports; (4) surface

coating (including but not limited to paint, epoxy, powder coating, zinc

and other metallic coating); (5) number of levels; (6) weight capacity; (7)
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shape (including but not limited to rectangular, square, and corner units);

(8) decking material (including but not limited to wire decking, particle

board, laminated board or no deck at all); or (9) the boltless method by

which vertical and horizontal supports connect (including but not limited

to keyhole and rivet, slot and tab, welded frame, punched rivet and clip).

Specifically excluded from the scope are:

• Wall‐mounted shelving, defined as shelving that is hung on the wall

and does not stand on, or transfer load to, the floor;10  

• wire shelving units, which consist of shelves made from wire that

incorporates both a wire deck and wire horizontal supports (taking the

place of the horizontal beams and braces) into a single piece with tubular

collars that slide over the posts and onto plastic sleeves snapped on the

posts to create the finished shelving unit;

• bulk‐packed parts or components of boltless steel shelving units; and  

• made‐to‐order shelving systems. Subject boltless steel shelving

enters the United States through Harmonized Tariff Schedule of the

United States (‘‘HTSUS’’) statistical subheadings 9403.20.0018 and

9403.20.0020, but may also enter through HTSUS 9403.10.0040. While

HTSUS subheadings are provided for convenience and Customs purposes,

the written description of the scope of this investigation is dispositive.11

Tariff treatment

Based upon the scope set forth by the Department of Commerce, information available

to the Commission indicates that the merchandise subject to these investigations are

classifiable in subheadings 9403.10.00 (statistical reporting number 9403.10.0040, for metal

furniture of a kind used in offices, other than filing cabinets) and 9403.20.00 (statistical

reporting number 9403.20.0020, for metal counters, lockers, racks, display cases, shelves,

partitions, and similar fixtures) of the Harmonized Tariff Schedule of the United States, which

have a general rate of duty of free.12 The petitioner noted that the subject product may also be

imported under statistical reporting number 9403.20.0018, covering household metal furniture

other than specified ironing boards and furniture for young children.13   

                                                      

10 The addition of a wall bracket or other device freestanding subject merchandise to a wall does not

meet the terms of this exclusion. 11 Boltless Steel Shelving Units Prepackaged for Sale From the People’s Republic of China: Initiation of

Antidumping Duty Investigation, 79 FR 56562, September 22, 2014, Boltless Steel Shelving Units

Prepackaged for Sale From the People’s Republic of China: Initiation of Countervailing Duty Investigation,

79 FR 56567, September 22, 2014. 12 Customs and Border Protection ruling letters NY 800843, August 19, 1994, and NY I87283, October

23, 2002.

13 Petitions, vol. I, pp. 9–10.
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THE PRODUCT

Description and Applications

Boltless steel shelving units that are prepackaged for sale are used for storage in homes,

garages, offices, and commercial and industrial operations. Boltless refers to a system of

assembly that uses rivets or other protrusions on horizontal support members that fit into slots

in the vertical posts (also called uprights) of the units and thereby avoids the use of nuts and

bolts, screws, or tubular collars on posts. The boltless system does not require tools for

assembly.

Description

Boltless steel shelving units are relatively high load capacity shelving in which horizontal

support members connect to vertical posts without the use of nuts, bolts, screws, and tubular

collars (figure I‐1). These units are designed for end‐user convenience by the boltless system

that eliminates the need for tools and a prepackaged unit containing the appropriate parts that

is sold in a number of common of sizes. Since boltless steel shelving is prepackaged, the end

user may easily purchase the unit at a large home improvement store or mass merchandise

retailer, handle the product, and transport the unit to its ultimate location. The units may be

sold with or without decking (i.e., shelves).

Figure I-1 

Boltless steel shelving unit 

Source: Edsal Manufacturing Co., http://www.edsal.com/index.php (accessed September 25, 2014).
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The boltless system relies on rivets or punched or cut tabs on the beams or braces

fitting into slots that are punched or cut into the posts at set intervals (figure I‐2).14 Boltless

steel shelving uses several configurations of beam and brace profiles in order to provide high

load capacity and also hold the decking.15 The Z‐beam, C‐beam, L‐beam, and step beam are

commonly used in boltless steel shelving. The Z‐beam is trade marked by the petitioner.16

Figure I-2 

Boltless steel shelving: Rivet lock beam and post with slots 

Source: Petitions, exh. GEN‐3, p. 1.

Boltless steel shelving units are produced and sold in common shelving unit sizes and

approximate per‐shelf weight capacities, although the scope of the subject product in this

investigation is not limited by these parameters. These factors determine the construction and

configuration of horizontal support members and the vertical posts that are needed for other

supports (front‐to‐back supports that connect the front posts and rear posts and tie bars or

center supports for decking support). Typical sizes for widths are 36, 48, 60, or 77 inches;

                                                      

14 Beams are horizontal supports that transcend the width of the shelving unit. Braces are also

horizontal supports but they transcend the depth of the unit and connect the front and rear posts. The

beams and braces are set at the same height to provide a ledge upon which decking is placed.

15 Petitioner’s postconference brief, exh. 4.

16 Whalen LLC (“Whalen”) uses the Z‐beam profile on its units and pays royalties to the petitioner.

The petitioner stated that it has experienced intellectual property issues with Chinese producers of

boltless steel shelving using the Z‐beam and other related innovations. Conference transcript, p. 93

(Whalen) and pp. 76‐77 (Liss), exhibit 10.
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depths are 18 or 24 inches; and heights are 60, 72, 78, or 84 inches. Whalen stated that it is

important to list the capacity of the unit on the packages of boltless steel shelving.17  

Of the five products identified by petitioner as representing a “significant volume of U.S.

sales and imports,”18 the two products with a 77‐inch width had per‐shelf load capacities that

ranged from 1,000–2,500 pounds, and the three products with widths of 34–48 inches had per‐

shelf load capacities ranged from 250–1,000 pounds.

Boltless steel shelving units are frequently sold with 4–5 levels of decking in the

package. Popular decking materials are particle board, laminated boards, and steel wire. Some

units may be sold without decking, so the user may purchase the decking of their choice. Other

accessories include add‐on kits that allow the end user to add an extension shelving unit onto

an existing boltless shelving unit so that the original unit and extension share some common

frame elements, such as posts.19 End users may also separately purchase additional beams,

braces, and decking (although these items are not prepackaged) in order to add shelves beyond

those that came in their original unit.   

Uses

Boltless steel shelving is used for storage in homes, garages, offices, and commercial

and industrial operations. Because it is prepackaged in a limited number of sizes and other

specifications, it may not be suitable for certain offices, commercial, and industrial operations

requiring more customized shelving.20 Boltless steel shelving is designed for utility, and

therefore because of its aesthetic appearance, is likely to be used in a “garage, basement, or

back room rather than in a kitchen, living room or sales display area.”21

Manufacturing process22

There are six major steps in the manufacture of boltless steel shelving. First, hot‐rolled,

flat‐rolled carbon steel is slit to widths for producing beam, braces, and post profiles; these

blanks are punched with notch holes and cut to length; formed to the final shape and profile;

painted or coated; attached with rivets or welded with supports; and then assembled and

packaged.

   

                                                      

17 Conference transcript, p. 118 (Whalen).

18 Petitions, vol. I, p. 19.

19 The petitioner noted that the volume of domestic and imported sales of add‐on kits in the United

States is “very small,” in fact, “insignificant.” Conference transcript, pp. 38‐39 (Liss).

20 Conference transcript, pp. 39–40 (Liss). 21 Petitioner’s postconference brief, p. 7. 22 The information about the manufacturing process is derived from the petitions, vol. I, pp. 7‐9,

unless otherwise noted.
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The slitting process cuts the steel to the desired widths to produce beam and post

profiles.23 The slitting may be performed in‐house by the producer, a service center, or another

third party. The slit steel blanks are then fed into presses that punch notch holes and cut to

length the posts, beams, or braces. These parts are then roll‐ or press‐formed into their final

shape and profile. The petitioner stated that the various profiles of the beams and braces have

dedicated machines that cannot be used to produce other profiles and that these machines

produce at a constant volume.24 For higher capacity boltless steel shelving, a small frame which

has punched or cut out tabs is welded to each end of the beams. Welding of front‐to‐back

supports to vertical posts to form end units also is done at this time. The next step is

phosphating and painting or coating. Phosphating changes the steel surface to iron phosphate

to increase corrosion resistance and provide a strong bonding surface for painting or other

coatings.25  The posts, beams, and braces are either painted, galvanized, powder coated or

enameled, or applied with other coatings.26 Rivets are attached to each end of the beams and

braces. Decking is typically particle board or other composite material (painted, printed, or

laminated on the top), or steel wire mesh. The decking is typically supplied by outside

vendors.27 The appropriate posts, beams, braces, and decking for a complete unit, as well as

plastic end pieces, center supports and other accessories, and assembly instructions are

gathered together and then packaged and labeled for the order and shipped.

The Chinese manufacturing processes are likely similar to those of the U.S. industry. One

Chinese producer listed the production steps as ***.28 Unlike U.S. producers that design and

produce their own boltless steel shelving products, Chinese producers may be producing under

contract for U.S. importers or marketers. For example, Whalen, which has changed its source

factories in China several times, provided its Chinese manufacturers with the design of the

shelving and assistance with the manufacturing process, as well as other services, such as

quality control, logistics, and product testing.29

                                                      

23 Beams and posts for boltless steel shelving are typically produced from hot‐rolled, flat‐rolled

carbon steel. The most common thicknesses used for posts are 14, 16, and 18 gauge steel and for beams

are 16 and 18 gauge steel. Hot‐rolled steel is used because it is less expensive than cold‐rolled and

corrosion resistant steel and, after forming, the beam and post components will be painted or coated.

Petitions, vol. I, p. 8.

24 Conference transcript, pp. 70–71 (Liss).

25  Corrosionpedia, “Phosphating,” http://www.corrosionpedia.com/definition/876/phosphating

(accessed September 23, 2014).

26 Powder coating is a high quality finish found on many products. Using the process of electrostatic

spray deposition (“ESD”), a spray gun generates an electrostatic charge to powdered coating material

that then is attracted and coats the target part that is grounded for the charge. The part is then baked in

a curing oven. Powder Coating Institute, “What is powder coating,”  

http://www.powdercoating.org/11/Industry/What‐is‐Powder‐Coating (accessed September 23, 2014).   27 Conference transcript, p. 70 (Liss).

28 ***, foreign producer questionnaire, question II‐4c.

29 Conference transcript, p. 97 (Whalen).
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DOMESTIC LIKE PRODUCT ISSUES

The petitioner proposes that the domestic like product in these investigations is boltless

steel shelving, mirroring the scope definition. It argues that an examination of the

Commission’s traditional six‐factor test demonstrates that boltless steel shelving comprises a

continuum of a single product with no clear dividing lines.30  

At the conference, respondent Whalen indicated that it did not “have any quarrel with

the definition of the domestic like product,” and stated that the products of importers and

producers are competitive.31 At the same time, Whalen’s opinion was that the focus should be

on boltless steel shelving with a high capacity per shelf.32 It noted that it does not participate in

the lower capacity shelving segment of the market and indicated that it would provide the

Commission with a definition of the lower and higher capacity shelving in a postconference

brief.33 In its postconference brief, Whalen proposed that the domestic like product should be

“boltless steel shelving with a capacity of 500 pounds or greater per shelf.”34 It argued that a

domestic like product definition without a capacity limit would be inconsistent with issues of

“interchangeability” and “customer perception,” and noted that “a 300‐pound capacity shelf is

not interchangeable with a 2,000‐pound capacity shelf.”35 Whalen added that lower capacity

shelving is more of a commodity product than Edsal’s primary product and Whalen’s imported

product.36 Whalen did not provide any discussion of its proposed domestic like product

definition in terms of the Commission’s traditional six‐factor test.37  

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.

   

                                                      

30 Petitions, vol. I, p. 13.

31 Conference transcript, pp. 99–100 (Herlach).

32 Conference transcript, p. 100 (Whalen).

33 Conference transcript, p. 121 (Herlach). Whalen did note that it thought that the lower capacity

shelving discussed at the conference is assembled using bolts. Conference transcript, p. 121 (Whalen).

