U.S. International Trade Commission

Publication 4162 June 2010

Washington, DC 20436

Prestressed Concrete Steel Wire Strand 

from China

Investigation Nos. 701-TA-464 and 731-TA-1160 (Final)
U.S. International Trade Commission

COMMISSIONERS

Deanna Tanner Okun, Chairman

Charlotte R. Lane

Daniel R. Pearson

Shara L. Aranoff

Irving A. Williamson

Dean A. Pinkert

Robert B. Koopman

Acting Director of Operations

Staff assigned

Mary Messer, Investigator

Jeremy Wise, Industry Analyst

Joshua Levy, Economist

Mary Klir, Accountant

Peter Sultan, Attorney

Mara Alexander, Statistician

Douglas Corkran, Supervisor Investigator

Address all communications to

Secretary to the Commission

United States International Trade Commission

Washington, DC 20436
U.S. International Trade Commission

Washington, DC 20436 

www.usitc.gov

Publication 4162 June 2010

Prestressed Concrete Steel Wire Strand 

from China

Investigation Nos. 701-TA-464 and 731-TA-1160 (Final)
 
CONTENTS

Page

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 the report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-3

U.S. market summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-3

Summary data and data sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-4

Previous and related investigations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-4

Antidumping and countervailing duty investigations and reviews . . . . . . . . . . . . . . . . . . . . . I-4

Safeguard investigations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-6

Nature and extent of subsidies and sales at LTFV . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-7

Subsidies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-7

Sales at LTFV . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

The subject merchandise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

Commerce’s scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

Tariff treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-9

The domestic like product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-10

Description and applications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-10

Manufacturing process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-12

Domestic like product issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-13

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

U.S. market characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1

Channels of distribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-2

Supply and demand considerations ................................................ II-2

Supply ................................................................... II-2

U.S. demand . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6

Substitutability issues .......................................................... II-10

Factors affecting purchasing decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-11

Comparison of domestic products, Chinese, and nonsubject imports ................... II-14

Elasticity estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-15

U.S. supply elasticity ........................................................ II-15

U.S. demand elasticity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-16

Substitution elasticity ....................................................... II-16

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

U.S. producers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1

U.S. capacity, production, and capacity utilization ................................... III-3

U.S. producers’ raw material supply ............................................... III-5

U.S. producers’ shipments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-6

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

U.S. producers’ imports and purchases ............................................. III-9

U.S. employment, wages, and productivity ......................................... III-10
ii

CONTENTS

Page

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

U.S. importers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-1

U.S. imports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-1

Critical circumstances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-7

Negligibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-7

Apparent U.S. consumption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-11

U.S. market shares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-13

Ratio of imports to U.S. production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-15

Part V: Pricing and related information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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-3

Price comparisons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-7

Lost sales and lost revenues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-8

Part VI: Financial experience of the U.S. producers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-1

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-1

Operations on PC strand . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-1

Variance analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-4

Capital expenditures and research and development expenses . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-4

Assets and return on investment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-5

Capital and investment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-6

Actual negative effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-6

Anticipated negative effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-6

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

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VII-1

The industry in China .......................................................... VII-4

U.S. inventories of PC strand . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VII-9

U.S. importers’ current orders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VII-10

Antidumping investigations in third-country markets ................................. VII-11

Appendixes

A. Federal Register notices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

B. Hearing calendar . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

C. Summary data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1

D. Nonsubject country and aggregated price data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1

Note.–Information that would reveal confidential operations of individual concerns may not be published

and therefore has been deleted from this report. Such deletions are indicated by asterisks.
UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation Nos. 701-TA-464 and 731-TA-1160 (Final)

PRESTRESSED CONCRETE STEEL WIRE STRAND 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 705(b) and 735(b) of the Tariff Act of

1930 (19 U.S.C. §§ 1671d(b) and 1673d(b)) (the Act), that an industry in the United States is materially

injured by reason of imports from China of prestressed concrete steel wire strand (PC strand), provided

for in subheading 7312.10.30 of the Harmonized Tariff Schedule of the United States, that have been

found by the Department of Commerce (Commerce) to be subsidized by the Government of China and

that have been found by Commerce to be sold in the United States at less than fair value (LTFV).

BACKGROUND

The Commission instituted these investigations effective May 27, 2009, following receipt of a

petition filed with the Commission and Commerce by American Spring Wire Corp. (Bedford Heights,

OH); Insteel Wire Products Co. (Mt. Airy, NC); and Sumiden Wire Products Corp. (Dickson, TN). The

final phase of the investigations was scheduled by the Commission following notification of preliminary

determinations by Commerce that imports of PC strand from China were being subsidized and sold at

LTFV within the meaning of sections 703(b) and 733(b) of the Act (19 U.S.C. §§ 1671b(b) and

1673b(b)). Notice of the scheduling of the final phase of the Commission’s investigations and of a public

hearing 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 February 23, 2010 (75 FR 8113). The hearing was held in Washington, DC, on May

6, 2010, and all persons who requested the opportunity were permitted to appear in person or by counsel.

 1 The record is defined in sec. 207.2(f) of the Commission’s Rules of Practice and Procedure (19 CFR § 207.2(f)).
 
 1

 See Confidential Staff Report (“CR”) and Public Staff Report (“PR”) at Table I-1 and CR/PR at I-6. The

Commission recently completed five-year reviews of the outstanding antidumping and countervailing duty orders,

and determined that revocation of those orders would likely lead to continuation or recurrence of material injury to

an industry in the United States within a reasonably foreseeable time. Prestressed Concrete Steel Wire Strand from

Brazil, India, Japan, Korea, Mexico, and Thailand, 701-TA-432 and 731-TA-1024-1028 (Review) and AA1921-188

(Third Review), USITC Pub. 4114 (Nov. 2009) (“2009 Sunset Review Report”). 

 2

 19 U.S.C. § 1677(4)(A).

 3

 19 U.S.C. § 1677(4)(A).

 4

 19 U.S.C. § 1677(10).

 5

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

(continued...)

3

VIEWS OF THE COMMISSION

Based on the record in the final phase of these investigations, we find that the domestic industry

producing prestressed concrete steel wire strand (“PC strand”) is materially injured by reason of imports

of PC strand from China that the U.S. Department of Commerce (“Commerce”) has found to be

subsidized by the Government of China and sold in the United States at less than fair value.

I. BACKGROUND

The petition in these investigations was filed on May 27, 2009, by domestic producers American

Spring Wire Corp. (“American”), Insteel Wire Products Co. (“Insteel”), and Sumiden Wire Products

Corp. (“Sumiden”) (collectively, “Petitioners”). Petitioners participated in the final phase of these

investigations. No respondent participated as a party in the final phase of these investigations. Importers

accounting for most U.S. shipments of subject merchandise responded to the Commission’s

questionnaire, but there was no response from foreign producers in the final phase of these investigations. 

The Commission has conducted several previous antidumping and countervailing duty

investigations and five-year reviews concerning PC strand. There are currently antidumping duty orders

on imports of PC strand from Brazil, India, Japan, Korea, Mexico, and Thailand, and a countervailing

duty order on imports of PC strand from India.1

II. DOMESTIC LIKE PRODUCT

A. In General

In determining whether 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.”2

 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 {w}hole 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.”3

 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 . . .”4

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.5

 No single factor is dispositive, and the Commission
 5

 (...continued)

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).

 6

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

 7 Nippon, 19 CIT at 455; Torrington, 747 F. Supp. at 748-49; see also S. Rep. No. 96-249 at 90-91 (1979)

(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.”).

 8

 See, e.g., USEC, Inc. v. United States, 34 Fed. Appx. 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).

 9

 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).

 10 See, e.g., Acciai Speciali Terni S.p.A. v. United States, 118 F. Supp. 2d 1298, 1304-05 (Ct. Int’l Trade 2000);

Nippon, 19 CIT at 455; Asociacion Colombiana de Exportadores de Flores v. United States, 693 F. Supp. 1165,

1169 n.5 (Ct. Int’l Trade 1988); Citrosuco Paulista, S.A. v. United States, 704 F. Supp. 1075, 1087-88 (Ct. Int’l

Trade 1988).

4

may consider other factors it deems relevant based on the facts of a particular investigation.6

 The

Commission looks for clear dividing lines among possible like products and disregards minor variations.7

Although the Commission must accept the determination of Commerce as to the scope of the imported

merchandise that is subsidized or sold at less than fair value,8

 the Commission determines what domestic

product is like the imported articles Commerce has identified.9

 The Commission must base its domestic

like product determination on the record in these investigations. The Commission is not bound by prior

determinations, even those pertaining to the same imported products, but may draw upon previous

determinations in addressing pertinent domestic like product issues.10

B. Product Description

The Department of Commerce has defined the scope of the imported merchandise under

investigation as follows:

steel wire strand, other than of stainless steel, which is suitable for use in, but not

limited to, prestressed concrete (both pre-tensioned and post-tensioned)

applications. The scope of this investigation encompasses all types and diameters

of PC strand whether uncoated (uncovered) or coated (covered) by any

substance, including but not limited to, grease, plastic sheath, or epoxy. This

merchandise includes, but is not limited to, PC strand produced to the American

Society for Testing and Materials (ASTM) A-416 specification, or comparable
 11 75 Fed. Reg. 28557, 28558 (May 21, 2010) (final countervailing duty determination) and 75 Fed. Reg. 28560,

28561 (May 21, 2010) (final antidumping duty determination).

 12 CR/PR at I-3.

 13 Petitioners’ Prehearing Brief at 4.

 14 Petitioners’ Prehearing Brief at 6. 

 15 Petitioners’ Prehearing Brief at 6 and Hearing Tr. at 11 (Selhorst).

 16 Petitioners’ Prehearing Brief at 7. 

 17 Id.

 18 Id.

 19 Id.

5

domestic or foreign specifications. PC strand made from galvanized wire is

excluded from the scope if the zinc and/or zinc oxide coating meets 

or exceeds the 0.40 oz./ft2

 standard set forth in ASTM-A-475.11

PC strand is produced from hot-rolled, high-carbon steel wire rod which, after cleaning and

descaling, is drawn into wire, fabricated into multi-wire strand, and thermally stress-relieved. PC strand

is used to compress concrete structural members to improve their ability to withstand loads. The PC

strand is tensioned either prior to the pouring of concrete (pre-tensioning) or after the pouring of the

concrete (post-tensioning). Typical applications for prestressed concrete in which PC strand is used

include bridge decks, bridge girders, pilings, precast concrete panels and structural supports, roof trusses,

floor supports, and certain concrete foundations.12 

C. Petitioners’ Arguments

Petitioners urge the Commission to define the domestic like product as coextensive with the

scope of these investigations. At the outset, they note that this is the definition that the Commission has

used in previous investigations and reviews for PC strand, and they assert that no significant changes have

occurred to the production of PC strand, the nature of the product, or its uses, that would warrant a

different definition here.13

First, Petitioners argue all PC strand shares the same basic characteristics of a seven-wire strand,

and that much PC strand is of the same dimension (1⁄2 inch) and grade (270K), and is a low-relaxation

product. To the extent that there are different types of PC strand, these are variations of a single product,

according to Petitioners. All PC strand has the same general use, which is to impart compressive forces to

concrete.14 Second, Petitioners argue that PC strand is produced in accordance with ASTM specifications

for various types of the product. Within each type, PC strand is interchangeable.15 Third, almost all PC

strand is sold in the same channel of distribution, namely directly to end users.16 Fourth, all PC strand is

made using the same facilities, employees, and the same basic manufacturing process, according to

Petitioners.17 Fifth, Petitioners maintain that domestic producers and customers perceive PC strand as a

single discrete product, and they do not perceive other products to be substitutable for PC strand.18

Finally, all types of PC strand are sold “within a reasonable range of prices,” according to Petitioners.19

D. Analysis

Physical Characteristics and Uses. All PC strand shares the same basic physical characteristics. 

It is made from hot-rolled, high-carbon steel wire rod which is drawn into wire and fabricated into multi-
 20 CR at I-11-I-15, PR at I-10-I-12.

 21 CR at I-12-I-13, PR at I-10.

 22 CR at I-13, PR at I-11.

 23 CR at I-14, PR at I-11.

 24 CR/PR at II-3.

 25 Petitioners’ Prehearing Brief at 7.

 26 CR at III-7, PR at III-4.

 27 Petitioners’ Prehearing Brief at 57.

 28 CR at III-7, PR at III-4.

 29 CR at III-7, PR at III-4.

6

wire strand. There are some variations in physical characteristics of the product, based on the

configuration of wires used (the most common PC strand configuration consists of six wires wound

helically around a single wire core); the grade (there are generally three grades: 250, 270, and 300,

corresponding to the minimum strength of the product in thousands of pounds per square inch); the

diameter; whether the product is “low-relaxation” (the predominant form) or “stress-relieved” strand (a

custom made form); whether the wire is “indented” or not; and whether it is coated after it is produced,

either with plastic or epoxy (most PC strand sold by domestic producers is uncoated).20

All PC strand is used for the same general purpose of imparting compressive forces to concrete. 

Concrete is prestressed in one of two ways, by pre-tensioning or by post-tensioning. In pre-tensioning,

the PC strand is tensioned by a calibrated tensioning apparatus, and the concrete is then poured around the

PC strand. The tension is released after the concrete has cured, and the tensile force of the strand induces

a compressive force. The PC strand is installed in this application uncovered because it is the bond

between the cured concrete and the PC strand that holds the concrete in compression.21

For post-tensioning, there is no bond between the PC strand and the cured concrete. The PC

strand is tensioned using a calibrated tensioning apparatus after the concrete has cured, and tension is

maintained by installing permanent mechanical anchors that remain in place after the tensioning apparatus

is removed.22

Interchangeability. PC strand is interchangeable within each physical size, configuration, and

grade.23

 Channel of Distribution. All of the domestic industry’s U.S. shipments of PC strand were made

directly to converters or other end users.24

Manufacturing Facilities, Production Processes, and Employees. There is no information in the

record to contradict Petitioners’ assertion that all PC strand is made using the same facilities, employees,

and the same basic manufacturing process,25 except that plastic coating of PC strand is generally done by

post-tensioners, not by the PC strand producers.26

Producer and Customer Perceptions. There is no information in the record to contradict

Petitioners’ assertion that domestic producers and customers perceive PC strand as a single discrete

product.27

Price. Most PC strand is sold uncoated. Epoxy or plastic coating adds a price premium to PC

strand. The two domestic producers that provide epoxy-coating reported that the bare strand accounts for

only approximately *** percent of the total value of the coated strand.28 None of the domestic PC strand

producers plastic-coat the product, although one producer has a small amount of PC strand plastic-coated

***.29 This producer indicated that the bare strand accounts for approximately *** percent of the total

value of the coated strand. Otherwise, any plastic coating of PC strand is done by domestic purchasers of
 30 CR at III-7, PR at III-4.

 31 CR at III-7, PR at III-4-III-5.

 32 19 U.S.C. § 1677(4)(A).

 33 19 U.S.C. § 1677(4)(B). 

7

bare strand.30 One major purchaser indicated that the coating amounts to about 20 percent of the total

cost of the covered strand.31

Conclusion. All PC strand shares the same basic physical characteristics in that it consists of a

multi-wire strand, made from high-carbon steel wire rod. All PC strand is used for the same general

purpose: imparting compressive force to concrete. All PC strand that has the same physical dimensions

and configuration, and it is interchangeable within each grade. Almost all domestically produced PC

strand is sold in the same channel of distribution, namely directly to end users. It appears that all PC

strand is made using the same types of facilities and employees and basic manufacturing process, and that

producers and customers perceive PC strand to be a single, discrete product. Although there can be

significant price differences between coated and uncoated PC strand, most domestically produced strand

is sold uncoated. In light of the foregoing, we define a single like product in a manner that is coextensive with the scope of the investigations, as the Commission has done in previous investigations

involving PC strand.

III. DOMESTIC INDUSTRY

The domestic industry is defined as the domestic “producers as a {w}hole 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.”32 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. 

Based on our definition of the domestic like product, we define the domestic industry as all domestic

producers of PC strand.

A. Related Parties

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

the domestic industry pursuant to 19 U.S.C. § 1677(4)(B). Subsection 1677(4)(B) 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.33 Exclusion

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

investigation. In these investigations, one domestic producer, Insteel, is a related party because it directly

imported subject PC strand during the period examined. 

1. Petitioners’ Arguments

Petitioners maintain that appropriate circumstances do not exist to exclude domestic producer

Insteel from the domestic industry. Petitioners note that Insteel imported *** of PC strand from China

towards the beginning of the period examined, but has not done so since 2007, and that the ratio of
 34 Petitioners’ Prehearing Brief at 8-9.

 35 Id.

 36 CR/PR at Table III-1.

 37 CR/PR at Table III-7.

 38 CR at III-17, PR at III-10.

 39 CR at III-17, PR at III-10.

 40 CR/PR at Table VI-2.

 41 One of the firms producing PC strand, Rettco, produces the product under a toll arrangement with another firm,

MMI Products, Inc., whereby MMI provides Rettco with the raw material and pays a conversion fee for Rettco to

produce finished PC strand, which MMI then sells. We treat Rettco, the toller, and not MMI, the tollee, as the

domestic producer, as it is Rettco that engages in the production activity. While toll producers that engage in

sufficient production related activity are included in the domestic industry, tollees “that merely supply raw materials

and pay a fabrication fee” are not. See Certain Welded Large Diameter Line Pipe from Japan, Inv. No. 731-TA-919

(Final), USITC Pub. 3464 (November 2001) at 10, n.53. See also, e.g., Ferrovanadium from China and South

Africa, Inv. Nos. 731-TA-986 and 987 (Preliminary), USITC Pub. 3484 (January 2002) at 7 & n.35. 

8

imports to domestic production was minor. Insteel’s interests lie in domestic production, as evidenced by

its role as a petitioner. The company did not benefit financially from its importations, according to

Petitioners.34

2. Analysis

Insteel, one of the petitioners,35 accounted for *** percent of domestic production in 2009.36 Its

imports of the subject merchandise were equivalent to *** percent of its production in ***, the only

period in which it imported the subject merchandise.37 The company explained that it made these

importations pursuant to a short-lived pilot program designed to determine whether it could profitably

import and resell PC strand from China.38

We find that appropriate circumstances do not exist to exclude Insteel from the domestic industry. 

It is the *** domestic producer and a petitioner, and the levels of its imports relative to its domestic

production ***. Its reason for importing was to supplement its domestic production, and it abandoned its

experiment with reselling imported product well before the filing of the petition in these investigations.39

Accordingly, we find that Insteel’s primary interests lie in domestic production rather than in the

importation of subject merchandise. Any benefit that it derived from importing the subject merchandise

is unlikely to skew the data for the industry overall.40

B. Conclusion

We define the domestic industry to include all domestic producers of PC strand during the period

examined, namely, American, Insteel, Rettco, Strand-Tech, Sumiden, and EMC.41 (EMC produced PC

strand during the very early part of the period examined, but ceased production very early in 2007.)
 42 In these investigations, subject imports accounted for more than 3 percent of the volume of PC strand imported

into the United States from all sources in the most recent 12-month period for which data are available preceding the

filing of the petition. CR at IV-15; PR at IV-6. Thus, we find that subject imports are not negligible under 19

U.S.C. § 1677(24).

 43 19 U.S.C. §§ 1671d(b), 1673d(b).

 44 19 U.S.C. § 1677(7)(B)( i). The Commission “may consider such other economic factors as are relevant to the

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

19 U.S.C. § 1677(7)(B).

 45 19 U.S.C. § 1677(7)(A).

 46 19 U.S.C. § 1677(7)(C)(iii).

 47 19 U.S.C. § 1677(7)(C)(iii).

 48 19 U.S.C. §§ 1671d(a), 1673d(a).

 49 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’d, 944 F. Supp. 943, 951 (Ct. Int’l Trade

1996).

 50 The Federal Circuit, in addressing the causation standard of the statute, 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 further ratified in

Mittal Steel Point Lisas Ltd. v. United States, 542 F.3d 867, 873 (Fed. Cir. 2008), where 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

(continued...)

9

IV. MATERIAL INJURY BY REASON OF IMPORTS OF SUBJECT MERCHANDISE

FROM CHINA42

A. Legal Standards

In the final phase of antidumping and countervailing duty investigations, the Commission

determines whether an industry in the United States is materially injured or threatened with material

injury by reason of the imports under investigation.43 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.44 The statute defines “material injury” as “harm which is not inconsequential, immaterial, or

unimportant.”45 In assessing whether 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.46 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.”47

Although the statute requires the Commission to determine whether the domestic industry is

“materially injured by reason of” unfairly traded imports,48 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.49 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.50
 50 (...continued)

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).

 51 Statement of Administrative Action (“SAA”) on Uruguay Round Agreements Act (“URAA”), 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 Steel, 542 F.3d at 877.

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

unfair imports.”); Taiwan Semiconductor Industry Ass’n v. USITC, 266 F.3d 1339, 1345 (Fed. Cir. 2001) (“{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, Invs. 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, Inc. v. United States,

132 F.3d 716, 722 (Fed. Cir. 1997) (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.”).

 53 S. Rep. 96-249 at 74-75; H.R. Rep. 96-317 at 47.

 54 See Nippon Steel Corp., 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.”).

10

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 non-subject

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.51 In performing its examination, however, the Commission need not

isolate the injury caused by other factors from injury caused by unfairly traded imports.52 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 non-subject

imports, which may be contributing to overall injury to an industry.53 It is clear that the existence of

injury caused by other factors does not compel a negative determination.54

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

determination unless it finds that a domestic industry is materially injured ‘by reason of’ subject imports, the

Commission is not required to follow a single methodology for making that determination ... {and has} broad

discretion with respect to its choice of methodology.”) citing United States Steel Group v. United States, 96 F.3d

1352, 1362 (Fed. Cir. 1996) and S. Rep. 96-249 at 75.

 56 Commissioner Pinkert does not join this paragraph or the following four 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

relating to present material injury, to undertake a particular kind of analysis of non-subject 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 non-subject or non-LTFV imports would have

replaced LTFV subject imports during the period of investigation without a continuing benefit to the

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

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

investigation, and it requires the Commission to provide an explanation of its conclusion with respect to

that factor.

542 F.3d at 878.

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

879 (“Bratsk did not read into the antidumping statute a Procrustean formula for determining whether a domestic

injury was ‘by reason’ of subject imports.”).

 58 Mittal Steel, 542 F.3d at 875-79.

 59 Mittal Steel, 542 F.3d at 873 (quoting from Gerald Metals, 132 F.3d at 722), 875-79 & n.2 (recognizing the

Commission’s alternative interpretation of Bratsk as a reminder to conduct a non-attribution analysis).

11

“ensure{s} that it is not attributing injury from other sources to the subject imports.”55 56 Indeed, the

Federal Circuit has examined and affirmed various Commission methodologies and has disavowed “rigid

adherence to a specific formula.”57

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

where the relevant “other factor” was the presence in the market of significant volumes of pricecompetitive non-subject 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 non-subject

imports.58 The additional “replacement/benefit” test looked at whether non-subject imports might have

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

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

and Tobago determination that underlies the Mittal Steel litigation.

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

that the Federal Circuit does not require the Commission to apply an additional test nor any one specific

methodology; instead, the court requires the Commission to have “evidence in the record” to “show that

the harm occurred ‘by reason of’ the LTFV imports,” and requires that the Commission not attribute

injury from non-subject imports or other factors to subject imports.59 Accordingly, we do not consider

ourselves required to apply the replacement/benefit test that was included in Commission opinions

subsequent to Bratsk.

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

commodity products where price-competitive non-subject imports are a significant factor in the U.S.
 60 Commissioner Lane also refers to her dissenting views in Polyethylene Terephthalate Film, Sheet, and Strip

from Brazil, China, Thailand, and the United Arab Emirates, Invs. Nos. 731-TA-1131 to 1134 (Final), USITC Pub.

4040 (Oct. 2008), for further discussion of Mittal Steel.

 61 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 non-subject countries that

accounted for substantial shares of U.S. imports of subject merchandise (if, in fact, there were large non-subject

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 non-subject imports.

 62 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.

 63 Mittal Steel, 542 F.3d at 873; Nippon Steel Corp., 458 F.3d at 1350, citing U.S. Steel Group, 96 F.3d at 1357;

S. Rep. 96-249 at 75 (“The determination of the ITC with respect to causation is ... complex and difficult, and is a

matter for the judgment of the ITC.”).

 64 CR at II-9, PR at II-6.

 65 CR at II-12, PR at II-8.

 66 CR at II-12, PR at II-8.

 67 CR/PR at Figure II-2.

 68 CR/PR at Table C-1.

12

market, the Court will require the Commission to give full consideration, with adequate explanation, to

non-attribution issues when it performs its causation analysis.60 61

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.62 Congress has delegated this factual finding to the Commission because of the agency’s

institutional expertise in resolving injury issues.63

B. Conditions of Competition

The following conditions of competition inform our analysis in the final phase of these

investigations.

1. Demand Conditions 

Demand for PC strand is derived from demand for prestressed concrete. In turn, demand for

prestressed concrete is tied to demand for construction projects, particularly infrastructure projects,

commercial and institutional construction, large housing projects, and single-family housing.64 Producers

and importers reported that demand had decreased or fluctuated since the beginning of the period

examined.65 Producers and importers reporting fluctuations in demand often described increasing demand

in commercial and residential construction applications during the first half of 2008, followed by sharply

declining demand in these sectors since then.66 Construction activity generally remained strong until late

2008, when it became clear that private residential activity would fall well below the level seen at the end

of the prior year.67

Apparent U.S. consumption of PC strand declined by 48.1 percent in the 2007-09 period, falling

from 980.5 million pounds to 508.6 million pounds.68 Most of this decline occurred from 2008 to 2009,

when apparent consumption fell precipitously from 942.7 million pounds to 508.6 million pounds, due to
 69 E.g., Hearing Tr. at 36-37, 69-70, 123-126 (Johnson, Suncoast Post-Tension).

 70 CR/PR at II-1 and Table II-1.

 71 CR at I-12-I-13, PR at I-10-I-11.

 72 See CR/PR at Table III-5.

 73 CR at II-16 n.21, PR at II-10 n.21.

 74 CR/PR at Table C-2.

 75 Petitioners’ Prehearing Brief at 19-20.

 76 Petitioners’ Prehearing Brief at 20.

 77 CR at II-11, PR at II-7.

 78 The domestic industry’s market share was 59.4 percent in 2007, 56.2 percent in 2008, and 78.0 percent in 2009. 

CR/PR at Table C-1. There is some indication in the record that the domestic industry may have been affected by

(continued...)

13

the economic downturn and because end users were drawing down their inventories rather than making

new purchases.69

Most of the subject imports were sold for post-tension applications, while the domestic product

was sold mostly for pre-tension applications.70 The predominant end uses of post-tensioned PC strand are

in slab-on-grade construction and in buildings for floors with moderate to long spans and moderate floor

loads such as in parking garages and residential buildings.71 Pre-tensioned concrete components may be

used in balconies, lintels, floor slabs, beams, or foundation piles.

Buy America(n) provisions are much more prevalent with respect to sales of PC strand to pretension customers.72 “Buy America” requirements apply to iron and steel products such as PC strand and

their coatings that are purchased for the Federal-aid highway construction program. Under “Buy

America,” Federal-aid funds may not be obligated for a project unless iron and steel products used in such

projects are manufactured in the United States (with limited exceptions based on the product cost or its

share of the original contract value). In addition, under an alternate-bid procedure, foreign-source

materials may be used if the total project bid using foreign-source materials is 25 percent less than the

lowest total bid using domestic materials. “Buy American” is a separate and distinct program from “Buy

America.” The Buy American Act, which covers specified products, requires the Federal Government to

purchase domestic goods and services unless the head of the agency involved in the procurement has

determined that the prices of the domestic suppliers are “unreasonable” or that their purchase would be

“inconsistent with the public interest.”73 

In 2007 and 2008, 28.6 percent and 33.9 percent respectively of total U.S. shipments of PC strand

were subject to Buy America(n) restrictions; in 2009, the figure was 49.5 percent.74 The increase in the

proportion of the market subject to Buy America(n) restrictions in 2009 appears to have been aberrational

when compared to the proportion of the market that the Commission has previously found to be subject to

Buy America(n) restrictions in the 2000-2008 period.75 The Petitioners attribute this increase to a

temporary decline in demand for PC strand in the commercial market in 2009.76

Demand for PC strand is seasonal in that PC strand is a construction material, and more

construction occurs during warmer weather than during the winter. Thus, demand for PC strand is

generally higher in the April-September period than in October-March.77

2. Supply Conditions

The domestic industry is the largest source of supply in the U.S. market, accounting for more than

half of U.S. consumption by quantity over the period of investigation.78 There were five domestic
 78 (...continued)

shortages of steel wire rod (the principal raw material used to make PC strand) for a time in 2008, but such

constraints appear to have been short-lived. CR at II-5, PR at II-4, and CR III-8, PR at III-5.

 79 CR at III-1-III-2, PR at III-1.

 80 CR/PR at Table C-1.

 81 CR at VII-3, PR at VII-1.

 82 CR/PR at Table IV-2. Nonsubject imports’ market share fell from 4.5 percent of apparent U.S. consumption in

2007 to 3.3 percent in 2008, and then rose to 14.8 percent in 2009. CR/PR at Table IV-7.

 83 CR/PR at Tables II-2 and IV-5.

 84 CR/PR at Table I-1.

 85 CR/PR at Table II-5.

 86 CR/PR at Table II-6.

 87 19 U.S.C. § 1677(7)(C)(i).

14

producers of PC strand at the end of the period examined and one additional producer ceased production

in early 2007.79 The market share of subject imports was 36.1 percent in 2007, 40.5 percent in 2008, and

7.2 percent in 2009.80 There are believed to be 30 or more producers of PC strand in China.81 Nonsubject

imports declined from 2007 to 2008, but increased in 2009 to a level higher than the 2007 level.82 The

principal sources of nonsubject imports in 2009 were Canada, Portugal, Italy, South Africa, Taiwan, and

Spain.83 As discussed earlier, a number of nonsubject suppliers of PC strand are currently subject to

antidumping and/or countervailing duties in the United States.84

3. Substitutability

The record indicates that there is a high degree of substitutability between PC strand from

domestic and other sources (subject to the proviso regarding “Buy America(n)” restrictions, discussed

below), and that price is an important consideration in purchasing decisions. Most responding producers

and importers reported that subject imports are “always” used interchangeably with the domestic like

product.85 When asked whether differences other than price are significant in their sales of PC strand, all

producers responded “never.” Most importers responded “sometimes” or “never” to this question, though

a significant minority of importers reported that differences other than price are “always” or “frequently”

significant to purchasers choosing between subject imports and the domestic like product.86 However, the

substitutability between domestically produced and imported PC strand is reduced somewhat by end-use

markets for the products that are subject to “Buy America(n)” provisions.

C. Volume of the Subject Imports

Section 771(7)(C)(i) of the 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.”87

As noted above, apparent consumption of PC strand fell precipitously towards the end of the

period examined, declining from 942.7 million pounds in 2008 to 508.6 million pounds in 2009, or by 46

percent. We evaluate the data on the volume of subject imports in the context of this sharp decline in

2009.
 88 CR/PR at Table C-1.

 89 CR/PR at Table C-1. The ratio of subject imports to domestic production measured by quantity was 58.8

percent in 2007, 68.3 percent in 2008, and 9.2 percent in 2009. CR/PR at Table IV-8.

 90 CR/PR at Table VII-7. The Commission did not receive end-of-period inventory data from all U.S. importers

of the subject merchandise. The importers that responded to the Commission’s questionnaire accounted for 83.4

percent of total U.S. imports from China in 2009. CR/PR at Table IV-1. Thus, to the extent that non-reporting

importers also held inventories, the data may be understated.

 91 Hearing Tr. at 36-37, 69-70, 123-126 (Johnson, Suncoast Post-Tension). The record also indicates that in this

period, when demand dropped precipitously and importers and purchasers largely stopped placing new orders until

they could work off excess inventories, Chinese PC strand producers often shipped product to the United States

before they had purchasers and then offered merchandise at very low prices to increase sales and reduce inventories. 

Petitioners’ Prehearing Brief at 11 and Exhibit 2.

 92 CR/PR at Table IV-5. 

 93 CR/PR at Tables V-1 and V-2, and Hearing Tr. at 90 (Feitler, Sumiden Wire Products Corp.) and 91 (Sehorst,

American Spring Wire Corp.).

15

The volume of subject imports was 353.9 million pounds in 2007, 381.7 million pounds in 2008,

and 36.6 million pounds in 2009.88 The market share of subject imports was 36.1 percent in 2007, 40.5

percent in 2008, and 7.2 percent in 2009.89 The much lower level of subject imports in 2009 coincides

with a sharp decline in demand in that year. 

The record in the final phase of these investigations, however, shows that the presence of subject

imports in the U.S. market in 2009 was more significant than the absolute volumes of subject imports

suggest. This was because of a substantial buildup of inventories of PC strand from China by U.S.

importers and purchasers in 2008 that had to be worked off before purchasers resumed buying PC strand. 

U.S. importers’ end-of-period inventories of PC strand from China were 31.7 million pounds at the end of

2007, 51.5 million pounds at the end of 2008, and 15.0 million pounds at the end of 2009.90 

Although we do not have precise data on inventories of PC strand from China held by U.S.

purchasers, there is information on the record indicating that these inventories were substantial. The

largest purchaser of PC strand in the United States testified at the hearing in these investigations that it

began increasing its purchases of PC strand from China in early 2008, as demand seemed to be strong. In

mid-2008, as demand began to decline, its inventories of Chinese PC strand grew dramatically, rising to

about 35 million pounds. The purchaser largely ceased ordering new PC strand until inventories were

worked off in the first and second quarters of 2009. This purchaser testified that other U.S. purchasers

had similar experiences with a build up of Chinese PC strand in inventory in the same period.91

In short, because of the drawdown of these substantial inventories of subject merchandise by

importers and purchasers in the first half of 2009, subject imports played a more significant role in the

U.S. market in that period than the data on import volume and market share in 2009 seem to suggest.

The lower level of subject imports in 2009 also corresponds to the filing of the petition

underlying these investigations in May 2009. An examination of monthly import data for 2009 shows

that subject imports dropped sharply after July 2009, two months after the petition was filed, and

remained at very low monthly levels for the rest of the year.92 The filing of the petition also affected the

pricing data in these investigations for the second half of 2009. There is evidence in the record that prices

stabilized after the filing of the petition, and even increased slightly in the fourth quarter of 2009.93 The

record also shows that the condition of the domestic industry improved in the second half of 2009 as

compared with the first half of the year, as evidenced by improvement in a number of the domestic
 94 The domestic industry’s production in the second half of 2009 was 223.3 million pounds, as compared with

172.4 million pounds in the first half of the year. Capacity utilization was 48.9 percent in the second half of 2009, as

compared with 37.8 percent in the first half of the year. Shipments were 213.5 million pounds in the second half of

2009, as compared with 183.0 million pounds in the first half of the year. Net sales were 201.6 million pounds in the

second half of 2009, as compared with 188.2 million pounds in the first half of the year. Operating income was $3.8

million in the second half of 2009, as compared with a loss of $7.5 million in the first half of the year. The ratio of

operating income to net sales was 3.4 percent in the second half of 2009, as compared with negative 7.5 percent in

the first half of the year. Petitioners’ Posthearing Brief at Exhibit 3.

 95 19 U.S.C. § 1677(7)(I) provides, in relevant part, that “[t]he Commission shall consider whether any change in

the volume, price effects, or impact of imports of the subject merchandise since the filing of the petition in an

investigation under part I or II of this subtitle is related to the pendency of the investigation and, if so, the

Commission may reduce the weight accorded to the data for the period after the filing of the petition in making its

determination of material injury . . . .”

 96 2009 Sunset Review Report at Table IV-1.

 97 2009 Sunset Review Report at Tables I-12 and IV-1, and CR/PR at Tables IV-6 and IV-7. The ratio of subject

imports to domestic production measured by quantity was 18.3 percent in the first half of 2009, as compared with

65.8 percent in the first half of 2008. 2009 Sunset Review Report at Tables III-3 and IV-1.

 98 19 U.S.C. § 1677(7)(C)(ii).

16

industry’s performance indicators in the second half of 2009 as compared with the first half.94 

Consequently, we accord less weight to the data for the second half of 2009, as we deem the decline in

imports as well as the improvements in prices and in the domestic industry’s condition in that period to be

related in part to the pendency of the investigations.95 

As detailed above, the volume and market share of subject imports was large and increasing in

2007 and 2008. Because we give less weight to the data for the second half of 2009, we examine the

volume of subject imports for the first half of 2009 separately. The volume of subject imports was 31.6

million pounds in the first half of 2009, as compared with 215.5 million pounds in the first half of 2008,96

and the market share of subject imports was 13.8 percent in the first half of 2009, as compared with 38.6

percent in the first half of 2008.97 We recognize that the volume and market share of subject imports was

substantially lower in the first half of 2009 than in the first half of 2008, but, as explained above, the

presence of subject imports was in fact more significant than these data suggest because of a substantial

buildup of inventories of PC strand from China by U.S. importers and purchasers. We conclude that

subject import volume is significant, both in absolute terms and relative to consumption and production in

the United States.

D. Price Effects of the Subject Imports

Section 771(C)(ii) of the 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.98

As noted above, the record indicates that there is a high degree of substitutability between PC

strand from domestic and other sources, so long as it is not subject to “Buy America(n)” restrictions, and

that price is an important consideration in purchasing decisions.
 99 CR at V-4, PR at V-3.

 100 CR/PR at Table V-5.

 101 CR/PR at Table II-1.

 102 CR/PR at Table V-3.

 103 The only other instance of overselling by the subject imports appears to have resulted from a difference in the

timing of price trends for U.S.-produced and imported Product 2. CR at V-13 n.9, PR at V-7 n.9.

 104 See CR/PR at Table V-6 and CR at V-13 and PR at V-8.

 105 CR/PR at Table V-7.

 106 CR/PR at Tables V-1 and V-2. 

 107 The unit COGS was $375 per 1,000 pounds in 2007, $513 per 1,000 pounds in 2008, and $516 per 1,000

pounds in 2009. The unit cost of raw materials was $287 per 1,000 pounds in 2007, $426 per 1,000 pounds in 2008,

and $370 per 1,000 pounds in 2009. The decrease in raw material costs from 2008 to 2009 was exceeded by an

increase in other factory unit costs, which rose from $65 in 2008 to $125 in 2009. CR/PR at Table VI-1.

 108 The unit value of net sales was $461 per 1,000 pounds in 2007, $600 per 1,000 pounds in 2008, and $541 per

1,000 pounds in 2009.

 109 CR/PR at Table VI-1.

 110 As noted above, in order to reach an affirmative price suppression finding, the statute requires that the effect of

subject imports is to prevent price increases, which otherwise would have occurred, to a significant degree. 

(continued...)

17

The Commission collected quarterly pricing data for two PC strand items. Product 1 was 1⁄2 inch,

grade 270, low relaxation, uncovered PC strand sold for pre-tensioned applications. Product 2 was the

same product, but sold for post-tensioned applications. Usable pricing data were provided by five

domestic producers, accounting for 57.8 percent of domestic producers’ shipments during 2009, and 15

importers, accounting for virtually all shipments of subject imports in that year.99 There was widespread

underselling by the subject imports. Subject imports undersold the domestic like product in 19 of 24

quarterly pricing comparisons by margins ranging from *** percent to *** percent.100 We note that most

of the underselling by subject imports (12 of the 19 instances) occurred with respect to the PC strand sold

in pre-tensioned applications (Product 1), the end use market dominated by the domestic industry.101

Moreover, the quarters in which there was overselling by subject imports (all with respect to Product 2)

occurred mostly in 2007,102 indicating that underselling intensified in 2008, as the volume and market

share of subject imports grew.103 Accordingly, we find subject import underselling of the domestic like

product to be significant.

Of lost sales allegations totaling $***, the Commission was able to confirm allegations totaling

$***.104 Of lost revenue allegations totaling $***, the Commission was able to confirm allegations

totaling $***.105

The prices of both the Chinese and domestic products fluctuated in a narrow range in 2007,

before increasing sharply in 2008, through the second quarter of that year in the case of the domestic

product, and the third quarter of that year in the case of the subject imports, and then declining sharply

until the fourth quarter of 2009, when they increased slightly.106 We find that subject import underselling 

prevented domestic price increases that otherwise would have occurred to a significant degree. On a per

unit basis, the domestic industry’s cost of goods sold (COGS) increased during 2007 to 2009 largely as a

result of an increase in per unit raw material costs.107 The industry was unable to increase the unit value

of its net sales sufficiently to offset rising costs.108 As a result, the domestic industry’s COGS as a ratio to

net sales increased from 81.4 percent in 2007 to 85.4 percent in 2008 and 95.4 percent in 2009, resulting

in a cost-price squeeze.109 110 While the fall in demand contributed to the increase in the domestic
 110 (...continued)

Commissioner Shara L. Aranoff notes that the domestic industry experienced a rise in its COGS/net sales ratio from

2007 to 2008, despite the facts that demand for PC strand was generally strong (CR/PR at Table C-1), there were

some temporary shortages in 2008 (CR at II-5, PR at II-4), and purchasers were building inventory (Hearing Tr. at

36-37, 69-70, 123-26 (Johnson, Suncoast Post-Tension)). Based on these market conditions, the domestic industry

should have been able to pass on cost increases to purchasers by way of higher prices from 2007 to 2008. Because

the domestic industry was unable to raise prices sufficiently to offset the increase in COGS from 2007 to 2008, even

though demand for PC strand was strong and moderately price inelastic, Commissioner Aranoff finds that subject

imports prevented price increases that otherwise would have occurred to a significant degree. Beginning in late

2008, demand for PC strand began to fall, and the domestic industry continued to experience an increase in the

COGS/net sales ratio. Although demand was falling during the first half of 2009, demand generally is not sensitive

to changes in price, given that there are no economically viable substitutes for PC strand and that PC strand

represents only a small cost component of the end product in its primary use in the construction of buildings, parking

garages, bridges, and other large structures. CR at I-12, PR at I-10. Moreover, once a construction project has been

initiated, demand for PC strand to complete that structure would be very unlikely to change significantly in reaction

to a change in price, given the size of the overall investment. Accordingly, Commissioner Aranoff finds that the

domestic industry should have been able to pass on at least some increases in price even in 2009. She finds that the

significant volume of lower-priced subject imports prevented price increases for domestic PC strand, which

otherwise would have occurred, to a significant degree.

 111 This purchaser testified that many Chinese producers, with large excess capacity, were offering huge amounts

of subject merchandise at ever decreasing prices, thereby creating chaos in the U.S. market. Conference Tr. at 35

(Johnson, Suncoast Post-Tension). 

 112 Petitioners’ Prehearing Brief at Exhibits 2 and 3.

 113 CR/PR at Tables V-2 and V-3.

 114 See CR/PR at Table V-6 and CR at V-13 and PR at V-8.

 115 CR/PR at Table V-7.

 116 2009 Sunset Review Report at Table C-1.

18

industry’s COGS ratio in 2009, that ratio increased from 2007 to 2008 while demand generally remained

strong. Accordingly, we attribute the COGS increase to the effect of subject imports in material part,

despite the presence of an additional cause arising in 2009. Thus, for much of the period examined, the

domestic industry was unable to raise its prices to cover increases in costs due to the presence of subject

imports. 

Further evidence of adverse price effects by subject imports throughout the period examined, and

particularly in early 2009, was provided by a large U.S. purchaser of the subject merchandise111 and by

importers.112

As noted above, we accord less weight to the data for the second half of 2009 as we deem the

improvements in prices in that period to be related in part to the pendency of the investigations.

Accordingly, we also examine the price effects of subject imports without including the data for the

second half of 2009 (i.e., for the period from 2007 through the first half of 2009). In this period, subject

imports undersold the domestic like product in 15 of 20 quarterly pricing comparisons by margins ranging

from *** percent to *** percent.113 Of lost sales allegations totaling $***, the Commission was able to

confirm allegations totaling $***,114 and of lost revenue allegations totaling $***, the Commission was

able to confirm allegations totaling $***.115 The domestic industry’s COGS as a ratio to net sales was

100.9 percent in the first half of 2009, as compared with 80.4 in the first half of 2008.116

For the foregoing reasons, we find that there has been significant underselling by the subject

imports and that such imports suppressed domestic prices to a significant degree. Accordingly, we find

that subject imports have had significant adverse effects on domestic prices. 
 117 In its final determinations of sales at LTFV, Commerce found the following weighted-average dumping 

margins: 42.97 percent for Wuxi Jinyang Metal Products Co., 175.94 percent for Xinhua Metal and Fasten Group

Import and Export, and 193.55 percent for all others. CR/PR at Table I-3.

 118 19 U.S.C. § 1677(7)(C)(iii); see also SAA at 851 and 885 (“In material injury determinations, the Commission

considers, in addition to imports, other factors that may be contributing to overall injury. While these factors, in

some cases, may account for the injury to the domestic industry, they also may demonstrate that an industry is facing

difficulties from a variety of sources and is vulnerable to dumped or subsidized imports.”)

 119 19 U.S.C. § 1677(7)(C)(iii); see also SAA at 851, 885; Live Cattle from Canada and Mexico, Inv. Nos. 701-

TA-386, 731-TA-812-813 (Prelim.), USITC Pub. 3155 at 25 n.148 (Feb. 1999).

 120 Production was 601.7 million pounds in 2007, 558.9 million pounds in 2008, and 395.7 million pounds in

2009. Capacity utilization was 66.7 percent in 2007, 61.8 percent in 2008, and 43.8 percent in 2009. Domestic

shipments were 582.8 million pounds in 2007, 530.0 million pounds in 2008, and 396.5 million pounds in 2009. 

Production related workers totaled 357 in 2007, 331 in 2008, and 258 in 2009. Hours worked totaled 771,000 in

2007, 715,000 in 2008, and 555,000 in 2009. CR/PR at Table C-1. Capital expenditures were $*** in 2007, $*** in

2008, and $*** in 2009. CR/PR at Table VI-4. Research and development spending was $*** in 2007, $*** in

2008, and $*** in 2009. Id.

 121 U.S. producers’ share of apparent U.S. consumption was 59.4 percent in 2007, 56.2 percent in 2008, and 78.0

percent in 2009. CR/PR at Table C-1.

 122 Production capacity was 902.8 million pounds in 2007, and 903.8 million pounds in both 2008 and 2009. 

Productivity (pounds per hours) was 780.1 in 2007, 781.9 in 2008, and 712.5 in 2009. CR/PR at Table C-1.

19

E. Impact of the Subject Imports on the Domestic Industry117

Section 771(7)(C)(iii) of the 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.”118 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.”119

We find that subject imports had a significant adverse impact on the domestic industry in 2008

and 2009. The domestic industry experienced declines in most statutory performance indicators in those

years, with precipitous declines in 2009. Production, capacity utilization, shipments, employment, and

capital expenditures/research and development all fell.120 The domestic industry’s market share declined

from 2007 to 2008, but then recovered sharply in 2009, as the market share of subject imports declined.121

Production capacity was fairly constant, but productivity declined.122 Domestic industry end-of-period

inventories rose between 2007 and 2008, and then declined in 2009 on an absolute basis. As a ratio of
 123 End-of-year inventories were 61.3 million pounds in 2007, 67.1 million pounds in 2008, and 57.6 million

pounds in 2009. The ratio of inventories to total shipments was *** percent in 2007, *** percent in 2008 and ***

percent in 2009. CR/PR at Table C-1.

 124 The domestic industry reported an operating income of $39.4 million in 2007 and $38.0 million in 2008, and a

loss of $3.7 million in 2009. The domestic industry’s ratio of operating income to net sales was 13.9 percent in

2007, 10.7 percent in 2008, and negative 1.8 percent in 2009. CR/PR at Table C-1. The industry’s return on

investment was 24.7 percent in 2007, 18.7 percent in 2008, and a negative 2.2 percent in 2009. CR/PR at Table VI5.

 125 We recognize that inventory write-down costs by one domestic producer (Insteel) contributed to the domestic

industry’s poor financial performance in 2009. These inventory adjustments (which were required by Generally

Accepted Accounting Principles) may have been, at least in part, related to the effects of subject imports, insofar as

they resulted from the collapse in PC strand prices due to low-priced subject imports, and that the write-downs See

Petitioners’ Prehearing Brief at 49-51. Moreover, we note that, even without the effects of these inventory writedowns, the domestic industry would still have suffered sharply lower operating income in 2009. CR at VI–3 n.4, PR

at VI-1 n.4.

 126 Production was 172.4 million pounds in the first half of 2009, as compared with 327.4 million pounds in the

first half of 2008. Capacity utilization was 37.8 percent in the first half of 2009, as compared with 72.0 percent in

the first half of 2008. Domestic producers’ U.S. shipments were 183.0 million pounds in the first half of 2009, as

compared with 325.5 million pounds in the first half of 2008. Production and related workers totaled 253 in the first

half of 2009, as compared with 337 in the first half of 2008. Hours worked by production and related workers and

productivity showed similar declines in the first half of 2009 relative to the first half of 2008. End-of-period

inventories were 51.3 million pounds in the first half of 2009, as compared with 47.7 million pounds in the first half

of 2008. The ratio of inventories to U.S. shipments was 28.0 percent in the first half of 2009, as compared with 14.6

percent in the first half of 2008. The domestic industry reported a loss of $7.5 million in the first half of 2009, as

compared with an operating income of $30.4 million in the first half of 2008. The domestic industry’s ratio of

operating income to net sales was negative 7.5 percent in the first half of 2009, as compared with 15.9 percent in the

first half of 2008. 2009 Sunset Review Report at Table C-1.

 127 Production capacity was 456.3 million pounds in the first half of 2009, as compared with 454.7 million pounds

in the first half of 2008. U.S. producers’ share of apparent U.S. consumption was 79.9 percent in the first half of

2009, as compared with 58.4 percent in the first half of 2008. 2009 Sunset Review Report at Table C-1.

20

total shipments, however, end-of-period inventories rose in both 2008 and 2009.123 The domestic

industry’s financial results deteriorated and the industry experienced an operating loss in 2009.124 125

As noted above, we accord less weight to the data for the second half of 2009 due to the effects of

the pendency of the investigations. Accordingly, we also examine data for the first half of 2009

separately. Almost all of the statutory performance indicators for the domestic industry were lower in the

first half of 2009 than in the first half of 2008.126 The only exceptions were production capacity and

market share.127

Based on all the foregoing trends, we find that there is a causal nexus between subject imports

and the deteriorating condition of the domestic industry. This conclusion is based on the substantial

presence and increase in subject import volume and market share in 2008, driven by pervasive subject

import underselling, which had a significant adverse impact on the domestic industry in 2008. The

adverse impact of subject imports continued into 2009, especially in the first half of the year. Even

though the absolute volume of subject imports declined sharply in 2009, subject imports continued to

have a disproportionately injurious effect in 2009 because of the large overhang of subject imports in

inventory held by importers and purchasers in the early part of the year. Apparent consumption of PC

strand fell sharply as importers and purchasers worked off their inventories. Moreover, as discussed
 128 Hearing Tr. at 35 (Johnson, Suncoast Post-Tension).

 129 CR/PR at Table C-1. Subject imports also displaced non-subject imports, whose market share fell from 4.5

percent in 2007 to 3.3 percent in 2008. Id.

 130 See CR/PR at Table V-6.

 131 Petitioners’ Prehearing Brief at 19-20. 

 132 Id.

 133 Petitioners’ Prehearing Brief at 20.

 134 Hearing Tr. at 11 (Selhorst, American Spring Wire Corp.).

21

above, even as the volume of subject imports declined, Chinese PC strand suppliers continued to offer

large amounts of subject merchandise at continually lower prices.128

We have considered whether there are other factors that have had an impact on the domestic

industry. We recognize that the decline in PC strand demand that became evident by late 2008 played a

role in the domestic industry’s worsening performance near the end of the period examined. But, the

injurious effects of subject imports on the domestic industry in 2008 and 2009 are observable

independently of the decline in demand. As noted above, the volume of subject imports increased in 2008

as compared with 2007, even as demand for PC strand fell. Consequently, the market share of subject

imports rose from 36.1 percent in 2007 to 40.5 percent in 2008, as subject imports displaced mainly the

shipments of U.S. producers, whose market share fell from 59.4 percent to 56.2 percent in this period.129

As noted above, the injurious price effects of subject imports intensified from 2007 to 2008. Most of the

domestic industry’s trade, employment, and financial variables deteriorated from 2007 to 2008. The

injurious effects of subject imports continued to be felt in the first half of 2009 due primarily to the large

overhang of inventories held by importers and purchasers, which materially worsened the effects of

declining demand for PC strand. Subject imports also continued to have direct effects on the domestic

industry in the first half of 2009, as Chinese producers sought to make sales at ever-lower prices. 

Domestic producers continued to lose sales to subject imports in the first half of 2009.130 In sum, we find

that the decline in demand for PC strand that became evident in late 2008, due to the economic downturn,

does not sever the causal link between subject imports and the injury suffered by the domestic industry,

and we do not attribute to subject imports the effects of any adverse demand conditions.

We have also considered whether Buy America(n) provisions may have shielded the domestic

industry from direct competition from subject imports in part of the domestic PC strand market.

With the exception of 2009, the proportion of the U.S. market subject to Buy America(n) requirements

has remained relatively stable at about one-third of the market.131 In 2009, the share of the market

accounted for by such requirements was 49.5 percent.132 As noted above, this increase may have been

attributable to a temporary decline in demand for PC strand in the commercial market in 2009.133 In

short, while Buy America(n) provisions may shield the domestic industry from direct competition with

subject imports in a part of the domestic market, a substantial part of the market – about two thirds – is

not shielded from such competition. Thus, we find that Buy America(n) provisions did not shield the

domestic industry from injury from subject imports.

We have also considered the market dynamics underlying sales for pre-tensioning and posttensioning applications, and the reasons why most of the subject imports were sold for post-tension

applications, while the domestic product was sold mostly for pre-tension applications. Although the

majority of the domestic industry’s shipments have been for pre-tensioned applications, and subject

imports have been sold mostly for post-tensioned applications, there is not a clear demarcation in the

market. The same product is sold for both types of applications.134 Subject imports also are sold for pre-
 135 CR/PR at Table C-2.

 136 CR/PR at Table C-2 and CR at III-14, PR at III-8.

 137 Hearing Tr. at 12 (Selhorst, American Spring Wire Corp.).

 138 CR/PR at Table C-1. We note that a number of nonsubject countries are subject to existing antidumping and

countervailing orders. See CR/PR at Table I-1.

 139 In 2009, the average unit value of nonsubject imports was $468 per 1,000 pounds, as compared with $378 per

1,000 pounds for subject imports. CR/PR at Table C-1.

 140 Commissioner Pinkert considers PC strand to be a commodity product for Bratsk purposes and finds that pricecompetitive, nonsubject imports had a significant presence in the U.S. market during the period under examination. 

He finds, however, that nonsubject imports would not have replaced the subject imports without benefit to the

domestic industry had the subject imports exited the U.S. market during that period. He notes in this regard both the

minor role that nonsubject imports played in the U.S. market relative to the subject imports and the fact that their

average unit values were substantially higher than those of the subject imports in 2009 (the only year in which the

U.S. market share of nonsubject imports exceeded 5.0 percent). CR/PR at Table C-1.

22

tensioned applications135 and the domestic industry also sells PC strand for post-tensioned applications

and has expressed an interest in increasing those sales.136 The ability of imports to gain market share in

post-tensioned applications may be due, in part, to the lower proportion of Buy America(n) sales in such

uses and to the greater ability of importers to sell to larger customers in larger quantities.137 Neither of

these factors supports the view that the domestic industry has abandoned, is not interested in, or is unable

to serve post-tensioned applications. All evidence is to the contrary. Thus, we find that the concentration

of the domestic product and subject imports in sales for different applications has not prevented the

subject imports from injuring the domestic industry.

Nonsubject imports played only a minor role in the U.S. market until 2009. The market share of

nonsubject imports was 4.5 percent in 2007, 3.3 percent in 2008, and 14.8 percent in 2009.138 Even

though the market share of nonsubject rose substantially in 2009 as compared with 2008, we note that the

prices of these imports were considerably higher than those of subject imports in 2009.139 We have not

attributed to subject imports any effects from nonsubject imports.140

CONCLUSION

For the foregoing reasons, and based on the record in the final phase of these investigations, we

find that an industry in the United States is materially injured by reason of subject imports of PC strand

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

China.
 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 Federal Register notices pertaining to the final phase of this proceeding are presented in app. A.

I-1

PART I: INTRODUCTION

BACKGROUND

These investigations result from a petition filed with the U.S. Department of Commerce

(“Commerce”) and the U.S. International Trade Commission (“USITC” or “Commission”) by counsel on

behalf of American Spring Wire Corp. (“American”) (Bedford Heights, OH); Insteel Wire Products Co.

(“Insteel”) (Mt. Airy, NC); and Sumiden Wire Products Corp. (“Sumiden”) (Dickson, TN), on May 27,

2009, 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 prestressed concrete steel

wire strand (“PC strand”)1

 from China. Information relating to the background of the investigations is

provided below.2

Effective date Action

May 27, 2009 Petition filed with Commerce and the Commission; institution of the

Commission's investigations (74 FR 26731, June 3, 2009)

June 16, 2009 Commerce’s notice of initiation of countervailing duty investigation (74 FR

29670, June 23, 2009)

June 23, 2009 Commerce’s notice of initiation of antidumping duty investigation (74 FR

29665)

July 13, 2009 Commission’s preliminary determinations transmitted to Commerce (74 FR

34872, July 17, 2009)

November 2, 2009 Commerce’s preliminary countervailing duty determination (74 FR 56576)

December 23, 2009

Commerce’s preliminary antidumping duty determination (74 FR 68232);

scheduling of final phase of Commission investigations (75 FR 4104, January

26, 2010 (as revised, 75 FR 8113, February 23, 2010))

May 6, 2010 Commission’s hearing1

May 21, 2010 Commerce’s final countervailing duty determination (75 FR 28557) and

Commerce’s final antidumping duty determination (75 FR 28560)

June 10, 2010 Commission’s vote

June 22, 2010 Commission’s determinations transmitted to Commerce

 1 A list of witnesses that appeared at the hearing is presented in app. B.
I-2

STATUTORY CRITERIA AND ORGANIZATION OF THE REPORT

Statutory Criteria

Section 771(7)(B) of the Tariff Act of 1930 (the “Act”) (19 U.S.C. § 1677(7)(B)) provides that in

making its determinations of injury to an industry in the United States, the Commission--

shall consider (I) the volume of imports of the subject merchandise, (II)

the effect of imports of that merchandise on prices in the United States

for domestic like products, and (III) the impact of imports of such

merchandise on domestic producers of domestic like products, but only

in the context of production operations within the United States; and . . .

may consider such other economic factors as are relevant to the

determination regarding whether there is material injury by reason of

imports.

Section 771(7)(C) of the Act (19 U.S.C. § 1677(7)(C)) further provides that--

In evaluating the volume of imports of merchandise, the Commission

shall consider whether the volume of imports of the merchandise, or any

increase in that volume, either in absolute terms or relative to production

or consumption in the United States is significant.

. . .

In evaluating the effect of imports of such merchandise on prices, the

Commission shall consider whether . . . (I) there has been significant

price underselling by the imported merchandise as compared with the

price of domestic like products of the United States, and (II) the effect of

imports of such merchandise otherwise depresses prices to a significant

degree or prevents price increases, which otherwise would have

occurred, to a significant degree.

. . .

In examining the impact required to be considered under subparagraph

(B)(i)(III), the Commission shall evaluate (within the context of the

business cycle and conditions of competition that are distinctive to the

affected industry) all relevant economic factors which have a bearing on

the state of the industry in the United States, including, but not limited to

. . . 

(I) actual and potential declines 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 domestic like product, and (V) in {an antidumping

investigation}, the magnitude of the margin of dumping.
 3

 RettCo (the “toller” or “toll producer”) produces PC strand under a toll agreement with MMI (the “tollee”). 

MMI furnishes RettCo with wire rod, pays RettCo a conversion fee for producing finished PC strand, and sells the

finished PC strand. The production, capacity, capacity utilization, and employment data presented in this report

were submitted by toller RettCo and the shipment, inventory, pricing, and primary financial data were provided by

MMI.

 4

 PCS of America (“PCS”) (Rosenberg, TX), formerly related to Mexican PC strand producer Aceros Camesa

S.A. de C.V. (“Camesa”), and EMC (Phoenix, AR), formerly owned by Mexican PC strand producer Cablesa S.A.

de C.V. (“Cablesa”), previously produced PC strand in the United States. PCS ceased U.S. production of PC strand

by *** (i.e., prior to the period for which information was requested in the final phase of these investigations) and

EMC ceased production by ***. Email from *** to Mary Messer, June 26, 2009; and petition, pp. 3-4.

 5

 Petitioners’ prehearing brief, p. 76.

I-3

Organization of the Report

Part I of this report presents information on the subject merchandise, 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.

U.S. MARKET SUMMARY

PC strand is steel strand produced from hot-rolled, high-carbon steel wire rod which, after

cleaning and descaling, is drawn into wire, fabricated into multi-wire strand, and thermally stressrelieved. PC strand is used to compress concrete structural members to improve their ability to withstand

loads. The PC strand is tensioned either prior to the pouring of concrete (pre-tensioning) or after the

pouring of the concrete (post-tensioning) to impart compressive force to the concrete in which it is placed. 

Demand for PC strand is derived from demand for prestressed concrete which, in turn, is derived from

demand for construction projects. Typical applications for prestressed concrete in which PC strand is

used include bridge decks, bridge girders, pilings, precast concrete panels and structural supports, roof

trusses, floor supports, and certain concrete foundations.

There are currently five U.S. producers of PC strand: American; Insteel; RettCo Steel, LLC

(“RettCo”)/MMI Products, Inc. (“MMI”);3

 Strand-Tech Martin (“Strand-Tech”); and Sumiden.4 *** is

the largest domestic PC strand producer, accounting for *** percent of production of PC strand in the

United States during 2009. The petitioners indicated that there are an estimated 30 or more producers of

PC strand in China.5

 The largest nonsubject sources of PC strand imported into the United States during

2007-09 include Canada (Bekaert Canada Ltd. and Stelwire Ltd.); Italy (CB Trafilati Accial, Far SPA,

Redaelli Tecnasud, Siderurgica Latina Martin, and Trafilati SPA); Korea (Dong-Il Steel Mfg. Co. Ltd.,

Kiswire Ltd., Manho Rope and Wire Ltd., and Youngheung Iron and Steel Co. Ltd.); Portugal (Fapricela

Industria de Trefilaria SA); South Africa (Scaw Metal Group); Spain (Emesa Trefileria and Tycsa); and

Taiwan (Chia Ta World Co., Ltd. and U-LEAD Industrial Corp.). At least 16 firms have imported PC

strand from China since 2007. The four largest importers providing responses to the questionnaire in

these investigations – *** – together accounted for more than two-thirds of total subject U.S. imports

from China in 2009 as measured by official Commerce import statistics. The leading U.S. importer of PC

strand from nonsubject countries is ***, which accounted for *** of total U.S. PC strand imports from

nonsubject countries in 2009 as measured by official Commerce statistics. U.S. purchasers of PC strand
 6

 There are currently five U.S. producers of PC strand: American, Insteel, RettCo/MMI, Strand-Tech, and

Sumiden. The data presented in this report do not include the data of U.S. PC strand producer EMC that

permanently ceased production during ***.

 7

 Staff attempted numerous times to elicit responses from Chinese PC strand producers during the final phase of

these investigations. The only communication received in response to the Commission’s requests for information

was an email correspondence from ***. Email to Mary Messer from ***, February 10, 2010.

I-4

are firms that typically either pre-tension or post-tension concrete structural components. Suncoast

Post-tension is reportedly the largest purchaser of PC strand in the United States. Other leading U.S.

purchasers include ***. 

Apparent U.S. consumption of PC strand totaled 508.6 million pounds ($248.7 million) in 2009. 

U.S. producers’ U.S. shipments of PC strand totaled 396.5 million pounds ($199.5 million) in 2009, and

accounted for 78.0 percent of apparent U.S. consumption by quantity and 80.2 percent by value. U.S.

imports from China totaled 36.6 million pounds ($13.8 million) in 2009 and accounted for 7.2 percent of

apparent U.S. consumption by quantity and 5.6 percent by value. U.S. imports from nonsubject sources

totaled 75.5 million pounds ($35.4 million) in 2009 and accounted for 14.8 percent of apparent U.S.

consumption by quantity and 14.2 percent by value. Apparent U.S. consumption, on the basis of quantity

and value, declined overall by 48.1 and 38.9 percent, respectively, from 2007 to 2009.

SUMMARY DATA AND DATA SOURCES

A summary of data collected in the investigations is presented in appendix C at table C-1. U.S.

industry data are based on questionnaire responses of five firms that accounted for all U.S. production of

PC strand during 2009.6

 U.S. imports presented in the body of this report are based on Commerce’s

official import statistics. Since there were no questionnaire responses received from producers of the

subject merchandise in China during the final phase of these investigations, data presented in this report

regarding the Chinese industry are based on four foreign producer questionnaire responses submitted

during the preliminary phase of these investigations.7

PREVIOUS AND RELATED INVESTIGATIONS

Antidumping and Countervailing Duty Investigations and Reviews

The Commission has conducted several previous antidumping and countervailing duty

investigations and five-year reviews concerning PC strand from 9 different countries. The earliest

investigations concerning PC strand were conducted by the Commission in 1978. The Commission’s

domestic like product and domestic industry determinations in all PC strand investigations and reviews

are similar in that the Commission has consistently found one domestic like product consisting of PC

strand and one domestic industry consisting of all domestic producers of PC strand. Table I-1 presents

information on previous and related Title VII investigations and five-year reviews concerning PC strand.
Table I-1

PC strand: Previous Title VII investigations and five-year reviews

Investigations/Reviews Dates

Country Number Begin End Domestic Like Product/Domestic Industry Determination 

India

AA1921-182(Final) 06/02/1978 08/25/1978

Under the then-applicable statutory provisions, the Commission made no domestic like productdetermination per se in its original determinations, but it essentially treated all PC strand as a sidomestic like product. The Commission determined that it "considered the relevant domestic into consist of facilities in the United States devoted to the production of steel wire strand for presconcrete."

Japan

AA1921-188(Final) 08/29/1978 11/22/1978

The Commission’s de facto domestic like product and domestic industry determinations in the o

final investigation concerning PC strand from Japan were the same as its determinations in the investigation concerning PC strand from India.

AA1921-188(First Review) 09/01/1998 02/02/1999

The Commission found that the appropriate definition of the domestic like product in the expeditinitial five-year review was the same as Commerce's scope: all steel wire strand, other than allonot galvanized, which has been stress-relieved and is suitable for use in prestressed concrete. 

further determined that the appropriate domestic industry was all U.S. producers of PC strand.

AA1921-188(SecondReview) 01/02/2004 06/07/2004

The Commission’s domestic like product and domestic industry determinations in the expedited five-year review was the same as its determinations in the expedited initial five-year review on P

strand from Japan.

Spain 

701-TA-164(Final) 04/26/1982 08/23/1982

The Commission defined the domestic like product as “all wire strand of steel for prestressing coand it defined the domestic industry as the producers of that domestic like product.

Brazil

701-TA-152(Final)

03/04/1982

03/14/1983

The Commission’s domestic like product and domestic industry determinations in the original fin

investigations concerning PC strand from Brazil, France, and the United Kingdom were the samdeterminations in the final investigation concerning PC strand from Spain.

France

701-TA-153(Final) 12/06/1982

UnitedKingdom

 731-TA-89(Final) 02/02/1983

Brazil,India,Korea,Mexico,andThailand

701-TA-432731-TA-1024-1028 (Final) 01/31/2003 01/21/2004

The Commission found the domestic like product to be all PC strand co-extensive with Commer

scope: steel strand produced from wire of non-stainless, non-galvanized steel that is suitable foprestressed concrete (both pre-tensioned and post-tensioned) applications and that encompasscovered and uncovered strand and all types, grades, and diameters of prestressed concrete ste

strand. The Commission found the domestic industry to be all producers of PC strand. The

Commission also determined that plastic coating did not constitute sufficient production-related 

to qualify coaters as members of the domestic industry producing PC strand. 

Brazil,India,Japan,Korea,Mexico,andThailand

AA1921-188(ThirdReview)701-TA-432731-TA-1024-1028(Review) 12/01/2008 11/25/2009

The Commission’s definition of the domestic like product was the same as its definition in the fininvestigations concerning the countervailing duty order on imports of PC strand from India and tantidumping duty orders on imports of PC strand from Brazil, India, Korea, Mexico, and ThailandCommission also noted that the description of the scope of these orders differed in a number oftechnical respects from that of the scope of the Japan finding, but found that these differences lsignificance. The Commission also found the domestic industry to include all producers of PC s

Source: Various Commission publications and Federal Register notices.

I-5
 8

 19 U.S.C. § 2252.

 9

 Carbon and alloy steel strand, rope, cable, and cordage, a product category that included PC strand, were found

to be a single ‘like or directly competitive’ product by Chairman Stephen Koplan, Vice Chairman Deanna Tanner

Okun, and Commissioners Marcia E. Miller and Jennifer A. Hillman. Commissioner Lynn M. Bragg included PC

strand in a broader wire product grouping that also included carbon and alloy steel wire as well as many downstream

products. Commissioner Dennis M. Devaney included PC strand in an even broader product grouping that included

all carbon and alloy steel long products. See, e.g., Steel, Inv. No. TA-201-73, Volume I: Determinations and Views

of Commissioners, USITC Publication 3479, December 2001, pp. 88-90, 273, and 312.

 10 Institution and Scheduling of an Investigation under Section 202 of the Trade Act of 1974 (19 U.S.C. 2252) (the

Act), 66 FR 35267, July 3, 2001.

 11 19 U.S.C. § 2251.

 12 Consolidation of Senate Finance Committee Resolution Requesting a Section 201 Investigation with the

Investigation Requested by the United States Trade Representative on June 22, 2001, 66 FR 44158, August 22,

2001.

 13 Steel; Import Investigations, 66 FR 67304, December 28, 2001. Specifically, Chairman Stephen Koplan, Vice

Chairman Deanna Tanner Okun, and Commissioners Marcia E. Miller and Jennifer A. Hillman made a negative

determination with respect to carbon and alloy steel strand, rope, cable, and cordage, while Commissioners Lynn M.

Bragg and Dennis M. Devaney dissented, having made affirmative determinations with respect to carbon and alloy

steel wire products (Commissioner Bragg) and carbon and alloy steel long products (Commissioner Devaney).

I-6

Safeguard Investigations

Following receipt of a request from the Office of the United States Trade Representative on June

22, 2001, the Commission instituted investigation No. TA-201-73, Steel, under section 202 of the Trade

Act of 19748

 to determine whether certain steel products, including PC strand,9 were being imported into

the United States in such increased quantities as to be a substantial cause of serious injury, or the threat

thereof, to the domestic industries producing articles like or directly competitive with the imported

article.10 On July 26, 2001, the Commission received a resolution adopted by the Committee on Finance

of the U.S. Senate (“Senate Finance Committee” or “Committee”) requesting that the Commission

investigate certain steel imports under section 201 of the Trade Act of 1974.11 Consistent with the Senate

Finance Committee’s resolution, the Commission consolidated the investigation requested by the

Committee with the Commission’s previously instituted investigation No. TA-201-73.12 On December

20, 2001, the Commission issued its determinations and remedy recommendations. The Commission

made a negative determination with respect to the product grouping that included PC strand.13
 14 Pre-Stressed Concrete Steel Wire Strand from the People’s Republic of China: Final Affirmative

Countervailing Duty Determination, 75 FR 28557, May 21, 2010. Commerce found the following 15 programs to

be countervailable: Provision of Wire Rod for Less Than Adequate Remuneration (“LTAR”); Provision of Land

Use Rights for LTAR to foreign invested enterprises (“FIEs”) in Jiangxi and the City of Xinyu; Import Tariff and

Value Added Tax Exemptions for FIES and Certain Domestic Enterprises Using Imported Equipment in Encouraged

Industries; Subsidies for Development of Famous Export Brands and China World Top Brands at Central and

Sub-Central Level; Implementing Measures on the Supporting Fund for Foreign Trade & Economic Development of

Jiangxi Province; Circular on Issuance of Management Methods for Foreign Trade Development Support Fund;

Export Grants Under Regulations for Export Product Research and Development Fund Management; Rebates for

Export and Credit Insurance Fee; Income Tax Benefits for FIEs Based on Geographic Location; Two Free, Three

Half Tax Exemptions for FIEs; Local Tax Exemptions and Reduction Programs for “Productive” FIEs; Federal

Provision of Electricity for LTAR; Grants Under the Science and Technology Program of Jiangsu Province; Federal,

Provincial, and Municipal Level Policy Lending to Producers of PC Strand; Income Tax Credits for Purchases of

Domestically Produced Equipment by Domestically Owned Firms; and other various grant programs. Issues and

Decision Memorandum for Final Determination, International Trade Administration, U.S. Department of

Commerce, May 14, 2010.

I-7

NATURE AND EXTENT OF SUBSIDIES AND SALES AT LTFV

Subsidies

On May 21, 2010, Commerce published in the Federal Register its final determination of

countervailable subsidies for producers and exporters of PC strand from China.14 Commerce’s final

determination concerning the total estimated net countervailable subsidy rates for producers/exporters of

the subject merchandise in China is summarized in table I-2. 

Table I-2

PC strand: Commerce’s final subsidy determination with respect to imports from China

Entity

Net subsidy rate

(percent ad valorem)

Fasten Group Corp. (“Fasten Corp.”), Fasten Group Import & Export Co., Ltd.

(“Fasten I&E”), Jiangyin Hongsheng Co. Ltd. (“Hongsheng”), Jiangyin Fasten

Steel (“Fasten Steel”), Jiangyin Hongyu Metal Products Co., Ltd. (“Hongyu

Metal”), and Jiangyin Walsin Steel Cable Co., Ltd. (“Walsin”) (collectively, the

“Fasten Companies”) 8.85

Xinhua Metal Products Co. (“Xinhua”), Xinyu Iron and Steel Joint Stock Ltd.

Co. (“Xinyu”), and Xinyu Iron and Steel LLC (“Xingang”) (collectively, the

“Xinhua Companies”) 45.85

All others 27.35

Source: 75 FR 28557, May 21, 2010.
 15 Prestressed Concrete Steel Wire Strand From the People’s Republic of China: Final Determination of

Sales at Less Than Fair Value, 75 FR 28560, May 21, 2010.

 16 Pre-Stressed Concrete Steel Wire Strand from the People’s Republic of China: Final Affirmative

Countervailing Duty Determination, 75 FR 28557, May 21, 2010. Although the scope language published in

Commerce’s final antidumping duty determination is worded differently than the scope language in Commerce’s

final countervailing duty determination, initiation notice, and the recently completed related five-year sunset reviews

on PC strand, the definition is essentially the same. Prestressed Concrete Steel Wire Strand From the People’s

Republic of China: Final Determination of Sales at Less Than Fair Value, 75 FR 28560, May 21, 2010.

I-8

Sales at LTFV

On May 21, 2010, Commerce published in the Federal Register its final determination of sales at

LTFV with respect to imports from China.15 Commerce’s final dumping margins with respect to imports

of PC strand from China are presented in table I-3.

Table I-3

PC strand: Commerce’s final weighted-average LTFV margins with respect to imports from China

Exporter Producer

Weighted-average

margin (percent)

Wuxi Jinyang Metal Products Co. Wuxi Jinyang Metal Products Co. 42.97

Xinhua Metal Xinhua Metal 175.94

Fasten Group Import & Export

Jiangyin Fasten Steel Products Co.,

Ltd., Jiangyin Walsin Steel Cable Co.,

Ltd., and Jiangyin Hongyu Metal

Products Co., Ltd. 175.94

All others 193.55

Source: 75 FR 28560, May 21, 2010.

THE SUBJECT MERCHANDISE

Commerce’s Scope

Commerce has defined the scope of these investigations as follows:

For purposes of this investigation, PC strand is steel wire strand, other than of stainless

steel, which is suitable for use in, but not limited to, pre-stressed concrete (both

pre-tensioned and post-tensioned) applications. The scope of this investigation

encompasses all types and diameters of PC strand whether uncoated (uncovered) or

coated (covered) by any substance, including but not limited to, grease, plastic sheath, or

epoxy. This merchandise includes, but is not limited to, PC strand produced to the

American Society for Testing and Materials (ASTM) A–416 specification, or comparable

domestic or foreign specifications. PC strand made from galvanized wire is excluded

from the scope if the zinc and/or zinc oxide coating meets or exceeds the 0.40 oz./ft.2

standard set forth in ASTM–A–475.16
I-9

Tariff Treatment

PC stand is classifiable in the Harmonized Tariff Schedule of the United States (“HTSUS”) under

subheading 7312.10.30 and reported for statistical purposes under statistical reporting numbers

7312.10.3010 and 7312.10.3012. Table I-4 presents current tariff rates for PC strand.

Table I-4

PC strand: Tariff treatment, 2010

HTSUS provision

Article description

Column 1

Column 22

Heading/

subheading

Stat.

suffix

General1 Special

Rates (percent ad valorem)

7312

7312.10

7312.10.30

10

12

Stranded wire, ropes, cables, plaited bands, slings

and the like, of iron or steel, not electrically

insulated:

Stranded wire, ropes and cables:

Stranded wire:

Other {than of stainless steel} ........

For prestressing concrete:

Covered with textile or other 

nonmetallic material

Other

Free (3

) 35%

1

 Normal trade relations rate, formerly known as the most-favored-nation duty rate. 2

 Applies to imports from a small number of countries that do not enjoy normal trade relations duty status. 3

 Special rates not applicable when General rate is free.

Source: HTSUS (2010).
 17 Although the seven-wire PC strand is the most prevalent product in the industry, PC strand may also be

produced with as few as three wires. Shemenski, Robert M. et al (eds.), Ferrous Wire Handbook, Guilford, CT: 

The Wire Association, 2008, pp. 922-923. While the majority of PC strand produced is one-half inch, 7-wire, low

relaxation strand, according to petitioners, “all types, grade, and diameters of PC strand are produced in the United

States.” Hearing transcript, p. 11 (Selhorst); Petition, vol. I, p. 9.

 18 For example, grade 270 PC strand has a minimum ultimate strength of 270,000 psi. According to petitioners,

one-half inch diameter grade 270 is the predominant size and grade used in the U.S. market. Petition, vol. I, pp. 9

and 14; conference transcript, p. 15 (Selhorst).

 19 Hearing transcript, p. 11 (Selhorst) and p. 58 (Johnson); conference transcript, p. 15 (Selhorst).

 20 Prestressed concrete may also contain reinforcing wire or wire fabric. Lankford, William T. et al (eds.), The

Making, Shaping, and Treating of Steel, 10th Edition, Pittsburgh, PA: Association of Iron and Steel Engineers, 1984,

pp. 1014-1015.

 21 Petition, vol. I, p. 10; hearing transcript, p. 60 (Johnson) and p. 100 (Wagner).

 22 Portland Cement Association Web site, http://www.cement.org/basics/concreteproducts_prestressed.asp,

accessed March 26, 2010.

 23 PC strand may be sold to pre- and post-tensioners for the same purpose—to impart compressive forces into

concrete so that it can withstand tensile forces without cracking. Hearing transcript, p. 11 (Selhorst) and pp. 58-59

(Johnson); conference transcript, p. 15 (Selhorst).

 24 Hearing transcript, p. 11 (Selhorst) and pp. 58-59 (Johnson); Petition, vol. I, p. 11.

 25 Hearing transcript, p. 11 (Selhorst) and pp. 58-59 (Johnson); conference transcript, p. 73 (Woltz).

I-10

THE DOMESTIC LIKE PRODUCT

Description and Applications

PC strand consists of multiple steel wires wound together to produce a strong, flexible product

that is used to strengthen concrete structures. PC strand is commonly available in three grades, in covered

and uncovered form, and in several nominal diameters. The most common PC strand configuration

consists of six wires wound helically around a single wire core.17 U.S. producers typically manufacture

PC strand in nominal diameters ranging from 0.25 to 0.70 inch and in three grade designations (250, 270,

and 300) corresponding to the minimum ultimate strength of the product in thousands of pounds per

square inch (“psi”) based on tensile strength and cross-sectional surface area of the PC strand.18

PC strand is used in the construction of prestressed concrete structural components to introduce

compression into the concrete.19 This compression offsets or neutralizes forces within the concrete that

occur when it is subjected to loads.20 Typical applications of prestressed concrete include bridge decks,

bridge girders, pilings, precast concrete panels and structural supports, roof trusses, floor supports, and

certain concrete foundations.21 One of the most widespread uses of prestressed concrete, however, is

parking garages.22

PC strand may be pre-tensioned or post-tensioned.23 Pre-tensioned PC strand is tensioned (pulled

tightly and slightly elongated) using a calibrated tensioning apparatus, and concrete is cured around the

PC strand.24 After the concrete has cured, the tension is released and the tensile force of the strand

induces a compressive force in the concrete. Pre-tensioned prestressed concrete depends upon the bond

created between the concrete and the PC strand to hold the concrete in compression. Most pre-tensioned

concrete elements are prefabricated in a factory and must be transported to the construction site.25

Pre-tensioned concrete components may be used in balconies, lintels, floor slabs, beams or foundation

piles.
 26 Hearing transcript, p. 11 (Selhorst) and pp. 58-59 (Johnson); Petition, vol. I, p. 11.