34 Whalen’s postconference brief, p. 5.

35 Whalen’s postconference brief, p. 4.

36 Whalen indicated that Edsal sells a variety of boltless steel shelving with per‐shelf capacities

beginning at 300 pounds. It argues that these lower capacity shelving units do not compete with

Whalen’s imported products. Whalen’s postconference brief, p. 4.

37 Whalen’s postconference brief, pp. 3‐4.
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Physical characteristics and uses

All boltless steel shelving shares similar physical characteristics and uses in that it is all

manufactured from flat‐rolled steel formed into vertical supports (posts or uprights) and

horizontal supports (beams and braces) that provide a strong and sturdy structural frame for  

the shelving unit and support for the horizontal storage surface (deck or shelf). The petitioner

argues that all boltless steel shelving is part of a continuum of products from which the

consumer can choose between various standard sizes of depth, width, height, and weight

capacity. All boltless steel shelving is alike in that the shelving (1) is primarily a consumer

product and is sold as a prepackaged kit with all of the posts and beams necessary to construct

a stand‐alone shelving unit or an add‐on unit; and (2) is designed to be easily and quickly

assembled by the end user without the use of screws, nuts, bolts, or other fasteners and

without the use of tools, such as a screwdriver or wrench. Other types of shelving (e.g., wood,

plastic, or wire shelving) are manufactured using different materials and bolted steel shelving

requires the use of fasteners and tools.38

All boltless steel shelving is used for storage in homes, offices, or businesses (generally

in garages, basements, or back rooms). It is designed for high capacity storage and utility, rather

than for aesthetics, and, for this reason, it is not generally used in kitchens, living rooms, or

sales display areas. These factors differentiate boltless steel shelving from wood, plastic, and

wire shelving, which tend to have lower shelving capacities, are generally offered in smaller

sizes, and are more likely to be found in the living or display areas of the home or business. In

the case of wire shelving, the product may also be offered with casters and a variety of other

accessories not found for subject boltless steel shelving.39  

Manufacturing facilities and production employees

The petitioner indicates that all boltless steel shelving is produced using the same basic

manufacturing process, and is produced on the same equipment and by the same employees.

Other types of shelving not within the scope definition (e.g., wire, wood, and  plastic shelving)

are not made by the same manufacturers on the same equipment or with the same

employees.40 In fact, the shelving components produced for sale in bulk (as opposed to

prepackaged kits) to material handling distributors (as opposed to retail distributors) are

produced on different equipment at Edsal because they require different profiles and steel

thicknesses.41

   

                                                      

38 Petitions, vol. I, p. 14; and petitioner’s postconference brief, pp. 6‐8.

39 Petitioner’s postconference brief, p. 7.

40 Petitions, vol. I, p. 15. 41 Petitioner’s postconference brief, p. 10.
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Within the product continuum of boltless steel shelving, the petitioner stated that there

are dedicated machines to produce specific post and lateral support profiles, and these

machines cannot be shifted to make other boltless steel shelving configurations.42 The other

U.S. producers of boltless steel shelving indicated ***.43

Interchangeability

The petitioner argues that all boltless steel shelving is interchangeable, varying only in

dimensions, weight capacity, number of decks, decking type, and other minor physical

characteristics. All boltless steel shelving is part of a continuum from which the end user can

select the specific prepackaged product with the combination of these physical characteristics

that meet their specific storage needs. The petitioner also argues that boltless steel shelving,

however, is not readily interchangeable with shelving that requires screws, bolts, and nuts as

the primary means of assembly due to its physical characteristics, including its tool‐less ease of

assembly. The petitioner explains that the individual, complete, prepackaged nature of boltless

steel shelving differentiates it from other types of shelving, which are missing one or more of

the characteristics that define the subject merchandise, such as steel frame construction, quick

and easy boltless assembly, and/or prepackaging of complete units for purchase on an “as is”

basis.44 The petitioner states that there are no substitutes for boltless steel shelving.45

According to responses to the Commission U.S. importers’ questionnaire, twelve firms

indicated that there were no substitute products and five firms indicated that substitutes

existed. One responded that bulk packaged boltless steel shelving may be purchased for use in

certain locations and others indicated that wire shelving, bolted shelving, and racking may be

substitutes for boltless steel shelving provided that the user capacity requirements were met or

that the assembly could be accomplished with fasteners and tools.46  

Customer and producer perceptions

The petitioner claims that producers, their customers, and consumers perceive all

boltless steel shelving to be the same product, due to its ease of assembly, sturdy design, and

storage capacity. It adds that market participants do not perceive other shelving products that

require fasteners and tools to assemble to be substitutable for boltless steel shelving.47

   

                                                      

42 Conference transcript, pp. 70–71 (Liss).

43 ***. 44 Petitions, vol. I, p. 14; and petitioner’s postconference brief, pp. 7‐9.

45 Conference transcript, pp. 73–74 (Liss).

46 For example, see responses of ***. 47 Petitions, vol. I, p. 15; and petitioner’s postconference brief, p. 10.
I‐15

Channels of distribution

The petitioner notes that all boltless steel shelving is sold through the same channels of

distribution, that is, through “big box,” home improvement, department, discount, and office

supply stores, as well as through commercial and industrial distributors and e‐commerce sites.

It explains that the shelving is primarily a prepackaged product that consumers (individuals,

businesses, offices, schools, etc.) purchase based on the characteristics that match their storage

needs and design preferences. By contrast, the vast majority of components and parts of

shelving, which are sold by producers in bulk (rather than in kits) through distributors in the

material handling industry (rather than at retail), are sold as made‐to‐order commercial and

industrial material handling and shelving systems. These sales often include design,

engineering, and installation services.48  

The respondent Whalen asserts that the dominant channels of distribution are the five

big box companies (Costco, The Home Depot U.S.A., Inc. (“Home Depot”), Lowe’s Companies,

Inc. (“Lowe’s”), Menard, Inc. (“Menard”), and Sam’s Club – USA (“Sam’s Club”)) and states that

there are several other small retail buyers.49 Whalen stated that for the larger, high‐capacity

boltless steel shelving, the dot.com channel was not a likely channel because, given the weight

of the units, the freight cost from such vendors is prohibitive for the potential purchasers.50

Price

With respect to price, the petitioner argues that all boltless steel shelving is sold within a

reasonable range of similar prices based on a continuum of sizes (depths, widths, number of

levels, and capacities) and options for physical characteristics, such as finish type (paint,

powder coating etc.), color, and deck types (particle board, laminated particle boards, wire

decks, etc.). It noted that shelving components are not priced similarly to boltless steel shelving

because the components are sold in bulk to material handling distributors and are aggregated

for specific projects by the distributors to include design and installation services. Resin and

other plastic shelving tend to be less expensive than boltless steel shelving, while wooden

shelving is generally more expensive. The petitioner argues that, although other types of

shelving (e.g., wire shelving) may overlap in price somewhat with some subject boltless steel

shelving, they are not similar based on their different material inputs, sizes, and capacities and

on the perceptions of the retailers and purchases that buy them.51

                                                      

48 Petitioner’s postconference brief, pp. 8‐9.

49 Whalen’s postconference brief, pp. 5–6.

50 Conference transcript, pp. 92–93 (Whalen). ***. Petitioner’s postconference brief, pp. 18‐20 and

exh. 1, pp. 3‐4.

51 Petitions, vol. I, p. 15; and petitioner’s postconference brief, p. 11.

II‐1

PART II: CONDITIONS OF COMPETITION IN THE U.S. MARKET

U.S. MARKET CHARACTERISTICS

Boltless steel shelving is a consumer product sold in a kit designed for quick assembly

and used for high capacity storage in homes, garages, offices, and other businesses.1 Boltless

steel shelving can be purchased at retailers, such as big box stores (e.g., Walmart), home

improvement stores (e.g., Home Depot and Lowe’s), club retailers (e.g., Costco and Sam’s Club),

department stores (e.g., Sears), office supply stores (e.g., Staples), and online retailers (e.g.,

Amazon) nationwide.2 At the conference, importer Whalen identified five big box retailers as

the major players that purchase boltless steel shelving: Lowe’s, Home Depot, Costco, Menard,

Inc. (“Menard’s”), and Sam’s Club.3 In addition to imports, there are four U.S. producers of

boltless steel shelving, with the petitioner representing *** percent of the domestic production

in 2013.   

CHANNELS OF DISTRIBUTION

U.S. producers and importers sold primarily to end users, as shown in table II‐1.

However, end users consist of different types of purchasers based on which type of firm is

responding to the question. End users to which U.S. producers sell boltless steel shelving

consist primarily of retailers, whereas importers’ end users are customers since most importers

are typically retailers.4 5 6

  

Table II-1 

Boltless steel shelving: U.S. producers’ and importers’ U.S. shipments, by sources and channels 

of distribution, 2011-2013, January to June 2013, and January to June 2014 

* * * * * * * 

 

1 Petitioner’s postconference brief, p. 7.   2 Conference transcript, p. 17 (Liss).

3 Conference transcript, p. 11 (Whalen). 4 Tabulations in Part II regarding general market characteristics include responses for ***, which

provided information regarding the market.  Although not the importer of record, its responses were

included with the importers as it arranges for importation of boltless steel shelving. 5 Importer data includes the petitioner’s import data.   6 Importer *** reported that *** percent of its commercial shipments are to ***. However, its

customer list reported that its top ten customers in 2013 were ***, the largest of which accounted for

*** percent of its sales of boltless steel shelving. Staff categorized these shipments as shipments to ***.
II‐2

GEOGRAPHIC DISTRIBUTION

U.S. producers and importers reported selling boltless steel shelving to all regions in the

contiguous United States (table II‐2). 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 sold *** percent within 100 miles of their U.S. point

of shipment, *** percent between 101 and 1,000 miles, and *** percent over 1,000 miles.  

Table II-2 

Boltless steel shelving: Geographic market areas in the United States served by U.S. producers 

and importers 

Region U.S. producers Importers 

Northeast 3 13 

Midwest 4 15 

Southeast 3 14 

Central Southwest 3 12 

Mountain 3 13 

Pacific Coast 3 15 

Other1 3 12 

All regions (except Other) 3 12 

Reporting firms 4 17 

1

 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 boltless steel shelving have the ability

to respond to changes in demand with moderate‐to‐large changes in the quantity of shipments

of U.S.‐produced boltless steel shelving to the U.S. market. The main contributing factors to this

degree of responsiveness of supply are unused capacity and inventories. Factors that hinder

responsiveness are the inability to use certain equipment to shift production and the lack of

alternative markets.

Industry capacity

U.S. production of boltless steel shelving was *** units in 2011 and reached *** units in

2013. Domestic capacity reported by U.S. producers totaled *** units in 2011 and rose to ***

units in 2013. Domestic capacity utilization declined from *** percent in 2011 to *** percent in

2013 and was *** percent in January‐June 2014, compared with *** percent in January‐June
II‐3

2013. This moderate level of capacity utilization suggests that U.S. producers may have some

ability to increase production of boltless steel shelving in response to an increase in prices.

Alternative markets

U.S. producers’ exports, as a percentage of total shipments, increased from *** percent

in 2011 to *** percent in 2013. U.S. producers’ export shipments were *** percent during

January‐June 2013 and *** percent during January‐June 2014. This proportion of total

shipments indicates that U.S. producers may have limited ability to shift shipments between

the U.S. market and other markets in response to price changes. ***. *** U.S. producers

reported exports of boltless steel shelving.

Inventory levels

U.S. producers’ inventories, as a percent of U.S. total shipments, declined from ***

percent in 2011 to *** percent in 2013. However, inventories, as a percent of U.S. production,

were higher at the end of January‐June 2014 (*** percent) compared to the end of January‐

June 2013 (*** percent). These inventory levels suggest that U.S. producers may have a low‐to‐

moderate ability to respond to changes in demand with changes in the quantity shipped from

inventories.

Production alternatives

Three of four responding U.S. producers stated that they could switch production from

boltless steel shelving to other products. Other products that producers reportedly can produce

with the same equipment and/or labor as boltless steel shelving are bolted steel shelving ***,

four‐post shelving, industrial clip, and other shelving posts. According to ***, “Certain

production lines are able to make a variety of parts for different products. Depending on

demand, the equipment is scheduled to meet requirements.” However, *** stated that

“production labor is shifted based on demand for our products. Production equipment is not

shifted between products.” *** reported that it is not able to shift production capacity between

boltless steel shelving and other products using the same equipment or labor. Edsal noted that

its equipment is uniquely specialized and that it is not able to produce varying specifications of

boltless steel shelving.7

   

Supply constraints

Three of the four U.S. producers indicated that certain key machinery limit their output,

particularly the roll forming, stamping lines, and special tooling equipment.