 27 Hearing transcript, p. 58 (Johnson); conference transcript, p. 73 (Woltz).

 28 Portland Cement Association Web site, http://www.cement.org/buildings/post_tensioned_splash.asp, accessed

March 26, 2010. 

 29 Craig D. Olson and Laura N. Smith, “Building with Concrete: Post-tensioned Concrete for Today’s Market,”

The Seattle Daily Journal of Commerce, May 9, 1997, http://www.djc.com/special/concrete97/10024302.htm,

accessed April 6, 2010.

 30 Shares of shipments for Post-Tensioning Institute (“PTI”) members only, estimates for non-member shipments

are not available. “PTI Tonnage Report: Summary of Post-Tensioning Industry Shipments in North America 1972-

2008,” 2009, p. 1.

 31 Both the epoxy coated and the plastic coated product provide a corrosion barrier or protection against

corrosion. Prestressed Concrete Steel Wire Strand from Brazil, India, Korea, Mexico, and Thailand, Invs. Nos. 701-

TA-432 and 731-TA-1024-1028 (Review) and AA1921-188 (Third Review), USITC Publication 4114, November

2009, p. I-26; Petition, vol. I, p. 11.

 32 Galvanized PC strand is rarely used in concrete. Galvanized PC strand is used mostly in perimeter railing such

as on garage parking decks, or some other open structure to prevent pedestrians or cars from falling over the side or

to prevent cars from damaging parking columns. Galvanized PC strand is used because it is a “very tough product

and a very high tensioned product. Both the epoxy coated and the plastic coated product provide a corrosion barrier

or protection against corrosion.” Prestressed Concrete Steel Wire Strand from Brazil, India, Korea, Mexico, and

Thailand, Invs. Nos. 701-TA-432 and 731-TA-1024-1028 (Review) and AA1921-188 (Third Review), USITC

Publication 4114, November 2009, p. I-27.

I-11

For post-tensioned PC strand, there is no bond between the PC strand and the cured concrete. 

Instead, the PC strand is tensioned using a calibrated tensioning apparatus after the concrete has cured.26

In post-tensioned prestressed concrete, tension is maintained by installing permanent mechanical anchors

that remain in place after the tensioning apparatus is removed. Unlike pre-tensioning, which is largely

performed at precast manufacturing facilities, post-tensioning takes place on the job site in cast-in-place

applications.27 The concrete component is cast in a way that allows PC strand to be installed so that it is

protected from bonding with the concrete. Post-tensioning gives designers the flexibility to optimize

material use by creating thinner concrete components.28 The predominant end uses of post-tensioned PC

strand are in slab-on-grade construction and in buildings for floors with moderate to long spans and

moderate floor loads such as in parking garages and residential buildings.29 Approximately *** percent

of U.S. shipments of post-tensioned PC strand in 2008 were used in building construction applications

(*** percent) and slab-on-grade (*** percent).30

Depending on the application, PC strand will be either uncoated or coated (with plastic or epoxy). 

For pre-tensioning applications, where the bond between the cured concrete and the PC strand holds the

concrete in compression, the PC strand is installed uncoated. In contrast, post-tensioning applications

may require uncoated or coated PC strand. Plastic-coated PC strand is lubricated with grease and encased

in a plastic tube, whereas epoxy-coated PC strand is coated with epoxy.

There are two methods of post-tensioning PC strand in concrete members: internal and external. 

For internal post-tensioning applications, the PC strand is either (1) greased and plastic-coated (which

keeps the concrete from bonding to the PC strand during the curing process) and concrete is cured around

the coated PC strand or (2) plastic or metal ducts are cast into the concrete and uncoated PC strand is

passed through each duct. If the duct method is used, after tensioning and anchoring, the ducts containing

the PC strand are filled with grout to protect it from corrosion.31 For external post-tensioning

applications, coated PC strand or uncoated, galvanized PC strand may be used to protect against

corrosion.32 Whether it is used uncoated or coated, PC strand of various suppliers is generally

interchangeable within each physical size, physical configuration, and grade.
 33 The American Society for Testing and Materials (“ASTM”) specifies mechanical properties for finished PC

strand, but does not specify the chemical composition of the wire used to make PC strand. ASTM Standard A416/A

416M-06, 2006, “Standard Specification for Steel Strand, Uncoated Seven-Wire for Prestressed Concrete,” ASTM

International, West Conshohocken, PA, 2009, Section 1, vol. 01.04, pp. 246-250; ASTM Standard A421/A 412M05, 2005, “Standard Specification for Uncoated Stress-Relieved Steel Wire for Prestressed Concrete,” West

Conshohoken, PA: ASTM, 2009, Section 1, vol. 01.04, pp. 251-254; and ASTM Standard A910/A 910M-05, 2005,

“Standard Specification for Uncoated, Weldless, 2- and 3-Wire Steel Strand for Prestressed Concrete,” West

Conshohoken, PA: ASTM, 2009, Section 1, vol. 01.04, pp. 514-517.

 34 ***.

 35 PC strand made from indented wire may be specified for certain pre-tensioning applications. The indentations

in the wire enhance the bond between the cured concrete and the PC strand. Post-tensioning applications do not

depend on the strand curing to the concrete but rather the use of anchors to compress the concrete.

 36 Low-relaxation strand is regarded as the standard type of PC strand and stress-relieved strand is not furnished

unless specifically requested by a customer. See ASTM Standard A416/A 416M-06, 2006, “Standard Specification

for Steel Strand, Uncoated Seven-Wire for Prestressed Concrete,” ASTM International, West Conshohocken, PA,

2009, Section 1, vol. 01.04, pp. 246-250; and ASTM Standard A910/A 910M-05, 2005, “Standard Specification for

Uncoated, Weldless, 2- and 3-Wire Steel Strand for Prestressed Concrete,” West Conshohoken, PA: ASTM, 2009,

Section 1, vol. 01.04, pp. 514-517.

 37 PC strand is coated or greased and covered to improve its resistance to corrosion. End users may purchase

epoxy-coated PC strand to further enhance the corrosion resistance of the strand in applications where there is an

abundance of moisture, such as in bridge and/or in other applications where the strand is exposed to the elements. 

Staff telephone interview, ***, June 29, 2009.

 38 Petition, vol. I, p. 10.

 39 PC strand packaged as a wrapped coil may be stenciled or have a label affixed. The label may include such

information as producer, raw material source, and certifications (Buy America(n) compliant), etc. Petitioners state,

however, that once this packaging is removed, PC strand coils manufactured by different producers and in different

countries are indistinguishable. Hearing transcript, p. 149 (Luberda, Johnson, and Feitler).

I-12

Manufacturing Process

PC strand is produced from hot-rolled, high-carbon steel wire rod33 through a production process

consisting of four distinct steps: drawing, stranding, stabilizing, and packaging. The drawing step begins

with cleaning and descaling to remove dirt and mill scale from the hot-rolled, high-carbon steel wire rod

before feeding it through the wire drawing dies. Cleaning and descaling can be accomplished chemically,

using a strong acid, or mechanically, using abrasive methods.34 The cleaned and descaled wire rod is then

coated with zinc phosphate and pulled through a series of wire drawing dies to reduce its size. Depending

on the finished size required, the rod may be drawn through up to nine dies. If indented wire is specified,

the wire is indented, using carbide rollers, after the final size reduction.35

After drawing, the wire undergoes stranding. During the stranding process, wires are wound into

a strand, helically and uniformly, by a stranding machine. The PC strand is then stabilized by removing

residual mechanical stresses through thermal and possibly mechanical treatments. The extent of the stress

relief determines the type of PC strand. Low-relaxation PC strand is subjected to simultaneous thermal

and mechanical treatment after stranding, while “normal”-relaxation PC strand (commonly referred to as

stressed-relieved PC strand) requires only thermal treatment.36 Finally, if coating is required, the PC

strand is either lubricated with grease and encased in a plastic tube, or coated with epoxy.37

The finished product is wound onto a drum, strapped into place with steel bands, and packaged as

a coil. The coil may be covered with a protective material, such as plastic or burlap and is packaged such

that the end user can place the coil directly onto a strand dispenser.38 PC strand ready for shipment is

labeled, either by stenciling or tagging.39
 40 Prestressed Concrete Steel Wire Strand from China: Investigation Nos. 701-TA-464 and 731-TA-1160

(Preliminary), USITC Publication 4086, July 2009, pp. 3-9.

 41 Petitioners’ postconference brief, pp. 3-7; petitioners’ prehearing brief, pp. 4-9.

 42 Petitioners’ prehearing brief, p. 4.

 43 Conference transcript, p. 137 (Levinson). During the preliminary phase, there were two parties to the

investigations: (1) American, Insteel, and Sumiden (domestic producers) and (2) Global Steel Sales Corp. (U.S.

importer of subject merchandise). However, Global Steel Sales Corp. is not participating in the final phase of these

investigations. In a letter dated February 9, 2010, counsel for Global Steel Sales Corp. withdrew the entry of

appearance on behalf of his client.

I-13

DOMESTIC LIKE PRODUCT ISSUES

No issues with respect to domestic like product and domestic industry have been raised in these

investigations concerning PC strand from China. In its determination in the preliminary phase of these

investigations, the Commission defined a single domestic like product in a manner that was co-extensive

with Commerce’s scope of the investigations, as the Commission has done in previous investigations

involving PC strand.40 Petitioners proposed in both the preliminary and final phases of these

investigations that the domestic like product and domestic industry should continue to be defined as they

were by the Commission in its 2003-04 investigations and 2009 reviews concerning PC strand from

Brazil, India, Korea, Mexico, and Thailand: all PC strand co-extensive with Commerce’s scope and all

U.S. producers of the domestic like product, excluding firms that solely coat PC strand.41 Petitioners

added that “{n}o significant changes have occurred to the production of the product, its nature, or its uses

that warrant adoption of a different like product definition here.”42 The respondent that participated in the

preliminary phase of these investigations indicated that it was in agreement with the petitioners with

regard to the definitions of the domestic like product and domestic industry.43
 
 1

 Conference transcript, pp. 15 (Selhorst) and 73 (Woltz).

 2

 Craig D. Olson and Laura N. Smith, “Building with Concrete: Post-tensioned Concrete for Today’s Market,”

The Seattle Daily Journal of Commerce, May 9, 1997, http://www.djc.com/special/concrete97/10024302.htm. The

Post-Tensioning Institute reported that buildings (*** percent) and slab-on-grade construction (*** percent)

accounted for the largest shares of PTI member tonnages to post-tensioners in 2008. Post-Tensioning Institute, PTI

Tonnage Report: Summary of Post-tensioning Industry Shipments in North America (1972-2008), 2009, p. 1. These

numbers indicate of shift in end uses from 2007, when buildings accounted for *** percent and slab-on-grade

accounted for *** percent of PTI member tonnages to post-tensioners in 2007. Post-Tensioning Institute, PTI

Tonnage Report: Summary of Post-tensioning Industry Shipments in North America (1972-2007), 2008, p. 1.

II-1

PART II: CONDITIONS OF COMPETITION IN THE U.S. MARKET

U.S. MARKET CHARACTERISTICS

PC strand is used in the construction of prestressed concrete structural members, compressing the 

members to offset, or neutralize, forces which occur when they are subject to load. Typical applications

for prestressed concrete include bridge decks, bridge girders, pilings, precast concrete panels and

structural supports, roof trusses, floor supports, and certain concrete foundations.

PC strand is used to prestress concrete either before the concrete is cured (pre-tensioning) or after

it is cured (post-tensioning). Most pre-tensioned concrete elements are prefabricated in a factory and

must be transported to the construction site. Pre-tensioned components may be used in balconies, lintels,

floor slabs, beams, or foundation piles. By contrast, post-tensioning takes place on the job site in

cast-in-place applications.1

 The predominant end uses of post-tensioned PC strand are in buildings for

floors with moderate-to-long spans and moderate floor loads such as in parking garages and residential

buildings, and in slab-on-grade construction.2

U.S. shipments of PC strand by U.S. producers and importers for post-tension applications and

pre-tension applications are shown in table II-1. During 2007-09, U.S. producers sold PC strand

primarily for use in pre-tension applications, while the vast majority of imported Chinese PC strand and

PC strand imported from all other countries was sold for post-tension applications. Overall, total U.S.

shipments of PC strand for pre-tension applications accounted for an increasing share of the U.S. PC

strand market during 2007-09 (figure II-1).

Figure II-1

PC strand: Total U.S. shipments of PC strand, by end use application, 2007-09

* * * * * * *
II-2

Table II-1

PC strand: U.S. producers’ and importers’ U.S. shipments, by sources and application, 2007-09

Item

Period

2007 2008 2009

 Quantity (1,000 pounds)

Domestic producers’ U.S. shipments of PC strand to:

 Pre-tensioned applications 451,955 424,117 340,235

 Post-tensioned applications 131,308 99,726 56,263

U.S. importers’ U.S. shipments of PC strand from China to:

 Pre-tensioned applications 46,175 37,973 7,247

 Post-tensioned applications 288,548 256,753 58,131

U.S. importers’ U.S. shipments of PC strand from all other countries to: 

 Pre-tensioned applications 5,493 3,804 7,498

 Post-tensioned applications 13,359 10,791 28,928

Total U.S. shipments of PC strand: 

 Pre-tensioned applications 503,623 465,894 354,980

 Post-tensioned applications 433,215 367,270 143,322

 Share of quantity (in percent)

Domestic producers’ U.S. shipments of PC strand to:

 Pre-tensioned applications 77.5 81.0 85.8

 Post-tensioned applications 22.5 19.0 14.2

U.S. importers’ U.S. shipments of PC strand from China to:

 Pre-tensioned applications 13.8 12.9 11.1

 Post-tensioned applications 86.2 87.1 88.9

U.S. importers’ U.S. shipments of PC strand from all other countries to: 

 Pre-tensioned applications 29.1 26.1 20.6

 Post-tensioned applications 70.9 73.9 79.4

Total U.S. shipments of PC strand: 

 Pre-tensioned applications 53.8 55.9 71.2

 Post-tensioned applications 46.2 44.1 28.8

Source: Compiled from data submitted in response to Commission questionnaires.
 3

 Examination of the companies identified as distributors/convertors indicates a substantial overlap with

companies identified as end users by U.S. producers.

II-3

CHANNELS OF DISTRIBUTION

U.S. producers sold PC strand only to end users (primarily pre-tensioners) during 2007-09. U.S.

importers reported that U.S. shipments of imported Chinese PC strand were relatively evenly split

between sales to end users and sales to distributors/converters, and were primarily used for post-tension

applications. PC strand imported from all other countries was sold primarily to distributors/converters

during 2007-09.3

SUPPLY AND DEMAND CONSIDERATIONS

Supply

U.S. Supply

Available information indicates that U.S. PC strand producers currently have the ability to

respond to changes in demand with relatively large changes in the quantity of shipments of U.S.-produced

PC strand to the U.S. market. The main contributing factors to the high degree of supply responsiveness

are relatively low industry capacity utilization rates and relatively large inventory levels. However, U.S.

producers and purchasers indicated that there have been periods during 2007-09 when U.S. producers

have been either unwilling or unable to fully supply U.S. purchasers with PC strand.

Industry capacity

U.S. producers operated at relatively low levels of capacity utilization, particularly by the end of

the period. U.S. producers’ capacity to produce PC strand increased from 902.8 million pounds in 2007

to 903.8 million pounds in 2008 and 2009. However, U.S. producers’ capacity utilization rates fell from

66.7 percent in 2007 to 61.8 percent in 2008, then declined sharply to 43.8 percent in 2009, as U.S.

production fell by 29.2 percent in 2009.

Alternative markets

U.S. producers’ export shipments accounted for a relatively small share of their total shipments

during 2007-09. U.S. producers’ export shipments, as a share of total shipments, fluctuated between ***

percent and *** percent during 2007-09. Principal U.S. export markets include ***.

Inventory levels

U.S. producers’ inventory levels, relative to shipments, increased over the period. The ratio of

U.S. producers’ inventories to total shipments grew from *** percent in 2007 to *** percent in 2009.
 4

 As reported in the trade press, Insteel, “faced with a major maintenance outage by one of its rod suppliers last

year after having been placed on controlled order entry by other domestic suppliers, looked overseas for relief,”

although the company reportedly paid “top-of-the-market” prices and saw the wire rod market “collapse” by the time

the wire rod arrived. AMM, “Insteel gets caught in import squeeze,” January 15, 2009.

 5

 *** reported that “{t}wo domestic suppliers refused to sell the amount of strand we needed. As a result, we had

to buy less strand from them. Remaining strand we had to buy from foreign suppliers.” *** reported that ***

declined to fill orders. *** reported that some suppliers were limited by lack of product from certain mills. ***

reported that “U.S. manufacturers had issues with rising rod prices, which caused them to look for ways to back out

of orders.”

 6

 Exports of PC strand to the United States by the four responding Chinese producers accounted for 19.1 percent

of total U.S. imports of PC strand from China in 2008.

II-4

Production alternatives

*** reported being able to switch production between PC strand and other products in response to

a relative change in the price of PC strand, using the same equipment and labor. ***.

Supply constraints 

Two of the five responding U.S. producers reported that there have been instances when they

have refused, declined, or been unable to supply PC strand since January 1, 2007. ***.4

***.

Several purchasers reported instances when domestic producers either refused to sell them the

amount of PC strand they needed, or were unable to fill orders.5

 One purchaser (***) reported that, in

2008, Chinese suppliers were late on deliveries, and that some of these orders were canceled.

Subject Imports from China

Based on available information, Chinese producers have the ability to respond to changes in

demand with large changes in the quantity of shipments of PC strand to the U.S. market. The main

contributing factors to the high degree of supply responsiveness are Chinese producers’ demonstrated

ability to add production capacity and the existence of substantial alternate markets. Chinese producers’

high rates of capacity utilization during most of the period likely affected their ability to respond to

changes in U.S. demand. The most recent data available, however, suggest that Chinese producers, like

U.S. producers, experienced lower capacity utilization rates in 2009.

No Chinese producers responded to Commission foreign producers’ questionnaires during the

final phase of these investigations. The information contained in this section is based on data provided by

four Chinese producers of PC strand during the preliminary investigations6

 and information provided by

petitioners (see Part VII for more information regarding the industry in China).

Industry capacity

According to estimates provided in the questionnaire responses of Chinese PC strand producers

received during the preliminary phase of these investigations, total 2008 production of PC strand in China

is believed to have been approximately 5.1 billion pounds. Petitioners maintain that there are at least 30

producers of PC strand in China, and provided information in their prehearing brief indicating that total

estimated Chinese PC strand capacity based on installed PC strand equipment is roughly 6.6 billion
 7

 Petitioners’ prehearing brief, p. 69 and exhibit 11.

 8

 Petitioners’ prehearing brief, p. 71.

 9

 Rob Hendricks of Global Steel Sales Corp. acknowledged that “{t}he Chinese have all the capacity they need to

supply all the strand that this market could possibly buy. That’s a true statement. So do the Europeans. The

Europeans are working at less than 50 percent. The whole world is in an economic crisis. Nobody is running their

facilities anywhere near capacity.” Conference transcript, p. 120 (Hendricks).

II-5

pounds as of March 2010.7

 To compare, aggregate reported capacity for European Union PC strand

producers was approximately 2.1 billion pounds in 2007, and available data for Brazil, India, Japan,

Korea, Mexico, and Thailand indicate that total 2008/09 capacity to produce PC strand in these six

countries combined is estimated at approximately 1.3 billion pounds. Petitioners note that Chinese PC

strand capacity of 6.6 billion pounds is 6.7 times larger than the peak apparent U.S. consumption level of

980 million pounds in 2007.8

The four responding Chinese producers reported an increase in capacity from 630.2 million

pounds in 2006 to 908.3 million pounds in 2008. Reported capacity utilization was close to 100 percent

during 2006-08 but was 74.0 percent in January-March 2008 and 84.5 percent in January-March 2009.9

Alternative markets

The four responding Chinese firms reported that more than two-thirds of their shipments were to

the Chinese home market during 2006-08. Exports to the United States, as a share of total shipments, fell

from 17.5 percent in 2006 to 8.6 percent in 2008, and accounted for only 0.9 percent of all shipments in

January-March 2009. These firms reported exporting to a large number of other markets; such exports, as

a share of total shipments, grew from 10.3 percent in 2006 to 23.4 percent in 2008. PC strand produced

in China is currently subject to antidumping duties in the European Union, effective May 5, 2009 (see

Part VII for more information regarding antidumping investigations in third-country markets).

Inventory levels

Inventories of PC strand in China reported by the four responding Chinese firms ranged from 3.6

to 6.8 percent of total shipments during 2006 to 2008, and reached 8.0 percent by March 2009. U.S.

importers’ end-of-period inventories of Chinese PC strand increased from 31.7 million pounds

(equivalent to 9.4 percent of U.S. shipments of imports) in December 2007 to 51.5 million pounds

(equivalent to 17.3 percent of U.S. shipments of imports) in 2008, but fell sharply to 15.0 million pounds

(equivalent to 22.8 percent of U.S. shipments of imports) by December 2009. 

Production alternatives

*** of the responding Chinese firms reported production of other products in addition to PC

strand on the same equipment and machinery used in the production of PC strand in China.

Nonsubject Imports

There are at least 22 producers of PC strand in the countries that comprise the European Union. 

Overall European Union production was reported to be 2.1 billion pounds in 2007, and these facilities

reportedly operated at 79 percent capacity utilization. In addition, the available data for Brazil, India,

Japan, Korea, Mexico, and Thailand indicate that PC strand capacity and production in each of these

countries is substantially smaller than that of China. Total 2008/09 capacity to produce PC strand by 23
 10 Tim Johnson of Suncoast Post-tensioners, reported that “I’m losing, on a single family house where we are

delivering a cable package, I’m losing business for $6 on a house. A house that you would buy for $200,000, I’m

losing business for $6 on that cable package that’s less than a half a cent a foot.” Conference transcript, p. 79

(Johnson).

 11 In addition, the Architecture Billings Index (“ABI”), a leading indicator of U.S. construction activity, was 48.4

in April, up from 46.1 in March. Although this score still indicates a decline in demand for design services (any

score below 50 indicates a decrease in billings), it is the highest score since January 2008 when revenue at

architecture firms headed into recession. “It appears that the design and construction industry may be nearing an

actual recovery phase,” said American Institute of Architects’ Chief Economist Kermit Baker. “The economic

landscape is improving, although not across the board, but doing so at a gradual pace. It is quite possible that we

will finally see positive business conditions in the foreseeable future.” Regional ABI averages were: Northeast

(51.0), Midwest (49.2), South (46.5), and West (44.7). ABI sector index breakdowns were: commercial/industrial

(48.5), mixed practice (48.4), institutional (46.8), and multi-family residential (45.8). “ABI News and Graphs,”

Architect Magazine, May 19, 2010. http://www.architectmagazine.com/economic-conditions/abi-report.aspx

II-6

producers in these six countries combined is estimated at approximately 1.3 billion pounds (see Part VII

for more information regarding the industry in nonsubject countries).

U.S. Demand

Based on available information, the overall demand for PC strand is likely to change moderately

in response to changes in price. The relatively large cost share that PC strand accounts for in its end-use

products, particularly in post-tensioned applications such as slabs-on-grade, suggests a higher demand

elasticity.10 However, the somewhat limited number of substitute products reduces the elasticity of

demand for PC strand.

Demand Characteristics

PC strand is used in the construction of prestressed concrete structural members. Prestressed

concrete members are used in the construction of buildings, bridges, parking decks and garages,

highways, and slabs for residences. Therefore, demand for PC strand is derived from the demand for

construction, particularly infrastructure projects, commercial and institutional construction, large housing

projects, and single-family housing. Monthly values of public, private nonresidential, and private

residential construction are shown in figure II-2. Cyclical monthly values of private residential

construction trended downward sharply, from a peak of $47.7 billion in July 2007 to a low of $17.3

billion in February 2009. Monthly values for private nonresidential construction trended upward through

2007 and into mid-2008, but began trending downward over the second half of 2008 and continued

downward through 2009. Cyclical trends for public construction were relatively stable during 2007-09.11

Private residential construction reportedly uses more slabs-on-grade, a post-tensioned application, than

public construction and private nonresidential construction. This suggests that the demand for posttensioning applications has decreased at a greater rate than demand for pre-tensioning applications since

2007.
 12 Conference transcript, p. 74 (Johnson and Woltz).

II-7

Figure II-2

Construction: Monthly values of construction put in place, by type, January 2007-December 2009

Source: U.S. Census Bureau, http://www.census.gov/const/www/totpage.html.

Business Cycles

Demand for PC strand is cyclical because it is a construction material, and demand for residential

and non-residential construction is cyclical. Demand for PC strand is also seasonal because construction

sites are more active during warmer weather months than during winter months, as can be seen in figure

II-2. Therefore, U.S. demand for PC strand is generally higher during April-September than during

October-March.12

Ten of 20 responding purchasers reported that the PC strand market is subject to business cycles

or conditions of competition that are distinctive to PC strand. In general, these purchasers noted that

demand for PC strand depends on demand for construction, which tends to follow general economic

trends. Only 3 of 18 responding purchasers reported that the emergence of new markets for PC strand

since 2003 affected PC strand business cycles. One purchaser, ***, maintained that world demand for

materials increased through 2008, and that materials markets are more global now than they were in the

past.

0

10,000

20,000

30,000

40,000

50,000

60,000

2007 2008 2009

millions of dollars

Private res idential Private nonres idential Public
 13 The PTI-defined regions differ from the regions used in USITC questionnaires. The PTI Rocky Mountain

states and Southwest zone includes CO, KS, MT, ND, NE, NM, OK, SD, TX, and WY. The PTI West Coast zone

includes AK, AZ, CA, HI, ID, NV, OR, UT, and WA. The PTI Southeast zone includes AL, AR, FL, GA, LA, MS,

NC, SC, TN. The PTI Midwest zone includes IL, IN, IA, KY, MI, MN, MO, OH, and WI. The PTI Northeast zone

includes CT, DE, MA, ME, MD, NH, NJ, NY, PA, RI, VT, VA, and WV. Post-Tensioning Institute, PTI Tonnage

Report: Summary of Post-tensioning Industry Shipments in North America (1972-2008), 2009, pp. 1 and 5.

 14 Ibid., p. 6.

II-8

Regional Demand for Post-Tensioned PC Strand

Data compiled by PTI indicate that U.S. shipments of PC strand for post-tensioning uses were

***.13 Post-tensioning shipments of PC strand to ***. Post-tensioning shipments to ***.14

Consumption

Available data indicate that apparent U.S. consumption of PC strand fell sharply over the period,

particularly in 2009. Apparent U.S. consumption of PC strand fell by 3.9 percent from 981 million

pounds in 2007 to 943 million pounds in 2008, then fell sharply by 46.0 percent to 509 million pounds in

2009. Overall, apparent U.S. consumption of PC strand was 48.1 percent lower in 2009 than it was in

2007.

Demand Trends

When asked how the U.S. demand for PC strand had changed since January 1, 2007, four U.S.

producers reported that U.S. demand had decreased and one reported that U.S. demand had fluctuated. 

Among the 19 responding importers, 9 reported that U.S. demand had fluctuated, 8 reported that U.S.

demand had decreased, 1 reported that U.S. demand had increased, and 1 reported no change in demand. 

Firms that reported fluctuating U.S. demand for PC strand often cited increasing U.S. demand for

commercial and residential construction during the first half of 2008, then sharply declining demand for

commercial and residential construction since then due to the economic conditions in the United States.

Most (12) responding purchasers reported that U.S. demand for PC strand had decreased since

January 2007, although four reported that U.S. demand had increased, two reported no change in demand,

and one reported that U.S. demand had fluctuated. In general, purchasers reported that U.S. demand for

PC strand was influenced by changes in the overall condition of the U.S. economy and by U.S.

construction activity in particular.

Nine of twenty responding purchasers reported that their purchasing patterns for PC strand from

domestic, subject, and nonsubject sources had changed since 2007. In general, responding purchasers

cited declines in PC strand purchase volumes due to declines in the U.S. residential and commercial

construction markets.

In general, responding purchasers reported that, since 2007, their purchases of imported Chinese

PC strand either declined or fluctuated relative to their purchases of PC strand from other sources. One

purchaser, ***, reported that its relative purchases of imported Chinese PC strand declined because more

projects were requiring U.S.-made PC strand. In contrast, four of seven responding purchasers reported

that their purchases of PC strand imported from nonsubject countries increased relative to their PC strand

purchases from other sources since 2007. Purchasers that reported increased relative purchases of

nonsubject-country PC strand cited the competitive prices of the nonsubject-country PC strand, the lack

of availability of imported Chinese PC strand, and the void in the U.S. market caused by a lack of U.S.

supply.
 15 OpenCongress Web site. http://www.opencongress.org/bill/111-h1/show (Accessed October 7, 2009).

 16 USAspending Web site. http://www.usaspending.gov/index.php (Accessed October 7, 2009).

 17 The top five DOT programs receiving ARRA funding in fiscal 2009 were the Highway Planning and

Construction program ($12.6 billion), Federal Transit Formula Grants ($3.1 billion), the Airport Improvement

program ($763 million), Federal Transit Capital Investment Grants ($656 million), and Formula Grants for Other

Than Urbanized Areas ($313 million). The top five DOT recipients of ARRA funding in fiscal 2009 were the

California Department of Transportation ($1.6 billion), the Florida Department of Transportation ($1.1 billion), the

Texas State Department of Highways ($726 million), the New York State Department of Transportation ($650

million), and the Pennsylvania Department of Transportation ($604 million). USAspending Web site. 

http://www.usaspending.gov/index.php (Accessed October 7, 2009).

 18 Hearing transcript, p. 14 (Selhorst) and pp. 63-64 and 119-120 (Woltz). Other U.S. steel firms agreed with

domestic interested parties’ assessment. Patrick Mcfadden of Nucor stated “we don’t think that steel is going to be

seriously affected by the ARRA until the latter half of 2010 at the earliest.” Robert Risser of the Concrete

Reinforcing Steel Institute dubbed ARRA “the Asphalt Resurfacing Recovery Act.” Stan Hasselbusch of L.B.

Foster estimated that only $16 billion of the $270 billion in infrastructure spending will be spent on steel. AMM,

“Steel is not Feeling One Bit Stimulated by Government: Experts, Execs,” October 7, 2009. At the AMM State of

Steel conference, Mario Longhi, president and CEO of Gerdau Ameristeel said “the federal stimulus package has

been disappointing at best,” citing a recent study that shows the only area where job growth occurred was in the

government sector. Mr. Longhi maintained that only 7 percent of projects funded by the stimulus package are

complete, and four of five projects are less than 50 percent complete or have not been started. All Business, “AMM

State of Steel Conference: Steel Industry at Critical Inflection Point,” January 27, 2010.

http://www.allbusiness.com/economy-economic-indicators/economic-conditions-growth/13821072-1.html (Accessed

April 16, 2010). See also petitioners’ posthearing brief, exhibit 1, pp. 29-30.

 19 Insteel reported in its 10-Q for the period ending January 2, 2010, that “Our visibility for business conditions

through the remainder of 2010 is clouded by the continued uncertainty regarding future global economic conditions

and the impact of the measures that have been undertaken by the federal government to ease the tightening in the

credit markets and stimulate the economy. We expect the ongoing weakness in nonresidential construction, our

primary demand driver, to continue, particularly for commercial projects which have been the most severely

impacted by the economic downturn. There continues to be uncertainty regarding the resolution of a new multi-year

federal highway funding authorization. Although the additional infrastructure-related funding provided for under the

American Recovery and Reinvestment Act is expected to increase during 2010, any favorable impact is likely to be

mitigated by continued deterioration in the fiscal positions of state and local governments. We anticipate that

residential construction will remain weak, which would continue to adversely affect shipments to customers that

have greater exposure to the housing sector.” 

II-9

Anticipated Demand

Federal spending on infrastructure is a factor that impacts U.S. demand for PC strand. On

February 17, 2009, President Obama signed into law the American Recovery and Reinvestment Act of

2009 (ARRA). ARRA is estimated by the Congressional Budget office to cost $787 billion over the

2009-2019 period.15 For fiscal year 2009, ARRA provided $17.4 billion worth of federal funds to the

U.S. Department of Transportation (DOT) through grants and cooperative agreements.16 17

However, at the Commission hearing, domestic interested parties maintained that the U.S. PC

strand industry is not currently benefitting from the stimulus package (ARRA). Domestic interested

parties reported that a disproportionate share of the stimulus funding is going to “shovel ready” projects

such as resurfacing and re-paving highways, which do not use PC strand. As a result, domestic interested

parties contended that the stimulus funding was unlikely to have any effect on the U.S. PC strand industry

in 2009, and only minimal effect in 2010.18 19
 20 Rebar is used to impart support, whereas PC strand imparts strength. In some cases, rebar and PC strand are

used in conjunction in the production of construction members. Since rebar and PC strand typically are used for

different purposes, they may not be direct substitutes.

 21 “Buy America” requirements apply to iron and steel products and their coatings that are purchased for the

Federal-aid highway construction program (highways, bridges, transit systems, and terminals). Under “Buy

America,” Federal-aid funds may not be obligated for a project unless iron and steel products used in such projects

are manufactured in the United States (with limited exceptions based on the product cost or its share of the original

contract value). In addition, under an alternate-bid procedure, foreign-source materials may be used if the total

project bid using foreign-source materials is 25 percent less than the lowest total bid using domestic materials. “Buy

American” is a separate and distinct program from “Buy America,” and has completely different rules. The Buy

American Act, which covers specified products, requires the Federal Government to purchase domestic goods and

services unless the head of the agency involved in the procurement has determined that the prices of the domestic

suppliers are “unreasonable” or that their purchase would be “inconsistent with the public interest.” U.S.

(continued...)

II-10

Substitute Products

No U.S. producers and only 3 of 19 responding importers reported substitutes for PC strand. The

importers that reported substitute products cited rebar, concrete indented wire, steel fiber, and shredded

steel as a possible substitute. All three importers that named rebar as a possible substitute also reported

that changes in rebar prices did not affect prices for PC strand.20

Only 3 of 15 responding purchasers reported substitutes for PC strand, with all three citing rebar

as a possible substitute product. Two purchasers that named rebar as a possible substitute reported that

changes in rebar prices did not affect prices for PC strand, whereas one purchaser reported that increases

in rebar prices have enabled PC strand producers to increase PC strand prices.

Cost Share

U.S. producers reported that the cost of PC strand accounts for 60-85 percent of the cost of end

use applications such as post-tensioned slabs, elevated slabs, and bridge cables, compared to 10-20

percent for prestressed concrete bridge members and 12-25 percent for hollow core planks, piling girders,

and double tees. U.S. importers of Chinese PC strand reported that PC strand accounts for 65-100 percent

of the cost of end-use products for post-tensioning applications such as residential slabs, versus 25

percent for prestressed applications.

Purchasers reported a wide range of PC strand end-use products, including piling, post-tensioning

cables, prestressed concrete beams, wall panels, double tees, bridge girders, precast planks, barrier cables,

and residential and commercial concrete reinforcing. Cost share estimates varied widely, from 3-4

percent for prestressed concrete products such as wall panels to 70-100 percent for end-use products such

as bridge girders and beams, barrier cable systems, and roof bolts.

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported PC strand depends upon such factors

as quality (e.g., meeting or exceeding ASTM specifications, defect rates, etc.), and conditions of sale

(e.g., “Buy America(n)” provisions, lead times between order and delivery dates, reliability of supply,

availability, payment terms, product services, etc.). Based on available information, staff believes that,

for PC strand made to the same ASTM specifications, there is a high degree of substitution between

domestic PC strand and subject imports sold for end uses not subject to “Buy America(n)” provisions. 

However, the existence of substantial end-use markets subject to “Buy America(n)” provisions reduces

the overall substitutability of PC strand in the U.S. market.21
 21 (...continued)

Department of Transportation, Federal Highway Administration Web site, “Construction Program Guide: Buy

America,” http://www.fhwa.dot.gov/construction/cqit/buyam.cfm (accessed July 6, 2009) and U.S. Department of

Transportation, Federal Highway Administration Memorandum, “Buy America Requirements (HHO-32),” dated,

July 6, 1989, last modified July 27, 2007, http://www.fhwa.dot.gov/programadmin/contracts/070689.cfm (accessed

July 6, 2009).

II-11

Factors Affecting Purchasing Decisions

Table II-2 summarizes the purchasers’ responses concerning the top three factors they consider in

their purchasing decisions. As indicated in the table, price was cited most frequently as the primary factor

in buying decisions, followed by quality. Quality was the most frequently cited second factor and

availability was the most frequently cited third factor.

Table II-2

PC strand: Ranking factors used in purchasing decisions by U.S. purchasers

Factor

Number of firms reporting

Number one factor Number two factor Number three factor

Price 10 5 5

Quality 7 8 2

Availability 1 4 7

Service 1 0 0

D0T approved 1 0 0

Credit/terms 0 1 1

Delivery 0 2 3

Traditional supplier 0 0 2

Source: Compiled from data submitted in response to Commission questionnaires.

Purchasers were asked to rate the importance of 15 factors in their purchasing decision (table II3). Seventeen purchasers rated “quality meets industry standards” and product consistency very

important; 16 firms rated price very important; 15 firms rated availability and reliability of supply very

important; 13 rated delivery time very important; and 11 rated delivery terms very important. In contrast,

seven firms reported that minimum quantity requirements and product range were not important factors.

Purchasers were asked for a country-by-country comparison on the same 15 factors (table II-4). 

A majority of purchasers reported that U.S. PC strand was comparable to imported Chinese PC strand for

all but 3 factors. Most purchasers reported that the U.S. delivery times were superior and half of the

responding purchasers reported that U.S. product technical support was superior. Alternatively, most

purchasers reported that Chinese prices were superior (lower). Most purchasers reported U.S. and

nonsubject PC strand were comparable for 10 factors, although for availability, delivery terms, delivery

time, and technical support most purchasers reported U.S. product was superior, while most purchasers

reported that U.S. PC strand was inferior in terms of price (i.e., higher-priced). No purchasers compared

Chinese PC strand with PC strand from nonsubject countries.
II-12

Table II-3

PC strand: Importance of purchase factors, as reported by U.S. purchasers 

Factor

Very important Somewhat important Not important

Number of firms responding

Availability 15 3 0

Delivery terms 11 7 0

Delivery time 13 5 0

Discounts offered 7 10 1

Extension of credit 5 10 3

Minimum qty requirements 4 7 7

Packaging 8 9 1

Price 16 2 0

Product consistency 17 1 0

Product range 2 9 7

Quality meets industry

standards 17 1 0

Quality exceeds industry

standards 6 11 1

Reliability of supply 15 3 0

Technical support/service 7 11 0

U.S. transportation costs 8 9 1

Note.--Not all purchasers responded for each factor.

Source: Compiled from data submitted in response to Commission questionnaires.
II-13

Table II-4

PC strand: Comparisons between U.S.-produced and subject and nonsubject countries as

reported by U.S. purchasers

Factor

U.S. vs. China U.S. vs. Nonsubject

S CISCI

Availability 3 7 0 5 4 0

Delivery terms 4 6 0 5 4 0

Delivery time 6 4 0 9 0 0

Discounts offered 1 7 2 2 7 0

Extension of credit 0 10 0 1 5 2

Minimum qty requirements 1 9 0 2 5 2

Packaging 1 9 0 3 5 1

Price 1 3 6 0 2 7

Product consistency 0 10 0 0 9 0

Product range 2 7 0 4 5 0

Quality meets industry standards 0 10 0 0 9 0

Quality exceeds industry standards 0 8 0 0 9 0

Reliability of supply 2 8 0 3 6 0

Technical support/service 5 4 1 7 2 0

U.S. transportation costs 3 5 0 2 5 2

Note.--S=first listed country’s product is superior; C=both countries’ products are comparable; I=first listed country’s

product is inferior. Data shown only for comparisons made by at least 3 purchasers. A rating of superior means that

price/U.S. transportation cost is generally lower. For example, if a firm reported “U.S. superior,” it meant that the

price of U.S. product was generally lower than the price of the imported product.

Source: Compiled from data submitted in response to Commission questionnaires.

When asked if certain grades/types/sizes of PC strand were available from only a single source,

16 of 20 responding purchasers answered “No.” Purchasers were also asked if they or their customers

ever specifically requested PC strand from one country over other possible sources. Ten of 19 responding

purchasers reported that they sometimes specifically order U.S. PC strand, citing factors such as “Buy

America(n)” provisions, preference for the quality and consistency of U.S. PC strand, the time required to

develop additional sources, and a desire to support the domestic industry.