 

7 Conference transcript, p. 70 (Liss).
II‐4

Subject imports from China8

Based on available information, producers of boltless steel shelving in China have the

ability to respond to changes in demand with large changes in the quantity of shipments of

boltless steel shelving to the U.S. market. The main contributing factors to this degree of

responsiveness of supply are the availability of unused capacity and existence of alternate

markets.

Industry capacity

Chinese capacity utilization declined from *** percent in 2011 to *** percent in 2012

and was *** percent in 2013. However, data for the first half of 2014 show that capacity

utilization was higher than reported in the first half of 2013. Projections show that capacity

utilization are expected to generally increase to *** percent in 2015. This low level of capacity

utilization suggests that foreign producers may have substantial capacity to increase production

of boltless steel shelving in response to an increase in prices.

Alternative markets

Chinese producers’ exports, as a percentage of total shipments, represented *** of their

shipments since January 1, 2011. Chinese producers’ export shipments to third‐country markets

fell from *** percent in 2011 to *** percent in 2013. However, data for the interim period (i.e.,

January‐June) show that exports to markets other than the United States were higher at ***

percent in the first half of 2014 than at *** percent in the first half of 2013. Projections indicate

further expansion of sales to markets other than the United States. Countries that these foreign

producers shipped to include ***. Therefore, Chinese producers may have moderate‐to‐large

ability to shift shipments between the U.S. market and other markets in response to price

changes.  

Inventory levels

Chinese producers’ inventories *** over the reporting period, with the exception of ***

units held in inventory at yearend 2013 and *** units held in inventory in June 2014. These

inventory levels suggest that foreign producers may not have ability to respond to changes in

demand with changes in the quantity shipped from inventories.

Supply constraints

Most responding Chinese producers indicated that certain key machinery limit their

output. Half of responding Chinese producers indicated that labor is also a constraint on supply.  

 

8 Exports to the United States reported by the *** responding Chinese producers combined

accounted for *** percent of reported U.S. imports of boltless steel shelving from China during 2013.
II‐5

Nonsubject imports

Imports of boltless steel shelving may be imported into the United States under HTS

statistical reporting numbers 9403.20.0018, 9403.20.0020, and 9403.10.0040, which comprise a

broad basket of goods. There is no discernable way to determine if boltless steel shelving was

imported from nonsubject countries using these data. The petitioner and respondent Whalen

stated that, to their knowledge, there are no subject imports from nonsubject countries.9

However, *** reported that it imports subject merchandise from ***.  

U.S. demand

Based on available information, the overall quantity demanded of boltless steel shelving

is likely to experience moderate‐to‐large changes in response to changes in price. The main

contributing factor is that it is an end‐use good.

End uses

Boltless steel shelving is a final good. It is sold prepackaged in a kit, ready for assembly

and installation by the consumer. It is used for high capacity storage in homes, garages, offices,

and other businesses.

Business cycles

All U.S. producers and 14 of 16 importers indicated that the market was not subject to

business cycles or distinctive conditions of competition other than general economy‐wide

conditions. Figure II‐1 illustrates the quarterly percent change in U.S. real gross domestic

product from 2011 to the second quarter of 2014. Two importers, *** and ***, indicated that

the market is subject to business cycles, noting seasonal demand spikes in spring and fall.

 

 

9 Conference transcript, pp. 9 (Cannon), 45 (Liss), and 112 (Whalen).
II‐6

Figure II-1 

U.S. real gross domestic product, quarter-over-quarter percent change, January 2011- June 2014 

Source: Bureau of Economic Analysis. 

Apparent consumption

Apparent U.S. consumption of boltless steel shelving increased from *** units in 2011 to

*** in 2012 to *** units in 2013.  

Demand trends

U.S. producers’ responses were mixed regarding changes in demand. One reported

increasing demand, another reported decreasing demand, and two reported fluctuating

demand. Nearly half of responding importers reported no change in U.S. demand for boltless

steel shelving since 2011 (table II‐3). Responses regarding demand outside the United States

were also mixed. *** U.S. producers reported that demand outside the United States

fluctuated, while *** reported that there was no change. Of the *** responding importers, ***

reported that demand outside the United States increased, *** reported that it decreased, ***

reported that it fluctuated, and *** reported that there was no change.  

Table II-3 

Boltless steel shelving: Firms’ responses regarding U.S. demand 

* * * * * * *

Substitute products

Identified substitutes for boltless steel shelving consisted of wire shelving, plastic

shelving, resin shelving, bolted steel shelving, shelving sold as components, and bulk‐packaged

boltless steel shelving. However, considering the boltless design and high load capacity of the
II‐7

subject product, most U.S. producers and importers reported that there were no substitutes.

Both the petitioner and respondent Whalen stated there are no close substitutes for boltless

steel shelving.10  

Cost share

Boltless steel shelving is a final good, and, as such, it accounts for all of the cost of a

finished good.

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported boltless steel shelving

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, boltless steel shelving services, etc.). Based on

available data, staff believes that there is high degree of substitutability between domestically

produced boltless steel shelving and boltless steel shelving imported from China.  

Lead times

Boltless steel shelving is sold primarily on a produced‐to‐order basis.  U.S. producers and

importers reported that *** percent and *** percent, respectively, of their commercial

shipments were produced to order, with lead times averaging *** days for U.S. producers and

*** days for U.S. importers. The remaining *** percent of U.S. producers’ sales and ***

percent of U.S. importers’ sales of commercial shipments came from inventories, with lead

times averaging *** days for U.S. producers and *** days for importers. The petitioner stated

that its domestic lead time ranges from 3 to 14 days, while shipment from its Chinese factory

has a lead time of 60 days.11     

Comparison of U.S.‐produced and imported boltless steel shelving

In order to determine whether U.S.‐produced boltless steel shelving can generally be

used in the same applications as imports from China, 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 boltless steel shelving and imported boltless steel shelving are “always”

 

10 Conference transcript, pp. 31 (Liss) and 114 (Whalen). 11 Conference transcript, p. 68 (Liss).
II‐8

interchangeable, while half of importers reported that the products are “frequently”

interchangeable.12   

Table II-4 

Boltless steel shelving: Interchangeability between boltless steel shelving produced in the United 

States and in other countries, by country pairs 

* * * * * * * 

Producers and importers were asked to assess how often differences other than price

were significant in sales of boltless steel shelving from the United States and China. As seen in

table II‐5, all U.S. producers reported that non‐price factors are “never” a significant difference

between boltless steel shelving produced in the United States and China. Half of the responding

importers reported that there are “frequently” significant differences other than price between

boltless steel shelving produced in the United States and China, including quality, product

diversity, and technical support.13 Some U.S. importers reported that that there are

“frequently” and “sometimes” significant differences other than price between boltless steel

shelving produced in the United States and nonsubject countries as well as between China and

nonsubject countries, respectively.  

 

12 Narrative responses in the importer questionnaires regarding interchangeability were received

from two importers. *** stated that “The types of boltless steel shelving produced in the US versus

China are not the same and the local US manufacturer(s) have not had the capacity to produce to the

order specifications of ***.” *** 13 Narrative responses in the importer questionnaire regarding factors other than price were received

from *** importers. *** stated that “Our current imported boltless shelving is of high quality than

boltless shelving that was available at the time of decision.  It is a thicker steel, better powdercoating,

better design features, and color options.  We also had issues with domestic supplier product being

available and shipping on time.” *** reported “U.S. ‐ China: Smaller minimum order quantity and

quicker lead times.” *** stated that “Brand diversity is important to ***.” *** reported that “When a

consumer purchases a product, price is not the only factor consumers consider. They obviously also

consider differences in quality, speed of delivery, sizing, etc.” *** stated that “Our made in China

product has lower quality steel (Q235) but higher gauge to compensate Gauge used by ***.” *** stated

that “US‐China country pair ‐ Quality, availability, product range, technical support and an established

transportation network are additional factors considered advantageous when sourcing boltless steel

shelving.” *** reported that “Edsal developed a solid reputation with customers and end users as a

supplier with little to no quality control, poor service, consistent backorders, and extreme difficulty in

scheduling trucks.  These delays resulted in lost orders to our company and substantial fines from our

customers due to our inability to provide agreed quantities on time.  Conversely, our foreign supply

chain provides consistently high quality products, on time and with excellent service.  The domestic

sources were unable or unwilling to compete on these factors.”
II‐9

Table II-5 

Boltless steel shelving: Significance of differences other than price between boltless steel 

shelving produced in the United States and in other countries, by country pairs 

* * * * * * * 

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 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 four firms that accounted for all known U.S. production of boltless

steel shelving during 2013.

U.S. PRODUCERS

The Commission issued a U.S. producer questionnaire to four firms based on

information contained in the petitions. The following four firms provided usable data on their

production operations: Edsal Manufacturing Co., Inc. (“Edsal”); Hallowell aka List Industries Inc.

(“Hallowell”); Hirsh Industries LLC (“Hirsh”); and Tennsco Corp. (“Tennsco”). Staff believes that

these responses represent all known U.S. production of boltless steel shelving.  

Table III‐1 lists U.S. producers of boltless steel shelving, their production locations,

positions on the petitions, and shares of total production.  

Table III-1 

Boltless steel shelving: U.S. producers, their positions on the petitions, production locations, and 

shares of reported production, 2013 

Firm 

Position on 

petitions Production location(s) 

Share of 2013 

production (percent) 

Edsal Petitioner Chicago, IL ***

Hallowell *** 

Deerfield Beach, FL 

Apopka, FL ***

Hirsh *** Dover, DE ***

Tennsco *** Dickson, Tennessee ***

Total 100.0 

Source: Compiled from data submitted in response to Commission questionnaires. 

Petitioner Edsal is the largest U.S. producer of boltless steel shelving, accounting for ***

percent of total domestic production in 2013. Edsal’s domestic manufacturing operations,

located in Chicago, Illinois, opened in 1957 and it began the production of boltless steel

shelving in 1985. The company has been family‐owned and operated since its inception.1

  

Edsal reported that it *** owns Chinese producer Edsal Sandusky Corp. Zhongshan

(“Edsal Sandusky”) and that it has imported boltless steel shelving from this Chinese

                                                      

1 Conference transcript, pp. 12‐13 (Liss).
III‐2

manufacturer, ***. Edsal first imported boltless steel shelving in ***.2 It explained that it

established the Chinese production facility approximately ten years ago with the primary goal

of supplying boltless steel shelving to the Chinese market. However, the demand growth in

China for the product did not take place and the Chinese producer turned to exporting to the

United States in order to remain competitive with other Chinese producers. Edsal claimed that

Edsal Sandusky in China is a “rather modest” facility and is not the major source of U.S. imports

from China. It also argued that its primary interest lies in domestic production, rather than

importation of the subject merchandise, and that it has been “forced” to import boltless steel

shelving from China to remain competitive with low‐priced imports from China.3

*** domestic producers of boltless steel shelving are related to foreign producers of the

subject merchandise and *** U.S. producers are U.S. importers of the subject merchandise ***

are related to U.S. importers of the subject merchandise. In addition, *** of the four U.S.

producers reported purchases of boltless steel shelving in the United States.  

In the Commission’s questionnaire, U.S. producers were asked if they had experienced

any plant openings, plant closings, relocations, expansions, acquisitions, consolidations,

prolonged shutdowns or production curtailments, or revised labor agreements since January 1,

2011.  ***. Table III‐2 summarizes the responses of *** regarding reported industry changes.

Table III-2 

Boltless steel shelving: U.S. producers’ changes in operations since 2011 

                    *                    *                    *                    *                    *                    *                    *

U.S. PRODUCTION, CAPACITY, AND CAPACITY UTILIZATION

Boltless steel shelving

Table III‐3 and figure III‐1 present U.S. producers’ boltless steel shelving production,

capacity, and capacity utilization.  