Twelve purchasers reported purchasing U.S. PC strand although comparable PC strand was

available from another source at a lower price. Reasons cited include: “Buy America(n)” requirements;

supplier diversification; desire to support the domestic industry; and U.S. quality, delivery, reliability, and

qualification time. One purchaser (***) reported that there were times when it purchased imported

Chinese PC strand at a higher price, because domestic suppliers were unwilling to fill its orders in 2008.

Asked whether or not they required their suppliers to become certified or qualified with respect to

the quality, chemistry, strength, or other performance characteristics of the PC strand they purchase, 16 of

21 responding purchasers reported that they required certification/qualification for all of their PC strand

purchases, and one purchaser required qualification/certification for 95 percent of its PC strand purchases. 

Cited qualification requirements include meeting ASTM, PTI, or Texas State standards. Other

qualification factors cited by purchasers include PC strand meeting minimum quality standards,
 22 During 2007-09, more than *** of U.S. producers’ total U.S. shipments of PC strand (quantity basis) were for

pre-tensioned applications, almost *** percent of which were subject to “Buy America(n)” restrictions. Of the less

than *** percent of U.S. producers’ total shipments that were destined for post-tensioned applications during 2007-

09, *** were subject to “Buy America(n) restrictions. 

 23 For a more detailed discussion of U.S. producers’ U.S. shipments see Part III: Condition of the U.S. Industry.

II-14

availability, reliability, and price. Reported qualification times ranged from one day to one year, with

seven of the nine responding purchasers reporting times ranging from one week to 3 months. 

Characteristics purchasers consider when determining the quality of PC strand include meeting 

ASTM A416, state DOT, or project standards; packaging (e.g., weather protection and ease of access to

material); quality consistency factors such as consistent elasticity, consistent cross sectional area, and

absence of breaks, welds, splices, and rust; bond strength; modulus; and performance in the past or mill

reputation.

Purchasers were asked if buying PC strand that is produced in the United States is an important

factor in their firm’s purchases of PC strand. Fourteen of 20 responding purchasers reported that buying

U.S. product is an important factor. A majority of these purchasers (12) reported that they were required

by law or regulation to purchase domestic product in certain instances (e.g., government purchases under

“Buy America(n)” provisions). Purchasers reported share of their firm’s PC strand purchases subject to

“Buy America(n)” requirements varied widely (from 3 to 100 percent), with five purchasers reporting that

at least 85 percent of their purchases were subject to “Buy America(n)” restrictions.

A substantial share of the U.S. PC strand market is subject to “Buy America(n)” restrictions. As

a share of total apparent U.S. consumption, total U.S. shipments of PC strand (quantity basis) subject to

“Buy America(n)” restrictions increased from 28.6 percent in 2007 to 33.9 percent in 2008, then

increased sharply to 49.5 percent in 2009, as sales of PC strand for post-tension applications fell to a

greater extent than sales of PC strand for pre-tension applications.22 23

Comparison of Domestic Products, Chinese, and Nonsubject Imports

All 5 responding U.S. producers, 12 of 18 responding importers, and 8 of 10 responding

purchasers indicated that U.S. and imported Chinese PC strand were “always” used interchangeably. All

four responding U.S. producers, most importers, and most purchasers reported that U.S., imported

Chinese, and nonsubject country PC strand were always interchangeable (table II-5). All five responding

U.S. producers reported that non-price differences between U.S. and Chinese PC strand were never

significant, and all four responding U.S. producers reported that non-price differences between U.S. and

nonsubject country PC strand and between Chinese and nonsubject country PC strand were never

significant. Alternatively, 5 of 17 responding importers reported that non-price differences between U.S.

and imported Chinese PC strand were either “always” or “frequently” significant, and half of the

responding importers reported that non-price differences between U.S. and nonsubject country PC strand

and between imported Chinese and nonsubject country product were either “always” or “frequently”

significant (table II-6).
II-15

Table II-5

PC strand: Perceived interchangeability of products produced in the United States, in China, and

in nonsubject countries, by country pairs1

Country pair

Number of U.S. 

producers reporting

Number of U.S.

importers reporting

Number of U.S.

purchasers reporting

AFSNAFSNAFSN

U.S. vs. China 5 0 0 0 12 5 1 0 8 1 1 0

U.S. vs. nonsubject 400082208020

China vs. nonsubject 400090006020

 1 Producers and importers were asked if PC strand produced in the United States and in other countries are used

interchangeably.

Note.--A = Always, F = Frequently, S = Sometimes, N = Never.

Source: Compiled from data submitted in response to Commission questionnaires.

Table II-6

PC strand: Perceived significance of differences other than price between products produced in

the United States, in China, and in nonsubject countries, by country pairs1

Country comparison

Number of 

U.S. producers reporting

Number of 

U.S. importers reporting

AFSNAFSN

U.S. vs. China 0 0 0 5 3 2 5 7

U.S. vs. nonsubject 00042415

China vs. nonsubject 00042204

 1 Producers and importers were asked if differences other than price between PC strand produced in the United

States and in other countries were a significant factor in their sales of the products.

Note.--“A” = Always, “F” = Frequently, “S” = Sometimes, “N” = Never.

Source: Compiled from data submitted in response to Commission questionnaires.

ELASTICITY ESTIMATES

U.S. Supply Elasticity

The domestic supply elasticity for PC strand measures the sensitivity of the quantity supplied by

the U.S. producers to changes in the U.S. market price for PC strand. The elasticity of domestic supply

depends on several factors, including the level of excess capacity, the existence of inventories, the

availability of alternate markets for U.S.-produced PC strand, and the ability of U.S. producers to switch

between production of PC strand and other products. Previous analysis of these factors indicates that the

U.S. industry has the ability to substantially increase or decrease shipments to the U.S. market based on

available excess capacity and inventory levels. An estimate in the range of 3 to 5 is suggested.

Petitioners did not comment on staff’s U.S. supply elasticity estimate range.
 24 Petitioners’ prehearing brief, p. 23.

 25 “However, the substantial share of the U.S. PC strand market subject to “Buy America(n)” restrictions

moderates the overall substitutability of domestic and imported PC strand in the U.S. market.” Prestressed Concrete

Steel Wire Strand from China, Inv. Nos. 701-TA-464 and 731-TA-1160 (Final), prehearing report, p. II-24.

 26 During 2007-09, the share of total apparent U.S. consumption of PC strand accounted for by U.S. shipments

subject to “Buy America(n)” restrictions ranged from 28.6 percent to 49.5 percent. See also Prestressed Concrete

Steel Wire Strand from Brazil, India, Korea, Mexico, and Thailand, Inv. Nos. 701-TA-432 and 731-TA-1024-1028

(Final), USITC Pub. 3663, January 2004, p. 14.

 27 Conference transcript, pp. 66-68 (Woltz, Johnson, and Selhorst). Hearing transcript, p. 66. (Woltz).

II-16

U.S. Demand Elasticity

The U.S. demand elasticity for PC strand measures the sensitivity of the overall quantity

demanded to a change in the U.S. market price of PC strand. This estimate depends on factors discussed

earlier, such as the existence, availability, and commercial viability of substitute products, as well as the

component share of PC strand in the final cost of end-products in which it is used. The lack of available

substitute products suggests an inelastic demand. However, the relatively large component share of PC

strand in the final cost of its end products indicates a more elastic demand. On balance, it is likely that

the aggregate demand for PC strand is moderately inelastic, with values ranging from -0.5 to -1.0.

Petitioners did not comment on staff’s U.S. demand elasticity estimate range.

Substitution Elasticity

The elasticity of substitution depends upon the extent of product differentiation between the

domestic and imported PC strand. Product differentiation, in turn, depends upon such factors as quality

and condition of sale (availability, delivery terms and time, product range, technical support/service, etc.). 

Based on available information indicating that price was the primary factor in purchasers’ buying

decision, and that the domestic and imported products can frequently be used interchangeably and were

comparable with respect to most purchasing decision factors, staff believes that, for PC strand made to the

same ASTM specifications, there is a high degree of substitution between domestic PC strand and subject

imports sold for end uses not subject to “Buy America(n)” provisions. However, the substantial share of

the U.S. PC strand market subject to “Buy America(n)” restrictions moderates the overall substitutability

of domestic and imported PC strand in the U.S. market. On balance, it is likely that domestic and

imported PC strand are moderately substitutable, with elasticity of substitution values ranging from 2 to 4.

Petitioners did not comment on staff’s substitution elasticity estimate range. However, petitioners

maintain that the “Buy America(n)” analysis should be focused on the share of the total U.S. PC strand

market subject to “Buy America(n)” restrictions; characterize the declining percentages of U.S. shipments

to non-“Buy America(n)” accounts as opposed to “Buy America(n)” accounts as an indication of injury

caused by imports; and stress the existence of a spillover effect of prices of imports sold to non-“Buy

America(n)” accounts on “Buy America(n)” account prices.24

Staff agrees with petitioners that the “Buy America(n)” analysis should be focused on the share of

the total U.S. PC strand market subject to “Buy America(n)” restrictions, as opposed to the share of U.S.

producers’ U.S. shipments subject to “Buy America(n)” restrictions, and accordingly continues to base its

analysis of “Buy America(n)” restrictions on the share of the total U.S. PC strand market subject to “Buy

America(n)” restrictions.25 While “Buy America(n) restrictions do not apply to the majority of the U.S.

PC strand market, staff believes that the share of the market affected by these restrictions can be fairly

and accurately characterized as “substantial.”26 While petitioners testified at the conference and the

hearing concerning the spillover effect of non-“Buy America(n)” pricing,27 Commission price data

indicate that prices for PC strand sold for pre-tension applications (greater share subject to “Buy
 28 Hearing transcript, p. 93 (Selhorst).

II-17

America(n)” restrictions) were consistently higher than prices for PC strand sold for post-tension

applications (lesser share subject to “Buy America(n)” restrictions). At the hearing, petitioners

acknowledged that one of the reasons for this price difference was that a higher percentage of PC strand

sold for pre-tension applications was subject to “Buy America(n)” restrictions.28 The enduring price

differences between pre-tension and post-tension prices suggest that the spillover effect identified by the

petitioners is moderate.

Based on the preceding considerations, staff believes that the prehearing report analysis of the

impact of “Buy America(n)” on the elasticity of substitution is correct and does not need to be amended. 

For these reasons, staff believes that an elasticity of substitution estimate range of 2 to 4 is appropriate.
 
 1

 As indicated earlier in Part I, toll producer RettCo produces PC strand under a toll agreement with tollee MMI,

whereas MMI furnishes RettCo with the raw material, pays RettCo a conversion fee for producing finished PC

strand, and sells the finished PC strand.

 2 Emails from *** to Mary Messer, June 26, 2009 and June 30, 2009.

 3 Prestressed Concrete Steel Wire Strand from Brazil, India, Japan, Korea, Mexico, Thailand, Investigation Nos.

701-TA-432 and 731-TA-1024-1028 (Review) and AA1921-188 (Third Review), hearing transcript, pp. 196-197

(Gomez).

 4

 Camesa Web site, http://www.camesa.com.mx/indexi.htm, accessed June 30, 2009; and WireCo World Group

Web site, http://www.wirecoworldgroup.com/Company/History-of-Growth, accessed June 30, 2009.

 5 Emails from *** to Mary Messer, June 26, 2009 and June 30, 2009.

 6

 Cablesa has since been acquired by Deacero. Petition, exh. INJURY-4.

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 nature of the subsidies and the margins of dumping was

presented earlier in 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 domestic

producers that accounted for all U.S. production of PC strand during 2009.

U.S. PRODUCERS

The Commission sent producer questionnaires to the petitioners (American, Insteel, and Sumiden)

and to three additional firms (MMI, RettCo,1

 and Strand-Tech). Completed questionnaire responses were

received from all domestic firms currently in operation. One domestic firm – PCS (Rosenberg, TX) –

produced PC strand in the United States prior to the period for which information was collected in the

final phase of these investigations and another domestic firm – EMC (Phoenix, AZ) – produced PC strand

in the United States during ***. Although producer questionnaire responses were not completed by these

two firms, certain information was provided to the Commission by related PC strand producers in

Mexico. 

PCS, formerly owned by *** and related to Mexican PC strand producer Camesa, began

production of PC strand at the Rosenberg, TX, site in ***. Production and shipments at that facility

ceased by ***. In 2007, the PC strand production equipment from the PCS Texas site was shipped to the

related PC strand producer in Mexico (Camesa).2

 In testimony presented at the hearing for the recently

completed five-year reviews concerning PC strand from Brazil, India, Japan, Korea, Mexico, and

Thailand, Camesa explained that it shut down its Texas PC strand facility and shipped its PC strand lines

to Mexico because it was faced with “growing capacity on the U.S. manufacturer side” and “the presence

of China” in the United States.3

 Camesa, owned by WireCo World Group, currently operates a wire rope

production facility at that former Rosenberg PC strand site.4

 Production and shipments in 2006 were

estimated for PCS by Camesa as totalling *** pounds. There were no reported production and shipments

of PC strand by PCS subsequent to 2006.5

 

EMC’s Arizona facility, formerly owned by Mexican PC strand producer Cablesa,6

 began

production of PC strand in ***. Production and shipments in 2006 were estimated for EMC by Deacero

as ranging from approximately *** pounds. Production and shipments for 2007 were estimated as

ranging from *** pounds. Production at that facility ceased early in 2007 when Cablesa’s U.S. subsidiary

defaulted on rent payments and the landlord seized the production equipment and premises. In
 7

 Petition, exh. INJURY-4; conference transcript, p. 90 (Woltz, Johnson); emails from *** to Mary Messer, June

26, 2009 and June 30, 2009; and Prestressed Concrete Steel Wire Strand from Brazil, India, Japan, Korea, Mexico,

and Thailand, Investigation Nos. 701-TA-432 and 731-TA-1024-1028 (Review) and AA1921-188 (Third Review),

USITC Publication 4114, November 2009, p. III-2.

 8

 Conference transcript, pp. 79-80 (Woltz); and AMM, “Insteel nixes pilot program to import wire products from

China,” October 22, 2007.

III-2

compliance with a judgment granted to the landlord, the production equipment at the Arizona facility was

auctioned by the landlord in October 2007.7

 Presented in table III-1 is a list of current domestic producers of PC strand and each company’s

position on the petition, production location(s), related and/or affiliated firm(s), and share of 2009 PC

strand production. As indicated in table III-1, the current U.S. producers are not related to any foreign

producers or U.S. importers of PC strand from China. However, two U.S. producers are related to foreign

producers in nonsubject countries: ***. In addition, as discussed in greater detail below, one U.S.

producer (Insteel) directly imported the subject merchandise from China during ***, but has not imported

the subject merchandise since that time.8

 None of the domestic producers reported having produced PC

strand in a foreign trade zone.

Table III-1

PC strand: U.S. producers, positions on the petition, U.S. production locations, related and/or

affiliated firms, and shares of 2009 U.S. production

Firm

Position on

petition

U.S. production

location(s)

Related and/or affiliated

firms

Share of

2009

production

(percent)

American Petitioner

Bedford Heights, OH

Houston, TX *** ***

Insteel Petitioner

Gallatin, TN

Sanderson, FL

Wholly owned by Insteel

Industries, Inc. (US) ***

MMI1 Support Houston, TX *** (2

)

RettCo1 Support Newnan, GA *** ***

Strand-Tech Support Summerville, SC *** ***

Sumiden Petitioner

Dickson, TN

Stockton, CA *** ***

 1 Tollee MMI has a contractual agreement with toll producer RettCo in which MMI supplies the raw materials,

the conversion fee, and the sales force and RettCo converts the raw material to finished PC strand. *** of RettCo’s

production of PC strand is produced for MMI under this tolling arrangement.

 2

 Not applicable.

Source: Compiled from data submitted in response to Commission questionnaires; petition, p. 4; conference

transcript, pp. 14 (Selhorst) and 25 (Cornelius).
 9

 The aggregate data presented for capacity, production, and capacity utilization are for toll producer RettCo and

producers American, Insteel, Strand-Tech, and Sumiden.

 10 Petitioners’ prehearing brief, p. 16.

 11 Calculated from table III-2 and questionnaire responses provided by domestic producers in the recently

completed five-year review concerning PC strand from Brazil, India, Japan, Korea, Mexico, and Thailand. 

Prestressed Concrete Steel Wire Strand from Brazil, India, Japan, Korea, Mexico, and Thailand: Investigation Nos.

701-TA-432 and 731-TA-1024-1028 (Review) and AA1921-188 (Third Review), USITC Publication 4114, November

2009, table III-3.

 12 ***. Insteel’s capacity increase of 70 million pounds from 2006 to 2007 was explained by the company’s

expansion of its Tennessee PC strand facility. The company indicated that at that time it added a production line and

it incorporated new technology into its production process. Conference transcript, pp. 84-85 (Woltz).

III-3

U.S. CAPACITY, PRODUCTION, AND CAPACITY UTILIZATION

U.S. producers’ capacity, production, and capacity utilization data for PC strand are presented in

table III-2.9

 These data show a 0.1-percent increase in capacity from 2007 to 2008 and no change in

capacity thereafter. U.S. producers reported a 34.2-percent decline in production during 2007-09, as their

capacity utilization fell by 22.9 percentage points over this period. The petitioners argued that by 2009,

when the domestic producers’ aggregate capacity utilization fell to 43.8 percent, there was enough

domestic PC strand capacity to supply nearly twice the entire level of domestic demand for PC strand.10

Table III-2

PC strand: U.S. capacity, production, and capacity utilization, 2007-091

Item

Calendar year

2007 2008 2009

Capacity (1,000 pounds) 902,782 903,795 903,795

Production (1,000 pounds) 601,717 558,885 395,658

Capacity utilization (percent) 66.7 61.8 43.8

 1 Capacity (production capability) data is based on operating 168 hours per week and 48.6 to 52 weeks per year. 

Note.--The aggregate data presented in the table are for toll producer RettCo and producers American, Insteel,

Strand-Tech, and Sumiden. The data presented do not include the following estimated data for EMC, the domestic

PC strand facility that was shuttered during early 2007: *** pounds of capacity and *** pounds of production in

2007.

Source: Compiled from data submitted in response to Commission questionnaires; petition, pp. 3-4 and exh.

INJURY-4; emails from *** to Mary Messer, June 26, 2009, and June 30, 2009.

As previously noted, there was an overall annual decline in PC strand production from 2007 to

2009; however, the domestic PC strand industry experienced an increase in PC strand production in the

last six months of 2009 as compared with the first six months of that year. During the first half of 2009,

the domestic industry produced 172.4 million pounds of PC strand. During the last half of 2009,

aggregate U.S. production of PC strand was calculated to be 223.3 million pounds, up by 29.5 percent

over the first half of the year.11

Although two domestic producers (*** and ***) reported capacity increases in the year prior to

the period for which data were collected in the final phase of these investigations,12 only one domestic PC

strand producer (***) reported an increase in its capacity to produce since 2007. ***.
 13 Petition, pp. 3-4 and exh. INJURY-4 and emails from *** to Mary Messer, June 26, 2009, and June 30, 2009.

 14 Conference transcript, pp. 54-55 (Woltz and Cornelius).

 15 Conference transcript, p. 54 (Woltz).

 16 Conference transcript, p. 91 (Selhorst).

III-4

The 2007 capacity and production data presented in table III-2, however, do not include the data

of EMC, the domestic PC strand facility in Arizona that was closed in early 2007. Estimated capacity and

production of PC strand at this firm for 2007 was approximately *** pounds and *** pounds,

respectively.13 If these estimates are included in the aggregate data, the annual capacity data would show

an overall ***-percent decrease in capacity during 2007-09, a ***-percent decline in production, and a

*** percentage point decline in capacity utilization.

The domestic PC strand producers were asked in Commission questionnaires to describe the

constraints that set the limit on their production capacity for PC strand. Four of the five producers

indicated that the stranding operations machinery was the production constraint at their facilities. One

producer indicated that it was specifically the cleaning/pickling operation that was the production

constraint for its production facility. None of the U.S. producers of PC strand reported the production of

other products on the same equipment and machinery and using the same production and related workers

employed in the production of PC strand. Likewise, no U.S. producer reported the ability to switch

production between PC strand and other products in response to a relative change in the price of PC

strand vis-a-vis the price of other products, using the same equipment and labor.

In the Commission’s questionnaire, U.S. producers were asked if they had experienced any plant

openings, relocations, expansions, acquisitions, consolidations, closures, or prolonged shutdowns because

of strikes or equipment failure; curtailment of production because of shortages of materials; or any other

change in the character of their operations or organization relating to the production of PC strand since

January 1, 2007. *** reported such changes; their responses to this inquiry are presented in table III-3.

Table III-3

PC strand: U.S. producers’ comments concerning changes in the character of operations

* * * * * * *

Two domestic producers, Insteel and Sumiden, reported that they epoxy-coat bare PC strand at

their U.S. PC strand facilities. These two U.S. producers are the only domestic firms that manufacture the

epoxy-coated PC strand, using an epoxy-coating process technology for which Insteel holds the patent. 

The epoxy-coating line uses a proprietary technology that is technically sophisticated. These firms

indicated that bare PC strand accounts for approximately *** percent of the total value of this highly

specialized epoxy-coated strand product. Insteel and Sumiden indicated that the epoxy-coated strand

accounts for a very small share of the companies’ overall sales.14 

Insteel also reported that it periodically will *** cover bare PC strand with grease and plastic for

unbonded post-tensioned applications but that this strand product accounts for a very small share of the

company’s overall sales.15 Otherwise, none of the domestic PC strand producers grease and cover bare

PC strand in-house and none perform post-tensioning services. In fact, conference testimony given

during the preliminary phase of these investigations revealed that these services are largely performed by

domestic purchasers of bare strand.16 Insteel indicated in its questionnaire response in the final phase of

these investigations that bare PC strand accounts for approximately *** percent of the total value of the

polyethylene-covered strand product. Suncoast, a domestic purchaser of PC strand that greases and

covers bare PC strand with plastic, indicated that the incremental cost of the greased and plastic-covered
 17 Conference transcript, pp. 61 and 92 (Johnson).

 18 PC strand made from indented wire may be specified for certain pre-tensioning applications. The indentations

in the wire enhance the bond between the cured concrete and the PC strand.

 19 American Iron and Steel Institute, “Shipments of Steel Mill Products, Carbon (AIS-10C),” Monthly report,

January 2007-September 2007; American Iron and Steel Institute, “Net Shipments of Steel Mill Products, All Grades

Including Carbon, Alloy, and Stainless (AIS-10),” Monthly report, October 2007-March 2010.

 20 AMM, “ArcelorMittal halting S.C. rod mill, buyers warn of shortage,” May 13, 2009; AMM, “Output cuts

widen as mills react to slowdown,” October 3, 2008; AMM, “Raw material costs, tight supply driving long products

market,” April 28, 2008; AMM, “Sivaco slates $150/ton hike, complains of allocations,” April 15, 2008; and AMM,

“Wire rod tightness hints at mart ‘allocation’ shift,” January 31, 2008.

 21 Timothy Selhorst, President, American Spring Wire Corporation, reported that the supply of high-carbon wire

rod during 2008 and 2009 has been “plentiful.” Howard Woltz, President, Insteel Wire Products Co., reported,

however, that “there certainly was a period of time in Insteel’s experience where wire rod was tight for a few

months. We did see sharply escalating prices in scrap that flowed through to rod. We were on allocation from our

suppliers for a period of time. That situation resolved itself relatively quickly...The condition today is obvious ample

internal capacity and ample raw material supply.” Conference transcript, pp. 80-81 (Woltz and Selhorst). As

reported in the trade press, Insteel, “faced with a major maintenance outage by one of its rod suppliers last year after

having been placed on controlled order entry by other domestic suppliers, looked overseas for relief,” although the

company reportedly paid “top-of-the-market” prices and saw the wire rod market “collapse” by the time the wire rod

arrived. AMM, “Insteel gets caught in import squeeze,” January 15, 2009.

 22 AMM, “ArcelorMittal halting S.C. rod mill, buyers warn of shortage,” May 13, 2009; AMM, “Output cuts

widen as mills react to slowdown,” October 3, 2008; AMM, “Raw material costs, tight supply driving long products

market,” April 28, 2008; AMM, “Sivaco slates $150/ton hike, complains of allocations,” April 15, 2008; AMM,

“Wire rod tightness hints at mart ‘allocation’ shift,” January 31, 2008; AMM, “Wire rode prices on dual track in

March,” March 8, 2008; “Nucor, Keystone set to hike wire rod products in April,” March 9, 2010; AMM, “Evraz

boosting wire rod prices Feb 1,” January 12, 2010; AMM, “Wire rod tags pegged to increase in January,” December

3, 2009.

III-5

strand is approximately 4 to 4.5 cents per foot, which based on the price of bare PC strand at that time,

amounted to about 20 percent of the total cost to produce the covered strand.17 

Insteel was the only domestic PC strand producer that reported the production of indented PC

strand.18 The company indicated that it produces the indented PC strand by mechanically deforming the

wire during the cold drawing process prior to stranding. Following the production of the indented wire, it

is stranded, stabilized, and packaged using the same processes and equipment that are used to produce

smooth PC strand. Insteel indicated that since the indented strand is not produced from “unprocessed” PC

strand, the percentage of value represented by unprocessed PC strand is not relevant.

U.S. PRODUCERS’ RAW MATERIAL SUPPLY

High-carbon wire rod is the primary raw material input into the production of PC strand. U.S.

shipments of wire rod (by volume) peaked in July 2008, but had decreased by 74 percent by December

2008. While shipments have increased nearly 102 percent since December 2008, March 2010 shipments

remained nearly 40 percent below 2008 levels.19 Moreover, citing worsening demand in the first quarter

of 2009, U.S. wire rod producers reportedly cut production capacity and shuttered production facilities.20

PC strand producers reported that while during 2008 there were some wire rod supply constraints the wire

rod supply has since been readily available.21

Downstream producers of other wire rod products, however, claim that the decline in wire rod

production is limiting the availability of high-carbon wire rod and that some wire rod producers have put

their customers on allocation or controlled order entry.22 Controlled order entry of PC strand producers
 23 Conference transcript, p. 81 (Woltz). 

 24 AMM, “ArcelorMittal halting S.C. rod mill, buyers warn of shortage,” May 13, 2009; AMM, “Output cuts

widen as mills react to slowdown,” October 3, 2008.

 25 The aggregate data presented for U.S. producers’ shipments are for tollee MMI and producers American,

Insteel, Strand-Tech, and Sumiden.

 26 Calculated from table III-4 and questionnaire responses provided by domestic producers in the recently

completed five-year review concerning PC strand from Brazil, India, Japan, Korea, Mexico, and Thailand. 

Prestressed Concrete Steel Wire Strand from Brazil, India, Japan, Korea, Mexico, and Thailand: Investigation Nos.

701-TA-432 and 731-TA-1024-1028 (Review) and AA1921-188 (Third Review), USITC Publication 4114, November

2009, table III-4.

 27 The calculated unit value of U.S. producers’ U.S. shipments was $550 per 1,000 pounds during the first half of

2008, $756 per 1,000 pounds in the second half of 2008, $535 per 1,000 pounds during the first half of 2009, and

$476 per 1,000 pounds in the second half of 2009. Ibid.

III-6

was last reported in 2008.23 Downstream products producers further claim that an extended shutdown,

limiting the supply of this important raw material, may cause greater strain in an industry that consumes

wire rod faster than it is produced.24

U.S. PRODUCERS’ SHIPMENTS

Data on U.S. producers’ shipments of PC strand are presented in table III-4.25 The domestic

commercial market accounted for all of the U.S. producers’ U.S. shipments of PC strand and for more

than 95 percent of the U.S. producers’ total shipments of PC strand throughout 2007-09. Export

shipments, which accounted for less than 5 percent of the U.S. producers’ total shipments of PC strand

throughout the entire period, were made by ***. The U.S. producers’ export markets during 2007-09

included ***. Domestic producers’ U.S. shipments and export shipments of PC strand fell, in terms of

quantity, in each year from 2007 to 2009. 

As is similar to the trend in the domestic industry’s production data, the aggregate domestic PC

strand industry experienced an increase in U.S. shipments of PC strand in the last six months of 2009 as

compared with the first six months of 2009. During the first half of 2009, the domestic industry shipped

183.0 million pounds ($97.9 million) of PC strand to the U.S. market. During the last half of 2009, the

domestic industry’s U.S. shipments of PC strand were calculated to be 213.5 million pounds ($101.6

million), up by 16.6 percent (in terms of quantity) over the first half of the year.26 The unit value of U.S.

producers’ U.S. shipments increased from $460 per 1,000 pounds in 2007 to $630 per 1,000 pounds in

2008, but fell to $503 per 1,000 pounds in 2009.27 The unit value of exports exhibited a similar annual

trend during 2007-09.

Presented in table III-5 are data provided by domestic PC strand producers on their U.S.

shipments, by type of application (i.e., bare/coated and pre-tensioned/post-tensioned) and restriction (i.e.,

“Buy America(n)”). These data reveal that, during 2007-09, more than *** percent of U.S. producers’

total U.S. shipments of PC strand were for pre-tensioned applications on the basis of quantity, the

majority of which were subject to “Buy America(n)” restrictions. Of the less than *** percent of U.S.

producers’ total U.S. shipments that were destined for post-tensioned applications during 2007-09, less

than *** were subject to “Buy America(n)” restrictions during 2007 and slightly more than *** were

subject to “Buy America(n)” restrictions during 2008-09. In the aggregate, slightly less than one-half of

the quantity of U.S. producers’ total U.S. shipments were subject to “Buy America(n)” restrictions during

2007. The aggregate share of U.S. producers’ total U.S. shipments subject to “Buy America(n)”

restrictions rose to almost two-thirds by 2009. 
III-7

Table III-4

PC strand: U.S. producers’ shipments, by types, 2007-091

Item

Calendar year

2007 2008 2009

Quantity (1,000 pounds)

U.S. commercial shipments 582,800 529,973 396,498

Export shipments2 *** *** ***

Total shipments *** *** ***

Value (1,000 dollars)

U.S. commercial shipments 268,344 333,721 199,547

Export shipments2 *** *** ***

Total shipments *** *** ***

Unit value (per 1,000 pounds)

U.S. commercial shipments $460 $630 $503

Export shipments2 *** *** ***

Total shipments *** *** ***

Share of quantity (percent)

U.S. commercial shipments *** *** ***

Export shipments2 *** *** ***

Total shipments 100.0 100.0 100.0

 1 U.S. producers reported no transfers to related firms and no internal consumption of the PC strand they

produced.

 2

 Principal export markets include ***.

Note.--The aggregate data presented are for tollee MMI and producers American, Insteel, Strand-Tech, and

Sumiden.

Source: Compiled from data submitted in response to Commission questionnaires.

Table III-5

PC strand: U.S. producers’ U.S. shipments, by type of application and restriction, 2007-09

* * * * * * *
 28 Hearing transcript, p. 14 (Selhorst).

 29 Petitioners’ prehearing brief, p. 15.

 30 Ibid., p. 45.

 31 Insteel Industries Inc., “Investor Presentation,” June 2009, p. 8.

 32 Conference transcript, pp. 23 and 76-77 (Woltz).

 33 Conference transcript, p. 79 (Napoli).

 34 Conference transcript, p. 78 (Wagner).

 35 Conference transcript, p. 56 (Selhorst).

 36 Petitioners’ prehearing brief, p. 46.

III-8

The petitioners argued that the increase in “Buy America(n)” shipments as a share of the U.S.

market in 2009 was an “aberration” and that such shipments are not expanding. They explained that the

U.S. market for PC strand fell substantially in 2009 and that, although “Buy America(n)” sales also fell,

such sales accounted for a bigger share of the market.28 They also argued that federal spending on

infrastructure through the American Recovery and Reinvestment Act (“ARRA”) has not benefitted the PC

strand industry and “very little benefit for the PC strand industry is expected from such programs in

2010.”29 They claimed that the largest decline in U.S. producers’s shipments occurred in sales to nonBuy America(n) post-tensioning customers “where subject imports are most heavily concentrated.”30

The U.S. producers’ data provided also show a shift away from serving customers using the PC

strand in post-tensioned applications in favor of pre-tensioning customers. In 2007, *** percent of the

domestic producers’ U.S. shipments were for pre-tensioned applications. By 2009, this share increased to

*** percent of total U.S. shipments by domestic producers. This shift is highlighted by the corporate

decision in the third quarter of 2007 by Insteel, ***, to “minimize {its} participation in slab-on-grade

post-tension market due to pricing deterioration resulting from low-priced Chinese import competition

and ongoing weakness in housing-related demand.”31 Insteel explained that, in the past, its post-tensioner

customers had traditionally been some of the company’s largest customers but that it had “lost a

tremendous amount of business with post-tensioners over the last three years, virtually all of it to Chinese

strand.”32 Domestic producer American also indicated that it has had difficulty making sales of PC strand

to the large post-tensioned customers because of stiff price competition with the Chinese product.33

Regardless, Insteel noted that it continues to monitor the environment for post-tensioned applications and

wants to “do business with Suncoast and with the other customers in the post-tensioned business from

which we had been forced out.”34

U.S. PRODUCERS’ INVENTORIES

Due to the seasonality of PC strand sales in the U.S. market, a substantial portion of domestic PC

strand is manufactured by U.S. producers to particular specifications for stocking in inventory during the

winter months when demand is lower in order to support anticipated sales in excess of capacity during the

summer months. Often, however, domestic PC strand producers manufacture PC strand in response to a

particular customer’s order during the summer months when demand for the product is higher. The

petitioners indicated that their PC strand inventory does not distinguish between product destined for

post-tensioned or pre-tensioned applications.35 

The petitioners reported that, during the period examined in the final phase of these

investigations, they “were forced to inventory an increasing percentage of their product” and that these

“{i}ncreasing inventories reflect an inability to sell product into the market.”36 Data collected in these
 37 The aggregate data presented for U.S. producers’ inventories are for tollee MMI and producers American,

Insteel, Strand-Tech, and Sumiden.

 38 Conference transcript, p. 56 (Selhorst).

 39 Calculated from table III-6 and questionnaire responses provided by domestic producers in the recently

completed five-year review concerning PC strand from Brazil, India, Japan, Korea, Mexico, and Thailand. 

Prestressed Concrete Steel Wire Strand from Brazil, India, Japan, Korea, Mexico, and Thailand: Investigation Nos.

701-TA-432 and 731-TA-1024-1028 (Review) and AA1921-188 (Third Review), USITC Publication 4114, November

2009, table III-6.

III-9

investigations on domestic producers’ end-of-period inventories of PC strand are presented in table

III-6.37 

Table III-6

PC strand: U.S. producers’ end-of-period inventories, 2007-09

Item

Calendar year

2007 2008 2009

Inventories (1,000 pounds) 61,262 67,081 57,644

Ratio to production (percent) 10.2 12.0 14.6

Ratio to U.S. shipments (percent) 10.5 12.7 14.5

Ratio to total shipments (percent) *** *** ***

Note.--The aggregate inventory data and aggregate shipment data used in the calculations of ratios to U.S. and total

shipments are for tollee MMI and producers American, Insteel, Strand-Tech, and Sumiden. The aggregate

production data used in the calculations of ratios to production are for toller RettCo and producers American, Insteel,

Strand-Tech, and Sumiden.

Source: Compiled from data submitted in response to Commission questionnaires.

As shown in table III-6, U.S. producers’ inventories increased (in terms of quantity) by 9.5

percent from 61.3 million pounds at year-end 2007 to 67.1 million pounds at year-end 2008, but fell by

14.1 percent to 57.6 million pounds in 2009. However, U.S. producers’ inventories as a ratio to

production and U.S. shipments increased throughout the period examined in the final phase of these

investigations. As a ratio to U.S. production and shipments, U.S. producers’ inventories increased from

10.2 percent and 10.5 percent in 2007 to 14.6 percent and 14.5 percent in 2009, respectively. Typical of

the seasonality of PC strand sales and U.S. producers’ inventory stocks,38 aggregate inventories held by

U.S. producers on June 30, 2008 (47.7 million pounds) and June 30, 2009 (51.3 million pounds) were

lower than reported year-end inventories.39 *** alone accounted for *** of the inventories held at the end

of calendar year 2009 and *** together accounted for *** percent of the inventories held at that time. 

U.S. PRODUCERS’ IMPORTS AND PURCHASES

U.S. producers’ imports and purchases of PC strand are presented in table III-7. As shown, one

U.S. producer (Insteel) directly imported the subject merchandise from China during 2007. Domestic

producer *** directly imported and domestically purchased PC strand produced in ***.
 40 Conference transcript, pp. 77-80 (Woltz).

 41 Conference transcript, p. 80 (Woltz).

 42 The aggregate data presented for U.S. producers’ employment-related indicators are for toller RettCo and

producers American, Insteel, Strand-Tech, and Sumiden.

 43 Conference transcript, pp. 26, 31 (Cornelius), and 40 (Beck); petitioners’ prehearing brief, p. 46.

III-10

Table III-7

PC strand: U.S. producers’ imports and purchases, 2007-09

* * * * * * *

Insteel’s direct imports of PC strand from China during 2007 accounted for *** percent of the

firm’s U.S. production of PC strand during that year. Insteel indicated that it made the decision to import

PC strand from China beginning in 2006 when it found that it could not compete with the low-priced

Chinese imports. The company developed a pilot program to determine whether it could import PC

strand from China and profitably distribute the product to its longstanding customer base. However,

Insteel indicated that the pilot program was abandoned after only a couple of import deliveries because

Chinese PC strand prices continued to fall and the imported material in transit was worth less when it

arrived in the United States than it was when it was initially purchased.40 In direct conference testimony,

Insteel explained that 

in fact the pilot program wound up being about half the size that we originally envisioned

it just due to the mess that was in the market and our quick realization that we couldn’t

add value and we couldn’t reduce prices fast enough to keep up with what was happening

from the real Chinese importers.41

***. 

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

The U.S. producers’ aggregate employment data for PC strand are presented in table III-8.42 Each

domestic PC strand producer reported an overall decline in the number of production and related workers

during the period examined in the final phase of these investigations. In the aggregate, U.S. PC strand

producers reported a decline of 27.7 percent in the number of production and related workers employed in

the manufacture of PC strand during 2007-09. Likewise, the number of hours worked by these

employees, as well as the total wages paid and productivity, fell overall during the same time period. In

contrast, hourly wages and unit labor costs increased overall during 2007-09. 

The domestic producers testified that the decline in their sales and shipments and the resulting

reductions in production led to the permanent layoff of many U.S. workers manufacturing PC strand. The

petitioners further argued that these declines in sales and shipments were due to “imports from China that

consistently undercut our prices.”43 In addition, press reports indicate and preliminary phase conference

testimony confirms that certain job losses in the PC strand industry were explained by investments in

technology improvements by the domestic producers and the general downturn in the economy. In

particular, 15 jobs were eliminated at Insteel’s PC strand operations in Sanderson, FL, in November 2008,

as that facility underwent a substantial investment program to upgrade its 1970s production technology. 
 44 AMM, “Insteel laying off 15 at PC strand plant,” November 13, 2008; conference transcript, pp. 84-85 (Woltz);

and petitioners’ prehearing brief, p. 47.

 45 AMM, “Insteel laying off 15 at PC strand plant,” November 13, 2008; and conference transcript, pp. 84-85

(Woltz).

 46 Petitioners’ prehearing brief, p. 47.

 47 Conference transcript, p. 85 (Selhorst and Cornelius).

III-11

Table III-8

PC strand: U.S. producers’ employment-related data, 2007-09

Item

Calendar year

2007 2008 2009

Production and related workers (PRWs) 357 331 258

Hours worked by PRWs (1,000 hours) 771 715 555

Hours worked per PRW 2,161 2,160 2,152

Wages paid to PRWs (1,000 dollars) 14,145 13,264 10,907

Hourly wages $18.34 $18.56 $19.64

Productivity (pounds produced per hour) 780.1 781.9 712.5

Unit labor costs (per 1,000 pounds) $23.51 $23.73 $27.57

Note.--The aggregate data presented are for toller RettCo and producers American, Insteel, Strand-Tech, and

Sumiden.

Source: Compiled from data submitted in response to Commission questionnaires.

Such improvements in the process technology led to a less labor-intensive manufacturing process. Insteel

reported that those jobs were originally scheduled for elimination in 2009 but the layoffs were accelerated

because of the immediate downturn in the market conditions. Insteel also carried out the expansion and

the total upgrade of its facility in Gallatin, TN, with internally developed proprietary technology. Insteel

reported that capital investment projects at both facilities resulted in significant gains in productivity and

labor utilization. The company further indicated that it expected the increase in the number of jobs at its

Tennessee facility to offset the job losses at its Florida facility; however, the company explained that by

the time the new investments were operational, the company was forced to cut back on production and

employment at both facilities because of the “injury suffered as a result of competition from low-priced

imports from China as well as declining demand.”44 Insteel added that the two capital investment projects

at its Florida and Tennessee facilities represented approximately $20 million and increased its PC strand

capacity by approximately 35,000 tons per year.45 Petitioners emphasized that the loss of jobs at other

domestic production facilities were not associated with investment upgrades but were a direct result of

declining sales and profits caused by unfair import competition in an already weak market.46 In fact,

domestic producers American and Sumiden reported capital investments for equipment upgrades but

neither firm reported significant changes in their work force as a result of any of the capital

improvements.47
 
 1

 The Commission sent questionnaires to those firms identified in the petition, along with U.S. firms that, based

on a review of data provided by U.S. Customs and Border Protection (“Customs”), may have imported at least 50

metric tons under HTS statistical reporting numbers 7312.10.3010 and 7312.10.3012 in any one year since 2007.

 2

 The questionnaire coverage for U.S. imports from nonsubject countries is likely to be somewhat higher because

official imports statistics are believed to include merchandise that does not meet the definition of PC strand,

especially for product originating in Mexico. Prestressed Concrete Steel Wire Strand from Brazil, India, Japan,

Korea, Mexico, and Thailand: Investigation Nos. 701-TA-432 and 731-TA-1024-1028 (Review) and AA1921-188

(Third Review), USITC Publication 4114, November 2009, p. IV-1, fn. 2. The questionnaire coverage for U.S.

imports from nonsubject countries is calculated to be 70.2 percent of the total imports from all nonsubject countries

(other than Mexico) during 2009.

 3

 Global Steel Sales, a U.S. importer of the subject merchandise and a party that actively participated in these

investigations during the preliminary phase by responding to the Commission’s questionnaire, filing a brief, and

presenting conference testimony, refused to complete and return the Commission’s questionnaire during the final

phase of these investigations. Mr. Rob Hendricks at Global Steel Sales indicated “***.” Email to Mary Messer

from Rob Hendricks, President, Global Steel Sales, March 24, 2010.

IV-1

PART IV: U.S. IMPORTS, APPARENT CONSUMPTION, AND

MARKET SHARES

U.S. IMPORTERS

Importer questionnaires were sent to 58 firms believed to be importers of subject PC strand, as

well as to all U.S. producers of PC strand.1

 Usable questionnaire responses were received from

23 companies, representing 83.4 percent of total imports from China and at least 64.7 percent of total

imports from all other countries combined during 2009 under HTS statistical reporting numbers

7312.10.3010 and 7312.10.3012.2

 Table IV-1 lists all responding U.S. importers of PC strand from China

and other sources, their locations, and their shares of U.S. imports in 2009.3

 As the table illustrates, ***,

the four largest importers providing responses to the Commission’s questionnaire in these investigations,

accounted for *** percent of total subject U.S. imports from China in 2009 and *** percent of total U.S.

imports from all countries as measured by official Commerce import statistics. 

U.S. IMPORTS

During 2001, there were no reported U.S. imports of PC strand from China. By 2003 (i.e., the

year before antidumping and countervailing duty orders concerning PC strand from Brazil, India, Korea,

Mexico, and Thailand entered into effect), U.S. imports of PC strand from China amounted to 38.5

million pounds and accounted for 15.9 percent of total U.S. PC strand imports on the basis of quantity. In

the following year, when imports from Brazil, India, Korea, Mexico, and Thailand declined by almost

100 million pounds in the aggregate, U.S. imports from China increased further by more than 100 million

pounds. By that time, China accounted for almost one-half of the total quantity of U.S. imports of PC

strand. The second largest supplier of PC strand to the U.S. market during 2004 was Taiwan,

representing 8.4 percent of total U.S. imports in that year. PC strand imports from China continued to

increase in terms of quantity from 2004 levels to a historical high of 391.4 million pounds in 2006. China

accounted for 80.7 percent of total U.S. imports during 2006.
IV-2

Table IV-1

PC strand: U.S. importers, U.S. locations, major source(s) of imports, and shares of official

imports in 2009

Firm Location(s)

Major source(s) of

imports

Share of 2009 official import

statistics (percent)

China Other Total

A.G. Royce Metal Marketing (dba

Concrete Reinforcing Products)1 Sunrise, FL *** *** *** ***

ArcelorMittal International LLC Chicago, IL *** ***2 *** ***2

Bekaert Canada Surrey, BC,Canada *** *** *** ***

BlueLinx Corp. Atlanta, GA *** *** *** (3

)

Cementhai SCTUSA, Inc. Torrance, CA *** ***2 *** ***2

Corus America, Inc. Schaumberg, IL *** *** *** ***

Crispin Co. (The) Houston, TX *** *** *** ***

Davis Wire Corp.

Irwindale, CA

Kent, WA *** ***2 *** ***2

Dywidag Systems International Bolingbrook, IL *** *** *** ***

Freyssinet, Inc.

Aurora, IL

Norcross, GA

Sterling, VA *** *** ***2 ***2

Insteel Wire Products Co. Mount Airy, NC *** ***2 *** ***2

Nedri Spanstaal

Venlo,

Netherlands *** *** *** ***

Nucor Steel Birmingham, Inc. Birmingham, AL *** *** *** ***

OM Industrial Products Corp. Houston, TX *** *** *** ***

Pacific Coast Steel San Diego, CA *** ***2 *** ***2

Precision Sure-Lock Dallas, TX *** *** ***2 ***2

SLM USA LLC Summerville, SC *** *** ***2 ***

Stemcor USA, Inc. New York, NY *** ***2 *** ***

Strand-Tech Martin, Inc. Summerville, SC *** ***2 ***2 ***2

Tata, Inc. New York, NY *** ***2 *** ***2

Tree Island Wire (USA) Walnut, CA *** *** *** ***

Westco Systems Inc.

San Francisco,

CA *** *** *** ***

Wireco WorldGroup Kansas City, MO *** ***2 *** ***2

Total, all companies *** *** ***

 1 ***.

 2 ***.

 3 ***.

Note.–Because of rounding, figures may not add to the totals shown.

Source: Compiled from data submitted in response to Commission questionnaires and from official Commerce

import statistics.
 4

 Petitioners’ prehearing brief, pp. 30-31.

 5

 Conference transcript, p. 23 (Woltz) and petitioners’ prehearing brief, pp. 10-11 and 31.

 6

 Petitioners’ prehearing brief, pp. 12 and 14.

IV-3

Table IV-2 presents data for U.S. imports of PC strand from China, primary nonsubject sources,

and all other sources combined for 2007 to 2009. Because Commission questionnaire import data

coverage from subject and nonsubject sources was less than complete, the import data presented in this

report are based on official import statistics of Commerce.

U.S. imports from China accounted for a relatively large and increasing share of the total quantity

of U.S. imports of PC strand from 2007 to 2008. By 2008, China accounted for more than 90 percent of

total U.S. PC strand imports; however, in 2009, China accounted for less than one-third of total U.S.

imports. The quantity of U.S. imports from China increased by 7.8 percent from 353.9 million pounds in

2007 to 381.7 million pounds in 2008, but fell by 90.4 percent to 36.6 million pounds in 2009. The unit

values of PC strand imports from China, which increased from $327 per 1,000 pounds in 2007 to $509

per 1,000 pounds in 2008, fell to $378 per 1,000 pounds in 2009. 

The petitioners argued that the decline in U.S. imports of PC strand in 2009 occurred primarily

for the following reasons: “(1) a huge inventory overhang of Chinese PC strand built in 2008 that lasted

well into 2009 and continued to take domestic sales; (2) a significant decline in demand from late 2008

through early 2009 that occurred as a result of the general economic collapse; and (3) the filing of the

trade cases, which led to the reduction in imports of Chinese PC strand in the second half of 2009 as

companies sought to avoid duty liability for demonstrated unfair trading practices.”4

 The petitioners

described the build up of inventories of the Chinese product by purchasers in the United States in late

2008 and early 2009 as “massive” and asserted that U.S. purchasers simply stopped purchasing all PC

strand, regardless of the origin, to consume their existing inventories.5

 They also indicated that “a huge

portion” of the PC strand being consumed by purchasers in the United States during 2009 was Chinese

PC strand that had been built up in inventories by purchasers in 2008.6

 

By contrast, U.S. imports from nonsubject sources accounted for a relatively small and declining

share of the total quantity of U.S. imports of PC strand from 2007 to 2008. By 2008, nonsubject sources

accounted for only 7.5 percent of total U.S. PC strand imports. However, by 2009, nonsubject sources

accounted for more than two-thirds of the total quantity. Canada, Portugal, and Italy were the largest

nonsubject sources of U.S. imports of PC strand during 2009, accounting for almost one-third of the total

quantity of U.S. PC strand imports in that year. The quantity of U.S. imports from countries other than

China fell from 2007 to 2008, but increased in 2009 to a level that was 72.5 percent higher than the level

for 2007. The unit values of PC strand imports from nonsubject sources increased from 2007 to 2008 but

fell in 2009 to a level that was below that reported in 2007. With the exception of imports from South

Africa during 2008 and 2009, the unit values of PC strand imports from major nonsubject sources were

consistently higher than the unit values of PC strand imported from China. The unit values of nonsubject

imports from major sources ranged from $486 to $1,002 per 1,000 pounds in 2008 and from $349 to $648

per 1,000 pounds in 2009.

U.S. importers provided data concerning their U.S. shipments of PC strand by type of application

(i.e., bare/coated and pre-tensioned/post-tensioned). These data, presented in tables IV-3 (China) and IV4 (nonsubject countries), reveal that, during 2007-09, more than 85 percent of the quantity of subject

importers’ total U.S. shipments of PC strand was for post-tensioned applications and less than 15 percent 

was bare strand for pre-tensioned applications. The data provided by nonsubject importers indicate that,

during 2007-09, approximately three-fourths of the quantity of nonsubject importers’ total U.S. shipments

of PC strand was bare strand for post-tensioned applications and approximately one-fourth was bare

strand for pre-tensioned applications. The data also show that very little coated PC strand is imported

into the United States.
IV-4

Table IV-2

PC strand: U.S. imports, by sources, 2007-09

Source

Calendar year

2007 2008 2009

Quantity (1,000 pounds)

China 353,937 381,652 36,591

Nonsubject sources:

 Canada 15,725 11,312 12,605

 Italy 5,245 3,574 10,303

 Japan 1,952 1,380 0

 Korea 2,831 3,325 462

 Mexico 2,283 1,514 5,870

 Portugal 3,864 7,223 12,187

 South Africa 2,800 957 8,165

 Spain 0 348 8,651

 Taiwan 1,659 0 8,064

 Other nonsubject sources1 7,406 1,454 9,210

 Total nonsubject sources 43,766 31,089 75,515

Total U.S. imports 397,703 412,741 112,107

Value (1,000 dollars)

2

China 115,843 194,276 13,816

Nonsubject sources:

 Canada 9,023 8,365 8,171

 Italy 3,345 2,668 5,037

 Japan 1,343 916 0

 Korea 1,399 2,201 276

 Mexico 1,036 885 2,541

 Portugal 1,776 4,166 4,876

 South Africa 1,002 465 2,846

 Spain 0 349 3,402

 Taiwan 731 0 3,231

 Other nonsubject sources1 3,328 1,757 4,994

 Total nonsubject sources 22,982 21,771 35,375

Total U.S. imports 138,825 216,047 49,191

Table continued on following page.
IV-5

Table IV-2--Continued

PC strand: U.S. imports, by sources, 2007-09

Source

Calendar year

2007 2008 2009

Unit value (per 1,000 pounds)

2

China $327 $509 $378

Nonsubject sources:

 Canada 574 739 648

 Italy 638 746 489

 Japan 688 663 (3

)

 Korea 494 662 597

 Mexico 454 584 433

 Portugal 460 577 400

 South Africa 358 486 349

 Spain (3

) 1,002 393

 Taiwan 441 (3

) 401

 Other nonsubject sources1 449 1,208 542

 Average, nonsubject sources 525 700 468

Average, all U.S. imports 349 523 439

Share of quantity (percent)

China 89.0 92.5 32.6

Nonsubject sources:

 Canada 4.0 2.7 11.2

 Italy 1.3 0.9 9.2

 Japan 0.5 0.3 0.0

 Korea 0.7 0.8 0.4

 Mexico 0.6 0.4 5.2

 Portugal 1.0 1.8 10.9

 South Africa 0.7 0.2 7.3

 Spain 0.0 0.1 7.7

 Taiwan 0.4 0.0 7.2

 Other nonsubject sources1 1.9 0.4 8.2

 Total nonsubject sources 11.0 7.5 67.4

Total U.S. imports 100.0 100.0 100.0

Table continued on following page.
IV-6

Table IV-2--Continued

PC strand: U.S. imports, by sources, 2007-09

Source

Calendar year

2007 2008 2009

Share of value (percent)

China 83.4 89.9 28.1

Nonsubject sources:

 Canada 6.5 3.9 16.6

 Italy 2.4 1.2 10.2

 Japan 1.0 0.4 0.0

 Korea 1.0 1.0 0.6

 Mexico 0.7 0.4 5.2

 Portugal 1.3 1.9 9.9

 South Africa 0.7 0.2 5.8

 Spain 0.0 0.2 6.9

 Taiwan 0.5 0.0 6.6

 Other nonsubject sources1 2.4 0.8 10.2

 Total nonsubject sources 16.6 10.1 71.9

Total U.S. imports 100.0 100.0 100.0

1

 Other nonsubject sources include Argentina, Austria, Belgium, Colombia, Germany, Hungary, India, Malaysia,

Netherlands, Panama, Saudi Arabia, Switzerland, Thailand, Turkey, and the United Kingdom. 2

 Landed, U.S. port of entry, duty-paid.

3

 Not applicable.

Note.–The official import statistics presented are believed to include an amount of merchandise that does not meet

the definition of PC strand, especially with respect to U.S. imports from Mexico. Prestressed Concrete Steel Wire

Strand from Brazil, India, Japan, Korea, Mexico, and Thailand: Investigation Nos. 701-TA-432 and

731-TA-1024-1028 (Review) and AA1921-188 (Third Review), USITC Publication 4114, November 2009, p. IV-1, fn.

2.

Source: Compiled from official statistics of the U.S. Department of Commerce.

Table IV-3

PC strand: U.S. shipments of U.S. imports from China, by application, 2007-09

* * * * * * *

Table IV-4

PC strand: U.S. shipments of U.S. imports from nonsubject sources, by application, 2007-09

* * * * * * *
 7

 Hearing transcript, pp. 12-13 (Selhorst), p. 19 (Woltz), and petitioners’ prehearing brief, p. 25.

 8

 Petitioners’ prehearing brief, pp. 10, 33, and 56-57.

 9

 Ibid., p. 57.

 10 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)).

 11 Section 771(24) of the Act (19 U.S.C. § 1677(24)).

IV-7

The petitioners explained that U.S. imports have historically had a greater presence with respect

to post-tensioned accounts in the U.S. market because the post-tensioners are typically the largest volume

customers. They added that the domestic producers would also “prefer” to make sales to these largevolume major accounts (such as the post-tensioners) “but have been increasingly unable to do so due

precisely to competition from low-price imports.”7

A review of monthly import data for January 2007 through December 2009 indicates that imports

of PC strand from China and Canada entered the United States in each month of the entire period for

which data were collected (table IV-5). These data also illustrate the seasonality of the product–that is,

lower quantities of PC strand were imported into the United States during the off-peak months from

November to February of each calendar year.

As the monthly import data also show, U.S. imports of PC strand from China fell substantially in

the final months of 2008 and again in the second half of 2009. As previously indicated, the petitioners

argued that U.S. importers largely stopped importing PC strand from China in the months following the

filing of the petition on May 27, 2009, and that the decline “reflects the effect of the case filing and not an

independent decision by China to withdraw from the U.S. market.”8

 The petitioners also suggested that

the actual presence of Chinese PC strand in the U.S. market during 2009 was greater than the official

import statistics reported because, subsequent to the filing of the petition, “Chinese producers developed

schemes to circumvent any duties imposed by transshipping PC strand through third countries and

claiming those countries as the origin of the product.”9

CRITICAL CIRCUMSTANCES

No “critical circumstances” were alleged by the petitioners in these investigations.

NEGLIGIBILITY

The statute requires that an investigation be terminated without an injury determination if imports

of the subject merchandise are found to be negligible.10 Negligible imports are generally defined in the

Tariff Act of 1930, as amended, as imports from a country of merchandise corresponding to a domestic

like product where such imports account for less than 3 percent of the volume of all such merchandise

imported into the United States in the most recent 12-month period for which data are available that

precedes the filing of the petition or the initiation of the investigation. However, if there are imports of

such merchandise from a number of countries subject to investigations initiated on the same day that

individually account for less than 3 percent of the total volume of the subject merchandise, and if the

imports from those countries collectively account for more than 7 percent of the volume of all such

merchandise imported into the United States during the applicable 12-month period, then imports from

such countries are deemed not to be negligible.11 The petition in these investigations was filed on 

May 27, 2009. For the most recent 12-month period for which data are available that precedes the filing

of the petition (May 2008-April 2009), imports of PC strand from China accounted for 91.2 percent of

total imports of PC strand by quantity.
Table IV-5

PC strand: Monthly U.S. imports, by sources, January 2007-December 2009

Country

2007

Jan. Feb. Mar. Apr. May June July Aug. Sept. Oct. Nov. 

Quantity (1,000 pounds)

Argentina 0 0 0 0 0 0 220 0 220 0 Austria 0 0 0 0 0 0 0 0 0 0 Belgium 0 0 81 0 0 0 0 0 0 0 Canada 1,198 1,081 1,408 1,063 1,540 1,330 1,519 1,160 1,441 1,422 1,0

China 20,206 13,086 28,911 30,822 53,950 38,256 50,968 20,140 28,688 34,986 15,9

Colombia 0 0 0 0 0 0 0 0 0 0 Germany 0 0 0 0 0 0 0 0 0 0 3Hungary 0000000000India 0 235 0 0 0 0 0 0 0 0 Italy 1,607 663 383 683 118 86 246 747 204 115 3Japan 325 0 0 244 407 0 0 488 163 163 1Korea 164 207 0 1,103 0 88 522 44 138 126 2Malaysia 0 863 0 451 1,022 1,320 540 0 0 0 Mexico 369 0 0 0 180 357 81 262 42 131 2Netherlands 0000000000Panama 0 0 0 0 0 0 0 0 0 94 Portugal 871 317 753 0 542 105 108 112 0 411 5Saudi Arabia 0000000000South Africa 281 39 0 477 567 0 487 476 0 0 4Spain 0 0 0 0 0 0 0 0 0 0 Switzerland 0 1 1,349 0 24 0 48 0 0 23 Taiwan 468 253 0 0 526 0 123 83 206 0 Thailand 0 0 0 0 0 0 0 0 0 0 Turkey 0 0 0 0 0 0 0 0 0 0 United Kingdom 36 35 0 0 70 0 0 107 34 0 1 Total 25,526 16,781 32,885 34,843 58,947 41,542 54,863 23,618 31,136 37,471 19,4Table continued on following page.

IV-8
Table IV-5--Continued

PC strand: Monthly U.S. imports, by sources, January 2007-December 2009

Country

2008

Jan. Feb. Mar. Apr. May June July Aug. Sept. Oct. Nov. 

Quantity (1,000 pounds)

Argentina 0000000000Austria 0 0 0 0 0 0 0 0 0 0 Belgium 0 0 0 0 0 0 577 0 0 0 Canada 759 989 895 1,018 1,193 830 1,055 1,001 1,017 1,244 2

China 30,644 23,502 37,123 31,574 41,874 50,736 38,649 49,660 23,818 39,644 9,5

Colombia 0 0 0 0 0 0 0 0 0 0 Germany 0 0 0 0 0 0 6 0 0 0 Hungary 0000000000India 0 0 0 0 0 0 0 48 0 0 Italy 0 322 0 776 915 227 238 669 172 0 Japan 407 4 0 407 203 203 157 0 0 0 Korea 138 120 404 506 122 372 169 226 435 111 5Malaysia 0 0 0 0 0 0 0 0 0 0 Mexico 0 117 281 361 0 0 0 0 0 0 3Netherlands 0000000000Panama 0000000000Portugal 324 1,273 2,046 1,094 270 112 1,505 104 342 155 Saudi Arabia 0000000000South Africa 0 0 0 0 0 0 479 0 0 0 Spain 0 0 0 0 0 0 0 0 193 0 1Switzerland 0 0 42 0 40 0 0 40 42 18 Taiwan 0 0 0 0 0 0 0 0 0 0 Thailand 0 0 0 0 0 0 0 0 0 0 Turkey 0 0 0 0 0 0 0 0 0 0 United Kingdom 0 0 105 0 0 0 0 6 0 181 1 Total 32,271 26,326 40,896 35,736 44,616 52,480 42,836 51,753 26,019 41,353 10,9Table continued on following page.

IV-9
Table IV-5--Continued

PC strand: Monthly U.S. imports, by sources, January 2007-December 2009

Country

2009

Jan. Feb. Mar. Apr. May June July Aug. Sept. Oct. Nov. 

Quantity (1,000 pounds)

Argentina 0 0 0 0 0 114 0 0 0 0 Austria 0 0 0 0 0 0 0 0 0 0 Belgium 0 0 0 0 0 0 0 0 0 0 Canada 671 1,008 1,157 1,544 1,239 1,625 1,203 605 410 1,506 8China 6,094 2,924 3,165 1,861 5,429 12,135 2,936 720 749 127 2Colombia 0 0 0 0 0 0 0 0 0 220 6Germany 0 0 2 0 0 82 0 0 0 0 Hungary 0 0 0 0 0 0 0 0 0 255 1India 0 0 0 0 0 0 0 0 0 0 Italy 43 85 43 342 0 650 1,213 1,083 1,219 2,663 1,5Japan 0000000000Korea 0 86 0 0 0 0 0 0 155 221 Malaysia 0 0 0 0 0 0 0 233 810 971 1,0Mexico 0 158 534 156 706 659 915 1,259 710 772 Netherlands 35 252 0 302 0 0 297 0 0 0 Panama 0000000000Portugal 0 0 0 851 297 691 449 1,558 2,152 2,401 3,1Saudi Arabia1 0 0 0 0 0 0 0 633 0 0 

South Africa 0 0 0 0 0 0 2,012 2,080 2,467 0 1,6Spain 0 0 0 294 0 0 0 557 1,393 1,181 2,9Switzerland 39 0 41 72 38 16 0 0 0 0 Taiwan 0 0 0 0 665 0 601 1,281 1,542 2,158 4Thailand 0 0 0 0 0 0 0 0 0 0 Turkey 0 0 0 0 0 0 0 0 132 440 United Kingdom 0 0 1 0 0 0 2 10 35 0  Total 6,883 4,513 4,942 5,424 8,373 15,972 9,627 10,019 11,773 12,915 12,8

1 One shipment of merchandise from Saudi Arabia was reported during July 2009. The foreign manufacturer of these U.S. imports from ***.

Source: Compiled from official statistics of the U.S. Department of Commerce.

IV-10
IV-11

APPARENT U.S. CONSUMPTION

Data concerning apparent U.S. consumption of PC strand during the period for which information

was requested are shown in table IV-6 and figure IV-1. Apparent U.S. consumption of PC strand, as

shown in table IV-6, is based on U.S. producers’ U.S. shipments of PC strand and subject imports as

compiled from official U.S. import statistics of Commerce. 

Table IV-6

PC strand: U.S. shipments of domestic product, U.S. imports, and apparent U.S. consumption,

2007-09

Item

Calendar year

2007 2008 2009

Quantity (1,000 pounds)

U.S. producers’ U.S. shipments 582,800 529,973 396,498

U.S. imports from–

China 353,937 381,652 36,591

Nonsubject countries1 43,766 31,089 75,515

Total U.S. imports 397,703 412,741 112,107

Apparent U.S. consumption 980,503 942,714 508,605

Value (1,000 dollars)

U.S. producers’ U.S. shipments 268,344 333,721 199,547

U.S. imports from--

China 115,843 194,276 13,816

Nonsubject countries1 22,982 21,771 35,375

Total U.S. imports 138,825 216,047 49,191

Apparent U.S. consumption 407,169 549,768 248,738

1

 Major nonsubject countries include Canada, Italy, Japan, Korea, Mexico, Portugal, South Africa, Spain, and

Taiwan.

Note.–Because of rounding, figures may not add to the totals shown.

Source: Compiled from data submitted in response to Commission questionnaires and from official import statistics

of the U.S. Department of Commerce.
IV-12

Figure IV-1

PC strand: Apparent U.S. consumption, by sources, 2007-09

Source: Table IV-6.
 12 Conference transcript, pp. 96-97 (Selhorst and Feitler) and petitioners’ prehearing brief, pp. 10 and 14-16.

 13 Conference transcript, pp. 69-70 (Selhorst).

 14 Petitioners’ prehearing brief, pp. 12 and 32.

 15 Petitioners’ prehearing brief, p. 20.

 16 Ibid.

IV-13

The demand for PC strand is derived from demand for prestressed concrete which, in turn, is

derived from demand in the construction industry. In terms of quantity, U.S. consumption of PC strand

fell by 48.1 percent from 2007 to 2009. The petitioners reported that although the demand for many end

uses of PC strand remained relatively steady from 2006 to late 2008, the demand for slab-on-grade

fabrication connected to residential construction has declined and the use and need for PC strand

associated with it has likewise declined since 2006, which was the peak year for U.S. residential

construction. They also pointed out that apparent U.S. consumption of PC strand as a whole actually

increased during late 2007 and early 2008 because of increased purchasing of PC strand in anticipation of

increases in steel prices. However, after the severe market downturn intensified in late 2008, apparent

U.S. consumption of PC strand fell markedly into 2009. The petitioners indicated that no improvements

in U.S. demand for PC strand are expected in 2010 and that “demand for PC strand appears as if it will

remain weak and is uncertain at best.”12

In terms of value, apparent U.S. consumption increased by 35.0 percent from 2007 to 2008,

which reflects the increasing unit values of imported and domestically produced PC strand during the

same time period. These increases are somewhat reflective of the increase in the cost of the primary raw

material (wire rod), which accounts for the vast majority of the cost of producing the product. The cost of

wire rod for the domestic producers of PC strand doubled from late 2007 to August 2008.13 However,

apparent U.S. consumption, in terms of value, fell in 2009 to a level well below that reported during 2007. 

U.S. MARKET SHARES

U.S. market share data are presented in table IV-7. The U.S. producers’ share of the domestic

market fell slightly from 59.4 percent in 2007 to 56.2 percent in 2008, but increased to 78.0 percent

during 2009. The share of the U.S. market held by subject imports of PC strand from China increased

from 36.1 percent in 2007 to 40.5 percent in 2008. However, the share of the U.S. market held by U.S.

imports from China during 2009 (7.2 percent) was much lower than the shares held in the previous two

annual periods. The petitioners pointed out that while the share of the U.S. market held by U.S. imports

of PC strand from China fell in 2009, “a huge portion of the PC strand actually being consumed by

Suncoast and other purchasers in the market in 2009 was Chinese PC strand from the inventory built in

2008.”14

U.S. importers and producers provided data concerning their U.S. shipments of PC strand for preand post-tensioned applications and U.S. shipments that were subject to “Buy America(n)” restrictions. 

These data (presented separately in appendix C, table C-2) show that the share of apparent U.S.

consumption held by U.S. shipments subject to “Buy America(n)” restrictions was *** percent in 2007,

*** percent in 2008, and *** percent in 2009. The petitioners argued that the increase in the “Buy

America(n)” shipments as a share of apparent U.S. consumption in 2009 “does not reflect growth in Buy

America sales, but rather reflects the decline in demand for PC strand generally in the commercial market

in 2009.”15 They added that the decline in demand for non-Buy America sales during 2009 was

“aberrational” and that once the demand for PC strand recovers, the share of the market held by “Buy

America(n) sales will once again return to roughly 30 percent.16
IV-14

Table IV-7

PC strand: U.S. consumption and market shares, 2007-09

Item

Calendar year

2007 2008 2009

Quantity (1,000 pounds)

Apparent U.S. consumption 980,503 942,714 508,605

Value (1,000 dollars)

Apparent U.S. consumption 407,169 549,768 248,738

Share of quantity (percent)

U.S. producers’ U.S. shipments 59.4 56.2 78.0

U.S. imports from--

China 36.1 40.5 7.2

Nonsubject countries1 4.5 3.3 14.8

All countries 40.6 43.8 22.0

Share of value (percent)

U.S. producers’ U.S. shipments 65.9 60.7 80.2

U.S. imports from--

China 28.5 35.3 5.6

Nonsubject countries1 5.6 4.0 14.2

All countries 34.1 39.3 19.8

 1 Major nonsubject countries include Canada, Italy, Japan, Korea, Mexico, Portugal, South Africa, Spain, and

Taiwan.

Note.–Because of rounding, figures may not add to the totals shown.

Source: Compiled from data submitted in response to Commission questionnaires and from offical Commerce

statistics.
IV-15

RATIO OF IMPORTS TO U.S. PRODUCTION

Information concerning the ratio of imports to U.S. production of PC strand is presented in table

IV-8. Subject imports were equivalent to 58.8 percent of U.S. production during 2007. This level

increased to 68.3 percent during 2008. However, U.S. imports of PC strand from China were equivalent

to only 9.2 percent of production during 2009.

Table IV-8

PC strand: U.S. production, U.S. imports, and ratios of imports to U.S. production, 2007-09

Item

Calendar year

2007 2008 2009

Quantity (1,000 pounds)

U.S. production 601,717 558,885 395,658

Imports from:

China 353,937 381,652 36,591

Nonsubject countries1 43,766 31,089 75,515

Total imports 397,703 412,741 112,107

Ratio of U.S. imports to production (percent)

Imports from:

China 58.8 68.3 9.2

Nonsubject countries1 7.3 5.6 19.1

Total imports 66.1 73.9 28.3

 1 Major nonsubject countries include Canada, Italy, Japan, Korea, Mexico, Portugal, South Africa, Spain, and

Taiwan.

Note.–Because of rounding, figures may not add to the totals shown.

Source: Compiled from official statistics of the U.S. Department of Commerce and data submitted in response to

Commission questionnaires.
 
 1

 *** reported that wire rod is the primary raw material in PC strand production. *** also reported that wire rod

is the primary raw material used to make PC strand, estimating that wire rod costs represent over *** percent of the

total cost to make PC strand. Insteel reported in its 10-Q for the period ending January 2, 2010, that “following an

extended decline that began in September 2008, prices for our primary raw material, hot-rolled steel wire rod, appear

to have bottomed out and are expected to trend higher due to the recent escalation in scrap costs for wire rod

producers and the reductions in domestic wire rod capacity that occurred during 2009. The magnitude of the

increase and the impact on prices and margins for our products is uncertain at this time.”

V-1

PART V: PRICING AND RELATED INFORMATION

FACTORS AFFECTING PRICES

Raw Material Costs

Raw materials costs accounted for between 72 and 83 percent of U.S. producers’ costs of goods

sold during 2007-09. The cost of steel wire rod in turn accounts for a substantial share of the total cost of

producing PC strand.1

 U.S. producers reported in their questionnaire responses that steel wire rod prices

have been volatile (increasing in late 2007 and 2008, then declining in late 2008) and have affected the

price of PC strand in the U.S. market. As shown in figure V-1, high carbon steel wire rod prices nearly

doubled from the latter part of 2007 through August 2008, dropped to close to their 2007 levels in 2009,

then increased through the first quarter of 2010.

Figure V-1

High carbon steel wire rod: Average wholesale spot price, by month, March 2007-March 2010

Source: American Metal Market, www.amm.com, retrieved May 17, 2010.
V-2

U.S. Inland Transportation Costs

U.S. producers reported that U.S. inland transportation costs ranged from 4 to 6 percent of the

total delivered cost of PC strand, while importers reported transportation costs ranging from 2 to 15

percent, with 13 of the 16 responding importers reporting transportation costs accounting for 5 percent or

less. All U.S. producers and 16 of 23 responding importers reported selling on a delivered basis, and all

U.S. producers and most responding importers also reported arranging transportation to their customers’

locations. Three U.S. producers reported that 90 to 95 percent of their sales were within 101 to 1,000

miles of their storage or production facilities; the other responding U.S. producer reported selling 30

percent within 100 miles and 65 percent within 101 to 1,000 miles. Nearly all imports are reportedly sold

within 1,000 miles of the importers’ storage facilities, with 13 of 18 responding importers reporting that

at least 50 percent of shipments were within 100 miles of their storage facilities. Firms reported selling to

the following regions (table V-1):

Table V-1

PC strand: Geographic market areas in the United States served by domestic producers and

importers of strand from subject and nonsubject sources

U.S. producers Importers (China)

Northeast1 5 5

Midwest2 5 7

Southeast3 5 9

Central Southwest4 5 12

Mountains5 3 11

Pacific Coast6 2 13

Other7 2 3

 1

 – CT, ME, MA, NH, NJ, NY, PA, RI, and VT.

 2 – IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.

 3 – AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.

 4 – AR, LA, OK, and TX.

 5 – AZ, CO, ID, MT, NV, NM, UT, and WY.

 6 – CA, OR, and WA. 7 – All other markets in the United States not previously listed, including AK, HI, PR, VI, among others. 

Source: Compiled from data submitted in response to Commission questionnaires.

PRICING PRACTICES

Pricing Methods

While all U.S. producers reported selling on a transaction-by-transaction basis, one U.S. producer

also uses set price lists, one also uses contracts, and one uses “other” methods of price setting. Three U.S.

producers reported that most (85 to 100 percent) of their 2009 sales were on a short-term contract basis;

one reported that nearly all (*** percent) of its sales were on a spot basis; and one sold *** percent on

long term contracts, *** percent short-term contracts, and *** percent spot sales. U.S. producers’ shortterm contracts’ durations range from one to three months. Four of the five producers reported that prices

and quantities are fixed while one reported that prices can be renegotiated during the contract. One of the

five responding U.S. producers reported that its short-term contracts have a meet-or-release provision. 
 2

 Two firms reported both transaction-by-transaction and contract sales. 

 3

 The other importer reported that contracts fix price and require a minimum quantity.

 4

 ***.

 5

 At the Commission’s conference, Tim Johnson of Suncoast Post-tensioners testified that “...I would like pricing

that’s commensurate with my volume. You know, if I go to buy 10 cars instead of one car, I expect a better price. 

So me being the biggest purchaser in the market, I expect to have a price commensurate with that.” Conference

transcript, p. 44 (Johnson).

V-3

Most importers (16 of 19) reported transaction-by-transaction sales and 5 reported contract sales.2

Thirteen of the 16 responding importers reported 1- to 3-month contracts, with the other firms reporting

contract durations of up to 12 months. Eleven of the 12 responding importers reported that contracts

typically fix both price and quantity.3

Sales Terms and Discounts

Two U.S. producers reported quantity discounts and annual total volume discounts, two reported

no discount policy, and one reported early payment discounts.4

 Fifteen of 19 responding importers

reported no discount policies, with two reporting quantity discounts and one reporting annual volume

discounts. However, Suncoast reported that, as the largest purchaser in the United States, it expects prices

commensurate with its purchase volumes.5 Most firms sell net 30 days, although a few offer a small

discount such as one-half percent for early payment.

PRICE DATA

The Commission requested U.S. producers and importers of PC strand to provide quarterly data

for the total quantity and value of PC strand shipped to unrelated U.S. customers during 2007-09. The

products for which pricing data were requested are as follows:

Product 1.--1⁄2 inch, grade 270 (270,000 PSI), low relaxation, uncovered prestressed concrete

stand sold for pre-tensioned applications.

Product 2.--1⁄2 inch, grade 270 (270,000 PSI), low relaxation, uncovered prestressed concrete

stand sold for post-tensioned applications.

Five U.S. producers and 15 importers of PC strand from China provided usable pricing data for

sales of the requested products, although not all firms reported pricing for all products for all quarters. 

Nonsubject and combined product 1 and product 2 price data are shown in appendix D. Pricing data

reported by these firms accounted for 57.8 percent of U.S. producers’ shipments of PC strand and

virtually all U.S. shipments of subject imports from China in 2009.

Price Trends

Price data for products 1 and 2 are shown in tables V-2 and V-3 and figure V-2. A summary of

price trends is shown in table V-4. 
V-4

Table V-2

PC strand: Weighted-average f.o.b. prices and quantities of domestic and imported product 11 and

margins of underselling/(overselling), by quarters, 2007-09

United States China

Price 

(per lineal foot)

Quantity

(1,000 lineal feet)

Price 

(per lineal foot)

Quantity

(1,000 lineal feet)

Margin

(percent)

2007:

 Jan.-Mar. $254 101,556 $201 13,704 20.8

 Apr.-June 252 112,694 *** *** ***

 July-Sept. 246 104,863 *** *** ***

 Oct.-Dec. 241 110,640 *** *** ***

2008:

 Jan.-Mar. 251 122,934 *** *** ***

 Apr.-June 346 136,478 *** *** ***

 July-Sept. 417 107,670 *** *** ***

 Oct.-Dec. 382 57,342 *** *** ***

2009:

 Jan.-Mar. 302 69,502 *** *** ***

 Apr.-June 265 92,220 *** *** ***

 July-Sept. 250 95,684 *** *** ***

 Oct.-Dec. 256 94,641 *** *** ***

 1

 Product 1: 1⁄2 inch, grade 270 (270,000 PSI), low relaxation, uncovered prestressed concrete strand sold for

pre-tensioned applications.

Source: Compiled from data submitted in response to Commission questionnaires.
V-5

Table V-3

PC strand: Weighted-average f.o.b. prices and quantities of domestic and imported product 21 and

margins of underselling/(overselling), by quarters, 2007-09

United States China

Price 

(per lineal foot)

Quantity

(1,000 lineal feet)

Price 

(per lineal foot)

Quantity

(1,000 lineal feet)

Margin

(percent)

2007:

 Jan.-Mar. $181 47,632 $186 113,816 (2.6)

 Apr.-June 180 61,028 184 157,830 (2.2)

 July-Sept. 182 51,890 182 137,088 (0.2)

 Oct.-Dec. 187 39,243 191 76,752 (2.2)

2008:

 Jan.-Mar. 226 52,327 213 157,819 5.6

 Apr.-June 302 25,304 252 175,197 16.4

 July-Sept. 317 10,431 310 138,670 2.4

 Oct.-Dec. 238 5,243 351 46,704 (47.8)

2009:

 Jan.-Mar. *** *** 222 18,757 ***

 Apr.-June 218 11,636 203 63,913 7.0

 July-Sept. 207 15,289 *** *** ***

 Oct.-Dec. 223 17,411 *** *** ***

 1

 Product 2: 1⁄2 inch, grade 270 (270,000 PSI), low relaxation, uncovered prestressed concrete strand sold for

post-tensioned applications.

Source: Compiled from data submitted in response to Commission questionnaires.

Figure V-2

PC strand: Weighted-average prices and quantities of domestic and imported products 1 and 2, by

quarters, 2007-09

* * * * * * *
 6

 ***.

 7

 The price trends for aggregated product 1 and product 2 price data were similar to price trends for the separate

product 1 and product 2 price series (appendix D). Prices for aggregated U.S. products 1 and 2 were higher than 

prices for aggregated imported Chinese products 1 and 2 in all 12 quarters, by margins ranging from 4.2 percent to

25.0 percent.

 8

 The correlation coefficient for U.S. product 1 prices and U.S. wire rod prices was 0.95 and for U.S. product 2

prices and U.S. wire rod prices was 0.87 (correlation coefficients range from 0-1). However, correlation does not

imply causation, as other factors (e.g., demand factors) may be influencing both variables.

V-6

Table V-4

PC strand: Summary of weighted-average f.o.b. prices for products 1 and 2 from the United States

and China

Item Number of

quarters

Low price 

(per 1,000 ft)

High price

(per 1,000 ft)

Change in price1

(percent)

Product 1 

United States 12 $241 $417 0.5

China 12 *** *** ***

Product 2

United States 12 180 317 23.0

China 12 182 351 ***

 1 Percentage change from the first quarter in which price data were available to the last quarter in which price

data were available, based on unrounded data.

Source: Compiled from data submitted in response to Commission questionnaires.

U.S.-produced and imported Chinese products 1 and 2 showed generally similar trends during the

period for which data were collected, with prices relatively stable during 2007, increasing substantially

during the first three quarters of 2008, and generally declining thereafter. However, prices for U.S.

product 1 tended to be more volatile than prices for imported Chinese product 1 during 2008.6

Furthermore, price declines for U.S. products 1 and 2 in the fourth quarter of 2008 were followed by price

declines by imported Chinese products 1 and 2 in the first quarter of 2009. The substantial price increases

for U.S.-produced and imported Chinese products 1 and 2 in 2008 coincided with substantial increases in

steel wire rod prices, as shown earlier in figure V-1.7

As discussed previously, steel wire rod accounts for a substantial share of raw material costs in

the production of PC strand, and U.S. producers have reported that changes in steel wire rod prices have

affected prices for PC strand. As shown in figure V-3, the substantial price increases in 2008 and

subsequent price declines at the end of 2008 and the first half of 2009 for U.S. products 1 and 2 occurred

together with similar increases and declines in steel wire rod prices.8

Figure V-3

PC strand: Indexes of average U.S. wire rod prices and weighted-average prices of U.S. products

1 and 2, by quarters, January 2007-September 2009

* * * * * * *
 9

 ***.

V-7

Prices for U.S. product 1 were consistently higher than prices for U.S. product 2, particularly

during the third and fourth quarters of 2008 (figure V-4). Prices for imported Chinese product 1 were

also higher than prices for imported Chinese product 2 in every quarter during 2007-09, although the

price differences were relatively smaller. On average, prices for U.S. product 1 were 28.9 percent higher

than prices for U.S. product 2 and prices for imported Chinese product 1 and were 10.0 percent higher

than prices for imported Chinese product 2 during 2007-09.