Table III-3 

Boltless steel shelving: U.S. producers’ production, capacity, and capacity utilization, 2011-13, 

January-June 2013, and January-June 2014 

                    *                    *                    *                    *                    *                    *                    *

Figure III-1 

Boltless steel shelving: U.S. producers’ production, capacity, and capacity utilization, 2011-13, 

January-June 2013, and January-June 2014 

                    *                    *                    *                    *                    *                    *                    *

                                                      

2 Petitioner’s postconference brief, exhibit 1, p. 6.

3 Petitions, vol. I, p. 16; and conference transcript, pp. 19‐21 (Liss).
III‐3

Total annual capacity to produce boltless steel shelving in the United States, which was

based on operating *** hours per week and *** weeks per year, increased from *** units to

*** units since 2011. Production of boltless steel shelving also increased from 2011 to 2013 by

*** percent, consistent with trends in capacity. However, boltless steel shelving production in

January‐June 2014 was *** percent lower than in January‐June 2013. Capacity utilization fell

from *** percent in 2011 to *** percent in 2013, and was even lower at *** percent in

January‐June 2014.

Edsal, the largest domestic producer of boltless steel shelving accounting for ***

percent of annual domestic capacity in 2013, reported that its production capacity was

calculated using average measured production rates for key operations as applied consistently

over the periods.4 It explained ***. It also noted that the domestic industry expansions are

keeping pace with demand increases in the U.S. market.5 Hallowell, which accounted for ***

percent of 2013 boltless steel shelving capacity, explained ***. Hirsh and Tennsco reported

***.

Producers were asked to describe the constraints that set the limits on their production

capacity. Although Hallowell reported ***, the remaining three U.S. producers reported that

the output of *** set the limits on their production capacity.

Overall capacity and production

The four domestic producers were asked to provide data on the overall capacity and

production in their boltless steel shelving facilities, by type of item produced. ***, which

accounted for *** and *** percent of overall plant capacity during 2013, respectively, reported

that no other products are made on the same equipment and machinery used to produce

boltless steel shelving.  

*** reported that it produces *** on the same equipment and machinery that is used to

produce boltless steel shelving. These other products account for *** of the firm’s overall

production. Tennsco, which accounted for *** percent of boltless steel shelving in the United

States during 2013, represented *** percent of overall U.S. facility capacity during 2013.

*** reported that, in addition to producing boltless steel shelving, it also produces ***

on the same equipment and machinery. Boltless steel shelving, ***, accounted for *** percent

of the firm’s overall production during *** and *** percent during ***. *** accounted for ***

percent of overall U.S. plant capacity during 2013.  

Table III‐4 presents the domestic industry’s overall U.S. capacity, production, and

capacity utilization of boltless steel shelving and other products combined. The allocated

capacity to produce boltless steel shelving (see table III‐3) accounted for *** percent of the

aggregate overall plant capacity reported by the four U.S. producers (compare with table III‐4).

Production of other products accounted for *** percent of overall facility production during

2013, whereas boltless steel shelving accounted for *** percent of the total. Although overall

                                                      

4 Conference transcript, pp. 45‐46 (Liss). 5 Petitioner’s postconference brief, p. 14.
III‐4

capacity mirrored the allocated capacity to produce boltless steel shelving, the production of

other products experienced a somewhat different year‐to‐year trend during 2011‐13 than that

experienced by boltless steel shelving. Whereas the production of boltless steel shelving

increased during each year from 2011 to 2013, the production of other products fell from 2011

to 2012 before increasing in 2013 to a level *** higher than reported in 2011. A similar trend in

production was reported for the partial‐year periods of 2013 and 2014.

Table III-4 

Boltless steel shelving: U.S. producers’ overall capacity, production, and capacity utilization, by 

product, 2011-13, January-June 2013, and January-June 2014 

                    *                    *                    *                    *                    *                    *                    *

Producers were asked about their ability to switch production (capacity) between

boltless steel shelving and other products using the same equipment and/or labor. Tennsco

reported ***. It explained that ***. Hallowell reported ***. It explained that its production line

does ***. Hirsh reported ***. Hirsh did not report data concerning ***. Edsal reported ***.

U.S. PRODUCERS’ U.S. SHIPMENTS AND EXPORTS

Table III‐5 presents U.S. producers’ U.S. shipments, export shipments, and total

shipments.

Table III-5 

Boltless steel shelving: U.S. producers’ U.S. shipments, export shipments, and total shipments, 

2011-13, January-June 2013, and January-June 2014 

                    *                    *                    *                    *                    *                    *                    *

*** U.S. producers reported internal consumption or transfers of boltless steel shelving

to related firms in the United States.U.S. producers’ commercial U.S. shipments accounted for

*** of total shipments (*** percent based on quantity in 2013). The quantity of U.S. producers’

U.S. shipments of boltless steel shelving increased by *** percent from *** units in 2011 to ***

units 2013, but was *** percent lower in the first half of 2014 than in the comparable period in

2013. The average unit value of U.S. shipments increased from $*** per unit in 2011 to $***

per unit in 2012, but fell to $*** per unit in 2013. The average unit value of commercial U.S.

shipments reached its highest point at $*** per unit in January‐June 2014, a period in which

relatively lower U.S. commercial shipments were reported.  

*** exports of boltless steel shelving. The firm reported that the export destinations for

its product are ***. Since 2011, exports have accounted for a *** increasing, share of total

domestic industry shipments. Domestic producers’ exports accounted for *** percent of the

total quantity of shipments in 2011 and *** percent during the first half of 2014. The average

unit values of exports, which were consistently higher than reported for commercial shipments,

experienced a somewhat different trend than commercial U.S. shipments. The average unit
III‐5

value of exports increased from $*** per unit in 2011 to $*** per unit in 2013, but was lower

at $*** per unit in the first half of 2014 as compared with $*** in the first half of 2013.

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 during 2011‐13,

January‐June 2013, and January‐June 2014. Edsal, *** the largest domestic producer of boltless

steel shelving, testified that its sales are generally produced to order, which appears to be

reflected in the *** ratio of inventories to production.6 Indeed, reported producers’ end‐of‐

period inventories as a ratio to production and shipments fell from *** percent in 2011 to ***

percent in 2013. The ratios of inventories to production and shipments were higher at *** and

*** percent, respectively, during January‐June 2014 as compared with January‐June 2013.   

Table III-6 

Boltless steel shelving: U.S. producers’ end-of-period inventories and ratios of inventories to U.S. 

production and shipments, 2011-13, January-June 2013, and January-June 2014 

                    *                    *                    *                    *                    *                    *                    *

Producers’ end‐of‐period inventories decreased by *** percent from 2011 to 2013. In

fact, inventories were at their lowest point at year‐end 2013, accounting for only *** percent of

U.S. production in that year. Most of the inventory decline from 2011 to 2013 was accounted

for by ***, which accounted for *** percent of inventories held at year‐end 2011 and ***

percent of inventories held at year‐end 2013. Producers’ inventories were higher in June 2014

than compared with the level reported in June 2013. *** accounted for *** percent of

inventories held in June 2014.

U.S. PRODUCERS’ IMPORTS AND PURCHASES

As previously indicated, petitioner Edsal *** imports the subject merchandise from

China into the United States. Edsal reported that it *** owns Chinese producer Edsal Sandusky

and that it is an importer of boltless steel shelving from its Chinese subsidiary, ***.

*** U.S. producers are U.S. importers of the subject merchandise *** are related to U.S.

importers of the subject merchandise and *** domestic producers are related to foreign

producers of the subject merchandise. As previously indicated, there were *** domestic

purchases of boltless steel shelving in the United States by the domestic producers.

U.S. producer *** U.S. imports of boltless steel shelving are presented in table III‐7. Also

presented are U.S. imports of boltless steel shelving produced in China that are arranged by

Edsal for other U.S. firms that are the importers of record. These items ***. These imports

                                                      

6 Conference transcript, p. 22 (Liss).
III‐6

increased both in terms of absolute quantity and relative to Edsal’s U.S. production from 2011

to 2013, and were higher in January‐June 2014 than reported during January‐June 2013.

Table III-7 

Boltless steel shelving: Edsal’s U.S. production and imports, 2011-13, January-June 2013, and 

January-June 2014 

                    *                    *                    *                    *                    *                    *                    *

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

The petitioner testified that, in addition to the curtailment of production, it has

experienced worker layoffs and reductions in the number of shifts as a result of “low‐priced

imports” from China in increasing volumes.7 Specifically, Edsal reported work force reductions

of *** employees in *** and shift *** reductions of ***. During 2013, Edsal reported that it

employed an average of *** production and related workers and during January‐June 2014 it

employed an average of *** workers. The petitioner noted the following:  

much of the injury the domestic industry has suffered is not reflected in the

Commission’s database that ends in June 2014. The massive lost sale of the ***.8

Table III‐8 shows U.S. producers’ employment‐related data during 2011‐13, January‐

June 2013, and January‐June 2014. In the aggregate, U.S. producers reported an overall

increase in the number of production and related workers (“PRWs”), total hours worked, and

total wages paid from 2011 to 2013. However, hours worked per PRW, as well as hourly wages

and unit labor costs, declined overall from 2011 to 2013. The number of PRWs employed and

hourly wages during January‐June 2014 were higher than reported in the comparable period in

2013; however, total hours worked, hours worked per PRW, total wages paid, and unit labor

costs were lower. Productivity remained relatively unchanged at *** units per hour in each of

the periods examined, although a *** higher productivity was reported during 2013.

Table III-8 

Boltless steel shelving: 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 

                    *                    *                    *                    *                    *                    *                    *

                                                      

7 Conference transcript, p. 19 (Liss).

8 Petitioner’s postconference brief, p. 36.
IV‐1

PART IV: U.S. IMPORTS, APPARENT U.S. CONSUMPTION, AND MARKET

SHARES

U.S. IMPORTERS

The Commission issued importer questionnaires to 46 firms believed to be possible

importers of subject boltless steel shelving, as well as to all U.S. producers of boltless steel

shelving.1 Twenty‐two firms indicated that they had not imported boltless steel shelving into

the United States since January 1, 2011.2 Two firms identified by Customs as importers of items

entering under the applicable HTS numbers for boltless steel shelving did not respond to the

Commission’s questionnaire.3 Five firms identified by the petitioner as possible importers of the

subject boltless steel shelving did not respond to the Commission’s importer questionnaire.4

Usable questionnaire responses were received from 17 companies. Staff estimates that the

responding importers represent the vast majority of total subject imports from China during

 

1 The Commission issued questionnaires to those firms identified in the petitions, along with firms

that, based on a review of data provided by U.S. Customs and Border Protection (“Customs”), may have

accounted for more than one percent of total imports under HTS statistical reporting numbers

9403.20.0018, 9403.20.0020, and 9403.10.0040 during January 2011‐June 2014. 2 One firm (***) reported that it is not the importer of record of the merchandise it arranges for

importation. Its customers (***) confirmed that such imports arranged by *** were included in their

questionnaire responses. Therefore, the import quantity and value data reported by *** were removed

from the data presented in this staff report to avoid double‐counting issues. The remaining 21 firms that

indicated that they had not imported boltless steel shelving into the United States since January 1, 2011

include the following: ***.

3 *** were the only firms identified solely by Customs’ documents that did not provide a response to

the Commission’s questionnaire. Based on the firm’s product offerings, *** is not believed to be an

importer of the subject boltless steel shelving. ***, accessed on September 23, 2014. *** imported ***

shipment of boltless steel shelving from China during ***. *** subsequent imports of the subject

merchandise from China were made. Staff telephone interview with ***. 4 The following five firms identified in the petitions as possible importers of boltless steel shelving did

not provide a response to the Commission’s importer questionnaire:  ***. Rapid Rack (Gorilla Rack) ***

in 2013, ***. *** was issued an importer questionnaire, but it reported ***. Conference transcript, pp.

103‐105 (Painter), and telephone conversation with ***, September 18, 2014. According to Customs,

*** imported items under the applicable HTS numbers in the following amounts:  ***. The other four

firms are not listed by Customs as importers of items under the applicable HTS numbers for boltless

steel shelving. Regardless, the “dot com” firms are believed to have accounted for a smaller segment of

the boltless steel shelving market between January 1, 2011 and June 30, 2014. Conference transcript, p.

93 (Whalen).
IV‐2

2013.5 Table IV‐1 lists all responding U.S. importers of boltless steel shelving from China and

other sources, their locations, and their shares of reported U.S. imports, in 2013.   