Figure V-4

PC strand: Weighted-average prices of domestic products 1 and 2 and imported Chinese products

1 and 2, by quarters, 2007-09

* * * * * * *

Ten purchasers identified firms they considered to be price leaders in the PC strand market since

2007. Most responding purchasers identified U.S. producers as price leaders, Insteel in particular

(identified by 7 firms). *** maintained that *** is typically the leader for PC strand price increases, and

the importers *** and *** seem to be the low price leaders for imported Chinese PC strand. The pricing

data in tables V-2 and V-3, and figure V-2 appear to indicate that prices for imported Chinese products 1

and 2 fell sharply in the first quarter of 2009, after prices for U.S.-produced products 1 and 2 had already

started to decline from peak levels.

Price Comparisons

Margins of underselling and overselling for the period are presented in table V-5. As can be seen

from the table, prices for imported Chinese product 1 were below those for U.S. product 1 in all 12

instances, and margins of underselling ranged from *** to *** percent. Prices for imported Chinese

product 2 were priced below those for U.S. product 2 in 7 of 12 instances, with margins of underselling

ranging from *** to *** percent. In the remaining 5 instances, prices for imported Chinese product 2

were between 0.2 and 47.8 percent above prices for U.S. product 2.9

 Overall, prices for PC strand

imported from China were below those for U.S.-produced PC strand in 19 of 24 instances and margins of

underselling ranged from *** to *** percent. In the remaining 5 instances, prices for PC strand from

China were between 0.2 and 47.8 percent above prices for the domestic product.

Table V-5

PC strand: Instances of underselling/overselling and the range and average of margins, 2007-09

Underselling Overselling

Number of

instances

Range

(percent)

Average

margin

(percent)

Number of

instances

Range

(percent)

Average

margin

(percent)

Product 1 12 *** *** 0 - -

Product 2 7 *** *** 5 0.2 to 47.8 11.0

Total 19 *** *** 5 0.2 to 47.8 11.0

Source: Compiled from data submitted in response to Commission questionnaires.
 10 ***. 

 11 A number of the allegations involved multiple locations for a given purchaser.

V-8

LOST SALES AND LOST REVENUES

The Commission requested U.S. producers of PC strand to report any instances of lost sales or

revenues they experienced due to competition from imports of PC strand from China during January

2006-February 2010. In the petition, the three petitioning firms provided *** lost sales allegations

totaling $*** involving *** lineal feet of PC strand and *** lost revenues allegations totaling $***

involving *** lineal feet of PC strand.10 During the final phase of these investigations, two of the

petitioning firms (***) also reported an additional *** lost sales allegations totaling $*** involving ***

lineal feet and 2 lost revenues allegations totaling $*** involving *** lineal feet that had occurred since

the preliminary investigation. Staff contacted all *** purchasers listed in the allegations.11 A summary of

the information obtained follows (tables V-6 and V-7).

Table V-6

PC strand: U.S. producers’ lost sales allegations

* * * * * * *

Table V-7

PC strand: U.S. producers’ lost revenue allegations

* * * * * * *

In addition to questions regarding the specific allegations, these purchasers were also asked if

their firm had switched from U.S.-produced to Chinese PC strand since January 2006, and if so, if price

was the reason. *** responding firms reported that they had switched from U.S.-produced PC strand to

Chinese PC strand because of price, *** reported that it switched for reasons other than price, and ***

reported that they had not switched to Chinese PC strand. When asked if, since January 2006, U.S.

producers had reduced their prices of PC strand to compete with prices of PC strand imported from China,

*** responded “yes” and *** responded “no.”

* * * * * * *
 1

 The U.S. firms are American, Insteel, MMI, RettCo, Strand-Tech, and Sumiden. 

 2

 MMI’s financial data are included in this section of the report to present industry profitability for the PC strand

produced and sold through the RettCo/MMI tolling arrangement. MMI’s net sales quantities and values align with

the shipment data reported in table III-4 and in appendix C, and MMI’s reported operating costs include all costs

associated with the reported sales, including raw material costs and selling expenses, as well as RettCo’s production

costs which are captured in MMI’s reported tolling fees. Consolidated operating income margins are presented as a

companion calculation in the statistical note of table VI-1.

 3

 From 2007 to 2009, all five firms reported decreases in net sales quantities, with *** firms reporting declines in

excess of *** percent. Four of the five firms also reported declines in net sales values during this time. All five

firms reported that the absolute value of their operating profits decreased by *** or more, and all five firms reported

decreases of *** percentage points or more in the ratio of their operating profits to their net sales.

 4

 Insteel reported inventory adjustments ***. E-mail correspondence from ***, June 19, 2009 and e-mail

correspondence from ***, March 31, 2010. Such inventory adjustments correspond to public information on

Insteel’s overall operations. See Insteel’s Form 10-K, November 9, 2009, pp. 16-17 and hearing transcript for PC

Strand from Brazil, India, Japan, Korea, Mexico, and Thailand, Inv. Nos. 701-TA-432 and 731-TA-1024-28

(Review) and AA1921-188 (Third Review), September 30, 2009, pp. 99-101. 

VI-1

PART VI: FINANCIAL EXPERIENCE OF THE U.S. PRODUCERS

BACKGROUND

Six U.S. firms provided usable financial data on their operations on PC strand.1

 These data are

believed to account for the vast majority of U.S. operations on PC strand since 2007. No firms reported

internal consumption or transfers to related firms. MMI and RettCo reported a tolling arrangement in

which MMI is the tollee and RettCo is the toller for all of MMI’s sales of PC strand.2

 All firms reported a

fiscal year end of December 31 except American, which reported a fiscal year end of September 30, and

Insteel, which reported a fiscal year end of the last Saturday closest to the end of September.

OPERATIONS ON PC STRAND

Income-and-loss data for U.S. firms on their operations on PC strand are presented in table VI-1,

while selected financial data, by firm, are presented in table VI-2. The domestic industry experienced a

decline in operating income from 2007 to 2008, followed by an operating loss in 2009. Both total net

sales quantity and value declined from 2007 to 2009; however, net sales quantity declined continually

while net sales value declined irregularly during this time. The per-unit cost of goods sold (“COGS”)

increased from 2007 to 2008 due to increased raw material costs, rising at a rate similar to per-unit

revenue during this time. From 2008 to 2009, a decline in per-unit raw material costs essentially offset an

increase in per-unit other factory costs; however, per-unit revenue also declined during this time and

resulted in the reported operating loss in 2009. 

While each of the five reporting firms reported a decline in its operating margin from 2007 to

2009, several firms had a relatively larger impact on the aggregate results presented in table VI-1.3

Insteel, which represented approximately *** percent of aggregate net sales quantities and values in 2009,

reported inventory adjustments ***. While such adjustments ***, the *** adjustment in 2009 represented

nearly *** percent of the firm’s reported COGS in that period.4
VI-2

Table VI-1

PC strand: Results of operations of U.S. producers, 2007-09

Item

Fiscal year

2007 2008 2009

Quantity (1,000 pounds)

Total net sales 613,704 589,793 389,834

Value ($1,000)

Total net sales 283,088 354,082 210,951

COGS 230,394 302,334 201,246

Gross profit/(loss) 52,694 51,748 9,705

SG&A expenses 13,317 13,795 13,437

Operating income/(loss) 39,377 37,953 (3,732)

Interest expense 3,193 1,820 1,599

Other income/(expense) 821 1,406 373

Net income/(loss) 37,005 37,539 (4,958)

Depreciation 7,602 8,550 8,474

Cash flow 44,607 46,089 3,516

Ratio to net sales (percent)

 COGS:

 Raw materials 62.1 70.9 68.3

 Direct labor 4.5 3.5 3.9

 Other factory costs 14.7 10.9 23.2

 Total COGS 81.4 85.4 95.4

Gross profit/(loss) 18.6 14.6 4.6

SG&A expenses 4.7 3.9 6.4

Operating income/(loss) 13.9 10.7 (1.8)

Net income/(loss) 13.1 10.6 (2.4)

Unit value (per 1,000 pounds)

Total net sales $461 $600 $541

 COGS:

 Raw materials 287 426 370

 Direct labor 21 21 21

 Other factory costs 68 65 125

 Total COGS 375 513 516

Gross profit/(loss) 86 88 25

SG&A expenses 22 23 34

Operating income/(loss) 64 64 (10)

Net income/(loss) 60 64 (13)

Number of firms reporting

Operating losses 0 1 3

Data 5 5 5

Table continued on next page.
 5

 At the hearing, Petitioners testified that the U.S. producers’ 2008 financial results were augmented by the use of

lower cost wire rod from inventory during a period of price increases for both wire rod and PC strand. As wire rod

prices began to fall, U.S. producers would have experienced better profitability in 2009, despite the use of higher

cost wire rod from inventory, had they not been forced to lower their selling prices due to competition from imports

of PC strand from China. There is no mechanism in the PC strand market that automatically adjusts the price of PC

strand on the basis of the cost of wire rod. Hearing transcript, pp. 127-129 (Selhorst).

 6

 E-mail correspondence from ***, April 7, 2010.

 7

 Both Insteel and the overall PC strand industry experienced an improvement in operating income in the last six

months of 2009 as compared to the first six months of 2009. During the first six months of 2009, the overall

industry and Insteel *** reported operating margins of negative 7.5 and *** percent, respectively. In contrast,

during the last six months of 2009, the overall industry and Insteel *** reported operating margins of 3.4 and ***

percent, respectively. Calculated from tables VI-1 and VI-2 in this section of the report and aggregated

questionnaire responses for PC Strand from Brazil, India, Japan, Korea, Mexico, and Thailand, Inv. Nos. 701-TA432 and 731-TA-1024-28 (Review) and AA1921-188 (Third Review). Staff notes that two firms have fiscal years

ending on or near September 30, which makes these calculations imprecise. However, they correspond to public

statements made during the hearing, and may serve as a useful gauge of trends in the PC strand industry during

2009. 

 8

 E-mail correspondence from ***, July 1, 2009, and August 31, 2009. ***. E-mail correspondence from ***,

August 31, 2009, and May 16, 2010.

VI-3

Table VI-1-- Continued

PC strand: Results of operations of U.S. producers, 2007-09

Note.-- MMI’s financial data are included in this section of the report to present industry profitability for the PC strand produced

and sold through the RettCo/MMI tolling arrangement. MMI’s net sales quantities and values align with the shipment data

reported in table III-4 and appendix C, and MMI’s reported operating costs include all costs associated with the reported sales,

including raw material costs and selling expenses, as well as RettCo’s production costs which are captured in MMI’s reported

tolling fees. If COGS are adjusted by the amount of operating income reported for RettCo’s toller operations, operating income

margins for 2007-09 would be ***, ***, and *** percent, respectively. This adjustment removes reported toller profitability from the

overall operations on PC strand and presents industry profitability on a consolidated basis. 

Source: Compiled from data submitted in response to Commission questionnaires.

Table VI-2

PC strand: Results of operations of U.S. producers, by firm, 2007-09

* * * * * * *

In its normal course of business, Insteel records the carrying value of its PC strand inventories at

the lower of cost or market. This analysis compares the current selling price for PC strand relative to the

sum of (1) the carrying value of wire rod, (2) the cost to convert wire rod to finished PC strand, and (3)

applicable selling expenses. When the sum of these costs exceeds current selling prices, Insteel’s

inventory values must be adjusted downward. Insteel performs this analysis and makes any necessary

adjustments ***.

Selling prices for finished PC strand declined markedly in late 2008 and early 2009, which U.S.

producers assert was due to low-priced imports from China.5

 ***. Insteel stated that the firm’s

accounting treatment of inventory carrying values was not discretionary and was in accordance with

Generally Accepted Accounting Principles (GAAP). The firm’s registered public accounting firm

concurs with Insteel’s valuation methodology.6 7

***, which represented approximately *** percent of aggregate net sales quantities and values in

2009, stated that ***.8
 9

 The analysis also shows that from 2007 to 2008, increases in prices (a positive variance) essentially offset

increases in costs/expenses (a negative variance), resulting in a relatively small change in the industry’s operating

income. In contrast, the decline in operating income from 2008 to 2009 reflects the combined effect of decreases in

prices and volume (both negative variances), and an increase in costs/expenses (a negative variance).

 10 A variance analysis is calculated in three parts: sales variance, cost of sales variance, and SG&A expense

variance. Each part consists of a price variance or a cost variance and a volume variance. The sales or cost variance

is calculated as the change in unit price times the new volume, while the volume variance is calculated as the change

in volume times the old unit price. Summarized at the bottom of the table, the price variance is from sales; the

cost/expense variance is the sum of those items from COGS and SG&A variances, respectively; and the volume

variance is the sum of the volume variance lines under price and cost/expense variance. The net volume component

is generally smaller than the price variance and the net cost/expense variance. The volume variance is relatively low

because the negative volume variance for sales is moderated by the positive volume variance for costs/expenses (in

other words, a decline in volume leads to overall lower costs/expenses, and thus a positive volume variance).

 11 E-mail correspondence from ***, June 22 and 23, 2009, and March 31, 2010. See also conference transcript, p.

84 (Woltz). In the firm’s 2008 annual report, Insteel reported the completion of a capital investment program in

2008 and stated the following. “During 2008, we completed extensive upgrades at our Florida PC strand facility,

including the installation of new wire drawing and stranding equipment together with the reconfiguration of the

operation. This project represents the last component of our three-year, $45.4 million capital investment program

under which we have added two new engineered structural mesh (“ESM”) production lines, reconfigured and

expanded our PC strand facilities, and upgraded and expanded our standard welded wire reinforcing capabilities....

With the completion of the program behind us, we expect a significant drop-off in capital expenditures, with

maintenance-related outlays expected to total less than $5.0 million in 2009.” Insteel’s 2008 annual report, p. 2. In

the firm’s 2009 annual report, Insteel stated the following. “From 2006 to 2008, we invested $45.4 million in our

facilities...These projects provide dual benefits in the form of operating cost reductions together with additional

capacity that can be ramped up as market conditions improve. Although the unprecedented collapse in demand that

we experienced over the past year has negated any contribution from the incremental capacity that was added, we

have achieved sizable improvements in efficiencies and productivity as we have shifted volume over to the new

equipment.” Insteel’s 2009 annual report, p. 6. 

 12 E-mail correspondence from ***, June 22 and 23, 2009, and March 31, 2010.

VI-4

VARIANCE ANALYSIS

A variance analysis for PC strand is presented in table VI-3. The information for the variance

analysis is derived from table VI-1. The analysis shows that the decline in operating income from 2007 to

2009 is primarily attributable to the higher unfavorable net cost/expense variance despite a favorable

price variance (that is, costs/expenses rose to a greater extent than prices).9 10

CAPITAL EXPENDITURES AND RESEARCH AND DEVELOPMENT EXPENSES

The responding firms’ aggregate data on capital expenditures and research and development

(“R&D”) expenses are shown in table VI-4. Four firms provided capital expenditure data, while only two

firms provided data on R&D expenses. Capital expenditures for PC strand irregularly declined from 2007

to 2009. Insteel accounted for more than *** percent of total capital expenditures ***, and Sumiden

accounted for more than *** percent of total reported R&D expenses ***. Insteel’s capital expenditures

primarily reflect ***,11 while Sumiden’s R&D expenses primarily reflect ***.12
VI-5

Table VI-3

PC strand: Variance analysis on operations of U.S. producers, 2007-09

Item

Between fiscal years

2007-09 2007-08 2008-09

Value ($1,000)

 Total net sales:

 Price variance 31,129 82,024 (23,086)

 Volume variance (103,266) (11,030) (120,045)

 Total net sales variance (72,137) 70,994 (143,131)

Cost of sales:

 Cost variance (54,896) (80,917) (1,413)

 Volume variance 84,044 8,977 102,501

 Total cost variance 29,148 (71,940) 101,088

Gross profit variance (42,989) (946) (42,043)

SG&A expenses:

 Expense variance (4,978) (997) (4,319)

 Volume variance 4,858 519 4,677

 Total SG&A variance (120) (478) 358

Operating income variance (43,109) (1,424) (41,685)

Summarized as:

 Price variance 31,129 82,024 (23,086)

 Net cost/expense variance (59,874) (81,913) (5,732)

 Net volume variance (14,364) (1,534) (12,867)

Note.-- Unfavorable variances are shown in parentheses; all others are favorable.

Source: Compiled from data submitted in response to Commission questionnaires.

Table VI-4

PC strand: Capital expenditures and research and development expenses of U.S. producers, 2007-09

* * * * * * *

ASSETS AND RETURN ON INVESTMENT

The Commission’s questionnaire requested data on assets used in the production, warehousing,

and sale of PC strand to compute return on investment (“ROI”). Data on the U.S. producers’ total assets

and their ROI are presented in table VI-5. From 2007 to 2009, the total assets for PC strand irregularly

increased from $159.2 million in 2007 to $167.3 million in 2009, and the ROI declined from 24.7 percent

in 2007 to negative 2.2 percent in 2009. Much of the change in the value of current assets relates to

changes in the selling prices and inventory values for PC strand. 
VI-6

Table VI-5

PC strand: Asset values and return on investment of U.S. producers, 2007-09

Item

Fiscal year

2007 2008 2009

Value of assets: Value ($1,000)

Current assets:

 Cash and equivalents 8,154 15,262 20,632

 Accounts receivable, net 35,722 42,804 24,108

 Inventories 41,047 73,013 52,491

 Other 2,166 1,652 7,340

 Total current assets 87,089 132,731 104,571

Property, plant and equipment:

Original cost 133,761 142,408 142,899

Less: accumulated depreciation 64,151 74,759 82,018

Equals: book value 69,611 67,648 60,882

Other non-current assets 2,526 2,287 1,834

 Total assets 159,226 202,666 167,287

Operating income or (loss) 39,377 37,953 (3,732)

Share (percent)

Return on investment 24.7 18.7 (2.2)

Source: Compiled from data submitted in response to Commission questionnaires.

CAPITAL AND INVESTMENT

The Commission requested U.S. producers to describe any actual or potential negative effects

since January 1, 2007, on their return on investment, growth, investment, ability to raise capital, existing

development and production efforts, or the scale of capital investments as a result of imports of PC Strand

from China. Their responses are as follows:

Actual Negative Effects

* * * * * * *

Anticipated Negative Effects

* * * * * * *
 1

 The global trade data presented are derived from Global Trade Atlas, HTS 7312.10. The products covered

under this six-digit HTS classification include all stranded wire, ropes, cables, and cordage, of iron or steel, which

have not been electrically insulated. The subject PC strand is included in the data presented, as are many other

products. Other products included in the data are stranded wire, ropes, cables, and cordage (including tire cord), of

stainless steel or which have been brass plated or galvanized. The Global Trade Atlas data presented exclude the

data for Malaysia because these data are not consistent with other data reported.

 2

 In their petition, the petitioners provided the names and contact information for 22 producers of PC strand in

China. In their prehearing brief in the final phase of these investigations indicated that there are 30 or more PC

strand producers in China. Petition, exh. General-4; petitioners’ prehearing brief, p. 76 and exh. 11.

VII-1

PART VII: THREAT CONSIDERATIONS AND INFORMATION ON

NONSUBJECT COUNTRIES

The Commission analyzes a number of factors in making threat determinations (see 19 U.S.C. §

1677(7)(F)(i)). Information on the dumping margins and the nature of the subsidies was presented earlier

in this report; information on the volume and pricing of imports of the subject merchandise is presented in

Part IV and Part 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.

OVERVIEW

According to Global Trade Atlas, the United States was the world’s largest importer of stranded

wire, ropes, cables, and cordage, of iron or steel, during 2007-09, accounting for almost one-fifth of

recorded total global imports (table VII-1).1

 In contrast, China was the world’s leading exporter during

that same time period. China’s exports increased by over 27 percent from 2007 to 2008, exceeding 2.3

billion pounds in 2008. China’s exports accounted for 30 percent of the world’s exports in 2007 and 36

percent in 2008. However, China’s exports, which fell in 2009 to a level 29 percent below that reported

in 2007, accounted for a smaller share (25 percent) of the world’s exports in 2009. China’s net trade

surplus reached nearly 2.2 billion pounds in 2008, but fell in 2009 to 1.1 billion pounds, a level below

that reported in 2007 (1.7 billion pounds).

There are five producers of PC strand in the United States and an estimated 30 or more producers

of PC strand in China.2

 Other sizeable producers of PC strand in other countries include the following: 

Austria (Voestalpine Austria Draht GMBH); Brazil (ArcelorMittal Belgo); Canada (Bekaert, Stelwire

Ltd., Titan Steel and Wire, and ArcelorMittal); Colombia (Empresa Colombiana de Cables SA); Germany

(DWK Drahtwerk Koln GmbH); India (Tata Steel, Usha Martin Industries, Indore Wire Co., and 

Ramsarup Lohh Udyog Ltd.); Italy (CB Trafilati Accial, Far SPA, Italcables SPA, Redaelli Tecnasud,

Siderurgica Latina Martin, and Trafilati SPA); Japan (Shinko Wire Co., Suzuki Metal Co., Tokyo Rope

Mfg. Co., and Tesac Corp.); Korea (Dong-Il Steel Mfg. Co., Kiswire, Manho Rope and Wire, and

Youngheung Iron and Steel Co.); Malaysia (Kiswire); Mexico (Camesa and Deacero); Netherlands (Nedri

Spanstaal, BV); Portugal (Fapricela Industria de Trefilaria SA, Socitrel, and Tycsa–Trenzas y Cables de

Acero PSC SL); Russia (Severstal Metiz); South Africa (Scaw Metals Group); Spain (Emesa Trefileria

and Tycsa); Taiwan (Chia Ta World Co., Ltd. and U-LEAD Industrial Corp.); Thailand (Bangkok Steel

Wire Co., Siam Wire Industry Co., Thai Wire Products Public Co., The Siam Industrial Wire Co., and 
VII-2

Table VII-1

PC strand and related products: World exports, imports, and trade balance of stranded wire,

ropes, cables, and cordage, of iron or steel, by country, 2007-09

Country Calendar year

2007 2008 2009

Quantity (1,000 pounds)

Exports from:

 China 1,823,793 2,323,358 1,288,423

 Thailand 200,227 211,702 745,667

 Korea 657,297 638,859 536,679

 Spain 425,508 432,842 287,074

 Italy 349,605 366,204 275,712

 Germany 245,491 260,081 219,931

 United States 156,586 180,970 147,079

 Japan 195,795 168,022 130,211

 Hungary 141,696 138,299 121,057

 France 201,421 165,235 107,545

 All other countries 1,594,534 1,599,613 1,267,879

 Total 5,991,953 6,485,185 5,127,256

Imports into:

 China 131,359 130,610 156,882

 Thailand 36,451 53,347 53,091

 Korea 258,201 285,735 211,787

 Spain 225,938 230,013 127,470

 Italy 133,850 143,381 99,154

 Germany 367,707 391,744 299,188

 United States 1,045,989 1,064,161 616,219

 Japan 160,082 166,371 145,532

 Hungary 19,083 18,025 10,659

 France 219,677 221,902 158,559

 All other countries 2,641,585 2,740,095 2,106,939

 Total 5,239,924 5,445,383 3,985,481

Trade balance:

 China 1,692,433 2,192,747 1,131,540

 Thailand 163,777 158,355 692,576

 Korea 399,095 353,124 324,892

 Spain 199,569 202,830 159,604

 Italy 215,755 222,823 176,558

 Germany (122,216) (131,663) (79,258)

 United States (889,403) (883,191) (469,140)

 Japan 35,713 1,652 (15,321)

 Hungary 122,613 120,274 110,398

 France (18,256) (56,667) (51,017)

 All other countries (1,047,051) (1,140,482) (839,060)

Note.--Positive numbers presented for “trade balance” show net exports and numbers in parentheses presented for “trade

balance” show net imports. Countries presented separately are based on the top ten exporting countries to the world in 2009.

Source: Global Trade Atlas, HTS 7312.10 (all stranded wire, ropes, cables, and cordage, of iron or steel, which have not been

electrically insulated), excluding data for Malaysia, retrieved April 20, 2010. 
 3

 There are currently antidumping and/or countervailing duty orders in place in the United States concerning PC

strand producers in six of the countries listed (Brazil, India, Japan, Korea, Mexico, and Thailand). These countries

currently ship little or no PC strand to the United States. According to official import statistics, there were no

imports of PC strand into the United States from Brazil, India, and Japan during 2009 and, according to the record in

the recently completed reviews concerning these six countries, Camesa and Deacero, the only PC strand producers in

Mexico, reportedly have not exported the subject merchandise to the United States in several years. Prestressed

Concrete Steel Wire Strand from Brazil, India, Japan, Korea, Mexico, and Thailand, Investigation Nos. 701-TA-432

and 731-TA-1024-1028 (Review) and AA1921-188 (Third Review), USITC Publication 4114, November 2009, p. IV1. U.S. imports of PC strand from Korea and Thailand combined during 2009 accounted for only 0.5 percent of total

U.S. imports of PC strand.

 4

 Petition, exh. General-4; petitioners’ prehearing brief, p. 76 and exh. 11.

 5

 Petitioners’ prehearing brief, pp. 69-70.

 6

 Commission Regulation (EC) No 1129/2008 of 14 November 2008, Official Journal of the European Union,

November 15, 2008, L 306/5.

 7 Prestressed Concrete Steel Wire Strand from Brazil, India, Japan, Korea, Mexico, and Thailand, Inv. Nos.

701-TA-432 and 73l-TA-1024-1028 (Review) and AA1921-188 (Third Review), USITC Publication 4114, November

2009, table IV-9; questionnaire responses submitted in the reviews concerning Prestressed Concrete Steel Wire

Strand from Brazil, India, Japan, Korea, Mexico, and Thailand (Inv. Nos. 701-TA-432 and 73l-TA-1024-1028

(Review) and AA1921-188 (Third Review); and domestic producers’ prehearing brief submitted in Prestressed

Concrete Steel Wire Strand from Brazil, India, Japan, Korea, Mexico, and Thailand (Inv. Nos. 701-TA-432 and

73l-TA-1024-1028 (Review) and AA1921-188 (Third Review), exh. 5 (used in these investigations with permission

from domestic parties, staff telephone conversation with ***, on April 22, 2010).

 8

 Production and capacity utilization information presented were obtained for all companies in Brazil and Mexico;

however, less than complete coverage was available for India (*** percent of PC strand production in India), Japan

(*** percent of PC strand production in Japan); Korea (*** percent of PC strand production in Korea); and Thailand

(*** percent of PC strand production in Thailand). Ibid.

VII-3

Thai Special Wire Co.); Turkey (Celik Halat ve Tel Sanayii AS); and the United Kingdom (Bridon

International and Carrington Wire Ltd.).3

 

There is no comprehensive source for capacity and/or production data for all countries producing

PC strand throughout the world; however, such data for China and several nonsubject sources have been

submitted into the record of these investigations and are presented, as follows. As previously indicated,

there are believed to be 30 or more producers of PC strand in China.4

 According to estimates provided in

the questionnaire responses of Chinese PC strand producers received during the preliminary phase of

these investigations, total 2008 production of PC strand in China is believed to have been approximately

5.1 billion pounds. The petitioners indicated that, based on ***, the capacity to produce PC strand in

China is currently roughly 6.6 billion pounds.5

 To compare, there are a total of at least 22 producers of

PC strand in the countries that comprise the European Union. Overall European Union production was

reported to be 2.1 billion pounds in 2007. With aggregate reported capacity for European Union PC

strand producers at approximately 2.7 billion pounds, these facilities were reported to be operating at 79

percent capacity utilization.6

 In addition, available data for Brazil, India, Japan, Korea, Mexico, and

Thailand reveal that PC strand capacity and production in each of these six countries is substantially

smaller than that in China. Total 2008/09 capacity to produce PC strand by 23 producers in these six

countries combined is estimated at approximately 1.3 billion pounds: Brazil (*** pounds); India (***

pounds); Japan (*** pounds); Korea (*** pounds); Mexico (*** pounds); and Thailand (*** pounds).7

Capacity utilization for PC strand facilities in these six countries ranged from 43.6 to 87.2 percent during

2008 and from 17.4 to 84.0 percent during the first half of 2009: Brazil (***); India (***); Japan (***);

Korea (***); Mexico (***); and Thailand (***).8
 9

 Petitioners’ prehearing brief, p. 76 and exh. 11.

 10 The petitioners provided a list of 22 producers of PC strand in China in their petition. Petition, exh. General-4.

In addition, staff requested through U.S. counsel that parties to Commerce’s investigations respond to the

Commission’s questionnaires.

 11 The only communication received in response to the Commission’s requests for information was an email

correspondence from ***. Email to Mary Messer from ***, February 10, 2010.

 12 Petitioners’ prehearing brief, p. 68.

 13 Ibid., p. 67.

 14 Ibid., p. 71.

VII-4

THE INDUSTRY IN CHINA

The petitioners indicated that there are currently are 30 or more producers of PC strand in China.9

The Commission sent foreign producer questionnaires to all firms identified in the petition as possible

producers/exporters of PC strand in China.10 Despite numerous attempts by staff to elicit responses from

producers of PC strand in China, no questionnaire responses were received from producers of the subject

merchandise in China during the final phase of these investigations.11 Data presented in this section of the

report regarding the Chinese industry are, therefore, based on the foreign producer questionnaire

responses received by the Commission during its preliminary phase of these investigations.

The petitioners argued that, because of the lack of cooperation from the Chinese in providing

questionnaire responses, the Commission should exercise its discretion in these investigations and apply

adverse inferences in reaching its decision.12 The petitioners stated that they

. . . believe that the failure on the part of the Chinese producers in this investigation to

respond to requests for information is similarly a “strategic choice” to deprive the

Commission of information that likely would not support respondents’ case, not an

inability to do so (as evidenced by their cooperation at the preliminary stage of this case

and before Commerce). Under these facts, the deliberate refusal of the Chinese producers

should not inure to their benefit. Instead, consistent with the statute, this behavior should

lead to the Commission’s adoption of adverse inferences when selecting among the facts

available in reaching a final determination.13

Four PC strand producers in China provided responses to the Commission’s request for

information during the preliminary phase of the investigations. The names of these firms, along with their

shares of reported production and subject exports to the United States (by quantity), are presented in table

VII-2. According to estimates provided in the questionnaire responses, the responding Chinese producers

believe that total production of PC strand in China amounted to about 5.1 billion pounds during 2008, of

which they accounted for about 17 percent in the aggregate. As previously indicated, the petitioners

estimated that the current capacity to produce PC strand in China is approximately 6.6 billion pounds, or

nearly 13 times larger than 2009 apparent U.S. consumption of PC strand.14 The four Chinese producers

that responded to the Commission’s questionnaire in the preliminary phase of the investigations also

reported that together they exported 72.7 million pounds of PC strand to the United States, which

accounted for 19.1 percent of official Commerce import statistics (381.7 million pounds) in 2008.

Table VII-2

PC strand: Reporting manufacturers/exporters in China, and quantities and shares of reported

production and exports to the United States, 2008

* * * * * * *
 15 Ibid., 79.

 16 Ibid., pp. 79-81.

 17 Ibid., p. 84 and 89.

VII-5

The Commission asked the Chinese producers to indicate whether they or any related firm

producers, have the capability to produce, or have any plans to produce PC strand in the United States or

other countries. ***.

The Commission also asked the Chinese firms to estimate the shares of their total sales that were

represented by sales of PC strand; firms’ estimates ranged from *** percent to *** percent of total

company sales in their most recent fiscal year. *** firms reported production of other products in

addition to PC strand on the same equipment and machinery used in the production of PC strand in China. 

In response to a question concerning changes in the character of operations concerning the

production of PC strand since January 1, 2006, *** responding producers in China reported *** plant

openings or closings, relocations, acquisitions, changes in ownership, consolidations, prolonged

shutdowns, importation curtailments, or revised labor agreements. *** responding Chinese producers

reported plant expansions in relation to their production of PC strand. Company responses concerning the

changes in the character of their PC strand operations in China are presented in table VII-3.

Table VII-3

PC strand: Chinese producers’ comments concerning changes in the character of operations

* * * * * * *

Data provided by the four Chinese PC strand producers responding to the Commission’s

questionnaire concerning capacity, production, inventories, and shipments are presented in table VII-4.

The reported aggregate capacity of these four firms to produce PC strand in China increased from 2006 to

2008, with their PC strand operations operating at levels close to or at full capacity. However, during the

first quarter of 2009, capacity utilization reported at 84.5 percent was substantially lower than calendar

year 2008 but higher than the first quarter of that same year. 

The petitioners argued that the relatively high rates of capacity utilization “bear no relation to,

and should not be cited as the basis of, current capacity utilization rates in China.”15 They indicated that

there is currently an oversupply of PC strand in China because of the continual expansion of capacity to

produce PC strand in China, coupled with the collapse of the global economy and the overall decline in

demand for PC strand in both the home and export markets, including major European export markets

that have imposed duties on Chinese PC strand. The petitioners estimated that the Chinese PC strand

industry currently has 4.4 billion pounds of excess capacity and is currently operating at a capacity

utilization rate of 33 percent.16 In addition, the petitioners claimed that Chinese producers of PC strand

are increasingly attempting to arrange unlawful plans to evade the preliminary duties associated with

these investigations. They have asserted that the Chinese PC strand producers have been proposing a plan

called “carry trade,” whereby the producers in China export PC strand to a third country (e.g., Malaysia,

Hong Kong, Vietnam, Indonesia, and Taiwan) where the merchandise is relabeled and/or repackaged with

the third country identified as the country of origin. The relabeled/repackaged merchandise would then

be exported to the United States accompanied by false documents in to avoid any antidumping duties.17
VII-6

Table VII-4

PC strand: China production capacity, production, shipments, and inventories, 2006-08, JanuaryMarch 2008, and January-March 2009

2006 2007 2008

January-March

2008 2009

Quantity (1,000 pounds)

Capacity1 630,219 768,246 908,336 218,816 240,863

Production 614,377 769,354 878,650 162,011 203,628

End of period inventories 31,504 27,974 57,857 31,278 63,538

Shipments:

Internal consumption 0 0 0 0 0

Home market 441,801 524,502 577,378 104,427 173,091

Exports to--

The United States 106,839 99,032 72,735 23,998 1,714

European Union2 14,646 20,712 21,121 5,321 2,000

All other markets3 48,567 128,639 177,532 24,959 21,141

Total exports 170,052 248,383 271,388 54,279 24,855

Total shipments 611,853 772,884 848,766 158,706 197,947

Ratios and shares (percent)

Capacity utilization 97.5 100.1 96.7 74.0 84.5

Inventories to production 5.1 3.6 6.6 4.8 7.8

Inventories to total shipments 5.1 3.6 6.8 4.9 8.0

Share of total quantity of shipments:

Internal consumption 0.0 0.0 0.0 0.0 0.0

Home market 72.2 67.9 68.0 65.8 87.4

Exports to--

The United States2 17.5 12.8 8.6 15.1 0.9

European Union3 2.4 2.7 2.5 3.4 1.0

All other markets 7.9 16.6 20.9 15.7 10.7

All export markets 27.8 32.1 32.0 34.2 12.6

1

 Reported capacity is based on operating from 156 to 168 hours per week, 49 to 50 weeks per year. 2

 Principal European Union export markets include Austria, Czech Republic, Estonia, Finland, Hungary, Italy, Lithuania,

Portugal, Spain, Sweden, and the United Kingdom. 3

 Principal other export markets include Africa, Australia, Brazil, Canada, Chile, Cuba, Hong Kong, Israel, Korea, Japan,

Malaysia, Middle East, Central and South America, New Zealand, Norway, Panama, Singapore, Southeast Asia, Thailand, United

Arab Emirates, and Vietnam.

Note.–Because of rounding, figures may not add to the totals shown.

Source: Compiled from data submitted in response to Commission questionnaires issued in the preliminary phase of these

investigations.
 18 The global trade data presented are derived from Global Trade Atlas, HTS 7312.10. The products covered

under this six-digit HTS classification include all stranded wire, ropes, cables, and cordage, of iron or steel, which

have not been electrically insulated. The subject PC strand is included in the data presented, as are many other

products. Other products included in the data are stranded wire, ropes, cables, and cordage (including tire cord), of

stainless steel or which have been brass plated or galvanized.

VII-7

Producers of PC strand in China reported no internal consumption of the product from 2006 to

2008. The Chinese producers’ largest commercial market for PC strand was the home market, accounting

for almost three-fourths of total shipments during 2006 and slightly more than two-thirds of total 

shipments during 2007-08. Such shipments were noticeably higher during the first quarter of 2009 than

in the first quarter of 2008. PC strand exports to the United States, which was the largest export market

for the Chinese PC strand during 2006, fell from 2006 to 2008. Exports to the United States accounted

for 17.5 percent of total shipments during 2006, 12.8 percent during 2007, and 8.6 percent during 2008. 

During the first quarter of 2009, the Chinese producers’ exports to the United States were only 0.9

percent of their total company shipments. 

Three of the four responding Chinese producers provided projected capacity data for calendar

years 2009 and 2010. Two of those producers (***) reported no capacity changes and one (***) reported

a ***-percent *** in capacity of *** pounds from 2008 to 2010. One of the four responding Chinese

producers (***) also provided projected home market shipment data and export shipment data for exports

to countries other than the United States and the European Union for calendar year 2009. This company

projected an increase in sales to the home market and a decline in exports to these other markets. Another

of the four responding Chinese producers (***) provided complete projections for calendar years 2009-

10. *** projected a ***-percent decline in production of *** pounds from 2008 to 2009 and a ***-

percent increase of *** pounds in 2010. The company’s projected home market shipments are expected

to increase overall by *** percent from *** pounds in 2008 to *** pounds in 2010 and exports to the

United States are expected to fall by *** percent from *** pounds in 2008 to *** pounds in 2009 but

climb by *** percent to *** pounds in 2010. The company, which reported shipments of *** pounds of

PC strand to the European Union in 2008, reported that it *** PC strand to the European Union during

2009-10. Inventories held by *** are expected to increase by *** percent from *** pounds in 2008 to

*** pounds in 2010. 

The producers in China provided explanations for their reported projections. Their explanations

are presented in table VII-5.

Table VII-5

PC strand: Chinese producers’ explanations for reported projections

* * * * * * *

According to Global Trade Atlas, China’s top export market for stranded wire, ropes, cables, and

cordage, of iron or steel, during 2007-09 was the United States (table VII-6).18 Even though China’s

exports fell for most of its top ten export markets from 2007 to 2009, the largest decline in China’s

exports was to the United States. In 2009, China’s exports to the United States fell to a level that

remained 25 million pounds above the level reported for Korea (China’s second largest export market).
VII-8

Table VII-6

PC strand and related products: China’s exports of stranded wire, ropes, cables, and cordage, of

iron or steel, by market, 2007-09

Country Calendar year

2007 2008 2009

Quantity (1,000 pounds)

China’s exports to:

 United States 525,600 555,653 187,922

 Korea 210,773 242,325 162,925

 Vietnam 60,746 59,663 88,210

 United Arab Emirates 80,424 210,117 77,653

 Japan 41,809 63,446 53,930

 Singapore 48,262 77,454 40,888

 Iran 24,711 37,983 38,161

 Indonesia 44,776 67,902 35,843

 Brazil 30,829 40,333 34,366

 India 48,967 66,006 32,610

 All other countries 706,896 902,476 535,914

 Total 1,823,793 2,323,358 1,288,423

Value (1,000 dollars)

China’s exports to:

 United States 210,694 329,598 144,551

 Korea 111,975 158,901 92,616

 Vietnam 23,019 30,832 36,872

 United Arab Emirates 26,664 112,995 28,635

 Japan 26,403 53,078 49,243

 Singapore 17,506 43,318 20,726

 Iran 8,967 22,532 17,158

 Indonesia 18,927 33,829 16,241

 Brazil 14,661 28,446 19,995

 India 26,030 42,360 25,217

 All other countries 346,482 596,605 319,693

 Total 831,328 1,452,493 770,947

Unit value (per 1,000 pounds)

China’s exports to:

 United States $401 $593 $769

 Korea 531 656 568

 Vietnam 379 517 418

 United Arab Emirates 332 538 369

 Japan 632 837 913

 Singapore 363 559 507

 Iran 363 593 450

 Indonesia 423 498 453

 Brazil 476 705 582

 India 532 642 773

 All other countries 490 661 597

 Total 456 625 598

Note.--Countries presented separately are based on China’s top ten export markets in 2009.

Source: Global Trade Atlas, HTS 7312.10 (all stranded wire, ropes, cables, and cordage, of iron or steel, which have not been

electrically insulated), retrieved April 20, 2010. 
 19 *** of the four PC strand producers in China that provided questionnaire responses in the preliminary phase of

these investigations reported maintaining inventories of PC strand in the United States.

 20 Conference transcript, p. 23 (Woltz and Cornelius); and petitioners’ prehearing brief, pp. 10-14, 31, 54-55.

VII-9

U.S. INVENTORIES OF PC STRAND

Data collected in these investigations on U.S. importers’ end-of-period inventories of PC strand

are presented in table VII-7.19 Nine U.S. importers reported holding inventories of PC strand imported

from China during the period for which data were collected in the final phase of these investigations. 

U.S. importers’ inventories of Chinese PC strand (based on quantity and as a share of imports and U.S.

shipments of imports) increased from 2007 to 2008. Between 2007 and 2008, U.S. importers’ inventories

of PC strand from China increased by 19.7 million pounds. The quantity of inventories of the imported

Chinese product fell by 36.4 million pounds between 2008 and 2009 but its share of imports and U.S.

shipments of imports increased. The inventories of PC strand imports from nonsubject sources followed

the opposite trend as the imports from these other sources fell by 464,000 pounds from 2007 to 2008 and

increased by 10.4 million pounds between 2008 and 2009. 

Table VII-7

PC strand: U.S. importers’ end-of-period inventories of imports, by source, 2007-09

Item

Calendar year

2007 2008 2009

China:

Inventories (1,000 pounds) 31,725 51,461 15,019

Ratio of inventories to imports (percent) 10.4 16.2 49.2

Ratio to U.S. shipments of imports (percent) 9.4 17.3 22.8

Other sources:

Inventories (1,000 pounds) *** *** ***

Ratio of inventories to imports (percent) *** *** ***

Ratio to U.S. shipments of imports (percent) *** *** ***

All sources:

Inventories (1,000 pounds) *** *** ***

Ratio of inventories to imports (percent) *** *** ***

Ratio to U.S. shipments of imports (percent) *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires.

The petitioners contended that there was a “massive” build up of inventories of the Chinese

product in the United States in 2008, especially by purchasers. They indicated that both importers and

purchasers in the United States were buying and stockpiling “huge quantities” of PC strand from China in

anticipation of an increase in demand for the product. They argued that this excess inventory, coupled

with the severe market downturn and the decline in demand for PC strand, “artificially suppressed” U.S.

imports of PC strand from China during late 2008 and 2009. In fact, the petitioners argued that the

presence of subject imports in the U.S. market was much higher than the official import statistics show

because of these “massive” amounts of purchaser inventory overhang.20
VII-10

U.S. IMPORTERS’ CURRENT ORDERS

The Commission requested importers to indicate whether they imported or arranged for the

importation of PC strand from China for delivery after December 31, 2009. The following seven U.S.

importers reported that they had placed import orders for PC strand for delivery into the United States

after December 31, 2008: ***. All seven U.S. importers reported such imports for delivery during the

first quarter of 2010 and four of the seven (***) reported imports for delivery during the second quarter of

2010. *** reported imports for delivery after the second quarter of 2010 and *** reported imports of

subject merchandise from China after December 31, 2009. Aggregate data reported by these U.S.

importers concerning their orders of PC strand are presented in table VII-8. According to first quarter

2010 official import statistics, U.S. imports of PC strand from China amounted to 346,333 pounds

($140,507) and U.S. imports of PC strand from all nonsubject countries amounted to 39.5 million pounds

($18.0 million).

Table VII-8

PC strand: U.S. importers’ orders for PC strand imports after December 31, 2009

Country of origin

2010

January-March April-June July- September

Quantity (1,000 pounds)

*** *** *** ***

*** *** *** ***

*** *** *** ***

*** *** *** ***

*** *** *** ***

*** *** *** ***

*** *** *** ***

*** *** *** ***

*** *** *** ***

*** *** *** ***

Total 24,633 17,199 ***

Source: Compiled from data submitted in response to Commission questionnaires.
 21 Council Regulation (EC) No 383/2009 of 5 May 2009, Official Journal of the European Union, May 13, 2009,

L 118/1.

 22 Petition, p. 32; and petitioners’ prehearing brief, p. 86. 

VII-11

ANTIDUMPING INVESTIGATIONS IN THIRD-COUNTRY MARKETS

PC strand produced in China is currently subject to antidumping duties in the European Union. 

On May 5, 2009, the Council of the European Union imposed definitive antidumping duties on imports of

pre- and post-stressing wires and wire strands of non-alloy steel from China.21 The weighted-average

dumping margins are presented in table VII-9.

The petitioners argued that, given the size of the antidumping duties imposed in 2009, exports of

Chinese PC strand to the European Union are expected to decline in 2010. They further argued that the

imposition of the European Union antidumping duty order will essentially encourage the Chinese

producers of PC strand to redirect the exports of their product from the European Union to the United

States and that this redirection to the U.S. market “would have a large and devastating impact on the

domestic industry.”22 

Table VII-9

PC strand: European Union antidumping duties on PC strand from China

Company

Dumping

margin (in

percent)

Injury

elimination 

margin (in

percent)

Definitive antidumping

duties rate (in

percent)

Kiswire Qingdao Ltd. (Qingdao) 26.8 0.0 0.0

Ossen MaanShan Steel Wire and Cable Co. Ltd

(Maanshan) and Ossen Liujiang Steel Wire

Cable Co. Ltd. (Liujiang) 49.8 31.1 31.1

Country-wide level 50.0 46.2 46.2

Source: Council Regulation (EC) No 383/2009 of 5 May 2009, Official Journal of the European Union, May 13,

2009, L 118/1.
 
APPENDIX A

FEDERAL REGISTER NOTICES

A-1

Federal Register / Vol. 75, No. 35 / Tuesday, February 23, 2010 / Notices 8113 

components thereof that infringe one or 

more of claims 15 and 23–27 of U.S. 

Patent No. 6,292,218, and whether an 

industry in the United States exists as 

required by subsection (a)(2) of section 

337; 

(2) For the purpose of the 

investigation so instituted, the following 

are hereby named as parties upon which 

this notice of investigation shall be 

served: 

(a) The complainant is: Eastman 

Kodak Company, 343 State Street, 

Rochester, NY 14650. 

(b) The respondents are the following 

entities alleged to be in violation of 

section 337, and are the parties upon 

which the complaint is to be served: 

Research In Motion, Ltd., 295 Phillip 

Street, Waterloo, Ontario, Canada N2L 

3W8; 

Research In Motion Corporation, 122 

West John Carpenter Parkway, Suite 

430, Irving, TX 75039; 

Apple Inc., 1 Infinite Loop, Cupertino, 

CA 95014. 

(c) The Commission investigative 

attorney, party to this investigation, is 

Vu Q. Bui, Esq., Office of Unfair Import 

Investigations, U.S. International Trade 

Commission, 500 E Street, SW., Suite 

401, Washington, DC 20436; and 

(3) For the investigation so instituted, 

the Honorable Paul J. Luckern, Chief 

Administrative Law Judge, U.S. 

International Trade Commission, shall 

designate the presiding Administrative 

Law Judge. 

Responses to the complaint and the 

notice of investigation must be 

submitted by the named respondents in 

accordance with section 210.13 of the 

Commission’s Rules of Practice and 

Procedure, 19 CFR 210.13. Pursuant to 

19 CFR 201.16(d)–(e) and 210.13(a), 

such responses will be considered by 

the Commission if received not later 

than 20 days after the date of service by 

the Commission of the complaint and 

the notice of investigation. Extensions of 

time for submitting responses to the 

complaint and the notice of 

investigation will not be granted unless 

good cause therefor is shown. 

Failure of a respondent to file a timely 

response to each allegation in the 

complaint and in this notice may be 

deemed to constitute a waiver of the 

right to appear and contest the 

allegations of the complaint and this 

notice, and to authorize the 

administrative law judge and the 

Commission, without further notice to 

the respondent, to find the facts to be as 

alleged in the complaint and this notice 

and to enter an initial determination 

and a final determination containing 

such findings, and may result in the 

issuance of an exclusion order or a cease 

and desist order or both directed against 

the respondent. 

By order of the Commission. 

Issued: February 17, 2010. 

Marilyn R. Abbott, 

Secretary to the Commission. 

[FR Doc. 2010–3426 Filed 2–22–10; 8:45 am] 

BILLING CODE P 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation Nos. 701–TA–464 and 731– 

TA–1160 (Final)] 

Prestressed Concrete Steel Wire 

Strand From China 

AGENCY: United States International 

Trade Commission. 

ACTION: Revised schedule for the subject 

investigations. 

DATES: Effective Date: February 16, 

2010. 

FOR FURTHER INFORMATION CONTACT: 

Mary Messer (202–205–3193), Office of 

Investigations, U.S. International Trade 

Commission, 500 E Street, SW., 

Washington, DC 20436. Hearingimpaired persons can obtain 

information on this matter by contacting 

the Commission’s TDD terminal on 202– 

205–1810. Persons with mobility 

impairments who will need special 

assistance in gaining access to the 

Commission should contact the Office 

of the Secretary at 202–205–2000. 

General information concerning the 

Commission may also be obtained by 

accessing its Internet server (http:// 

www.usitc.gov). The public record for 

these investigations may be viewed on 

the Commission’s electronic docket 

(EDIS) at http://edis.usitc.gov. 

SUPPLEMENTARY INFORMATION: Effective 

December 23, 2009, the Commission 

established a schedule for the conduct 

of the final phase of the subject 

investigations (75 FR 4104, January 26, 

2010). On January 28, 2010, the 

Commission was notified by the 

petitioners of a substantial conflict with 

respect to their ability to participate in 

the hearing. Accordingly, at the request 

of the petitioners and absent any 

argument to the contrary, the 

Commission is revising its schedule. 

The Commission’s new schedule for 

the investigations is as follows: requests 

to appear at the hearing must be filed 

with the Secretary to the Commission 

not later than April 30, 2010; the 

prehearing conference will be held at 

the U.S. International Trade 

Commission Building at 9:30 a.m. on 

May 4, 2010; the prehearing staff report 

will be placed in the nonpublic record 

on April 22, 2010; the deadline for filing 

prehearing briefs is April 29; the hearing 

will be held at the U.S. International 

Trade Commission Building at 9:30 a.m. 

on May 6, 2010; the deadline for filing 

posthearing briefs is May 14, 2010; the 

Commission will make its final release 

of information on June 2, 2010; and final 

party comments are due on June 4, 

2010. 

For further information concerning 

these investigations see the 

Commission’s notice cited above and 

the Commission’s Rules of Practice and 

Procedure, part 201, subparts A through 

E (19 CFR part 201), and part 207, 

subparts A and C (19 CFR part 207). 

Authority: These investigations are being 

conducted under authority of title VII of the 

Tariff Act of 1930; this notice is published 

pursuant to section 207.21 of the 

Commission’s rules. 

Issued: February 17, 2010. 

By order of the Commission. 

Marilyn R. Abbott, 

Secretary to the Commission. 

[FR Doc. 2010–3425 Filed 2–22–10; 8:45 am] 

BILLING CODE P 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation Nos. 701–TA–474 and 731– 

TA–1176 (Preliminary)] 

Drill Pipe From China 

AGENCY: United States International 

Trade Commission. 

ACTION: Revised schedule for the subject 

antidumping and countervailing duty 

investigations. 

DATES: Effective Date: February 16, 

2010. 

FOR FURTHER INFORMATION CONTACT: 

Angela M.W. Newell (202–708–5409), 

Office of Investigations, U.S. 

International Trade Commission, 500 E 

Street, SW., Washington, DC 20436. 

Hearing-impaired persons can obtain 

information on this matter by contacting 

the Commission’s TDD terminal at 202– 

205–1810. Persons with mobility 

impairments who will need special 

assistance in gaining access to the 

Commission should contact the Office 

of the Secretary at 202–205–2000. 

General information concerning the 

Commission may also be obtained by 

accessing its Internet server (http:// 

www.usitc.gov). The public record for 

these reviews may be viewed on the 

Commission’s electronic docket (EDIS) 

at http://edis.usitc.gov 

mstockstill on DSKH9S0YB1PROD with NOTICES

Federal Register / Vol. 75, No. 98 / Friday, May 21, 2010 / Notices 28557 

submission and not considered during 

the selection process. 

Timeframe for Recruitment and 

Applications 

Mission recruitment will be 

conducted in an open and public 

manner, including publication in the 

Federal Register, posting on the 

Commerce Department trade mission 

calendar (www.ita.doc.gov/doctm/ 

tmcal.html) and other Internet Web 

sites, press releases to general and trade 

media, direct mail, notices by industry 

trade associations and other multiplier 

groups, and publicity at industry 

meetings, symposia, conferences, and 

trade shows. Recruitment for the 

mission will begin immediately and 

conclude no later than August 2, 2010. 

Applications received after that date 

will be considered only if space and 

scheduling constraints permit. 

Contacts 

U.S. Commercial Service in Mexico 

City: 

Aliza Totayo, Commercial Officer, T: 

+52 (55) 5140–2635, 

Aliza.Totayo@mail.doc.gov; 

Juan Carlos Prieto, Commercial 

Specialist, T: +52 (55) 5140–2634, 

JuanCarlos.Prieto@mail.doc.gov. 

Natalia Susak, 

Global Trade Programs, Commercial Service 

Trade Missions Program. 

[FR Doc. 2010–12207 Filed 5–20–10; 8:45 am] 

BILLING CODE 3510–FP–P 

DEPARTMENT OF COMMERCE 

International Trade Administration 

[A–549–502)] 

Circular Welded Carbon Steel Pipes 

and Tubes From Thailand: Extension 

of Time Limit for Final Results of 

Antidumping Duty Administrative 

Review 

AGENCY: Import Administration, 

International Trade Administration, 

Department of Commerce. 

DATES: Effective Date: May 21, 2010. 

FOR FURTHER INFORMATION CONTACT: 

Jacqueline Arrowsmith, AD/CVD 

Operations, Office 6, Import 

Administration, International Trade 

Administration, U.S. Department of 

Commerce, 14th Street and Constitution 

Avenue, NW., Washington DC 20230; 

telephone: (202) 482–5255. 

SUPPLEMENTARY INFORMATION: 

Background 

On April 13, 2010, the Department of 

Commerce (the Department) published 

the preliminary results of the 

administrative review of the 

antidumping duty order on circular 

welded carbon steel pipes and tubes 

from Thailand. See Circular Welded 

Carbon Steel Pipes and Tubes from 

Thailand: Preliminary Results and 

Rescission, in Part, of Antidumping 

Duty Administrative Review, 75 FR 

18788 (April 13, 2010) (Preliminary 

Results). This administrative review 

covers the period March 1, 2008 through 

February 28, 2009. This review covers 

one producer/exporter of the subject 

merchandise to the United States, Saha 

Thai Steel Pipe (Public) Company, Ltd. 

Extension of Time Limit for Final 

Results 

Pursuant to section 751(a)(3)(A) of the 

Tariff Act of 1930, as amended (the Act), 

and 19 CFR 351.213(h)(1), the 

Department shall issue final results in 

an administrative review of an 

antidumping duty order within 120 

days after the date on which notice of 

the preliminary results is published in 

the Federal Register. However, if the 

Department determines that it is not 

practicable to complete the review 

within the time limits, section 

751(a)(3)(A) of the Act and 19 CFR 

351.213(h)(2) allow the Department to 

extend the 120-day period up to a 180- 

day period. 

Pursuant to section 751(a)(3)(A) of the 

Act and 19 CFR 351.213(h)(2), we 

determine that it is not practicable to 

complete the results of this review 

within the original time limit. The 

Department requested comments from 

interested parties on the effect, if any, of 

the application of the quarterly cost 

methodology on the Department’s level 

of trade analysis. In particular, the 

Department requested that parties 

comment on whether the quarterly cost 

approach requires an evaluation on a 

quarterly basis of the pattern of price 

differences and how any such 

differences should be analyzed for 

purposes of determining whether a level 

of trade adjustment is warranted. 

Consequently, the Department needs 

additional time to consider comments 

that were filed by the parties and to 

develop an appropriate analytical 

approach. 

In accordance with section 

751(a)(3)(A) of the Act and 19 CFR 

351.213(h)(2), the Department has 

decided to extend the time limit for the 

final results from 120 days to 180 days, 

making the new due date for the final 

results, October 10, 2010. However, 

October 10, 2010 falls on a Sunday, and 

Monday, October 11, 2010 is a federal 

holiday. It is the Department’s longstanding practice to issue a 

determination the next business day 

when the statutory deadline falls on a 

weekend, federal holiday, or any other 

day when the Department is closed. See 

Notice of Clarification: Application of 

‘‘Next Business Day’’ Rule for 

Administrative Determination Deadlines 

Pursuant to the Tariff Act of 1930, As 

Amended, 70 FR 24533 (May 10, 2005). 

Accordingly, the deadline for the 

completion of the final results is now 

October 12, 2010, the first business day 

following the 180-day period. 

This notice is issued and published in 

accordance with sections 751(a)(3)(A) 

and 777(i)(1) of the Act. 

Dated: May 14, 2010. 

John M. Andersen, 

Acting Deputy Assistant Secretary for 

Antidumping and Countervailing Duty 

Operations. 

[FR Doc. 2010–12305 Filed 5–20–10; 8:45 am] 

BILLING CODE 3510–DS–P 

DEPARTMENT OF COMMERCE 

International Trade Administration 

[C–570–946] 

Pre–Stressed Concrete Steel Wire 

Strand from the People’s Republic of 

China: Final Affirmative Countervailing 

Duty Determination 

AGENCY: Import Administration, 

International Trade Administration, 

Department of Commerce. 

SUMMARY: The Department of Commerce 

(the Department) determines that 

countervailable subsidies are being 

provided to producers and exporters of 

pre–stressed concrete steel wire strand 

from the People’s Republic of China (the 

PRC). For information on the estimated 

subsidy rates, see the ‘‘Suspension of 

Liquidation’’ section of this notice. 

EFFECTIVE DATE: May 21, 2010. 

FOR FURTHER INFORMATION CONTACT: 

Robert Copyak, AD/CVD Operations, 

Office 3, Operations, Import 

Administration, U.S. Department of 

Commerce, Room 4014, 14th Street and 

Constitution Avenue, NW, Washington, 

DC 20230; telephone: (202) 482–2209. 

SUPPLEMENTARY INFORMATION: 

Background 

This investigation covers 61 programs 

and the following producers/exporters: 

Fasten Group Import & Export Co., Ltd. 

(Fasten I&E), Fasten Group Corporation 

(Fasten Corp.), Jiangyin Fasten Steel 

(Fasten Steel), Jiangyin Hongyu Metal 

Products Co., Ltd. (Hongyu Metal), 

Jiangyin Walsin Steel Cable Co., Ltd. 

(Walsin) and Jiangyin Hongsheng Co., 

Ltd. (Hongsheng) (collectively, the 


emcdonald on DSK2BSOYB1PROD with NOTICES
28558 Federal Register / Vol. 75, No. 98 / Friday, May 21, 2010 / Notices 

Fasten Companies) and Xinhua Metal 

Products Company (Xinhua), Xinyu Iron 

and Steel Joint Stock Limited Company 

(Xinyu), and Xinyu Iron and Steel 

Limited Liability Company (Xingang) 

(collectively, the Xinhua Companies). 

The petitioners in this investigation are 

American Spring Wire Corp., Insteel 

Wire Products Company, and Sumiden 

Wire Products Corp. (collectively, the 

petitioners). 

Period of Investigation 

The period of investigation (the POI) 

for which we are measuring subsidies is 

January 1, 2008, through December 31, 

2008, which corresponds to the PRC’s 

most recently completed fiscal year. See 

19 CFR 351.204(b)(2). 

Case History 

The following events have occurred 

since the Department announced the 

Preliminary Determination on October 

27, 2009. See Pre–Stressed Concrete 

Steel Wire Strand from the People’s 

Republic of China: Preliminary 

Affirmative Countervailing Duty 

Determination, 74 FR 56756 (November 

2, 2009) (Preliminary Determination). 

From November 3, 2009, through 

December 23, 2009, we issued 

supplemental questionnaires to 

Government of the PRC (the GOC), the 

Fasten Companies, and the Xinhua 

Companies. From November 9, 2009, 

through January 25, 2010, the GOC, the 

Fasten Companies, and the Xinhua 

Companies submitted supplemental 

questionnaire responses. On October 28, 

2009, petitioners requested that the 

Department align the due date of the 

final determination of the 

countervailing duty (CVD) investigation 

with the due date of the final 

determination in the companion 

antidumping (AD) investigation. On 

November 13, 2009, the Department 

aligned the due date of the final 

determination in the CVD investigation 

with the due date of the final 

determination in the AD investigation. 

See Pre–Stressed Concrete Steel Wire 

Strand from the People’s Republic of 

China: Alignment of Final 

Countervailing Duty Determination with 

Final Antidumping Duty Determination, 

74 FR 59960 (November 19, 2009). On 

November 20, 2009, the Xinhua 

Companies submitted a request for a 

public hearing. From November 23, 

2009, through January 22, 2010, we 

issued verification outlines to the Fasten 

Companies, the GOC, and the Xinhua 

Companies. From January 14, 2010, 

through February 3, 2010, verifiers from 

the Department conducted verification 

of the questionnaire responses 

submitted by the Fasten Companies, the 

Xinhua Companies, and the GOC. From 

February 23, 2010, through March 9, 

2010, we issued verification reports for 

the GOC, the Fasten Companies, and the 

Xinhua Companies. On March 16 and 

March 24, interested parties submitted 

their case and rebuttal briefs. On April 

14, 2010, the Department placed on the 

record of the investigation publicly 

available information concerning the 

provision of wire rod for less than 

adequate remuneration (LTAR) program. 

See Memorandum to the File from Eric 

B. Greynolds, Program Manager, Office 

3, Operations (April 14, 2010) (New 

Information Memorandum). On April 21 

and 26, 2010, interested parties 

submitted comments and clarifying 

information concerning the information 

the Department placed on the record. 

As explained in the memorandum 

from the Deputy Assistant Secretary for 

Import Administration, the Department 

has exercised its discretion to toll 

deadlines for the duration of the closure 

of the Federal Government from 

February 5, through February 12, 2010. 

Thus, all deadlines in this segment of 

the proceeding have been extended by 

seven days. The revised deadline for 

this CVD investigation is now May 14, 

2010. See Memorandum to the Record 

from Ronald K Lorentzen, Deputy 

Assistant Secretary for Import 

Administration, regarding ‘‘Tolling of 

Administrative Deadlines As a Result of 

the Government Closure During the 

Recent Snowstorm,’’ dated February 12, 

2010.’’ 

Scope of Investigation 

For purposes of this investigation, PC 

strand is steel wire strand, other than of 

stainless steel, which is suitable for use 

in, but not limited to, pre–stressed 

concrete (both pre–tensioned and post– 

tensioned) applications. The scope of 

this investigation encompasses all types 

and diameters of PC strand whether 

uncoated (uncovered) or coated 

(covered) by any substance, including 

but not limited to, grease, plastic sheath, 

or epoxy. This merchandise includes, 

but is not limited to, PC strand 

produced to the American Society for 

Testing and Materials (ASTM) A–416 

specification, or comparable domestic or 

foreign specifications. PC strand made 

from galvanized wire is excluded from 

the scope if the zinc and/or zinc oxide 

coating meets or exceeds the 0.40 oz./ft2

standard set forth in ASTM–A–475. 

The PC strand subject to this 

investigation is currently classifiable 

under subheadings 7312.10.3010 and 

7312.10.3012 of the Harmonized Tariff 

Schedule of the United States (HTSUS). 

Although the HTSUS subheadings are 

provided for convenience and customs 

purposes, the written description of the 

scope of this investigation is dispositive. 

Injury Test 

Because the PRC is a ‘‘Subsidies 

Agreement Country’’ within the meaning 

of section 701(b) of the Act, the 

International Trade Commission (the 

ITC) is required to determine whether 

imports of the subject merchandise from 

the PRC materially injure, or threaten 

material injury to, a U.S. industry. On 

July 17, 2009, the ITC published its 

preliminary determination finding that 

there is a reasonable indication that an 

industry in the United States is 

materially injured or threatened with 

material injury by reason of imports 

from the PRC of the subject 

merchandise. See Pre–Stressed Concrete 

Steel Wire Strand from China, 

Investigation Nos. 701–TA–464 and 

731–TA–1160 (Preliminary), 74 FR 

34782 (July 17, 2009). 

Analysis of Comments Received 

All issues raised in the case and 

rebuttal briefs by parties to this 

investigation are addressed in the 

Decision Memorandum. Attached to this 

notice as an Appendix is a list of the 

issues that parties raised and to which 

we have responded in the Decision 

Memorandum. Parties can find a 

complete discussion of all issues raised 

in this investigation and the 

corresponding recommendations in this 

public memorandum, which is on file in 

the Department’s Central Records Unit. 

In addition, a complete version of the 

Decision Memorandum can be accessed 

directly on the Internet at http:// 

ia.ita.doc.gov/frn/. The paper copy and 

electronic version of the Decision 

Memorandum are identical in content. 

Suspension of Liquidation 

In accordance with section 

705(c)(1)(B)(i)(I) of the Act, we have 

calculated an individual rate for the 

companies under investigation: the 

Fasten Companies and the Xinhua 

Companies. Sections 703(d) and 

705(c)(5)(A) of the Act state that for 

companies not investigated, we will 

determine an all–others rate by 

weighting the individual company 

subsidy rate of each of the companies 

investigated by each company’s exports 

of the subject merchandise to the United 

States. The all–others rate may not 

include zero and de minimis net 

subsidy rates, or any rates based solely 

on the facts available. 

Notwithstanding the language of 

section 705(c)(1)(B)(i)(I) of the Act, we 

have not calculated the all–others rate 

by weight averaging the rates of the 

Fasten Companies and the Xinhua 


emcdonald on DSK2BSOYB1PROD with NOTICES
Federal Register / Vol. 75, No. 98 / Friday, May 21, 2010 / Notices 28559 

Companies because doing so risks 

disclosure of proprietary information. 

Therefore, for the all–others rate, we 

have calculated a simple average of the 

two responding firms’ rates. 

Producer/Exporter Subsidy Rate 

Fasten Group Corporation (Fasten Corp.), Fasten Group Import & Export Co., Ltd. (Fasten I&E), 

Jiangyin Hongsheng Co. Ltd. (Hongsheng), Jiangyin Fasten Steel (Fasten Steel), Jiangyin 

Hongyu Metal Products Co., Ltd. (Hongyu Metal), and Jiangyin Walsin Steel Cable Co., Ltd. 

(Walsin) (Collectively, the Fasten Companies) .................................................................................. 8.85 percent ad valorem 

Xinhua Metal Products Company (Xinhua), Xinyu Iron and Steel Joint Stock Limited Company 

(Xinyu), and Xinyu Iron and Steel Limited Liability Company (Xingang) (Collectively the Xinhua 

Companies) ........................................................................................................................................ 45.85 percent ad valorem 

All Others ............................................................................................................................................... 27.35 percent ad valorem 

As a result of our Preliminary 

Determination and pursuant to section 

703(d) of the Act, we instructed the U.S. 

Customs and Border Protection (CBP) to 

suspend liquidation of all entries of 

subject merchandise from the PRC 

which were entered or withdrawn from 

warehouse, for consumption on or after 

November 2, 2009, the date of the 

publication of the Preliminary 

Determination in the Federal Register. 

In accordance with sections 703(d) of 

the Act, we issued instructions to CBP 

to discontinue the suspension of 

liquidation for countervailing duty 

purposes for subject merchandise 

entered, or withdrawn from warehouse, 

on or after March 2, 2010, but to 

continue the suspension of liquidation 

of all entries from November 2, 2010, 

through March 1, 2010. 

We will issue a CVD order and 

reinstate the suspension of liquidation 

under section 706(a) of the Act if the 

ITC issues a final affirmative injury 

determination, and will require a cash 

deposit of estimated countervailing 

duties for such entries of merchandise 

in the amounts indicated above. If the 

ITC determines that material injury, or 

threat of material injury, does not exist, 

this proceeding will be terminated and 

all estimated duties deposited or 

securities posted as a result of the 

suspension of liquidation will be 

refunded or canceled. 

ITC Notification 

In accordance with section 705(d) of 

the Act, we will notify the ITC of our 

determination. In addition, we are 

making available to the ITC all non– 

privileged and non–proprietary 

information related to this investigation. 

We will allow the ITC access to all 

privileged and business proprietary 

information in our files, provided the 

ITC confirms that it will not disclose 

such information, either publicly or 

under an APO, without the written 

consent of the Assistant Secretary for 

Import Administration. 

Return or Destruction of Proprietary 

Information 

In the event that the ITC issues a final 

negative injury determination, this 

notice will serve as the only reminder 

to parties subject to an administrative 

protective order (APO) of their 

responsibility concerning the 

destruction of proprietary information 

disclosed under APO in accordance 

with 19 CFR 351.305(a)(3). Timely 

written notification of the return/ 

destruction of APO materials or 

conversion to judicial protective order is 

hereby requested. Failure to comply 

with the regulations and terms of an 

APO is a violation which is subject to 

sanction. 

This determination is published 

pursuant to sections 705(d) and 777(i) of 

the Act. 

Dated: May 14, 2010. 

Ronald K. Lorentzen, 

Deputy Assistant Secretary for Import 

Administration. 

APPENDIX 

List of Comments and Issues in the 

Decision Memorandum 

Comment 1: Whether the Imposition of 

Countervailing Duties on the Same 

Imports that are Subject to Commerce’s 

NME AD Methodology is Contrary to 

Law 

Comment 2: Whether the Simultaneous 

Application of CVD Market Benchmarks 

and the AD Surrogate Value 

Methodology Unlawfully Double– 

Counts the Remedy for Domestic 

Subsidies 

Comment 3: Whether the Department 

May Place the Burden on Respondents 

to ‘‘Prove’’ the Double–Counting of 

Remedies 

Comment 4: Whether the Department’s 

Application of a December 11, 2001 

‘‘Cut–Off’’ Date for Examining Alleged 

Subsidies Is Appropriate 

Comment 5: Whether the GOC Failed to 

Cooperate in Providing Ownership 

Information for Producer A in a Manner 

that Warrants the Application of AFA 

Comment 6: Whether the GOC Failed to 

Cooperate in Providing Ownership 

Information for Producer B in a Manner 

that Warrants the Application of AFA 

Comment 7: Whether Record Evidence 

Demonstrates that Producer A is a GOC 

Authority 

Comment 8: Whether Record Evidence 

Demonstrates that Producer B is a GOC 

Authority 

Comment 9: Whether the GOC Failed to 

Indicate Whether Certain Wire Rod 

Suppliers Were Producers or Trading 

Companies 

Comment 10: Whether SOEs and Firms 

Majority–Owned by the GOC Constitute 

Government Authorities 

Comment 11: Whether Private Resellers 

of Wire Rod Should Be Treated as 

Government Authorities 

Comment 12: Whether the Provision of 

Wire Rod to PC Strand Producers is 

Specific 

Comment 13: Whether the Benchmark 

for the Wire Rod for LTAR Program 

Should Reflect All Delivery Charges, 

Including Shipping and Insurance Costs 

Comment 14: Whether the Department 

Should Include Wire Rod Prices from 

the CRU Monitor and AMM Monitor in 

the LTAR Benchmark 

Comment 15: Whether to Use an In– 

Country Benchmark to Measure Benefits 

Under the Provision of Wire Rod for 

LTAR Program 

Comment 16: Whether Benefits Under 

the Provision of Wire Rod Program 

Should Be Attributed to Sales of Fasten 

I&E and Hongshen 

Comment 17: Whether the Wire Rod 

Sold for LTAR Should be Attributed 

Only to Sales of Wire Rod 

Comment 18: Whether the Department 

Committed a Ministerial Error for the 

Fasten and the Xinhua Companies 

Under the Provision of Wire Rod for 

LTAR Program And Whether the 

Department Should Correct the GOC 

Verification Report for Alleged Errors 


emcdonald on DSK2BSOYB1PROD with NOTICES
28560 Federal Register / Vol. 75, No. 98 / Friday, May 21, 2010 / Notices 

1See Prestressed Concrete Steel Wire Strand 

From the People’s Republic of China: Preliminary 

Determination of Sales at Less Than Fair Value, 74 

FR 68232 (December 23, 2009) (‘‘Preliminary 

Determination’’). 

2Memorandum to the File, from Alexis Polovina, 

Case Analyst, through Alex Villanueva, Program 

Manager, Verification of the Sales and Processing 

Response of Xinhua Metal Products Co., Ltd. in the 

Antidumping Duty Investigation of Prestressed 

Concrete Steel Wire Strand From the People’s 

Republic of China (‘‘PRC’’), dated March 2, 2010 

(‘‘Xinhua Metal Verification Report’’); Memorandum 

to the File, from Alan Ray, Case Analyst, through 

Alex Villanueva, Program Manager, Verification of 

the Sales and Processing Response of Wuxi Jinyang 

Metal Products Co., Ltd. in the Antidumping Duty 

Investigation of Prestressed Concrete Steel Wire 

Strand From the People’s Republic of China 

(‘‘PRC’’), dated March 2, 2010 (‘‘WJMP Verification 

Report’’). 

3American Spring Wire Corp., Insteel Wire 

Products Company, and Sumiden Wire Products 

Corp., (collectively, ‘‘Petitioners’’). 

Comment 19: Whether the Department 

Erred By Including Intra–Company 

Sales in the Denominator Used in the 

Net Subsidy Calculation of the Wire Rod 

for LTAR Program 

Comment 20: The Suitability of the 

Benchmark Used to Calculate Benefits 

Under the Policy Lending Program 

Comment 21: Whether GOC Policy 

Lending Is Specific 

Comment 22: Whether Chinese Banks 

are Government Authorities 

Comment 23: Whether The Department 

Should Apply AFA Available to 

Unverifiable Information Provided by 

Xinhua 

Comment 24: Whether the Department 

Should Investigate the PRC’s Alleged 

Undervaluation of its Currency and 

Find that it Constitutes a 

Countervailable Export Subsidy 

Comment 25:Whether Provision of Land 

by Municipal and Provincial 

Governments to Respondents Was 

Countervailable 

Comment 26:Whether the Provision of 

Electricity Is Not Countervailable 

Because the Program Provides General 

Infrastructure Which Does Not 

Constitute a Financial Contribution, Co 

27, 45 

[FR Doc. 2010–12292 Filed 5–20–10; 8:45 am] 

BILLING CODE 3510–DS–S 

DEPARTMENT OF COMMERCE 

International Trade Administration 

[A–570–945] 

Prestressed Concrete Steel Wire 

Strand From the People’s Republic of 

China: Final Determination of Sales at 

Less Than Fair Value 

AGENCY: Import Administration, 

International Trade Administration, 

Department of Commerce. 

DATES: Effective Date: May 21, 2010. 

SUMMARY: On December 23, 2009, the 

Department of Commerce (the 

‘‘Department’’) published its notice of 

preliminary determination of sales at 

less than fair value (‘‘LTFV’’) in the 

antidumping investigation of 

prestressed concrete steel strand (‘‘PC 

strand’’) from the People’s Republic of 

China (‘‘PRC’’).1 The period of 

investigation (‘‘POI’’) is October 1, 2008, 

through March 31, 2009. We invited 

interested parties to comment on our 

preliminary determination. Based on 

our analysis of the comments received, 

we have made changes to our margin 

calculations for the respondents. We 

determine that PC strand from the PRC 

is being, or is likely to be, sold in the 

United States at LTFV as provided in 

section 735 of the Tariff Act of 1930, as 

amended (‘‘the Act’’). The estimated 

margins of sales at LTFV are shown in 

the ‘‘Final Determination Margins’’ 

section of this notice. 

FOR FURTHER INFORMATION CONTACT: 

Alan Ray or Alexis Polovina, AD/CVD 

Operations, Office 9, Import 

Administration, International Trade 

Administration, U.S. Department of 

Commerce, 14th Street and Constitution 

Avenue, NW., Washington DC 20230; 

telephone: (202) 482–5403 or (202) 482– 

3927, respectively. 

SUPPLEMENTARY INFORMATION: 

Case History 

The Department published its 

Preliminary Determination on December 

23, 2009. Between January 18, 2010, and 

January 27, 2010, the Department 

conducted verifications of Wuxi Jinyang 

Metal Products Co., Ltd. (‘‘WJMP’’) and 

Xinhua Metal Products Co., Ltd. 

(‘‘Xinhua Metal’’). See the ‘‘Verification’’ 

section below for additional 

information. 

Upon the March 2, 2010, release of 

the verification reports,2 we invited 

parties to comment on the Preliminary 

Determination. On March 15, 2010, we 

received case briefs from Petitioners,3

Xinhua Metal, WJMP, and the separaterate applicant Fasten Group Import & 

Export Co. Ltd. (‘‘Fasten I&E’’). On 

March 22, 2010, we received rebuttal 

briefs from Petitioners, Xinhua Metal, 

WJMP, and the Government of China 

(‘‘GOC’’). The Department held the 

public hearing on March 31, 2010. 

Tolling of Administrative Deadlines 

As explained in the memorandum 

from the Deputy Assistant Secretary for 

Import Administration, the Department 

has exercised its discretion to toll 

deadlines for the duration of the closure 

of the Federal Government from 

February 5, through February 12, 2010. 

Thus, all deadlines in this segment of 

the proceeding have been extended by 

seven days. The revised deadline for 

this final determination is now May 14, 

2010. See Memorandum to the Record 

from Ronald Lorentzen, DAS for Import 

Administration, ‘‘Tolling of 

Administrative Deadlines As a Result of 

the Government Closure During the 

Recent Snowstorm,’’ dated February 12, 

2010. 

Analysis of Comments Received 

All issues raised in the case and 

rebuttal briefs by parties to this 

investigation are addressed in the 

‘‘Investigation of Prestressed Concrete 

Steel Strand From the People’s Republic 

of China: Issues and Decision 

Memorandum’’ (‘‘Issues and Decision 

Memorandum’’), dated concurrently 

with this notice and which is hereby 

adopted by this notice. A list of the 

issues which parties raised and to 

which we respond in the Issues and 

Decision Memorandum is attached to 

this notice as Appendix I. The Issues 

and Decision Memorandum is a public 

document and is on file in the Central 

Records Unit (‘‘CRU’’), Room 1117, and 

is accessible on the World Wide Web at 

http://trade.gov/ia/index.asp. The paper 

copy and electronic version of the 

memorandum are identical in content. 

Changes Since the Preliminary 

Determination 

Based on our analysis of information 

on the record of this investigation, we 

have made changes to the margin 

calculations for the final determination. 

For the final determination, we have 

calculated surrogate financial ratios 

using the fiscal year 2008–2009 

financial statements of Rajratan Global 

Wire Ltd. See Issues and Decision 

Memorandum at Comment 1. 

Additionally, unlike in the Preliminary 

Determination, where World Trade 

Atlas (‘‘WTA’’) data was available for 

only the first five months of the POI, for 

the final determination, WTA data 

covering the full POI is available. 

Therefore, for surrogate values 

calculated for the final determination 

derived from WTA data, we have relied 

on WTA data covering the full POI. See 

Memorandum to the File, from Alan 

Ray, Case Analyst, through Alex 

Villanueva, Program Manager, 

Prestressed Concrete Steel Wire Strand 

from the People’s Republic of China: 

Placing Additional Surrogate Value Data 

on the Record, dated January 11, 2010; 

Memorandum to the File from Alexis 

Polovina, Case Analyst, through Alex 


emcdonald on DSK2BSOYB1PROD with NOTICES
Federal Register / Vol. 75, No. 98 / Friday, May 21, 2010 / Notices 28561 

4See Xinhua Metal’s 1st Supplemental D 

Questionnaire response at 5, dated November 2, 

2009. 

Villanueva, Program Manager, AD/CVD 

Operations, Office 9: Prestressed 

Concrete Steel Wire Strand from the 

People’s Republic of China: Surrogate 

Values for the Final Determination, 

dated May 14, 2010 (‘‘Final Surrogate 

Value Memo’’). 

In addition, we have made some 

company-specific changes since the 

Preliminary Determination. Specifically, 

for the final determination, we have 

applied partial facts available to Xinhua 

Metal’s wire rod usage pursuant to 

section 776(a)(2)(D). See Issues and 

Decision Memorandum at Comment 2. 