Table IV-1 

Boltless steel shelving: U.S. importers, headquarters, and share of reported 2013 imports, by 

source 

                    *                    *                    *                    *                    *                    *                    *

U.S. IMPORTS  

Table IV‐2 presents data for U.S. imports of boltless steel shelving from China and all

other sources (***). As indicated previously, official import statistics for the HTS statistical

reporting numbers under which boltless steel shelving is believed to be entering the United

States (9403.20.0018, 9403.20.0020, and 9403.10.0040) vastly overstate the amount of subject

U.S. imports since these HTS statistical reporting numbers are basket categories that also

include relatively large amounts of nonsubject items (e.g., other metal office and household

furniture, such as counters, lockers, display cases, partitions, bed railings, etc.). Therefore, the

import data presented in this report are compiled from importer questionnaire responses

received in these preliminary investigations.

 

5 As previously indicated, the HTS statistical reporting numbers under which subject boltless steel

shelving enter the United States are “basket” categories and cannot be used as an accurate measure

from which to calculate importer questionnaire coverage. Based on Customs documents, staff believes

that *** are the only importers of record that have not provided a response to the Commission’s

questionnaire. *** is believed to account for approximately *** percent of subject imports from China

during 2013 (based on company landed, duty‐paid value reported by Customs). *** imported only one

shipment of boltless steel shelving from China during 2011. The petitioner’s estimate of *** percent

coverage of subject imports from China during 2013 is based on fewer questionnaire responses, does

not account for certain questionnaire revisions, and does not appear to account for certain firms that

certified they did not import. Petitioner’s postconference brief, exhibit 1, Responses to Questions, p. 2.

The petitioner lists in its postconference brief 13 firms that it argued did not respond to the

Commission’s questionnaire. Petitioner’s postconference brief, p. 20. *** of these firms responded that

they did not import boltless shelving (***). *** of the firms the petitioner listed (***) provided data in

response to the Commission’s questionnaire, albeit imports of *** products were reportedly sourced

from ***. *** of the firms identified by the petitioner did not provide a response (***); however, as

previously discussed, staff believes that, of the *** firms listed, only *** is an importer of record for the

subject merchandise from China.  
IV‐3

Table IV-2 

Boltless steel shelving: U.S. imports by source, 2011-13, January-June 2013, and January-June 

2014 

                    *                    *                    *                    *                    *                    *                    *

Subject imports from China rose from a level of *** units in 2011 to *** units in 2012,

an increase of *** percent. Imports as reported in 2013 fell to *** units, a level *** percent

above import volume levels in 2011.6 During the first half of 2014, imports from China were ***

percent higher at *** units than reported during the first half of 2013. Imports of boltless steel

shelving from other countries (i.e., ***), which accounted for *** percent of total U.S. imports,

followed a similar trend as U.S. imports from China.7

As a share of total domestic production, U.S. imports of boltless steel shelving from

China increased from *** percent in 2011 to *** percent in 2012, but fell to *** percent in

2013. The ratio of U.S. imports from China to U.S. production was higher at *** percent during

January‐June 2014 than *** percent in the comparable period of 2013.

NEGLIGIBILITY

The statute requires that an investigation be terminated without an injury

determination if imports of the subject merchandise are found to be negligible.8 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

 

6 In its postconference brief, the petitioner disputes the import data provided by ***, arguing that

the reported data should show larger volumes and greater increases. Petitioner’s postconference brief,

pp. 20‐23. *** subsequently provided a revision to their import data that addresses the petitioner’s

concern. *** confirmed that its import data has been correctly reported and accurately reflects the

company’s ***. *** explained, “***.” As previously indicated, *** provided data concerning the U.S.

imports of boltless steel shelving that it arranged for importation into the United States but reported

that it is not the importer of record for the merchandise. Its customers (***) are the importers of record

and confirmed that the imports arranged by *** were included in the import data that were reported in

their questionnaire responses. Therefore, the import quantity and value data reported by *** were

removed from the data presented in this staff report to avoid double counting the amounts. 7 The petitioner testified that there are no known U.S. imports of boltless steel shelving from

countries other than China. Conference transcript, p. 45 (Liss). The *** quantities of U.S. imports of

boltless steel shelving from *** presented in this staff report were reported by U.S. importer ***, which

indicated that the imported items were supplied by *** and the country of origin was ***.   8 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)).
IV‐4

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.9 Imports from China accounted

for *** (***) percent of total imports of boltless steel shelving by quantity during 2013.10

APPARENT U.S. CONSUMPTION AND U.S. MARKET SHARES  

According to the petitioner in these investigations, demand for boltless steel shelving in

the United States “has been healthy and increasing.”11 It added that, “Unlike other industries in

which demand is tied to factors such as residential construction or even the overall economy,

demand for boltless steel shelving is driven by price. Retail offers of promotions and discounts

for sales of the product tend to drive sales.”12  

Respondent Whalen argued that the common industry practice of regularly offering

discounted prices for boltless steel shelving has “weakened current demand for prepackaged

boltless steel shelving.” It added that its overall business is slightly declining.13

Table IV‐3 presents data on apparent U.S. consumption and U.S. market shares for

boltless steel shelving.14 These data show that apparent U.S. consumption, by quantity,

increased by *** percent from 2011 to 2013, but was *** percent lower in January‐June 2014

than in January‐June 2013. Apparent U.S. consumption, by value, showed similar trends from

2011 to 2013, but was *** percent higher in the first half of 2014 as compared with the first

half of 2013. The U.S. producers’ share of the domestic market (in terms of quantity) fell from

*** percent in 2011 to *** percent in 2012, rebounded in 2013 to *** percent, but was lower

at *** percent during January‐June 2014. Conversely, the Chinese share of the domestic market

(in terms of quantity) rose from *** percent in 2011 to *** percent in 2012, fell in 2013 to ***

percent, but was higher at *** percent during January‐June 2014.

Edsal’s direct subject imports from China and other Edsal‐arranged U.S. imports

together accounted for an increasing share of U.S. imports of the subject merchandise from

China and apparent U.S. consumption, as shown in table IV‐4.

 

9 Section 771 (24) of the Act (19 U.S.C § 1677(24)).

10 The petitioner argues that China accounts for all U.S. imports and that there are no other countries

that supply the United States with boltless steel shelving. Petitioner’s postconference brief, p. 16. 11 Petitioner’s postconference brief, p. 13. 12 Petitioner’s postconference brief, p. 14.

13 Whalen postconference brief, p. 17. 14 Due to errors in reported import shipment data, U.S. import data reported in questionnaire

responses are used in the calculation of apparent U.S. consumption.
IV‐5

Table IV-3 

Boltless steel shelving: U.S. shipments of domestic product, U.S. imports, and apparent U.S. 

consumption, 2011-13, January-June 2013, and January-June 2014 

                    *                    *                    *                    *                    *                    *                    *

Table IV-4 

Boltless steel shelving: Total imports from China, total apparent U.S. consumption, Edsal U.S. 

imports, by source, share of U.S. imports, and market share, 2011-13, January-June 2013, and 

January-June 2014 

                    *                    *                    *                    *                    *                    *                    *

V‐1

PART V: PRICING DATA

FACTORS AFFECTING PRICES

Raw material costs

Boltless steel shelving is primarily made from hot‐rolled steel with finishing components

for decking, such as wire racks and particle board. The price for domestic hot‐rolled sheet

increased to $887 per short ton in 2011, then declined and averaged $660 per short ton in

2012, $631 per short ton in 2013, and $666 per short ton in the first half of 2014 (figure V‐1).

Half of the U.S. producers reported that raw materials costs had increased while the other half

reported that raw materials costs had fluctuated since January 1, 2011. *** reported that it has

not been able to increase prices enough to offset the increased cost of materials. *** reported

that high variability in steel costs makes setting prices difficult. Nearly half of the 15 responding

importers reported that the cost of raw materials had increased since 2011; four reported that

costs had fluctuated; and the remaining reported either no change or decreased raw material

costs. Four importers commented that increased raw material costs lead to increased selling

prices.1 2

                                                      

1 ***.   2 Tabulations in Part V regarding general market characteristics include responses for *** which

provided information regarding the market. Although not the importer of record, its responses were

included with the importers as it arranges for importation of boltless steel shelving. However, it is not

included in the price analysis below as its sales were to importers of record that submitted

questionnaire responses.
V‐2

Figure V-1 

Average hot-rolled steel sheet prices (Midwest), monthly, January 2011-June 2014

Source: American Metal Market, www.amm.com, retrieved August 2014.

U.S. inland transportation costs

One of four responding U.S. producers and eight of 17 responding importers reported

that they typically arrange transportation for their customers. Responding U.S. producers

reported that U.S. inland transportation costs ranged from 2 to 15 percent, while importers

reported costs of less than 1 to 20 percent.

PRICING PRACTICES

Pricing methods

U.S. producers reported using transaction‐by‐transaction negotiations, contracts, price

lists and other methods for setting their prices. Importers reported using transaction‐by‐

transaction negotiations, set price lists, and other methods for price setting. As presented in
V‐3

table V‐1, U.S. producers were mixed in their price‐setting methods while importers sell

primarily by other methods.3

  

Table V-1 

Boltless steel shelving: U.S. producers and importers reported price setting methods, by number 

of responding firms1

* * * * * * *

U.S. producers and importers reported selling the vast majority of their boltless steel

shelving in the spot market (table V‐2).4

  

Table V-2 

Boltless steel shelving: U.S. producers’ and importers’ shares of U.S. commercial shipments by 

type of sale, 2013 

* * * * * * *

Sales terms and discounts

U.S. producers and importers typically quote prices on an f.o.b. basis. Half of the U.S.

producers (two) offer quantity and total volume discounts, while the other half offer no

discounts. The majority of responding importers do not offer discounts; however, some

importers that sell direct to retail customers and their suppliers may be expected to help offset

promotional discounts offered to retail customers. The petitioner described periods of

promotions, particularly upcoming Black Friday (day after Thanksgiving) sales, for which

retailers have already approached U.S. producers and importers for pricing quotes and the

petitioner alleges lost sales and revenue claims associated with such discounts and

promotions.5 U.S. producers and importers reported a mix of sales terms, including net 30, 60,

and 90 days, and, for some retailers, point‐of‐sale transactions.  

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 boltless steel shelving products shipped to

                                                      

3 Other methods include: market analysis (***), net landed cost plus margin (***), price matching

(***), catalogs (***), retail sales (***), and “negotiated price list considers product cost and features,

FOB shipping terms, required retail price points” (***).   4 *** reported that all of its sales are on a long‐term contract basis. Since table V‐2 is calculated

based on shipments, and *** had no commercial shipments, its long‐term contract data do not appear

in the table (see Part II, fn 3).   5 Conference transcript, pp. 9 (Cannon), 26‐28 (Quick), and 62 (Liss).
V‐4

unrelated U.S. customers during 2011‐13 and the first half of 2014. The Commission also

requested importers to provide quarterly data for the total quantity and purchase cost value of

the following boltless steel shelving products imported then sold directly to retail customers.  

Product 1.—77” Width x 24” Depth x 72” to 78” Height, 4‐level rack with steel wire

decking, with load capacity of 1,000 pounds to 2,500 pounds per level

Product 2.—77” Width x 24” Depth x 72” Height, 3‐level rack with steel wire decking,

with load capacity of 1,000 pounds to 2,500 pounds per level

Product 3.—36” Width x 18” Depth x 72” Height, 5‐level boltless/rivet steel shelving

with particle board deck, with load capacity of 250 pounds to 1,000 pounds per

level

Product 4.—48” Width x 24” Depth x 72” Height, 5‐level boltless/rivet steel shelving

with particle board deck, with load capacity of 250 pounds to 1,000 pounds per

level

Product 5.—34” to 36” Width x between 15” and 18” Depth x 60” Height, 4‐level

boltless/rivet steel shelving with particle board deck, with load capacity of 250

pounds to 1,000 pounds per level

Three U.S. producers and 13 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 U.S. producers accounted for approximately *** percent of their

shipments of boltless steel shelving by quantity between January 1, 2011 and June 30, 2014.

Cost data reported by importers covered *** percent of U.S. shipments of subject imports from

China but pricing data reported by importers covered only *** percent of U.S. shipments of

subject imports from China in the same period.6 7

                                                      

6 Data includes products that may not have met exact specifications or capacity but the products are

viewed to be competitive with the closest definition above. For example, *** reported *** data for

products *** which had capacities *** the maximum capacity threshold defined by the pricing products.

Importer *** submitted data with *** items it stated were competitive with the pricing definition of

product ***. Data for “***” is included in the data presented. Data for “***” which had a purchase cost

of approximately $*** per unit more were not included in the data. It accounted for about *** of its

sales of these *** products during the *** quarters for which it reported data (***). 7 Importer data includes the petitioner’s import data.  
V‐5

Price data for products 1‐5 are presented in tables V‐3 to V‐7 and figures V‐2 to V‐6.

Import cost data was also requested for direct import comparison. These data are included in

the tables below and figures are presented in Appendix D.

Table V-3 

Boltless steel shelving: 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 

* * * * * * *

Table V-4 

Boltless steel shelving: 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 

*            *            *            *           *            *            *

Table V-5 

Boltless steel shelving: 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 China2 China (cost)2

Price 

 (per unit) 

Quantity 

(units) 

Price

 (per unit) 

Quantity

(units) 

Margin

(percent) 

Price 

(per unit) 

Quantity

(units) 

2011: 

Jan.-Mar. $*** *** $60.36 2,535 *** $31.72 3,406

Apr.-June *** *** 58.23 2,515 *** 38.79 5,810

July-Sept. *** *** 60.23 2,417 *** 36.38 4,786

Oct.-Dec. *** *** 57.38 2,897 *** 35.01 6,612

2012: 

Jan.-Mar. *** *** 59.62 2,194 *** 35.46 4,259

Apr.-June *** *** 55.38 3,326 *** 46.25 11,785

July-Sept. *** *** 62.59 2,598 *** 41.40 4,627

Oct.-Dec. *** *** 56.70 3,418 *** 35.23 4,164

2013: 

Jan.-Mar. *** *** *** *** *** 37.78 3,596

Apr.-June *** *** *** *** *** 38.90 4,188

July-Sept. *** *** *** *** *** 33.52 2,496

Oct.-Dec. *** *** *** *** *** 36.42 4,336

2014: 

Jan.-Mar. *** *** *** *** *** 34.14 9,936

Apr.-June *** *** *** *** *** *** ***

1

 Product 3: 36” Width x 18” Depth x 72” Height, 5-level boltless/rivet steel shelving with particle board 

deck, with load capacity of 250 pounds to 1,000 pounds per level. 

2

 Prices and quantities presented for the United States and China are the U.S. producers’ and U.S. 

importers’ sales of boltless steel shelving. Prices and quantities presented for China (cost) are the U.S. 

importers’ purchase cost of boltless steel shelving. 

Source: Compiled from data submitted in response to Commission questionnaires. 
V‐6

Table V-6 

Boltless steel shelving: 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 China2 China (cost)2

Price 

(per unit) 

Quantity 

(units) 

Price

(per unit) 

Quantity

(units) 

Margin

(percent) 

Price 

(per unit) 

Quantity

(units) 

2011: 

Jan.-Mar. $*** *** $69.83 4,504 *** $*** ***

Apr.-June *** *** 67.04 4,699 *** *** ***

July-Sept. *** *** 72.47 4,016 *** *** ***

Oct.-Dec. *** *** 69.29 4,286 *** *** ***

2012: 

Jan.-Mar. *** *** 69.73 4,158 *** *** ***

Apr.-June *** *** 69.51 4,492 *** *** ***

July-Sept. *** *** 74.14 3,528 *** *** ***

Oct.-Dec. *** *** 65.00 5,630 *** 55.45 8,369

2013: 

Jan.-Mar. *** *** *** *** *** *** ***

Apr.-June *** *** *** *** *** *** ***

July-Sept. *** *** *** *** *** *** ***

Oct.-Dec. *** *** *** *** *** *** ***

2014: 

Jan.-Mar. *** *** *** *** *** *** ***

Apr.-June *** *** 60.48 10,317 *** *** ***

1

 Product 4: 48” Width x 24” Depth x 72” Height, 5-level boltless/rivet steel shelving with particle board 

deck, with load capacity of 250 pounds to 1,000 pounds per level. 

2

 Prices and quantities presented for the United States and China are the U.S. producers’ and U.S. 

importers’ sales of boltless steel shelving. Prices and quantities presented for China (cost) are the U.S. 

importers’ purchase cost of boltless steel shelving. 

Source: Compiled from data submitted in response to Commission questionnaires. 

Table V-7 

Boltless steel shelving: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 51

 and margins of underselling/(overselling), by quarters, January 2011-June 2014 

*            *            *            *           *            *            *

Figure V-2 

Boltless steel shelving: Weighted-average prices and quantities of domestic and imported product 

1, by quarters, January 2011-June 2014 

*            *            *            *           *            *            *
V‐7

Figure V-3 

Boltless steel shelving: Weighted-average prices and quantities of domestic and imported product 

2, by quarters, January 2011-June 2014 

*            *            *            *           *            *            *

Figure V-4 

Boltless steel shelving: Weighted-average prices and quantities of domestic and imported product 

3, by quarters, January 2011-June 2014 

*            *            *            *           *            *            *

Figure V-5 

Boltless steel shelving: Weighted-average prices and quantities of domestic and imported product 

4, by quarters, January 2011-June 2014 

*            *            *            *           *            *            *

Figure V-6 

Boltless steel shelving: Weighted-average prices and quantities of domestic and imported product 

5, by quarters, January 2011-June 2014 

*            *            *            *           *            *            *

Price trends

Overall, U.S. prices decreased during January 2011 to June 2014, whereas Chinese prices

decreased for products 1, 4, and 5, but increased for products 2 and 3. Table V‐8 summarizes

the price trends, by product and by country. The decrease in domestic prices ranged from ***

to *** percent during the period while the change in import prices ranged from a decrease of

*** percent to an increase of *** percent.

Table V-8 

Boltless steel shelving: Summary of weighted-average f.o.b. prices for products 1-5 from the 

United States and China 

* * * * * * *
V‐8

Price comparisons

As shown in table V‐9, prices for boltless steel shelving imported from China were below

those for U.S.‐produced boltless steel shelving in 18 of 68 instances; margins of underselling

ranged from 0.7 to 16.4 percent. In the remaining 50 instances, prices for boltless steel shelving

from China were between 3.3 and 126.3 percent above prices for the domestic product.

Table V-9 

Boltless steel shelving: Instances of underselling/(overselling) and the range and average of 

margins, by product, January 2011-June 2014 

Product 

Number of 

quarters of 

underselling

Number of 

quarters of 

(overselling)

Margins of underselling Margins of (overselling)

Average 

(percent)

Range (percent)

Average 

(percent)

Range (percent)

Min Max Min Max

1 *** *** -- -- -- *** *** *** 

2 *** *** *** *** *** *** *** *** 

3 *** *** -- -- -- *** *** *** 

4 *** *** -- -- -- *** *** *** 

5 *** *** *** *** *** -- -- -- 

Total 18 50 7.8 0.7 16.4 (47.1) (3.3) (126.3) 

Source: Compiled from data submitted in response to Commission questionnaires.

LOST SALES AND LOST REVENUE

The Commission requested U.S. producers of boltless steel shelving to report any

instances of lost sales or lost revenue they experienced due to competition from imports of

boltless steel shelving from China since January 1, 2011. Of the four responding U.S. producers,

***. The *** lost sales allegations totaled $*** and involved *** units of boltless steel shelving

and the *** lost revenue allegations totaled $*** and involved *** units of boltless steel

shelving. Staff contacted *** purchasers and a summary of the information obtained is

presented in tables V‐10 and V‐11.8

                                                      

8 *** reported *** lost sales and *** lost revenue allegations with regard to importer/purchaser ***.

The lost sales allegations accounted for *** units and $*** of the total alleged quantity and value of lost

sales. The lost revenue allegations accounted for *** units and $*** of the total alleged quantity and

value of lost revenue. *** stated it disagreed with these allegations. In its response to further questions,

*** stated that there was an ***. *** did not specify who *** was competing with, who won the sale,

or to which lost sale or lost revenue allegation(s) it was referring.
V‐9

Table V-10 

Boltless steel shelving: U.S. producer’s lost sales allegations 

*            *            *            *           *            *            *

Table V-11 

Boltless steel shelving: U.S. producer’s lost revenue allegations 

*            *            *            *           *            *            *

Over half of responding purchasers provided comments regarding the allegations. ***

stated for its *** allegations, ***.

In response to the *** in which it was named, *** stated, “***”.

*** stated it “makes its buying determinations based on a number of factors, price

being one factor.”

*** stated, “The merchants currently in role at *** within this category are not aware of

a domestic lost sale in the Fall of 2013 as described above. We were not able to contact the

merchant who was in role at the time to confirm whether the allegation is accurate because

they are no longer with the company.”  

*** stated, “Edsal Manufacturing, Inc. Chicago, IL, is the sole supplier to *** for ***. As

such, the per unit purchase prices of *** were the offer prices presented by Edsal and accepted

by *** at the time of purchase. *** purchased the items domestically. Edsal indicated that the

items were made in China.”

***.9 ***.10

Purchasers responding to the lost sales allegations also were asked whether they shifted

their purchases of boltless steel shelving from U.S. producers to suppliers of boltless steel

shelving from China since 2011. In addition, they were asked whether U.S. producers reduced

their prices in order to compete with suppliers of boltless steel shelving from China. *** of the

*** responding purchasers reported that they had shifted purchases of boltless steel shelving

from U.S. producers to subject imports since 2011; *** of these purchasers reported that price

was the reason for the shift. *** purchasers reported that the U.S. producers had reduced their

prices in order to compete with the prices of subject imports since 2011.

Table V-12 

Boltless steel shelving: Purchasers’ responses regarding shifting supply and price reductions 

*            *            *            *           *            *            *

                                                      

9 Petitioner’s postconference brief, p. 31 and exhibit 5.

10 Staff telephone interview with ***; and e‐mail from ***.
V‐10

In addition to their responses to the questions above, *** provided additional

comments on their purchasing decisions. *** stated “***” *** stated, “***.” *** stated it has

“***"
VI‐1

PART VI: FINANCIAL EXPERIENCE OF U.S. PRODUCERS

BACKGROUND

Four U.S. producers, Edsal, Hallowell, Hirsh, and Tennsco, which accounted for all U.S.

production of boltless steel shelving during the period of investigation, supplied financial data

on their boltless steel shelving operations. However, *** for each period examined. Even

though Edsal’s fiscal year ends July 31 and Tennsco’s fiscal year ends March 31, their reported

financial data are based on calendar year.  No firms reported any transfers to related parties or

any internal consumption of boltless steel shelving.

OPERATIONS ON BOLTLESS STEEL SHELVING

Table VI‐1 presents aggregate income‐and‐loss data for the U.S. producers. Even though

net sales quantities and values increased continuously from 2011 to 2013, the financial

condition of the domestic boltless steel shelving industry deteriorated between 2011 and 2013.

Operating profits of the U.S. producers decreased substantially during the same period. While

the domestic industry continued to report *** between 2011 and 2013, the level declined from

*** in 2011 to *** in 2012, and to *** in 2013. Between 2011 and 2013, the increase in per‐

unit total cost1

, despite the increase in per‐unit sales value (by *** per unit), resulted in a lower

per‐unit operating income in 2013 (by *** per unit compared to 2011). Accordingly, the

operating income.margin decreased from *** in 2011 to *** in 2013, reflecting mainly the

increase in per‐unit total cost (by ***).  

Both net sales quantities and values were lower in January‐June (“interim”) 2014 than

interim 2013. Operating income in interim 2013 (***) changed to *** in interim 2014, due

mainly to *** higher per‐unit total cost, despite higher per‐unit sales value in interim 2014. As a

result, the operating income margin, which was *** percent in interim 2013, was *** percent in

interim 2014.  

Table VI-1 

Boltless steel shelving: Results of operations of U.S. producers, fiscal years 2011-13, JanuaryJune 2013, and January-June 2014 

* * * * * * * 

Table VI‐2 presents selected company‐by‐company data. Total net sales (quantities and

values), operating income (loss), the ratio of operating income (loss) to net sales, and per‐unit

values (sales, COGS, SG&A, and operating income), are presented in this table on a firm‐by‐firm

basis. *** between 2011 and 2013 and *** in January‐June 2014 than in January‐June 2013.

***. While ***. ***.

 

1 Total cost is cost of goods sold (“COGS”) and selling, general, and administrative (“SG&A”) expenses

combined.
VI‐2

Of the three producers (all except Hallowell), which reported production and sales in all

periods, all three experienced *** between 2011 and 2013. ***.2 Hirsh’s *** compared to

those costs in the prior periods. Hirsh responded to Commission staff’s inquiry about these

increases by noting that ***.3 ***.

No producer reported any inputs purchased from a related firm. ***.4

All producers reported operating income between 2011 and 2013 and also in interim

2013, while *** reported operating losses in interim 2014.

Table VI-2 

Boltless steel shelving: Results of operations of U.S. producers, by firm, fiscal years 2011-13, 

January-June 2013, and January-June 2014 

* * * * * * * 

Selected aggregate per‐unit cost data of the producers on their operations, i.e., COGS

and SG&A expenses, are presented in table VI‐3.  Overall per‐unit COGS and total cost (which

includes SG&A expenses) increased between 2011 and 2013 (though they decreased slightly

from 2012 to 2013), driven mainly by changes in raw material costs (it was mainly due to the

actual increases of raw material costs as well as changes in product mix, as explained earlier).

Per‐unit SG&A expenses decreased somewhat during the same period. Per‐unit COGS and per‐

unit total costs were higher in interim 2014 compared to interim 2013, due to the ***.

However, per‐unit sales price and cost data by each producer were largely affected by product

mix, based on the emails from two of the producers, ***. The ratio of total COGS to net sales

increased *** between 2011 and 2013 (from *** percent to *** percent), and was higher in

interim 2014 than in interim 2013 (*** percent compared to *** percent).

Table VI-3 

Boltless steel shelving: Average unit costs of U.S. producers, fiscal years 2011-13, January-June 

2013, and January-June 2014 

* * * * * * * 

A variance analysis showing the effects of prices and volume on the producers’ sales of

boltless steel shelving, and the effects of costs and volume on their total costs is presented in

table VI‐4.5 The information for this variance analysis is derived from table VI‐1. The analysis

 

2 E‐mail from ***, September 12, 2014.

3 E‐mail from ***, September 11, 2014. 4 E‐mail from ***, September 12, 2014. 5 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 or expense variance (in the case of the COGS and SG&A expense

variance), and a volume variance.  The sales or cost/expense variance is calculated as the change in unit

price or per‐unit cost/expense times the new volume, while the volume variance is calculated as the

change in volume times the old unit price or per‐unit cost/expense.  Summarized at the bottom of the
VI‐3

indicates that the decrease in operating income between 2011 and 2013 (by ***) was the result

of the negative effect of increased per‐unit costs and expenses, despite increased sales price

and volume. The summary at the bottom of the table illustrates that the negative effect of

increased costs and expenses (***), the positive effects of increased prices (***) and higher

sales quantities (***) between 2011 and 2013. Comparing the two interim periods, the variance

analysis indicates that operating income was lower by (***) which resulted from the combined

negative effects of higher costs and expenses (***) and lower sales volume (***), despite the

increased sales price (***).

Table VI-4 

Boltless steel shelving: Variance analysis of operations of U.S. producers, fiscal years 2011-13, 

January-June 2013, and January-June 2014 

* * * * * * * 

CAPITAL EXPENDITURES AND RESEARCH AND DEVELOPMENT EXPENSES

Table VI‐5 presents aggregate data on capital expenditures and research and

development (“R&D”) expenses. Only *** producers reported capital expenditures. Capital

expenditures decreased *** between 2011 and 2013. Data for capital expenditures on a  

firm‐by‐firm basis are shown in table VI‐6. The majority of capital expenditures were reported

by ***. *** reported R&D expenses.

Table VI-5 

Boltless steel shelving: Capital expenditures and R&D expenses by U.S. producers, fiscal years 

2011-13, January-June 2013, and January-June 2014 

* * * * * * * 

Table VI-6 

Boltless steel shelving: Capital expenditures by U.S. producers, by firms, fiscal years 2011-13, 

January-June 2013, and January-June 2014 

* * * * * * * 

 

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 net volume variance is the sum of the price, COGS, SG&A

volume variance. All things equal, a stable overall product mix generally enhances the utility of the

Commission’s variance analysis.
VI‐4

ASSETS AND RETURN ON ASSETS

Table VI‐7 presents data on the U.S. producers’ total net assets and their return on

assets. Total net assets remained relatively at the same level between 2011 and 2013. At the

same time, the return on assets decreased between 2011 and 2013 due to lower operating  

income during the same period. The trend of return on assets during 2011‐13 was the same as

the trend of the operating income (loss) margin shown in table VI‐1.

Table VI-7 

Boltless steel shelving: Value of assets and return on assets of U.S. producers, fiscal years 2011-

13 

* * * * * * * 

CAPITAL AND INVESTMENT

The Commission requested U.S. producers to describe any actual negative effects on

their return on investment, or their growth, investment, ability to raise capital, existing

development and production efforts, or the scale of capital investments as a result of imports

of boltless steel shelving from China. Their comments are as follows:

Actual Negative Effects

Edsal.–***

Hallowell.–***

Hirsh.–***

Tennsco.–***

Anticipated Negative Effects

Edsal.–***

Hallowell.–***

Hirsh.–***

Tennsco.–***
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.3

  

                                                            

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.”

3 Global Trade Atlas (“GTA”) export and import data are not presented in this staff report because

such data comprise too large of a basket category to be meaningful. The data reported by GTA under

which the subject boltless steel shelving are included are for the 6‐digit level subheadings 9403.10 and

9403.20 (other metal household and office furniture (e.g., shelves, counters, lockers, display cases,

partitions, bed railings, cribs, play enclosures, ironing boards, filing cabinets, etc.)). Based on information

(continued...)
VII‐3

THE INDUSTRY IN CHINA

Background

The Chinese boltless steel shelving industry is comprised of approximately 32 Chinese

producers.4

According to the petitioner, the five largest Chinese producers of steel shelving are

***.5 Chinese producer Edsal Sandusky, established in 2006, is owned by the petitioner.6

Although some producers have reportedly exited the Chinese industry,7 responding Chinese

producer Guangdong Guanyu Metal Products Co., Ltd. (“Guangdong Guanyu”) was founded in

May of 2013 and began production ***.8  

Operations on boltless steel shelving

The Commission issued foreign producers’ or exporters’ questionnaires to 25 firms

believed to produce and/or export boltless steel shelving in China.9 Usable responses to the

Commission’s questionnaire were received from four firms: Edsal Sandusky Corp. Zhongshan

(“Edsal Sandusky”); HoiFat (NingBo) Office Facilities Co., Ltd. (“HoiFat”); Intradin (Shanghai)

Machinery Co., Ltd. (“Intradin”); and Guangdong Guanyu. The exports to the United States

reported by the four responding Chinese producers combined were equivalent to *** percent

                                                            

(...continued)

reported in Commission questionnaire responses, subject boltless steel shelving accounted for ***

percent of total exports from China in 2013, as reported by GTA under subheadings 9403.10 and

9403.20. 4 This includes 20 producers identified by the petitioner (USITC staff found one producer identified

twice in the petitioner’s list) and 12 producers that were identified by U.S. importers in their responses

to Commission questionnaires. Petitions, exh. GEN‐7 and responses to U.S importers’ questionnaires. In

addition to the foreign producers of subject merchandise in China that were identified in the petitions or

in importer questionnaires, Kunshan Xingyue Zhaoyuan Metal Products Co., Ltd.; Hangzhou Great Star

Industrial Co., Ltd.; Kunshan Wheelink Metal Product Co., Ltd.; and Ningbo ETDZ Huixing Trade Co., Ltd.

submitted information to Commerce on their exports to the United States of boltless steel shelving

produced in China. 5 Petitions, exh. GEN‐2, p. 5.

6 Edsal Sandusky Corporation Zhongshan, “Welcome to the website of Edsal Sandusky Corporation

Zhongshan,” http://www.edsal.com.cn/ (accessed September 25, 2014). 7 Conference transcript, p. 90 (Whalen). According to Whalen, a foreign producer’s excess capacity in

China typically does not lead to increased production in what it describes as a low‐margin industry.

Instead, Whalen explained that it often leads to producers leaving the market. It added that of its six

Chinese suppliers, only two currently produce boltless steel shelving and four have switched production

to other products. Whalen postconference brief, pp. 19‐20.   8 Guangdong Guanyu postconference letter.

9 These firms were identified through a review of information submitted in the petitions and

contained in proprietary Customs records.  
VII‐4

of reported U.S. imports of boltless steel shelving from China during 2013, as calculated from

Commission importer questionnaire responses.  

The petitioner notes that the Commission is missing foreign producer questionnaire

responses “from 16 known producers, including several of the very largest producers and

exporters of subject product with significant capacity and idle capacity.”10 It estimated that the

reported data represents *** percent of Chinese production of boltless steel shelving industry.

It added that the current capacity to produce boltless steel shelving in China is *** the size of

the U.S. market at an estimated capacity of *** units annually.11

Table VII‐1 presents information on the boltless steel shelving operations of the

responding producers in China. The aggregate reported annual capacity of the four responding

firms to produce boltless steel shelving in China increased by 68.4 percent from 617,500 units in

2011 to 1.04 million units in 2013. The firms’ reported capacity was once again higher in

January‐June 2014 than in January‐June 2013. Reported production by the four firms in China

increased overall by 7.2 percent from 2011 to 2013, and was 89.7 percent higher in January‐

June 2014 than in January‐June 2013, for the most part reflecting ***. Boltless steel shelving

production in China, as reported by the four responding producers, is projected to increase by

58.4 percent from 2013 to 2015. Capacity utilization fell from 62.8 percent in 2011 to 39.9

percent in 2013, but was higher at 60.2 percent in January‐June 2014 than reported in January‐

June 2013. Projections indicate that capacity utilization in China is expected to decline slightly

to 57.8 percent in 2015.

In 2013, *** percent of total reported shipments of boltless steel shelving produced in

China was exported to the United States. Exports from China to the United States increased

overall by *** percent from 2011 to 2013, and were higher in January‐June 2014 than in

January‐June 2013. However, projections indicate that exports to the United States will be

lower in 2014 and 2015 than reported in 2013. In 2013, *** percent of total shipments of

boltless steel shelving produced in China were exported to markets other than the United

States. Edsal Sandusky reported ***. Guangdong Guanyu reported ***. HoiFat reported ***.

Intradin reported ***. ***. The aggregate home market shipments of boltless steel shelving

accounted for *** percent of total Chinese shipments in 2013.

                                                            

10 Petitioner’s postconference brief, p. 4. 11 Petitioner’s postconference brief, pp. 41‐42, and exhibit 1, p. 1.
VII‐5

Table VII-1 

Boltless steel shelving: Data for producers in China, 2011-13, January-June 2013, and JanuaryJune 2014 

Item 

Actual experience Projections 

Calendar year January-June Calendar year 

2011 2012 2013 2013 2014 2014 2015 

 Quantity (units) 

Capacity1 617,500 790,000 1,040,000 400,000 555,000 1,054,000 1,138,000

Production 387,522 385,459 415,359 176,018 333,858 644,000 658,000

End-of-period inventories *** *** *** *** *** *** ***

Shipments: 

 Internal consumption/ 

 Transfers *** *** *** *** *** *** ***

 Home market shipments *** *** *** *** *** *** ***

Export shipments to: 

 United States *** *** *** *** *** *** ***

All other markets2 *** *** *** *** *** *** ***

Total exports *** *** *** *** *** *** ***

Total shipments *** *** *** *** *** *** ***

 Ratios and shares (percent) 

Capacity utilization 62.8 48.8 39.9 44.0 60.2 61.1 57.8

Inventories/production *** *** *** *** *** *** ***

Inventories/total shipments *** *** *** *** *** *** ***

Share of total shipments: 

 Internal consumption/ 

 Transfers *** *** *** *** *** *** ***

 Home market shipments *** *** *** *** *** *** ***

Export shipments to: 

 United States *** *** *** *** *** *** ***

All other markets2 *** *** *** *** *** *** ***

Total exports *** *** *** *** *** *** ***

Total shipments *** *** *** *** *** *** ***

1

 The production capacity reported is based on operating *** hours per week, *** weeks per year. 

2 ***. 

Source: Compiled from data submitted in response to Commission questionnaires. 
VII‐6

Listed in table VII‐2 are summary production and shipment data for the responding

Chinese producers of boltless steel shelving, by firm.

Table VII-2 

Boltless steel shelving: Summary data of responding producers in China, January 2011-June 2014 

                    *                    *                    *                    *                    *                    *                    *

Edsal Sandusky (the Chinese manufacturer that is *** by the petitioner) accounted for

*** percent of reported production in China during January 2011‐June 2014. The firm reported

that *** percent of its total sales in the most recent fiscal year were sales of boltless steel

shelving. The Chinese company reported that during January 2011‐June 2014, *** percent of its

total shipments were exports to the United States, ***. *** of Edsal Sandusky’s total shipments

of boltless steel shelving during January 2011‐June 2014 was made to the Chinese market. The

firm’s largest U.S. importers include ***.

Guangdong Guanyu, which began production of boltless steel shelving in China during

***. The firm reported that *** percent of its total sales in the most recent fiscal year were

sales of boltless steel shelving. The company reported that during 2013, *** percent of its total

shipments were exports to the United States, with *** of the remainder going to other export

markets (***). Guangdong Guanyu reported that *** U.S. importer of its boltless steel shelving

but noted ***.

HoiFat, ***, accounted for *** percent of reported production in China during January

2011‐June 2014. The firm reported that *** percent of its total sales in the most recent fiscal

year were sales of boltless steel shelving. The Chinese company reported that during January

2011‐June 2014, *** percent of its total shipments were exports to the United States, with ***

of the remainder going to other export markets (***). *** of HoiFat’s boltless steel shelving

was shipped to the Chinese market during January 2011‐June 2014. The firm’s largest U.S.

importers include ***.

Intradin accounted for *** percent of reported production in China during January

2011‐June 2014. The firm reported that *** percent of its total sales in the most recent fiscal

year were sales of boltless steel shelving. The Chinese company reported that, during January

2011‐June 2014, ***. The firm’s largest U.S. importer is ***.

In the Commission’s questionnaire, producers in China were asked if they experienced

any plant openings, plant closings, relocations, expansions, acquisitions, consolidations,

prolonged shutdowns or production curtailments, or revised labor agreements since January 1,

2011.  The data reported in the questionnaire responses of *** Chinese producers indicate an

increase in each of the firms’ capacity to produce boltless steel shelving. Intradin reported

capacity ***. Edsal Sandusky not only reported ***, it also indicated ***. Chinese producer

HoiFat reported ***. The data provided by Guangdong Guanyu *** indicate that the firm began

production of boltless steel shelving during ***. Concerning changes to its business, Guangdong

Guanyu indicated only that “***.”

Producers in China were asked if they anticipate any changes in the character of their

operations or organization relating to the production of boltless steel shelving in the future. ***
VII‐7

do not anticipate any changes in the future, whereas *** indicated that certain changes to the

character of their operations are expected. Table VII‐3 summarizes the responses of ***

concerning such anticipated changes.

Table VII-3 

Boltless steel shelving: Chinese producers’ anticipated changes in operations 

                    *                    *                    *                    *                    *                    *                    *

Alternative products

Chinese producers Intradin and HoiFat reported ***, while Chinese producers Edsal

Sandusky and Guangdong Guanyu reported ***. Edsal Sandusky indicated ***. Since beginning

boltless steel production ***, Guangdong Guanyu reported ***.  

Aggregate data regarding the overall facility capacity and production of the four

responding Chinese producers of boltless steel shelving are presented in table VII‐4. These data

show that, prior to the establishment of production by Guangdong Guanyu in 2013, boltless

steel shelving accounted for *** of the reporting firms’ overall plant production.

Table VII-4 

Boltless steel shelving: Overall plant capacity, production, and capacity utilization in China, 2011-

13, January-June 2013, and January-June 2014 

                    *                    *                    *                    *                    *                    *                    *

U.S. INVENTORIES OF IMPORTED MERCHANDISE

Table VII‐5 presents data on U.S. importers’ reported inventories of boltless steel

shelving. End‐of‐period inventories of subject merchandise increased overall by *** percent

from 2011 to 2013, but were *** percent lower in June 2014 than reported in June 2013. As a

share of U.S. imports, inventories fell overall from *** percent in 2011 to *** percent in 2013.

The ratio of inventories to U.S. imports was lower during January‐June 2014 than reported in

January‐June 2013. U.S. importers *** accounted for *** percent of total end‐of‐period

inventories of the subject merchandise held in the United States at yearend 2013.

Table VII-5 

Boltless steel shelving: U.S. importers’ inventories, 2011-13, January-June 2013, and JanuaryJune 2014 

                    *                    *                    *                    *                    *                    *                    *
VII‐8

U.S. IMPORTERS’ OUTSTANDING ORDERS

The Commission requested importers to indicate whether they imported or arranged for

the importation of boltless steel shelving from China after June 30, 2014. These data are

presented in table VII‐6.12 Reported imports of boltless steel shelving arranged for entry into

the United States from China are expected to increase by *** percent from the third to the

fourth quarter of 2014.  However, reported arranged imports of subject merchandise are

expected to fall by *** percent from the fourth quarter of 2014 to the first quarter of 2015.

According to reported data, a relatively smaller increase in arranged imports is expected during

the second quarter of 2015.

Table VII-6 

Boltless steel shelving: U.S. importers’ arranged imports, July-September 2014, OctoberDecember 2014, January-March 2015, and April-June 2015 

                    *                    *                    *                    *                    *                    *                    * 

ANTIDUMPING OR COUNTERVAILING DUTY ORDERS IN THIRD‐COUNTRY MARKETS

The four responding Chinese producers reported that they were unaware of any

antidumping and/or countervailing duty findings, remedies, or proceedings in countries other

than the United States for the boltless steel shelving they export. The petitioner is not aware of

any either.13

                                                            

12 The petitioner points out that the data collected on arranged imports in the Commission’s

questionnaire responses do not account for future sales that were made after the questionnaire

responses were submitted to the Commission. It notes that actual imports for full year 2014, which it

argues are ***.” The petitioner points out, in particular, ***. Petitioner’s postconference brief, p. 19.

13 Petitioner’s postconference brief, exh. 1, p. 2.
VII‐9

INFORMATION ON NONSUBJECT COUNTRIES

In assessing whether the domestic industry is materially injured or threatened with

material injury “by reason of subject imports,” the legislative history states “that the

Commission must examine all relevant evidence, including any known factors, other than the

dumped or subsidized imports, that may be injuring the domestic industry, and that the

Commission must examine those other factors (including non‐subject imports) ‘to ensure that it

is not attributing injury from other sources to the subject imports.’”14

The petitioner stated that there are currently no nonsubject imports of boltless steel

shelving, citing both the petitioner’s and Whalen’s testimony and responses to Commission U.S.

importers’ questionnaire.15 However, Whalen did state that approximately ten years ago there

were some imports from Mexico.16 Commission staff determined from questionnaire responses

that there are likely imports of boltless steel shelving from ***, but have not yet located

specific information regarding the volume of production by the industry in ***.17

The petitioner indicated that it believes that, in addition to the United States and China,

there are producers of boltless steel shelving in Mexico (Tam‐Mex, SA de CV), Canada

(Rousseau Metal), Poland (Metalka), and Australia (Summit Storage Solutions).18

                                                            

14 Mittal Steel Point Lisas Ltd. v. United States, Slip Op. 2007‐1552 at 17 (Fed. Cir. Sept. 18, 2008),

quoting from Statement of Administrative Action on Uruguay Round Agreements Act, H.R. Rep. 103‐316,

Vol. I at 851‐52; see also Bratsk Aluminum Smelter v. United States, 444 F.3d 1369 (Fed. Cir. 2006).

15 Petitioner’s postconference brief, p. 15; and conference transcript, p. 19 (Liss).   16 Conference transcript, p. 112 (Whalen) and pp. 43‐44 (Liss). 17 For example, https://beatties‐

store.basics.com/webapp/wcs/stores/servlet/Product_10551_10201_41829_‐

1_Safco_Boltless_Steel_Shelving_4812_x_1814 (accessed September 24, 2014).

18 Petitioner’s postconference brief, exhibit 1, p. 2.

A‐1

APPENDIX A

FEDERAL REGISTER NOTICES  

A‐3

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 52040

September 2,

2014

Boltless Steel Shelving Units

Prepackaged for Sale From China;

Institution of Antidumping and

Countervailing Duty Investigations

and Scheduling of Preliminary Phase

Investigations

http://www.gpo.gov/fdsys/pkg/FR‐

2014‐09‐02/pdf/2014‐20780.pdf  

79 FR 56562

September 22,

2014

Boltless Steel Shelving Units

Prepackaged for Sale From the

People’s Republic of China: Initiation

of Antidumping Duty Investigation

http://www.gpo.gov/fdsys/pkg/FR‐

2014‐09‐22/pdf/2014‐22491.pdf  

79 FR 56567

September 22,

2014

Boltless Steel Shelving Units

Prepackaged for Sale From the

People’s Republic of China: Initiation

of Countervailing Duty Investigation

http://www.gpo.gov/fdsys/pkg/FR‐

2014‐09‐22/pdf/2014‐22494.pdf

B‐1

APPENDIX B

CALENDAR OF THE PUBLIC STAFF CONFERENCE

‐ 3 ‐ 

CALENDAR OF PUBLIC PRELIMINARY CONFERENCE

Those listed below appeared as witnesses at the United States International 

Trade Commission’s preliminary conference: 

Subject: Boltless Steel Shelving Units Prepackaged for Sale from 

China 

Inv. Nos.: 701-TA-523 and 731-TA-1259 (Preliminary) 

Date and Time: September 16, 2014 - 9:30 am 

Sessions were held in connection with these preliminary investigations in the Main Hearing 

Room (room 101), 500 E Street, S.W., Washington, DC. 

OPENNG REMARKS: 

Petitioner (Kathleen W. Cannon, Kelley, Drye & Warren LLP) 

Respondents (Mark D. Herlach, Sutherland Asbill & Brennan LLP) 

 

 

In Support of the Imposition of 

Antidumping and Countervailing Duty Orders: 

Kelley, Drye & Warren LLP 

Washington, DC 

on behalf of 

Edsal Manufacturing Company 

 Mitchell Liss, Vice President, Edsal Manufacturing Company 

Chris Quick, Sales Director, Edsal Manufacturing Company 

 

 Gina Beck, Economist, Georgetown Economic Services 

 

 Kathleen R. Cannon ) 

Paul C. Rosenthal ) – OF COUNSEL 

R. Alan Luberda ) 

 
‐ 4 ‐ 

In Opposition to the Imposition of 

Antidumping and Countervailing Duty Orders: 

 

Sutherland Asbill & Brennan LLP 

Washington, DC 

on behalf of 

Whalen LLC 

 Kenneth Whalen, President, Whalen LLC 

 

Mark D. Herlach ) 

 ) – OF COUNSEL 

 Charlie Kruly ) 

 

REBUTTAL/CLOSING REMARKS:

Petitioner (Kathleen W. Cannon, Kelley, Drye & Warren LLP) 

Respondents (Mark D. Herlach, Sutherland Asbill & Brennan LLP) 
C‐1

APPENDIX C

SUMMARY DATA

C‐3

Table C-1 

Boltless shelving: Summary data concerning the U.S. market, 2011-13, January to June 2013, and 

January to June 2014   

                    *                    *                    *                    *                    *                    *                    *

        

D‐1

APPENDIX D

QUARTERLY DOMESTIC PRICE AND IMPORT COST DATA

D‐3

Figures D‐1 through D‐5 present data on domestic sales prices of the five pricing

products described in Part V, as well as import cost data for those five products. Import cost

data do not reflect sales inside the United States but rather the cost to the importer to import

subject merchandise.   

 

Figure D-1 

Boltless steel shelving: Weighted-average import costs and quantities of domestic and imported 

product 1, by quarters, January 2011-June 2014 

*            *            *            *           *            *            *

Figure D-2 

Boltless steel shelving: Weighted-average import costs and quantities of domestic and imported 

product 2, by quarters, January 2011-June 2014 

*            *            *            *           *            *            *

Figure D-3 

Boltless steel shelving: Weighted-average import costs and quantities of domestic and imported 

product 3, by quarters, January 2011-June 2014 

*            *            *            *           *            *            *

Figure D-4 

Boltless steel shelving: Weighted-average import costs and quantities of domestic and imported 

product 4, by quarters, January 2011-June 2014 

*            *            *            *           *            *            *

Figure D-5 

Boltless steel shelving: Weighted-average import costs and quantities of domestic and imported 

product 5, by quarters, January 2011-June 2014 

*            *            *            *           *            *            *