Regarding WJMP, for the final 

determination, we have decided not to 

value movement expenses between the 

pickling plant and the main factory as 

a factor of production. Additionally, 

lime used by WJMP to neutralize water 

is being considered as part of factory 

overhead. We have revalued the 

surrogate values for steel belt and coal 

consumed by WJMP. See Issues and 

Decision Memorandum at Comment 3. 

Finally, we have applied partial FA to 

WJMP‘s drawbench consumption factor. 

Scope of Investigation 

The scope of this investigation 

consists of PC strand, produced from 

wire of non-stainless, non-galvanized 

steel, which is suitable for use in 

prestressed concrete (both pre-tensioned 

and post-tensioned) applications. The 

product definition encompasses covered 

and uncovered strand and all types, 

grades, and diameters of PC strand. PC 

strand is normally sold in the United 

States in sizes ranging from 0.25 inches 

to 0.70 inches in diameter. PC strand 

made from galvanized wire is only 

excluded from the scope if the zinc and/ 

or zinc oxide coating meets or exceeds 

the 0.40 oz./ft standard set forth in 

ASTM–A–475. The PC strand subject to 

this investigation is currently 

classifiable under subheadings 

7312.10.3010 and 7312.10.3012 of the 

Harmonized Tariff Schedule of the 

United States (‘‘HTSUS’’). Although the 

HTSUS subheadings are provided for 

convenience and customs purposes, the 

written description of the scope of this 

investigation is dispositive. 

Affiliation 

In the Preliminary Determination, the 

Department determined that, based on 

the evidence on the record in this 

investigation including evidence 

presented in WJMP’s questionnaire 

responses, WJMP is affiliated with 

Corus America, Inc. (‘‘CAI’’). CAI was 

involved in WJMP’s sales process 

pursuant to sections 771(33)(E), (F) and 

(G) of the Act, based on ownership and 

common control. See Preliminary 

Determination, 74 FR at 68234–35. 

No other information has been placed 

on the record since the Preliminary 

Determination to contradict the above 

information upon which we based our 

finding that these companies are 

affiliated. Therefore, for the final 

determination, we continue to find that 

WJMP and CAI are affiliated. 

Use of Facts Available 

Section 776(a)(2) of the Act provides 

that if an interested party: (A) 

Withholds information that has been 

requested by the Department; (B) fails to 

provide such information in a timely 

manner or in the form or manner 

requested, subject to subsections 

782(c)(1) and (e) of the Act; (C) 

significantly impedes a determination 

under the antidumping statute; or (D) 

provides such information but the 

information cannot be verified, the 

Department shall, subject to subsection 

782(d) of the Act, use facts otherwise 

available in reaching the applicable 

determination. 

Section 782(c)(1) of the Act provides 

that if an interested party ‘‘promptly 

after receiving a request from {the 

Department} for information, notifies 

{the Department} that such party is 

unable to submit the information in the 

requested form and manner, together 

with a full explanation and suggested 

alternative form in which such party is 

able to submit the information,’’ the 

Department may modify the 

requirements to avoid imposing an 

unreasonable burden on that party. 

Section 782(d) of the Act provides 

that, if the Department determines that 

a response to a request for information 

does not comply with the request, the 

Department will inform the person 

submitting the response of the nature of 

the deficiency and shall, to the extent 

practicable, provide that person the 

opportunity to remedy or explain the 

deficiency. If that person submits 

further information that continues to be 

unsatisfactory, or this information is not 

submitted within the applicable time 

limits, the Department may, subject to 

section 782(e), disregard all or part of 

the original and subsequent responses, 

as appropriate. 

Section 782(e) of the Act states that 

the Department shall not decline to 

consider information deemed ‘‘deficient’’ 

under section 782(d) if: (1) The 

information is submitted by the 

established deadline; (2) the information 

can be verified; (3) the information is 

not so incomplete that it cannot serve as 

a reliable basis for reaching the 

applicable determination; (4) the 

interested party has demonstrated that it 

acted to the best of its ability; and (5) 

the information can be used without 

undue difficulties. 

Furthermore, section 776(b) of the Act 

states that if the administering authority 

finds that an interested party has not 

acted to the best of its ability to comply 

with a request for information, the 

administering authority may, in 

reaching its determination, use an 

inference that is adverse to that party. 

The adverse inference may be based 

upon: (1) The petition, (2) a final 

determination in the investigation under 

this title, (3) any previous review under 

section 751 or determination under 

section 753, or (4) any other information 

placed on the record. 

Xinhua Metal 

Pursuant to sections 776(a)(2)(D) of 

the Act, we are applying partial facts 

otherwise available to Xinhua Metal 

because the Department finds that the 

information necessary to calculate an 

accurate and otherwise reliable margin 

is not available on the record with 

respect to a portion of Xinhua Metal’s 

wire rod usage. On November 2, 2009, 

Xinhua Metal stated in their 

supplemental questionnaire response 

that that ‘‘Xinhua Metal does not weigh 

the wire rod after it has been de-scaled 

and cut. The best demonstration of yield 

loss is the FOP for wire rod.’’ 4 However, 

at verification and after an analysis of 

the actual data reported for wire rod 

usage and subtracting the by-products 

offsets from the wire rod usage rate, the 

wire rod usage rate was less than 1 

kilogram for 1 kilogram of PC strand 

produced by Xinhua Metal. Although 

Xinhua Metal does collect many of its 

wire rod by-products, it is not possible 

to produce 1 kilogram of PC strand from 

less than 1 kilogram of wire rod input. 

Therefore, the information supplied by 

Xinhua Metal could not be verified, and 

we are applying FA, pursuant to 

776(a)(2)(D) of the Act to Xinhua Metal’s 

wire rod usage. 

For the final determination, the 

Department will use a simple average of 

information from the petition and 

WJMP, to add a yield loss to Xinhua 

Metal’s POI wire rod usage. See Issues 

and Decision Memorandum at Comment 

2. 

WJMP 

Pursuant to section 776(a) of the Act, 

we are applying partial facts otherwise 

available to WJMP because the 

Department finds that the information 

necessary to calculate an accurate and 


emcdonald on DSK2BSOYB1PROD with NOTICES
28562 Federal Register / Vol. 75, No. 98 / Friday, May 21, 2010 / Notices 

5See WJMP Verification Report at 2, dated March 

3, 2010. 

6See Memorandum to the File from Alan Ray, 

Case Analyst, through Alex Villanueva, Program 

Manager, Analysis of the Final Determination of the 

Antidumping Duty Investigation of Prestressed 

Concrete Steel Wire Strand (‘‘PC strand’’): Wuxi 

Jinyang Metal Products Co., Ltd. (‘‘WJMP’’), dated 

May 14, 2010. 

otherwise reliable margin is not 

available on the record with respect to 

WJMP’s consumption of drawbench 

factor of production (‘‘FOP’’). At 

verification, the Department found that 

WJMP was consuming drawbench as a 

factor to produce PC strand.5 Because 

WJMP could have reported drawbench, 

as it was used in the same production 

process step as the drawing lubricants, 

a factor that was reported by WJMP, and 

WJMP could have easily identified it by 

reviewing the raw materials account, we 

determine that WJMP did not act to the 

best of its ability and that we will apply 

an adverse inference, pursuant to 

section 776(b) of the Act. As an adverse 

inference, the Department will use the 

highest monthly consumption factor for 

drawing lubricants as the consumption 

factor for drawbench and value 

drawbench using the surrogate value for 

drawing lubricants.6 The Department is 

using drawing lubricants as a surrogate 

factor and value for drawbench because 

it is used in the same stage of the 

production process, which represents 

the best information available on the 

record. 

Verification 

As provided in section 782(i) of the 

Act, we conducted verification of the 

information submitted by WJMP and 

Xinhua Metal for use in our final 

determination. See Xinhua Metal 

Verification Report; WJMP Verification 

Report. We used standard verification 

procedures, including examination of 

relevant accounting and production 

records, as well as original source 

documents provided by Respondents. 

Surrogate Country 

In the Preliminary Determination, we 

stated that we selected India as the 

appropriate surrogate country to use in 

this investigation for the following 

reasons: (1) It is a significant producer 

of comparable merchandise; (2) it is at 

a similar level of economic development 

pursuant to 773(c)(4) of the Act; and (3) 

we have reliable data from India that we 

can use to value the factors of 

production. See Preliminary 

Determination, 74 FR at 68234. For the 

final determination, we received no 

comments and made no changes to our 

findings with respect to the selection of 

a surrogate country. 

Separate Rates 

In proceedings involving non-marketeconomy (‘‘NME’’) countries, the 

Department begins with a rebuttable 

presumption that all companies within 

the country are subject to government 

control and, thus, should be assigned a 

single antidumping duty deposit rate. It 

is the Department’s policy to assign all 

exporters of merchandise subject to an 

investigation in an NME country this 

single rate unless an exporter can 

demonstrate that it is sufficiently 

independent so as to be entitled to a 

separate rate. See Final Determination of 

Sales at Less Than Fair Value: Sparklers 

From the People’s Republic of China, 56 

FR 20588 (May 6, 1991) (‘‘Sparklers’’), as 

amplified by Notice of Final 

Determination of Sales at Less Than 

Fair Value: Silicon Carbide From the 

People’s Republic of China, 59 FR 22585 

(May 2, 1994) (‘‘Silicon Carbide’’), and 

19 CFR 351.107(d). In the Preliminary 

Determination, we found that Xinhua 

Metal, WJMP, and the separate-rate 

applicant, Fasten I&E, demonstrated 

their eligibility for, and were hence 

assigned, separate-rate status. No party 

has commented on the eligibility of 

these companies for separate rate status. 

See Preliminary Determination, 74 FR at 

68235–36. For the final determination, 

we continue to find that the evidence 

placed on the record of this 

investigation by these companies 

demonstrates both a de jure and de facto 

absence of government control with 

respect to their exports of the 

merchandise under investigation. Thus, 

we continue to find that they are eligible 

for separate-rate status. 

As indicated in the Preliminary 

Determination, Liaonin TongDa 

Building Material Industry Co., Ltd. 

(‘‘Tongda’’) did not respond to the 

supplemental questionnaire, Silvery 

Dragon PC Steel Products Group Co., 

Ltd. (‘‘Silvery Dragon Steel’’) stated that 

it would not participate as a mandatory 

respondent, and Tianjin Shengte filed a 

deficient Section A questionnaire and 

failed to respond to the Department’s 

request for more information. See 

Preliminary Determination, 74 FR at 

68240. We preliminarily found that 

Tongda, Silvery Dragon Steel, and 

Tianjin Shengte were not eligible for 

separate rates. For this final 

determination, we continue to find that 

Tongda, Silvery Dragon Steel, and 

Tianjin Shengte are not eligible for 

separate rates. 

The PRC-Wide Rate 

In the Preliminary Determination we 

treated PRC exporters/producers that 

did not respond to the Department’s 

request for information as part of the 

PRC-wide entity because they did not 

demonstrate that they operate free of 

government control. See Preliminary 

Determination, 74 FR at 68236–37. No 

additional information has been placed 

on the record with respect to these 

entities after the Preliminary 

Determination. The PRC-wide entity has 

not provided the Department with the 

requested information; therefore, 

pursuant to section 776(a)(2)(A) of the 

Act, the Department continues to find 

that the use of FA is appropriate to 

determine the PRC-wide rate. Section 

776(b) of the Act provides that, in 

selecting from among the facts 

otherwise available, the Department 

may employ an adverse inference if an 

interested party fails to cooperate by not 

acting to the best of its ability to comply 

with requests for information. See 

Statement of Administrative Action 

accompanying the URAA, H.R. Rep. No. 

103–316, vol. 1, at 870 (1994) (‘‘SAA’’). 

We find that, because the PRC-wide 

entity did not respond to our request for 

information, it has failed to cooperate to 

the best of its ability. Therefore, the 

Department finds that, in selecting from 

among the facts otherwise available, an 

adverse inference is appropriate for the 

PRC-wide entity. Because we begin with 

the presumption that all companies 

within a NME country are subject to 

government control and because only 

the companies listed under the ‘‘Final 

Determination Margins’’ section below 

have overcome that presumption, we are 

applying a single antidumping rate—the 

PRC-wide rate—to all other exporters of 

subject merchandise from the PRC. Such 

companies did not demonstrate 

entitlement to a separate rate. See, e.g., 

Synthetic Indigo From the People’s 

Republic of China: Notice of Final 

Determination of Sales at Less Than 

Fair Value, 65 FR 25706, 25707 (May 3, 

2000). The PRC-wide rate applies to all 

entries of subject merchandise except 

for entries from Xinhua Metal, WJMP, 

and Fasten I&E, which are listed in the 

‘‘Final Determination Margins’’ section 

below. 

Corroboration 

Section 776(c) of the Act provides 

that, when the Department relies on 

secondary information rather than on 

information obtained in the course of an 

investigation as FA, it must, to the 

extent practicable, corroborate that 

information from independent sources 

reasonably at its disposal. Secondary 

information is described in the SAA as 

‘‘information derived from the petition 

that gave rise to the investigation or 

review, the final determination 

concerning subject merchandise, or any 


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Federal Register / Vol. 75, No. 98 / Friday, May 21, 2010 / Notices 28563 

7SAA at 870. 

8 Id. 

9 Id. 

10See Tapered Roller Bearings and Parts Thereof, 

Finished and Unfinished, From Japan, and Tapered 

Roller Bearings, Four Inches or Less in Outside 

Diameter, and Components Thereof, From Japan; 

Preliminary Results of Antidumping Duty 

Administrative Reviews and Partial Termination of 

Administrative Reviews, 61 FR 57391, 57392 

(November 6, 1996), unchanged in Tapered Roller 

Bearings and Parts Thereof, Finished and 

Unfinished, From Japan, and Tapered Roller 

Bearings, Four Inches or Less in Outside Diameter, 

and Components Thereof, From Japan; Final 

Results of Antidumping Duty Administrative 

Reviews and Termination in Part, 62 FR 11825 

(March 13, 1997). 

previous review under section 751 

concerning the subject merchandise.’’ 7

The SAA provides that to ‘‘corroborate’’ 

means simply that the Department will 

satisfy itself that the secondary 

information to be used has probative 

value.8 The SAA also states that 

independent sources used to corroborate 

may include, for example, published 

price lists, official import statistics and 

customs data, and information obtained 

from interested parties during the 

particular investigation.9 To corroborate 

secondary information, the Department 

will, to the extent practicable, examine 

the reliability and relevance of the 

information used.10 As total adverse 

facts available (‘‘AFA’’) the Department 

preliminarily selected the rate of 193.55 

percent from the Petition. In the 

Preliminary Determination, we 

preliminarily found that the rate of 

193.55 percent is corroborated within 

the meaning of section 776(c) of the Act. 

See Preliminary Determination, 74 FR at 

68237. Because no parties commented 

on the selection of the PRC-wide rate, 

we continue to find that the margin of 

193.55 percent has probative value. 

Accordingly, we find that the rate of 

193.55 percent is corroborated within 

the meaning of section 776(c) of the Act. 

Final Determination Margins 

We determine that the following 

percentage weighted-average margins 

exist for the following entities for the 

POI: 

Exporter Producer 

Weighted-average 

margin 

WJMP ............................................................ WJMP .................................................................................................................................. 42.97 

Xinhua Metal ................................................. Xinhua Metal ....................................................................................................................... 175.94 

Fasten I&E .................................................... Jiangyin Fasten Steel Products Co., Ltd., Jiangyin Walsin Steel Cable Co., Ltd. .............

Jiangyin Hongyu Metal Products Co., Ltd. .........................................................................

175.94 

PRC-wide Entity* ........................................... .............................................................................................................................................. 193.55 

*This rate also applies to Tianjin Shengte, Silvery Dragon Steel, and Tongda. 

Disclosure 

We will disclose the calculations 

performed within five days of the date 

of publication of this notice to parties in 

this proceeding in accordance with 19 

CFR 351.224(b). 

Continuation of Suspension of 

Liquidation 

Pursuant to section 735(c)(1)(B) of the 

Act, we will instruct U.S. Customs and 

Border Protection (‘‘CBP’’) to continue to 

suspend liquidation of all entries of 

subject merchandise from the PRC 

entered, or withdrawn from warehouse, 

for consumption on or after December 

23, 2009, the date of publication of the 

Preliminary Determination. CBP shall 

continue to require a cash deposit or the 

posting of a bond equal to the estimated 

amount by which the normal value 

exceeds the U.S. price as shown above. 

These instructions suspending 

liquidation will remain in effect until 

further notice. 

Additionally, the Department 

determined in its final determination for 

the companion countervailing duty 

(‘‘CVD’’) investigation that Xinhua 

Metal’s merchandise benefited from 

export subsidies. Therefore, we will 

instruct CBP to require a cash deposit or 

posting of a bond equal to the weightedaverage amount by which normal value 

exceeds U.S. price for Xinhua Metal, as 

indicated above, minus the amount 

determined to constitute an export 

subsidy. See, e.g., Notice of Final 

Determination of Sales at Less Than 

Fair Value: Carbazole Violet Pigment 23 

from India, 69 FR 67306, 67307 

(November 17, 2004). 

With respect to WJMP, the voluntary 

respondent in this proceeding, the 

Department did not individually 

examine its exports of merchandise 

under investigation in the final 

determination for the companion CVD 

investigation. As a result, WJMP is 

captured under the ‘‘All Others’’ rate, 

which is an average of the companies 

examined in final determination for the 

companion CVD investigation. 

Therefore, we will instruct CBP to 

require a cash deposit or posting of a 

bond equal to the weighted-average 

amount by which normal value exceeds 

U.S. price for WJMP, indicated above, 

minus the amount determined to 

constitute an export subsidy in the ‘‘All 

Others’’ rate. 

With respect to Fasten Group I&E, the 

separate rate company, we note that the 

rate applied in this proceeding as a 

separate rate is derived from the 

calculated rate received by Xinhua 

Metal. Therefore, because Xinhua Metal 

received export subsidies in final 

determination for the companion 

countervailing duty investigation, we 

will instruct CBP to require a cash 

deposit or posting of a bond equal to the 

weighted-average amount by which 

normal value exceeds U.S. price for 

Xinhua Metal, as indicated above, 

minus the amount determined to 

constitute an export subsidy. 

ITC Notification 

In accordance with section 735(d) of 

the Act, we have notified the 

International Trade Commission (‘‘ITC’’) 

of our final determination of sales at 

LTFV. As our final determination is 

affirmative, in accordance with section 

735(b)(2) of the Act, within 45 days the 

ITC will determine whether the 

domestic industry in the United States 

is materially injured, or threatened with 

material injury, by reason of imports or 

sales (or the likelihood of sales) for 

importation of the subject merchandise. 

If the ITC determines that material 

injury or threat of material injury does 

not exist, the proceeding will be 

terminated and all securities posted will 

be refunded or canceled. If the ITC 

determines that such injury does exist, 

the Department will issue an 

antidumping duty order directing CBP 

to assess antidumping duties on all 

imports of the subject merchandise 

entered, or withdrawn from warehouse, 

for consumption on or after the effective 

date of the suspension of liquidation. 

Notification Regarding APO 

This notice also serves as a reminder 

to the parties subject to administrative 


emcdonald on DSK2BSOYB1PROD with NOTICES
28564 Federal Register / Vol. 75, No. 98 / Friday, May 21, 2010 / Notices 

protective order (‘‘APO’’) of their 

responsibility concerning the 

disposition of proprietary information 

disclosed under APO in accordance 

with 19 CFR 351.305. Timely 

notification of return or destruction of 

APO materials or conversion to judicial 

protective order is hereby requested. 

Failure to comply with the regulations 

and the terms of an APO is a 

sanctionable violation. 

This determination and notice are 

issued and published in accordance 

with sections 735(d) and 777(i)(1) of the 

Act. 

Dated: May 14, 2010. 

Ronald K. Lorentzen, 

Deputy Assistant Secretary for Import 

Administration. 

Appendix I 

Comment 1: Surrogate Values 

A. Financial Ratios 

B. Wire Rod 

C. By-product Offset for Scrap Tie Wire 

Comment 2: Xinhua Metal 

A. Adverse Facts Available (‘‘AFA’’) 

B. Foreign Brokerage and Handling 

C. PRC Domestic Insurance 

Comment 3: WJMP 

A. AFA 

B. Treatment of Certain Factors as Factory 

Overhead 

C. Valuation of Coal 

D. Valuation of Seals—Steel Belts 

Comment 4: Fasten Group I&E’s Separate 

Rate 

Comment 5: Surrogate-Value Based 

Methodology 

[FR Doc. 2010–12310 Filed 5–20–10; 8:45 am] 

BILLING CODE 3510–DS–P 

DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric 

Administration 

RIN 0648–XW26 

Fisheries of the Northeast Region; 

Pacific Region 

AGENCY: National Marine Fisheries 

Service (NMFS), National Oceanic and 

Atmospheric Administration (NOAA), 

Commerce. 

ACTION: Notification of determination of 

overfishing or an overfished condition. 

SUMMARY: This action serves as a notice 

that NMFS, on behalf of the Secretary of 

Commerce (Secretary), has determined 

that in the Northeast Region, Gulf of 

Maine/Georges Bank pollock, Gulf of 

Maine/Georges Bank windowpane and 

Northwestern Atlantic Coast witch 

flounder are subject to overfishing and 

are in an overfished condition. Also, in 

the Northeast Region, Southern New 

England/Mid-Atlantic windowpane is 

subject to overfishing and Georges Bank 

winter flounder is in an overfished 

condition. In addition, in the Pacific 

Region, the fall Chinook salmon stock in 

the Sacramento River has been 

determined to be in an overfished 

condition. 

NMFS notifies the appropriate fishery 

management council (Council) 

whenever it determines that; overfishing 

is occurring, a stock is in an overfished 

condition, or a stock is approaching an 

overfished condition. If a Council has 

been notified that a stock is in an 

overfished condition the Council must, 

within 2 years, prepare and implement 

an FMP amendment or proposed 

regulations to rebuild the affected stock. 

FOR FURTHER INFORMATION CONTACT: 

Mark Nelson, (301) 713–2341. 

SUPPLEMENTARY INFORMATION: Pursuant 

to sections 304(e)(2) and (e)(7) of the 

Magnuson-Stevens Fishery 

Conservation and Management Act 

(Magnuson-Stevens Act), 16 U.S.C. 

1854(e)(2) and (e)(7), and implementing 

regulations at 50 CFR 600.310(e)(2), 

NMFS, on behalf of the Secretary, 

notifies Councils whenever it 

determines; a stock or stock complex is 

approaching an overfished condition, a 

stock or stock complex is overfished, or 

existing action taken to prevent 

previously identified overfishing or 

rebuilding a previously identified 

overfished stock or stock complex has 

not resulted in adequate progress. 

NMFS also notifies Councils when it 

determines a stock or stock complex is 

subject to overfishing. 

For a fishery determined to be 

overfished or approaching an overfished 

condition, NMFS also requests that the 

appropriate Council, or the Secretary, 

for fisheries under section 302(a)(3) of 

the Magnuson-Stevens Act, take action 

to end or prevent overfishing in the 

fishery and to implement conservation 

and management measures to rebuild 

overfished stocks. Councils (or the 

Secretary) receiving notification that a 

fishery is overfished must, within 2 

years of notification, implement a 

rebuilding plan, through an FMP 

Amendment or proposed regulations, 

which ends overfishing immediately 

and provides for rebuilding the fishery 

in accordance with 16 U.S.C. 1854(e)(3)- 

(4) as implemented by 50 CFR 

600.310(j)(2)(ii). Councils receiving a 

notice that a fishery is approaching an 

overfished condition must prepare and 

implement, within two years, an FMP 

amendment or proposed regulations to 

prevent overfishing from occurring. 

When developing rebuilding plans 

Councils (or the Secretary), in addition 

to rebuilding the fishery within the 

shortest time possible in accordance 

with 16 U.S.C. 1854(e)(4) and 50 CFR 

600.310(j)(2)(ii), must ensure that such 

actions address the requirements to 

amend the FMP for each affected stock 

or stock complex to establish a 

mechanism for specifying and actually 

specify Annual Catch Limits (ACLs) and 

Accountability Measures (AMs) to 

prevent overfishing in accordance with 

16 U.S.C. 1853(a)(15) and 50 CFR 

600.310(j)(2)(i). 

On August 4, 2008, NMFS published 

the Report of the 3rd Groundfish 

Assessment Review Meeting (GARM III) 

which showed that Gulf of Maine/ 

Georges Bank pollock, Gulf of Maine/ 

Georges Bank windowpane and 

Northwestern Atlantic Coast witch 

flounder are subject to overfishing and 

are in an overfished condition. In 

addition, GARM III showed that 

Southern New England/Mid-Atlantic 

windowpane is subject to overfishing 

and Georges Bank winter flounder is in 

an overfished condition. The New 

England Fishery Management Council 

(NEFMC) was notified on September 2, 

2008, of the results of the GARM III. 

However, official status changes could 

not be made at the time because GARM 

III also recommended changes in the 

status determination criteria (SDC) 

contained in the Multispecies FMP, 

which required an FMP amendment 

before the status determinations could 

be changed. These changes occurred in 

January 2010. 

On March 2, 2010, NMFS informed 

the Pacific Fisheries Management 

Council that the Sacramento River Fall 

Chinook salmon stock failed to meet the 

escapement goal for the third 

consecutive year, which has triggered an 

overfished status determination. 

As noted above, within 2 years of 

notification of an overfished 

determination, the respective Council 

(or the Secretary) must adopt and 

implement a rebuilding plan, through 

an FMP Amendment or proposed 

implementing regulations, which ends 

overfishing immediately and provides 

for rebuilding of the stock. In addition, 

for the fisheries experiencing 

overfishing, the responsible Councils 

must propose, and NMFS must adopt, 

effective ACLs and AMs to end 

overfishing. 

Dated: May 14, 2010. 

Emily H. Menashes, 

Acting Director, Office of Sustainable 

Fisheries, National Marine Fisheries Service. 

[FR Doc. 2010–12282 Filed 5–20–10; 8:45 am] 

BILLING CODE 3510–22–S 


emcdonald on DSK2BSOYB1PROD with NOTICES
 
APPENDIX B

HEARING CALENDAR

B-1

CALENDAR OF PUBLIC HEARING

Those listed below appeared as witnesses at the United States International Trade

Commission’s hearing:

Subject: Prestressed Concrete Steel Wire Strand from China

Inv. Nos.: 701-TA-464 and 731-TA-1160 (Final)

Date and Time: May 6, 2010 - 9:30 a.m.

Sessions were held in connection with these investigations in the Main Hearing Room

(room 101), 500 E Street, S.W., Washington, D.C.

OPENING REMARKS:

Petitioners (Paul C. Rosenthal, Kelley Drye & Warren LLP)

In Support of the Imposition of

 Antidumping and Countervailing Duty Orders:

Kelley Drye & Warren LLP

Washington, D.C.

on behalf of

Petitioners

Howard Woltz, III, President and CEO, Insteel Wire Products Co.

Timothy Selhorst, President and CEO, American Spring Wire Corp.

Jon Cornelius, General Manager, PC Strand Division, Sumiden Wire Products Corp.

Timothy Johnson, Chief Operating Officer, Suncoast Post-Tension Ltd.

B-3
In Support of the Imposition of

 Antidumping and Countervailing Duty Orders (continued):

Jeff Feitler, Vice President of Sales and Marketing, Sumiden Wire Products Corp.

Joseph Napoli, Products Sales Manager, American Spring Wire Corp.

Richard Wagner, Vice President and General Manager, Insteel Wire Products Co.

Gina Beck, Economic Consultant, Georgetown Economic Consulting Services

Paul C. Rosenthal )

Kathleen W. Cannon ) – OF COUNSEL

R. Alan Luberda )

CLOSING REMARKS:

Petitioners (Kathleen W. Cannon, Kelley Drye & Warren LLP)

B-4
APPENDIX C

SUMMARY DATA

C-1
C-2
Table C-1

PC strand: Summary data concerning the U.S. market, 2007-09

(Quantity=1,000 pounds, value=1,000 dollars, unit values, unit labor costs, and unit expenses are per 1,000 pounds;

(period changes=percent, except where noted)

Reported data Period changes

Item 2007 2008 2009 2007-09 2007-08 2008-09

U.S. consumption quantity:

 Amount . . . . . . . . . . . . . . . . . . . 980,503 942,714 508,605 -48.1 -3.9 -46.0

 Producers' share (1) . . . . . . . . . 59.4 56.2 78.0 18.5 -3.2 21.7

 Importers' share (1):

 China . . . . . . . . . . . . . . . . . . . . 36.1 40.5 7.2 -28.9 4.4 -33.3

 All other countries . . . . . . . . . . 4.5 3.3 14.8 10.4 -1.2 11.5

 Total imports . . . . . . . . . . . . . 40.6 43.8 22.0 -18.5 3.2 -21.7

U.S. consumption value:

 Amount . . . . . . . . . . . . . . . . . . . 407,169 549,768 248,738 -38.9 35.0 -54.8

 Producers' share (1) . . . . . . . . . 65.9 60.7 80.2 14.3 -5.2 19.5

 Importers' share (1):

 China . . . . . . . . . . . . . . . . . . . . 28.5 35.3 5.6 -22.9 6.9 -29.8

 All other countries . . . . . . . . . . 5.6 4.0 14.2 8.6 -1.7 10.3

 Total imports . . . . . . . . . . . . . 34.1 39.3 19.8 -14.3 5.2 -19.5

U.S. imports (2) from:

 China:

 Quantity . . . . . . . . . . . . . . . . . . 353,937 381,652 36,591 -89.7 7.8 -90.4

 Value . . . . . . . . . . . . . . . . . . . . 115,843 194,276 13,816 -88.1 67.7 -92.9

 Unit value . . . . . . . . . . . . . . . . . $327 $509 $378 15.4 55.5 -25.8

 Ending inventory quantity . . . . 31,725 51,461 15,019 -52.7 62.2 -70.8

 All other countries:

 Quantity . . . . . . . . . . . . . . . . . . 43,766 31,089 75,515 72.5 -29.0 142.9

 Value . . . . . . . . . . . . . . . . . . . . 22,982 21,771 35,375 53.9 -5.3 62.5

 Unit value . . . . . . . . . . . . . . . . . $525 $700 $468 -10.8 33.4 -33.1

 Ending inventory quantity . . . . *** *** *** *** *** ***

 All sources:

 Quantity . . . . . . . . . . . . . . . . . . 397,703 412,741 112,107 -71.8 3.8 -72.8

 Value . . . . . . . . . . . . . . . . . . . . 138,825 216,047 49,191 -64.6 55.6 -77.2

 Unit value . . . . . . . . . . . . . . . . . $349 $523 $439 25.7 50.0 -16.2

 Ending inventory quantity . . . . *** *** *** *** *** ***

U.S. producers':

 Average capacity quantity . . . . . 902,782 903,795 903,795 0.1 0.1 0.0

 Production quantity . . . . . . . . . . 601,717 558,885 395,658 -34.2 -7.1 -29.2

 Capacity utilization (1) . . . . . . . . 66.7 61.8 43.8 -22.9 -4.8 -18.1

 U.S. shipments:

 Quantity . . . . . . . . . . . . . . . . . . 582,800 529,973 396,498 -32.0 -9.1 -25.2

 Value . . . . . . . . . . . . . . . . . . . . 268,344 333,721 199,547 -25.6 24.4 -40.2

 Unit value . . . . . . . . . . . . . . . . . $460 $630 $503 9.3 36.8 -20.1

 Export shipments:

 Quantity . . . . . . . . . . . . . . . . . . *** *** *** *** *** ***

 Value . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** ***

 Unit value . . . . . . . . . . . . . . . . . *** *** *** *** *** ***

 Ending inventory quantity . . . . . 61,262 67,081 57,644 -5.9 9.5 -14.1

 Inventories/total shipments (1) . . *** *** *** *** *** ***

 Production workers . . . . . . . . . . 357 331 258 -27.7 -7.3 -22.1

 Hours worked (1,000s) . . . . . . . 771 715 555 -28.0 -7.3 -22.3

 Wages paid ($1,000s) . . . . . . . . 14,145 13,264 10,907 -22.9 -6.2 -17.8

 Hourly wages . . . . . . . . . . . . . . . $18.34 $18.56 $19.64 7.1 1.2 5.8

 Productivity (pounds per hour) . . 780.1 781.9 712.5 -8.7 0.2 -8.9

 Unit labor costs . . . . . . . . . . . . . $23.51 $23.73 $27.57 17.3 1.0 16.2

 Net sales:

 Quantity . . . . . . . . . . . . . . . . . . 613,704 589,793 389,834 -36.5 -3.9 -33.9

 Value . . . . . . . . . . . . . . . . . . . . 283,088 354,082 210,951 -25.5 25.1 -40.4

 Unit value . . . . . . . . . . . . . . . . . $461 $600 $541 17.3 30.1 -9.9

 Cost of goods sold (COGS) . . . . 230,394 302,334 201,246 -12.7 31.2 -33.4

 Gross profit or (loss) . . . . . . . . . 52,694 51,748 9,705 -81.6 -1.8 -81.2

 SG&A expenses . . . . . . . . . . . . 13,317 13,795 13,437 0.9 3.6 -2.6

 Operating income or (loss) . . . . 39,377 37,953 (3,732) (3) -3.6 (3)

 Capital expenditures . . . . . . . . . *** *** *** *** *** ***

 Unit COGS . . . . . . . . . . . . . . . . . $375 $513 $516 37.5 36.5 0.7

 Unit SG&A expenses . . . . . . . . . $22 $23 $34 58.8 7.8 47.4

 Unit operating income or (loss) . $64 $64 ($10) (3) 0.3 (3)

 COGS/sales (1) . . . . . . . . . . . . . 81.4 85.4 95.4 14.0 4.0 10.0

 Operating income or (loss)/

 sales (1) . . . . . . . . . . . . . . . . . . 13.9 10.7 (1.8) -15.7 -3.2 -12.5

 (1) "Reported data" are in percent and "period changes" are in percentage points.

 (2) Import quantities and values compiled from official Commerce statistics.

 (3) Not meaningful.

Note.--Financial data are reported on a fiscal year basis and may not necessarily be comparable to data reported on a calendar year b

Because of rounding, figures may not add to the totals shown. Unit values and shares are calculated from the unrounded figures.

Source: Compiled from data submitted in response to Commission questionnaires and from official Commerce statistics.

C-3
Table C-2

PC strand: U.S. shipments of domestic product, U.S. shipments of imported product, total consumption

and shares, by sources and by applications, 2007-09

Item

Calendar year

2007 2008 2009

Pre-tensioned applications

Quantity (1,000 pounds)

U.S. producers’ U.S. shipments:

Subject to “Buy America(n)” restrictions *** *** ***

Not subject to “Buy America(n)” restrictions *** *** ***

Total, U.S. producers’ U.S. shipments *** *** ***

U.S. importers’ U.S. shipments:

China *** *** ***

Nonsubject countries *** *** ***

All countries *** *** ***

Total *** *** ***

Share of quantity (percent)

U.S. producers’ U.S. shipments:

Subject to “Buy America(n)” restrictions 51.5 55.7 65.2

Not subject to “Buy America(n)” restrictions 37.4 34.9 30.6

Total, U.S. producers’ U.S. shipments 88.9 90.6 95.8

U.S. importers’ U.S. shipments:

China 10.1 8.5 2.0

Nonsubject countries 0.9 0.9 2.2

All countries 11.1 9.4 4.2

Total 100.0 100.0 100.0

Table continued on following page.

C-4
Table C-2--Continued

PC strand: U.S. shipments of domestic product, U.S. shipments of imported product, total consumption

and shares, by sources and by applications, 2007-09

Item

Calendar year

2007 2008 2009

Post-tensioned applications

Quantity (1,000 pounds)

U.S. producers’ U.S. shipments:

Subject to “Buy America(n)” restrictions *** *** ***

Not subject to “Buy America(n)” restrictions *** *** ***

Total, U.S. producers’ U.S. shipments *** *** ***

U.S. importers’ U.S. shipments:

China *** *** ***

Nonsubject countries *** *** ***

All countries *** *** ***

Total *** *** ***

Share of quantity (percent)

U.S. producers’ U.S. shipments:

Subject to “Buy America(n)” restrictions 4.9 9.5 15.4

Not subject to “Buy America(n)” restrictions 17.5 13.8 21.7

Total, U.S. producers’ U.S. shipments 22.4 23.3 37.1

U.S. importers’ U.S. shipments:

China 74.1 73.6 42.1

Nonsubject countries 3.6 3.1 20.8

All countries 77.6 76.7 62.9

Total 100.0 100.0 100.0

Table continued on following page.

C-5
Table C-2--Continued

PC strand: U.S. shipments of domestic product, U.S. shipments of imported product, total consumption

and shares, by sources and by applications, 2007-09

Item

Calendar year

2007 2008 2009

Total

Quantity (1,000 pounds)

U.S. producers’ U.S. shipments:

Subject to “Buy America(n)” restrictions *** *** ***

Not subject to “Buy America(n)” restrictions *** *** ***

Total, U.S. producers’ U.S. shipments *** *** ***

U.S. importers’ U.S. shipments:

China *** *** ***

Nonsubject countries *** *** ***

All countries *** *** ***

Total *** *** ***

Share of quantity (percent)

U.S. producers’ U.S. shipments:

Subject to “Buy America(n)” restrictions 28.6 33.9 49.5

Not subject to “Buy America(n)” restrictions 33.6 28.9 30.0

Total, U.S. producers’ U.S. shipments 62.3 62.9 79.6

U.S. importers’ U.S. shipments:

China 35.7 35.4 13.1

Nonsubject countries 2.0 1.8 7.3

All countries 37.7 37.1 20.4

Total 100.0 100.0 100.0

Note.--Total consumption data presented in this table do not equal total apparent U.S. consumption data presented elsewhere in this

report due to inconsistencies reported by domestic producers within individual questionnaire responses and because apparent

consumption presented elsewhere was calculated using official import statistics rather than questionnaire responses.

Source: Compiled from data submitted in response to Commission questionnaires.

C-6
D-1

APPENDIX D

NONSUBJECT COUNTRY AND AGGREGATED PRICE DATA

 1

 Figure D-1 only includes price data for country data series that include three or more data points.

D-3

Nonsubject Price Comparisons

Reported prices for imported Malaysian products 1 and 2 were higher than prices for U.S.-

produced and imported Chinese products 1 and 2 in all four instances. Prices for the two products from

Spain were generally lower than prices for the corresponding domestic products but generally higher than 

prices for the corresponding Chinese products. Imported Canadian product 2 was priced lower than both

the domestic and imported Chinese product 2 in the one available comparison. Prices for the two

products from Taiwan were generally lower than prices for the corresponding domestic products, but

were always above the prices for the corresponding Chinese products. Prices for product 1 from the

Netherlands were always higher than prices for both the domestic and imported Chinese product 1. Prices

for both products from South Africa were generally lower than prices for the corresponding domestic

products, but were generally higher than prices for the corresponding imported Chinese products (table D1). Price data for U.S.-produced, imported Chinese, and imported nonsubject products 1 and 2 are shown

in figure D-1.1

Table D-1

PC strand: Number of quarterly price comparisons of imported nonsubject and U.S. products 1

and 2, and of imported nonsubject and Chinese products 1 and 2

Nonsubject

Countries

United States China

Higher1 Lower Higher1 Lower

Canada 0101

Malaysia 4 0 4 0

Netherlands 3030

South Africa 4 10 11 3

Spain 1 4 3 2

Taiwan 1 2 3 0

Total 13 17 24 6

 1 “Higher” signifies that the price of the nonsubject country’s product was higher than the U.S. or Chinese price. 

Source: Compiled from data submitted in response to Commission questionnaires. 

Figure D-1

PC strand: Weighted-average prices and quantities of domestic and imported products 1 and 2, by

quarters, 2007-09

* * * * * * *
D-4

Table D-2

PC strand: Weighted-average f.o.b. prices and quantities of domestic and imported products 1 and

2 (combined) and margins of underselling/(overselling), by quarters, January 2007-December 2009

United States China

Price 

(per lineal foot)

Quantity

(1,000 lineal feet)

Price 

(per lineal foot)

Quantity

(1,000 lineal feet)

Margin

(percent)

2007:

 Jan.-Mar. $231 149,188 $188 127,521 18.8

 Apr.-June 227 173,722 *** *** ***

 July-Sept. 225 156,753 *** *** ***

 Oct.-Dec. 227 149,883 *** *** ***

2008:

 Jan.-Mar. 244 175,261 *** *** ***

 Apr.-June 339 161,782 *** *** ***

 July-Sept. 409 118,101 *** *** ***

 Oct.-Dec. 370 62,585 *** *** ***

2009:

 Jan.-Mar. *** *** *** *** ***

 Apr.-June 260 103,856 *** *** ***

 July-Sept. 244 110,973 *** *** ***

 Oct.-Dec. 250 112,052 *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires.