U.S. International Trade Commission

Publication 4445 January 2014

Washington, DC 20436

Hot-Rolled Steel Products from 

China, India, Indonesia, 

Taiwan, Thailand, and Ukraine

Investigation Nos. 701-TA-405, 406, and 408 & 

731-TA-899-901 and 906-908 (Second Review)
U.S. International Trade Commission

COMMISSIONERS 

 

Irving A. Williamson, Chairman 

Shara L. Aranoff 

Dean A. Pinkert 

David S. Johanson 

Meredith M. Broadbent 

F. Scott Kieff

Robert B. Koopman

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Director of Operations

Nathanael Comly, Investigator 

Karen Taylor, Industry Analyst 

Craig Thomsen, Economist 

Charles Yost, Accountant 

Jennifer Brinckhaus, Statistician 

Darlene Smith, Statistical Assistant 

Robin Turner, Attorney 

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

Washington, DC 20436 

www.usitc.gov

Publication 4445 January 2014

Hot-Rolled Steel Products from 

China, India, Indonesia, 

Taiwan, Thailand, and Ukraine

Investigation Nos. 701-TA-405, 406, and 408 & 

731-TA-899-901 and 906-908 (Second Review)

  

CONTENTS

Page

i

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

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

Separate and dissenting views of Commissioners Meredith M. Broadbent and F. Scott Kieff 53

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

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

The original investigations..................................................................................................... I‐2

Subsequent five‐year reviews............................................................................................... I‐4

Summary data ........................................................................................................................... I‐5

Related investigations............................................................................................................. I‐10

Previous and related Title VII investigations....................................................................... I‐10

Previous and related safeguard investigations................................................................... I‐13

Statutory criteria and organization of the report................................................................... I‐14

Statutory criteria ................................................................................................................. I‐14

Organization of the report .................................................................................................. I‐16

Commerce’s reviews............................................................................................................... I‐17

Administrative reviews........................................................................................................ I‐17

Changed circumstances review........................................................................................... I‐19

Five‐year reviews................................................................................................................. I‐20

The subject merchandise ........................................................................................................ I‐23

Commerce’s scope .............................................................................................................. I‐23

Tariff treatment................................................................................................................... I‐25

The product............................................................................................................................. I‐25

Description and applications............................................................................................... I‐25

Manufacturing processes.................................................................................................... I‐27

Domestic like product issues................................................................................................... I‐32
  

CONTENTS

Page

ii

Part I: Introduction‐‐Continued..................................................................................................

U.S. market participants.......................................................................................................... I‐32

U.S. producers..................................................................................................................... I‐32

U.S. importers...................................................................................................................... I‐38

U.S. purchasers.................................................................................................................... I‐40

Apparent U.S. consumption .................................................................................................... I‐40

U.S. market shares .................................................................................................................. I‐42

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

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

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

Supply and demand considerations......................................................................................... II‐4

Supply ................................................................................................................................... II‐4

Demand .............................................................................................................................. II‐10

Substitutability issues............................................................................................................. II‐17

Purchaser characteristics.................................................................................................... II‐17

Knowledge of country sources........................................................................................... II‐18

Factors affecting purchasing decisions............................................................................... II‐19

Comparisons of domestic products, subject imports, and nonsubject imports................ II‐23

Elasticity estimates................................................................................................................. II‐30

U.S. supply elasticity........................................................................................................... II‐30

U.S. demand elasticity ........................................................................................................ II‐30

Substitution elasticity ......................................................................................................... II‐30

Part III: Condition of the U.S. industry ................................................................................. III‐1

Overview ................................................................................................................................. III‐1

Background.......................................................................................................................... III‐3

Changes experienced by the industry ................................................................................. III‐4

Anticipated changes in operations...................................................................................... III‐4
  

CONTENTS

Page

iii

Part III: Condition of the U.S. industry‐‐Continued.....................................................................

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

Constraints on capacity ....................................................................................................... III‐5

Alternative and downstream products............................................................................... III‐6

U.S. producers’ U.S. shipments and exports........................................................................... III‐8

U.S. producers’ inventories................................................................................................... III‐10

U.S. producers’ imports and purchases................................................................................ III‐11

U.S. employment, wages, and productivity .......................................................................... III‐12

Financial experience of U.S. producers..................................................................................... 13

Background............................................................................................................................ 13

Operations on hot‐rolled steel .............................................................................................. 13

Variance analysis................................................................................................................... 19

Capital expenditures and research and development expenses.......................................... 21

Assets and return on investment.......................................................................................... 22

Part IV: U.S. imports and the foreign industries...................................................................IV‐1

U.S. imports............................................................................................................................. IV‐1

Overview.............................................................................................................................. IV‐1

Imports from subject and nonsubject countries.................................................................IV‐2

Leading nonsubject sources of imports ..............................................................................IV‐5

U.S. importers’ imports subsequent to June 30, 2013 ...........................................................IV‐7

U.S. importers’ inventories .....................................................................................................IV‐7

Cumulation considerations .....................................................................................................IV‐8

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

Presence in the market .....................................................................................................IV‐10

The subject foreign industries...............................................................................................IV‐11

The industry in China.............................................................................................................IV‐12

Overview............................................................................................................................IV‐12
  

CONTENTS

Page

iv

Part IV: U.S. imports and the foreign industries‐‐Continued ......................................................

The industry in India..............................................................................................................IV‐16

Overview............................................................................................................................IV‐16

Operations on hot‐rolled steel ..........................................................................................IV‐19

Alternative and downstream products.............................................................................IV‐20

The industry in Indonesia......................................................................................................IV‐20

Overview............................................................................................................................IV‐20

The industry in Taiwan ..........................................................................................................IV‐24

Overview............................................................................................................................IV‐24

Operations on hot‐rolled steel ..........................................................................................IV‐28

Alternative and downstream products.............................................................................IV‐29

The industry in Thailand........................................................................................................IV‐29

Overview............................................................................................................................IV‐29

Operations on hot‐rolled steel ..........................................................................................IV‐33

Alternative and downstream products.............................................................................IV‐34

The industry in Ukraine .........................................................................................................IV‐34

Overview............................................................................................................................IV‐34

Global market........................................................................................................................IV‐38

Production .........................................................................................................................IV‐38

Consumption .....................................................................................................................IV‐38

Prices .................................................................................................................................IV‐39

Additional global supply and demand factors...................................................................IV‐40
  

CONTENTS

Page

v

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

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

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

Transportation costs to the United States...........................................................................V‐5

U.S. inland transportation costs...........................................................................................V‐6

Pricing practices .......................................................................................................................V‐6

Pricing methods....................................................................................................................V‐6

Sales terms and discounts....................................................................................................V‐8

Price data..................................................................................................................................V‐8

Price trends.........................................................................................................................V‐15

Price comparisons ..............................................................................................................V‐17

Appendixes

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

B. Hearing witnesses............................................................................................................. B‐1

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

D. Responses of U.S. processors, U.S. importers, U.S. purchasers, and foreign producers

concerning significance of the AD/CVD orders and the likely affects of revocation........D‐1

E. Hot‐rolled steel: Results of operations of U.S. producers (valuation of internal

consumption and transfers to related firms based on cost plus downstream profit) ......E‐1

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

be published and therefore has been deleted.  Such deletions are indicated by asterisks.

UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation Nos. 701‐TA‐405, 406, and 408 and 731‐TA‐899‐901 and 906‐908 (Second Review)

HOT‐ROLLED STEEL PRODUCTS FROM CHINA, INDIA, INDONESIA, TAIWAN, THAILAND, AND

UKRAINE

DETERMINATION

On the basis of the record1 developed in the subject five‐year reviews, the United

States International Trade Commission (Commission) determines, pursuant to section 751(c) of

the Tariff Act of 1930 (19 U.S.C. ' 1675(c)), that revocation of the countervailing duty orders on

hot‐rolled steel products from India, Indonesia, and Thailand and the antidumping duty orders

on hot‐rolled steel products from China, India, Indonesia, Taiwan, Thailand, and Ukraine would

be likely to lead to continuation or recurrence of material injury to an industry in the United

States within a reasonably foreseeable time. 2

BACKGROUND

The Commission instituted these reviews on November 1, 2012 (77 F.R. 66078) and

determined on February 4, 2013 that it would conduct full reviews (78 F.R. 11901, February 20,

2013).    Notice of the scheduling of the Commission=s reviews 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 on April 16, 2013 (78 F.R. 24435, April 25, 2013) and revised on October

21, 2013 (78 F.R. 64008, October 25, 2013).    The hearing was held in Washington, DC, on

October 31, 2013, 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)).

2 Commissioners Meredith M. Broadbent and F. Scott Kieff dissent with respect to the

determinations regarding hot‐rolled steel products from Indonesia.

 

3

Views of the Commission

Based on the record in these five‐year reviews, we determine under section 751(c) of

the Tariff Act of 1930, as amended (“the Tariff Act”), that revocation of the countervailing duty

orders on hot‐rolled steel products (“hot‐rolled steel”) from India, Indonesia, and Thailand and

the antidumping duty orders on hot‐rolled steel from China, India, Indonesia, Taiwan, Thailand,

and Ukraine would be likely to lead to continuation or recurrence of material injury to an

industry in the United States within a reasonably foreseeable time.1 2

I. Background

Original Investigations:  In August and November 2001, the Commission unanimously

determined that an industry in the United States was materially injured by reason of subsidized

imports of hot‐rolled steel from Argentina, India, Indonesia, South Africa, and Thailand, and by

reason of less than fair value imports of hot‐rolled steel from Argentina, China, India, Indonesia,

Kazakhstan, the Netherlands, Romania, South Africa, Taiwan, Thailand, and Ukraine.  The

Commission’s original final determinations in 2001 were based on petitions filed on the same

day involving dumped and subsidized imports of hot‐rolled steel from eleven countries.3    

Sixteen antidumping and countervailing duty orders were issued by the Department of

Commerce (“Commerce”) on various dates in September, November, and December 2001.4

First reviews:  On August 1, 2006, the Commission instituted the first five‐year reviews

concerning hot‐rolled steel products from Argentina, China, India, Indonesia, Kazakhstan, the

Netherlands, Romania, South Africa, Taiwan, Thailand, and Ukraine.5

  It conducted full reviews

based on adequate domestic interested party group response and the adequate respondent

interested party group responses with respect to the reviews on subject imports from

                                                       

1 Commissioner Shara L. Aranoff did not participate in the determinations concerning these

reviews.2 Commissioners Meredith M. Broadbent and F. Scott Kieff determine that revocation of the

countervailing duty order and the antidumping duty order on hot‐rolled steel from Indonesia would not

be likely to lead to continuation or recurrence of material injury to an industry in the United States

within a reasonably foreseeable time.  See Separate and Dissenting Views of Commissioners Meredith

M. Broadbent and F. Scott Kieff.  They join these views except as noted.

3 See Hot‐Rolled Steel Products from Argentina and South Africa, Inv. Nos. 701‐TA‐404 and 731‐

TA‐ 898 and 905 (Final), USITC Pub. 3446 (August 2001) and Hot‐Rolled Steel Products from China, India,

Indonesia, Kazakhstan, the Netherlands, Romania, South Africa, Taiwan, Thailand, and Ukraine, Inv. Nos.

701‐TA‐ 405‐408 and 731‐TA‐899‐904 and 906‐908 (Final), USITC Pub. 3468 (November 2001)

(collectively referred to as “Original Determinations”). 4 66 Fed. Reg. 47173 (Sept. 11, 2001) (Argentina CVD); 66 Fed. Reg. 48242 (Sept. 19, 2001)

(Argentina and South Africa AD); 66 Fed. Reg. 58435 (Nov. 21, 2001) (Kazakhstan AD); 66 Fed. Reg.

59559, 59561 ‐ 59566 (Nov. 29, 2001) (China, the Netherlands, Romania, Taiwan, Thailand, and Ukraine

AD); 66 Fed. Reg. 60192 and 60194 (Dec. 3, 2001) (India and Indonesia AD); 66 Fed. Reg. 60197 ‐ 60198,

and 60201 (Dec. 3, 2001) (India, Indonesia, South Africa, and Thailand CVD). 5 71 Fed. Reg. 43521 (Aug. 1, 2006).
 

4

Argentina, China, the Netherlands, South Africa, and Thailand; there were no respondent

interested party responses for the reviews of subject merchandise from India, Indonesia,

Kazakhstan, Romania, Taiwan, and Ukraine.  In October 2007, the Commission made affirmative

determinations concerning the reviews of hot‐rolled steel products from China, India,

Indonesia, Taiwan, Thailand, and Ukraine, and negative determinations concerning the reviews

of hot‐rolled steel products from Argentina, Kazakhstan, Romania, and South Africa.6 7

  

Commerce subsequently issued notices continuing the countervailing duty orders on subject

imports from India, Indonesia, and Thailand, and the antidumping duty orders on subject

imports from China, India, Indonesia, Taiwan, Thailand, and Ukraine.8

Second reviews:  The Commission instituted the instant reviews on November 1, 2012.9

On February 4, 2013, it determined to conduct full reviews for each order under review based

on an adequate domestic interested party group response and the adequate respondent

interested party group responses with respect to the reviews on subject imports from Taiwan

and Thailand; there were no respondent interested party responses for the reviews of subject

merchandise from China, India, Indonesia, and Ukraine.10

The Commission received prehearing and posthearing submissions from domestic

producers ArcelorMittal Steel USA (“AMUSA”); Nucor Corp. (“Nucor”); United States Steel Corp.

(“U.S. Steel”); and joint submissions from Gallatin Steel (“Gallatin”), SSAB Enterprises LLC

(“SSAB”), and Steel Dynamics, Inc. (“SDI”)(collectively referred to as “domestic interested

parties” or “domestic producers”).  The Commission also received prehearing and posthearing

submissions from the following respondent interested parties:  Essar Steel India Ltd. (“Essar”)

and JSW Steel Ltd. (“JSW”), producers and exporters of the subject merchandise in India

(collectively referred to as “Indian Respondents”); Shang Chen Steel Co., Ltd. (“Shang Chen” or  

“Taiwanese Respondent”), a producer of subject merchandise in Taiwan; and Sahaviriya Steel

Industries Public Company Ltd. (“SSI” or “Thai Respondent”), a producer and exporter of the

subject merchandise in Thailand.  A statement and responses to questions from the

Commission were submitted jointly by non‐parties China Steel Corporation, Chung Hung Steel

Corporation, and Dragon Steel Corporation (collectively referred to as “China Steel Group”),

producers of the subject merchandise in Taiwan.  Ford Motor Company, a U.S. automobile

                                                      

6 Hot‐Rolled Steel Products from Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, Inv. Nos. 701‐TA‐404‐408 and 731‐TA‐ 898‐902 and 904‐908

(Review), USITC Pub. 3956 (October 2007) (“First Five‐Year Reviews”). 7 In its final results in the first five‐year review concerning the antidumping duty order on hot‐

rolled steel from the Netherlands, Commerce revoked the order effective November 29, 2006.  72 Fed.

Reg. 35220 (June 27, 2007).  Accordingly, the Commission terminated its five‐year review regarding hot‐

rolled steel from the Netherlands, effective June 27, 2007 and considered any imports from the

Netherlands in the first five‐year reviews as nonsubject rather than subject imports.  72 Fed. Reg. 40322

(July 24, 2007).

8 72 Fed. Reg. 73316 (Dec. 27, 2007).

9 77 Fed. Reg. 66078 (Nov. 1, 2012).

10 78 Fed. Reg. 11901 (Feb. 20, 2013).  See Explanation of Commission Determinations on

Adequacy (http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11548). (EDIS 503832)
 

5

producer and purchaser of hot‐rolled steel, also submitted a statement.   Representatives of

parties both in favor and in opposition to continuation of the orders appeared at the

Commission’s hearing accompanied by counsel.11  No briefs supporting revocation of the orders

regarding China, Indonesia, or Ukraine were filed and no respondent party from any of these

countries appeared at the Commission hearing.

Data/Response Coverage.  U.S. industry data are based on the questionnaire responses

of 14 U.S. producers of hot‐rolled steel that accounted for more than 95 percent of U.S.

production of hot‐rolled steel during January 2007 to June 2013.12  U.S. import data and related

information are based on Commerce’s official import statistics and the questionnaire responses

of 32 U.S. importers of hot‐rolled steel that accounted for approximately two‐thirds of total

U.S. imports during January 2007 to June 2013 and less than one‐quarter of subject imports

during the same period.13  Foreign industry data and related information are based on the

questionnaire responses of seven producers and exporters of subject merchandise:  two

producers/exporters in India, accounting for approximately *** of total production in India in

2012; four producers/exporters in Taiwan, accounting for virtually all production in Taiwan in

2012; and one producer in Thailand, accounting for all or nearly all production in Thailand at

the end of 2012.14  No questionnaire responses were received from producers of hot‐rolled

steel in China, Indonesia, or Ukraine.15  Accordingly, for our determinations, we rely as

appropriate on the facts available from the original investigations and first reviews, and new

information on the record in these second five‐year reviews.

                                                      

11 A full list of hearing witnesses can be found in Appendix B of the final staff report. 12 Confidential Report (“CR”) at I‐19; Public Report (“PR”) at I‐16.  These reports reflect the

revisions contained in memoranda INV‐LL‐110 (December 11, 2013) and INV‐LL‐114 (December 16,

2013).

13 CR at I‐19 and IV‐1; PR at I‐16 and IV‐1.  U.S. importers responding to the Commission’s

questionnaire accounted for:  less than one percent of subject imports from China, substantially all the

subject imports from India, approximately one‐half of the subject imports from Taiwan, approximately

one‐quarter of the subject imports from Thailand, and no share of subject imports from Ukraine during

the January 2007 to June 2013 period; there were no imports from Indonesia during this period.  CR/PR

at IV‐1. 14 While SSI estimated that it accounted for *** of hot‐rolled steel production in Thailand in

2012, evidence in the record demonstrates that G Steel and GJ Steel did not cease production of hot‐

rolled steel until August 5, 2012 and GJ Steel restarted its operations in March 2013.  Moreover, based

on industry data, SSI accounted for *** of hot strip rolling capacity in Thailand in 2012.  CR at IV‐45; PR

at IV‐30.

15 CR at I‐19, IV‐18, IV‐31, and IV‐52; PR at IV‐12, IV‐20, and IV‐34.
 

6

II. Domestic Like Product and Industry

A. Domestic Like Product

In making its determination under section 751(c) of the Tariff Act, the Commission

defines the “domestic like product” and the “industry.”16  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 under this subtitle.”17  The Commission’s

practice in five‐year reviews is to examine the domestic like product definition from the original

investigation and consider whether the record indicates any reason to revisit the prior

findings.18  

In its final expedited five‐year review determinations, Commerce defined the scope of

imported merchandise subject to the orders under review as follows:

. . . certain hot‐rolled carbon steel flat products of a rectangular shape, of a

width of 0.5 inch or greater, neither clad, plated, nor coated with metal and whether or

not painted, varnished, or coated with plastics or other non‐metallic substances, in coils

(whether or not in successively superimposed layers), regardless of thickness, and in

straight lengths, of a thickness of less than 4.75 mm and of a width measuring at least

10 times the thickness.  Universal mill plate (i.e., flat‐rolled products rolled on four faces

or in a closed box pass, of a width exceeding 150 mm, but not exceeding 1250 mm, and

of a thickness of not less than 4 mm, not in coils and without patterns in relief) of a

thickness not less than 4.0 mm is not included within the scope of these orders.

Specifically included within the scope of these orders are vacuum degassed, fully

stabilized (commonly referred to as interstitial‐free (IF)) steels, high strength low alloy

(HSLA) steels, and the substrate for motor lamination steels.  IF steels are recognized as

low carbon steels with micro‐alloying levels of elements such as titanium or niobium

(also commonly referred to as columbium), or both, added to stabilize carbon and

nitrogen elements.  HSLA steels are recognized as steels with micro‐alloying levels of

elements such as chromium, copper, niobium, vanadium, and molybdenum.  The

substrate for motor lamination steels contains micro‐alloying levels of elements such as

silicon and aluminum.

                                                      

16 19 U.S.C. § 1677(4)(A). 17 19 U.S.C. § 1677(10); see, e.g., Cleo Inc. v. United States, 501 F.3d 1291, 1299 (Fed. Cir. 2007);

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

v. United States, 19 CIT 450, 455 (1995); Timken Co. v. United States, 913 F. Supp. 580, 584 (Ct. Int’l

Trade 1996); Torrington Co. v. United States, 747 F. Supp. 744, 748‐49 (Ct. Int’l Trade 1990), aff’d, 938

F.2d 1278 (Fed. Cir. 1991); see also S. Rep. No. 249, 96th Cong., 1st Sess. 90‐91 (1979).

18 See, e.g., Internal Combustion Industrial Forklift Trucks from Japan, Inv. No. 731‐TA‐377

(Second Review), USITC Pub. 3831 at 8‐9 (Dec. 2005); Crawfish Tail Meat from China, Inv. No. 731‐TA‐

752 (Review), USITC Pub. 3614 at 4 (July 2003); Steel Concrete Reinforcing Bar from Turkey, Inv. No. 731‐

TA‐745 (Review), USITC Pub. 3577 at 4 (Feb. 2003).
 

7

Steel products included in the scope of the orders, regardless of definitions in

the Harmonized Tariff Schedule of the United States (HTSUS), are products in which:  (i)

iron predominates, by weight, over each of the other contained elements; (ii) the

carbon content is 2 percent or less, by weight; and (iii) none of the elements listed

below exceeds the quantity, by weight, respectively indicated:

1.80 percent of manganese, or

2.25 percent of silicon, or

1.00 percent of copper, or

0.50 percent of aluminum, or

1.25 percent of chromium, or

0.30 percent of cobalt, or

0.40 percent of lead, or

1.25 percent of nickel, or

0.30 percent of tungsten, or

0.10 percent of molybdenum, or

0.10 percent of niobium, or

0.15 percent of vanadium, or

0.15 percent of zirconium.

All products that meet the physical and chemical descriptions provided above

are within the scope of the orders unless otherwise excluded.19 20

                                                      

19 78 Fed. Reg. 16252, 16253 (Mar. 14, 2013) (Certain Hot‐Rolled Carbon Steel Flat Products

from India, Indonesia, and Thailand:  Final Results of Expedited Sunset Reviews).  The following

products, by way of example, are outside or specifically excluded from the scope of the orders:

‐ Alloy hot‐rolled steel products in which at least one of the chemical elements exceeds

those listed above (including, e.g., American Society for Testing and Materials (ASTM)

specifications A543, A387, A514, A517, A506).

‐ Society of Automotive Engineers (SAE)/American Iron & Steel Institute (AISI) grades of

series 2300 and higher.

‐ Ball bearings steels, as defined in the HTSUS.

‐ Tool steels, as defined in the HTSUS.

‐ Silico‐manganese (as defined in the HTSUS) or silicon electrical steel with a silicon level

exceeding 2.25 percent.

‐ ASTM specifications A710 and A736.

‐ USS Abrasion‐resistant steels (USS AR 400, USS AR 500).

‐ All products (proprietary or otherwise) based on an alloy ASTM specification (sample

specifications:  ASTM A506, A507).

‐ Non‐rectangular shapes, not in coils, which are the result of having been processed by

cutting or stamping and which have assumed the character of articles or products classified

outside chapter 72 of the HTSUS.

(Continued...)
 

8

In the original and first five‐year review determinations, the Commission defined the

domestic like product as all hot‐rolled steel products corresponding to Commerce’s scope

definition.21  In the second reviews, the record contains no information suggesting the

characteristics and uses of hot‐rolled steel have changed appreciably since the prior

proceedings or that the domestic like product definition should be revisited.22  In addition, no

party argued that the Commission should reexamine its definition of the domestic like

product.23  We therefore find a single domestic like product that is coextensive with

Commerce’s scope definition.

                                                                                                                                                                              

(...Continued)

The merchandise subject to these orders is classified in the HTSUS at subheadings:

7208.10.15.00, 7208.10.30.00, 7208.10.60.00, 7208.25.30.00, 7208.25.60.00, 7208.26.00.30,

7208.26.00.60, 7208.27.00.30, 7208.27.00.60, 7208.36.00.30, 7208.36.00.60, 7208.37.00.30,

7208.37.00.60, 7208.38.00.15, 7208.38.00.30, 7208.38.00.90, 7208.39.00.15, 7208.39.00.30,

7208.39.00.90, 7208.40.60.30, 7208.40.60.60, 7208.53.00.00, 7208.54.00.00, 7208.90.00.00,

7211.14.00.90, 7211.19.15.00, 7211.19.20.00, 7211.19.30.00, 7211.19.45.00, 7211.19.60.00,

7211.19.75.30, 7211.19.75.60, and 7211.19.75.90. Certain hot‐rolled carbon steel flat products covered

by these orders, including vacuum degassed fully stabilized, high strength low alloy, and the substrate

for motor lamination steel, may also enter under the following tariff numbers: 7225.11.00.00,

7225.19.00.00, 7225.30.30.50, 7225.30.70.00, 7225.40.70.00, 7225.99.00.90, 7226.11.10.00,

7226.11.90.30, 7226.11.90.60, 7226.19.10.00, 7226.19.90.00, 7226.91.50.00, 7226.91.70.00,

7226.91.80.00, and 7226.99.00.00. Subject merchandise may also enter under 7210.70.30.00,

7210.90.90.00, 7211.14.00.30, 7212.40.10.00, 7212.40.50.00, and 7212.50.00.00. Although the HTSUS

subheadings are provided for convenience and customs purposes, the written product description

remains dispositive.

20 The scope of imported merchandise subject to the antidumping duty orders is virtually

identical for all subject countries and to the scope for the countervailing duty orders set forth above.  78

Fed. Reg. 15703, 15704 (Mar. 12, 2013) and Issues and Decisions Memorandum for the Final Results of

the Expedited Sunset Reviews of the Antidumping Duty Orders on Certain Hot‐Rolled Carbon Steel Flat

Products from India, Indonesia, the People’s Republic of China, Taiwan, Thailand, and Ukraine, March 5,

2013. 21 Original Determinations, USITC Pub. 3446 at 6 and USITC Pub. 3468 at 3; First Five‐Year

Reviews, USITC Pub. 3956 at 8.  The scope of investigation and the single domestic like product in the

original determinations included hot‐rolled steel with slightly elevated levels of microalloying elements.  

Original Determinations, USITC Pub. 3446 at 6 and Hot‐Rolled Steel Preliminary, USITC Pub. 3381 at 4

(Jan. 2001).  As the Commission noted in its preliminary determinations, the scope in these hot‐rolled

steel investigations differed slightly from the scope in the 1999 hot‐rolled steel investigations involving

imports from Brazil, Japan, and Russia; slight variations made to “fully comport with the general industry

practice as to what constituted ‘carbon’ as opposed to ‘alloy’ steel.”  Hot‐Rolled Steel Preliminary, USITC

Pub. 3381 at 4, n.11.  No parties contested the different scope of investigation nor raised any arguments

regarding microalloyed steels in the original investigations or the subsequent first and second reviews. 22 See CR at I‐30‐39; PR at I‐25‐31.

23 Domestic interested parties’ response at 28; AMUSA Prehearing Brief at 5; SDI Prehearing

Brief at 2; Shang Chen response at 18; China Steel response at 8; Chung Hung response at 6; Dragon

Steel response at 6; SSI response at 16.
 

9

B. Domestic Industry  

Section 771(4)(A) of the Tariff Act defines the relevant industry as the domestic  

“producers as a whole of a domestic like product, or those producers whose collective output

of a domestic like product constitutes a major proportion of the total domestic production of

the product.”24  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.  

In the original and first five‐year review determinations, the Commission defined the

domestic industry to be all domestic producers of hot‐rolled steel.  The Commission also

recognized that certain domestic producers were related parties, but determined that

appropriate circumstances did not exist to exclude any producer from the domestic industry as

a related party under 19 U.S.C. § 1677(4)(B).25

In light of our domestic like product definition, we continue to find one domestic

industry consisting of all domestic producers of hot‐rolled steel, which is consistent with

Commerce’s scope definition.26  No U.S. producer directly imported or purchased hot‐rolled

steel from subject countries during the period of review.27  We find that appropriate

circumstances do not exist to exclude any producer from the domestic industry as a related

party.28 29  We consequently define the domestic industry as all U.S. producers of hot‐rolled

steel products.

                                                      

24 19 U.S.C. § 1677(4)(A).  The definitions in 19 U.S.C. § 1677 are applicable to the entire subtitle

containing the antidumping and countervailing duty laws, including 19 U.S.C. §§ 1675 and 1675a.  See 19

U.S.C. § 1677.

25 Original Determinations, USITC Pub. 3446 at 6‐8; First Five‐Year Reviews, USITC Pub. 3956 at 8

and 9.

26 The domestic interested parties view the domestic industry as encompassing all domestic

producers of hot‐rolled steel, and no party advocated the exclusion of any domestic producer as a

related party.  In particular, AMUSA indicates that there do not appear to be any affiliations or

importations by domestic producers that provide appropriate circumstances to exclude any U.S.

producer from the industry in these reviews.  AMUSA Prehearing Brief at 5.

27 CR at I‐45 and III‐19; PR at I‐35 and III‐11.

28 There are two possible related party issues in these reviews.  First, domestic producer AMUSA

is owned by ArcelorMittal SA, which is ***.  CR at I‐44; PR at I‐35; see also AMUSA Prehearing Brief at 5,

n.3.  The record, however, does not indicate either whether *** exports, or intends to export, subject

merchandise or the extent to which ArcelorMittal SA exercises direct or indirect control of ***.  19

U.S.C. § 1677(4)(B)(ii)(III).  Moreover, assuming arguendo that AMUSA is a related party, we find that

appropriate circumstances do not exist to exclude it from the domestic industry.  Considerations

supporting this conclusion are that AMUSA accounted for a substantial share (***) of domestic

production in 2012, it *** continuation of the orders, its interests appear to be primarily those of a

domestic producer, and there is no indication that it derives any benefit or operates in a manner that is

different from other domestic producers as a result of this affiliation.  See CR/PR at Tables I‐8 and III‐12;

see also AMUSA Prehearing Brief at 5, n.3 (***).  

(Continued...)
 

10

III. Cumulation

A. Legal Standard and Background

With respect to five‐year reviews, section 752(a) of the Tariff Act provides as follows:

the Commission may cumulatively assess the volume and effect of imports of the

subject merchandise from all countries with respect to which reviews under

section 1675(b) or (c) of this title were initiated on the same day, if such imports

would be likely to compete with each other and with domestic like products in

the United States market.    The Commission shall not cumulatively assess the

volume and effects of imports of the subject merchandise in a case in which it

determines that such imports are likely to have no discernible adverse impact on

the domestic industry.30

Cumulation therefore is discretionary in five‐year reviews, unlike original investigations,

which are governed by section 771(7)(G)(i) of the Tariff Act.31  The Commission may exercise its

discretion to cumulate, however, only if the reviews are initiated on the same day, the

Commission determines that the subject imports are likely to compete with each other and the

domestic like product in the U.S. market, and imports from each such subject country are not

likely to have no discernible adverse impact on the domestic industry in the event of

revocation.  Our focus in five‐year reviews is not only on present conditions of competition, but

also on likely conditions of competition in the reasonably foreseeable future.

The Original Investigations and Prior Reviews.  In the original investigations, the

Commission determined on balance that there was a reasonable overlap of competition and

cumulated subject imports from all subject countries for purposes of material injury by reason

                                                                                                                                                                               

(...Continued)

A second possible related party issue involves subject merchandise imported from *** during

the period of review by importer ***, which does not produce hot‐rolled steel.  CR/PR at Table I‐9.  

Domestic producer ***, and thus we find that appropriate circumstances do not exist to exclude it from

the domestic industry.  CR/PR at Table I‐8.

29 Assuming arguendo that AMUSA is a related party, Commissioner Pinkert does not rely upon

its financial performance as set forth in Table III‐12 to determine whether there are appropriate

circumstances to exclude it from the domestic industry.  In his view, the present record is not sufficient

to link the producer’s financial performance with respect to its U.S. operations to any specific benefit it

derives from its related party status.

30 19 U.S.C. § 1675a(a)(7).

31 19 U.S.C. § 1677(7)(G)(i); see also, e.g., Nucor Corp. v. United States, 601 F.3d 1291, 1293 (Fed.

Cir. 2010) (Commission may reasonably consider likely differing conditions of competition in deciding

whether to cumulate subject imports in five‐year reviews); Allegheny Ludlum Corp. v. United States, 475

F. Supp. 2d 1370, 1378 (Ct. Int’l Trade 2006) (recognizing the wide latitude the Commission has in

selecting the types of factors it considers relevant in deciding whether to exercise discretion to cumulate

subject imports in five‐year reviews); Nucor Corp. v. United States, 569 F. Supp. 2d 1328, 1337‐38 (Ct.

Int’l Trade 2008).
 

11

of subject imports.32  In the first five‐year reviews, the Commission did not cumulate subject

imports from Argentina because they were likely to have no discernible adverse impact on the

domestic industry in the event of revocation.33  With respect to the remaining subject

countries, the Commission found that the no discernible adverse impact exception to

cumulation did not apply and that there would likely be a reasonable overlap of competition

between subject imports from each country and the domestic like product as well as among

subject imports from each country.  The Commission also determined that, based on the

existence of unique conditions of competition, subject imports from Kazakhstan, Romania, and

South Africa would not be likely to compete under similar conditions of competition with  

subject imports from China, India, Indonesia, Taiwan, Thailand, and Ukraine.  Accordingly, the

Commission considered subject imports from Argentina separately from all other subject

imports, exercised its discretion to cumulate subject imports from Kazakhstan, Romania, and

South Africa and consider them separately from all other subject imports, and exercised its

discretion to cumulate subject imports from China, India, Indonesia, Taiwan, Thailand, and

Ukraine.34

Current Reviews.  In these reviews, the statutory threshold for cumulation is satisfied

because all reviews were initiated on the same day:  November 1, 2012.35  In addition, we

consider the following issues in deciding whether to exercise our discretion to cumulate the

subject imports:  (1) whether imports from any of the subject countries are precluded from

cumulation because they are likely to have no discernible adverse impact on the domestic

industry; (2) whether there is a likelihood of a reasonable overlap of competition among

imports from the subject countries and the domestic like product;  and (3) whether subject

imports are likely to compete in the U.S. market under different conditions of competition.36   

Domestic producers argue that the Commission should cumulate imports from all

subject countries.37  Indian, Taiwanese, and Thai Respondents contend that subject imports

from India, Taiwan, and Thailand should not be cumulated with imports from any other subject

country because they will have no discernible adverse impact on the domestic industry upon

revocation and, in the alternative, because subject imports from each of these countries are

                                                      

32 Original Determinations, USITC Pub. 3446 at 9‐14.

33 First Five‐Year Review, USITC Pub. 3956 at 12‐14.

34 First Five‐Year Review, USITC Pub. 3956 at 10‐20.  The Commission’s cumulation finding was

affirmed and not included in the issues remanded to the Commission with respect to its negative

determinations concerning subject imports from Kazakhstan, Romania, and South Africa in Nucor Corp.

v. United States, 605 F. Supp. 2d 1361 (Ct. Int’l Trade 2009).

35 See 77 Fed. Reg. 66439 (Nov. 5, 2012).

36 19 U.S.C. § 1675a(a)(7).

37 AMUSA Posthearing Brief at 1‐3; AMUSA Prehearing Brief at 5‐57; US Steel Posthearing Brief

at 10‐11; US Steel Prehearing Brief at 16‐22; Nucor Prehearing Brief at 8, 39‐50 and Exhibit 2; SDI

Prehearing Brief at 2.
 

12

likely to compete under different conditions of competition than any of the other subject

countries.38

B. Likelihood of No Discernible Adverse Impact

The statute precludes cumulation if the Commission finds that subject imports from a

country are likely to have no discernible adverse impact on the domestic industry.39  Neither the

statute nor the Uruguay Round Agreements Act (“URAA”) Statement of Administrative Action

(“SAA”) provides specific guidance on what factors the Commission is to consider in

determining that imports “are likely to have no discernible adverse impact” on the domestic

industry.40  With respect to this provision, the Commission generally considers the likely volume

of subject imports and the likely impact of those imports on the domestic industry within a

reasonably foreseeable time if the orders are revoked.  Our analysis for each of the subject

countries takes into account, among other things, the nature of the product and the behavior of

subject imports in the original investigations.

Based on the record in these reviews, we do not find that imports from any of the

subject countries would likely have no discernible adverse impact on the domestic industry in

the event of revocation.41 42

China.  In the original investigations, subject imports from China increased from 102,588

short tons in 1998 to 485,299 short tons in 2000.43  During the first five‐year reviews, subject

imports from China remained in the U.S. market at relatively low levels.44  Subject imports from

China were present each year during the current period of review; they were 1,093 short tons

in 2007, and fluctuated from a low of 159 short tons in 2009 to a high of 2,419 short tons in

2012.45  The share of the quantity of apparent U.S. consumption accounted for by subject

                                                      

38 Essar/JSW Prehearing Brief at 10; Essar/JSW Posthearing Brief at 7‐14; Shang Chen Prehearing

Brief at 12‐24; Shang Chen Posthearing Brief at 7‐11; SSI Prehearing Brief at 3‐19; SSI Posthearing Brief

at 2‐11.

39 19 U.S.C. § 1675a(a)(7).

40 Uruguay Round Agreements Act Statement of Administrative Action (SAA), H.R. Rep. No. 103‐

316, vol. I at 887 (1994). 41 Commissioners Broadbent and Kieff do not join this finding with respect to subject imports

from Indonesia.  They find that subject imports from Indonesia would likely have no discernible adverse

impact on the domestic industry in the event of revocation.  See Additional and Dissenting Views of

Commissioners Meredith M. Broadbent and F. Scott Kieff.

42 In the first five‐year reviews, the Commission found that subject imports from Argentina were

likely to have no discernible adverse impact on the domestic industry in the event of revocation and

thus did not cumulate them.  First Five‐Year Review, USITC Pub. 3956 at 12‐14.

43 CR/PR at Table I‐1. 44 CR/PR at Table I‐1.  Subject imports from China were 42,184 short tons in 2001, and

fluctuated from a low of 28 short tons in 2003 to a high of 6,456 short tons in 2004, with 3,851 short

tons imported in 2006.  Id. 45 CR/PR at Table I‐1.  Subject imports from China were 1,763 short tons in January‐June

(“interim”) 2012 and 1,481 short tons in interim 2013.  Id. at Table IV‐1.
 

13

imports from China was 0.7 percent in 2000, 0.1 percent in 2001, and zero or less than 0.05

percent from 2002 to 2012.46

No Chinese producer reported data to the Commission on its hot‐rolled steel operations

for the period of review.47  Thus, the limited data in the record regarding hot‐rolled steel

production in China are derived from the original investigations, the prior reviews, and other

available industry sources.   Available information regarding the Chinese hot‐rolled steel

industry from ***, an industry monitoring source, estimates that Chinese capacity increased

from *** short tons in 2009 to *** short tons in 2012.48 Production also has increased from

*** short tons in 2009 to *** short tons in 2012.49

According to Global Trade Atlas data, exports of hot‐rolled carbon and alloy steel from

China were 12.8 million short tons in 2007, ranged from a 2007‐2012 period low of 4.9 million

short tons in 2009 to a period high of 13.3 million short tons in 2008, and were 10.7 million

short tons in 2012.50  Available information shows that China is increasingly a *** of hot‐rolled

steel.51  Finally, Chinese exports of hot‐rolled steel faced import barriers in a number of third

countries during the period of review.52  Based on the record, we do not find that subject

                                                      

46 CR/PR at Table I‐1. 47 CR at IV‐18; PR at IV‐12.  In the current reviews, the domestic interested parties identified

more than 160 Chinese producers/exporters of hot‐rolled steel while respondent parties identified nine

Chinese producers/exporters.  Id.  In the first five‐year reviews, eight firms, accounting for between one‐

quarter and one‐half of Chinese production of hot‐rolled steel in 2006, responded to the Commission’s

questionnaire. CR at IV‐17‐18; PR at IV‐12.  In the original investigations, five Chinese producers

responded to the Commission questionnaires, including Shanghai Baosteel, which reportedly accounted

for *** of Chinese hot‐rolled steel production in 2000.  CR at IV‐17; PR at IV‐12.

48 CR/PR at Table IV‐7.  In the first five‐year reviews, available estimates regarding the Chinese

hot‐rolled steel industry from *** indicated that Chinese production capacity was *** and production

was *** in 2006.  First Five‐Year Review at Table IV‐17.

49 CR/PR at Table IV‐7.

50 CR/PR at Table IV‐8.  The markets accounting for the largest volume of Chinese exports of hot‐

rolled steel in 2012 were Korea (3.5 million short tons), Vietnam (1.3 million short tons), India (867,240

short tons) and Thailand (760,121 short tons).  Exports to both Taiwan and Indonesia also were

substantial in 2012 at 166,599 short tons and 123,880 short tons, respectively.  Id.  Published

descriptions of exports of Chinese hot‐rolled coil (“HRC”) include terms such as “commercial‐grade,

boron containing HRC,” suggesting that some volume of hot‐rolled steel exports with elevated boron

levels (possibly within micro‐alloy levels specified in the scope of the current reviews) might be classified

for export purposes as alloy steel product rather than carbon steel product; thus the export data for

China includes hot‐rolled carbon and alloy steel.  CR at IV‐19, n.23; PR at IV‐13, n.23.

51 CR/PR at Table IV‐7.  China’s net export balance *** short tons in 2009 to *** short tons in

2012.  Id.

52 CR at IV‐18; PR at IV‐13.  Chinese exports of hot‐rolled steel have been subject to an

antidumping duty order in Canada since 2001; an antidumping duty order in Indonesia since 2008;

antidumping duty orders since 2011 (nonalloy) and 2012 (alloy) in Thailand; and a 2013 safeguard

measure in Thailand that will remain in place until February 26, 2016.  Id.
 

14

imports from China would likely have no discernible adverse impact on the domestic industry if

the orders were revoked.

India.  In the original investigations, subject imports of hot‐rolled steel from India

increased from 109,941 short tons in 1998 to 876,264 short tons in 2000.53  During the first five‐

year reviews, subject imports from India remained in the U.S. market at lower levels.54  During

the current period of review, subject imports from India were 17,665 short tons in 2007,

declined to 185 short tons in 2008 and remained at zero in each year and interim period

thereafter.55   The share of the quantity of apparent U.S. consumption accounted for by subject

imports from India was 1.2 percent in 2000, 0.1 percent in 2001 and 2006, and zero or less than

0.05 percent in each year from 2002 to 2012 (except for 2006).56

Two firms – Essar  and  JSW Steel – accounting for *** of Indian production of hot‐rolled

steel in 2012, responded to the Commission’s questionnaire in these reviews.57 Thus, the

record regarding hot‐rolled steel production in India is derived from the original investigations,

the first five‐year reviews, and other available industry sources, in addition to these

questionnaire responses.  According to ***, Indian production capacity steadily increased from

*** short tons in 2009 to *** short tons in 2012; its production also increased from *** short

tons in 2009 to *** short tons in 2012.58

Reported Indian production capacity increased from *** short tons in 2007 to *** short

tons in 2012.59  Reported production also increased from *** short tons in 2007 to *** short

tons in 2012.60  Reported capacity utilization declined irregularly from *** in 2007 to *** in

2012.61

During the period of review, the Indian hot‐rolled steel industry’s reported exports of

hot‐rolled steel as a share of its total shipments fluctuated between years, ranging from a low

of *** in 2012.62  Although reported home market shipments and internal consumption

                                                      

53 CR/PR at Table I‐1.

54 CR/PR at Table I‐1.  Subject imports from India were 51,480 short tons in 2001, and fluctuated

from a low of zero in 2003 to a high of 62,234 short tons in 2006.  Id. 55 CR/PR at Table I‐1 and IV‐1.

56 CR/PR at Table I‐1. 57 CR at IV‐23; PR at IV‐16.  Staff estimates that these two responding firms accounted for *** of

hot strip rolling capacity in India in 2012.  CR at IV‐23, n.26; PR at IV‐16, n.26.  In the original

investigations, four firms (Ispat, Essar, SAIL, and Tata) responded to the Commission questionnaire and

in the first five‐year review, two firms (JSW and Tata) provided useable data and Essar provided a

response with little usable data.  CR at IV‐23; PR at IV‐16.

58 CR/PR at Table IV‐9.  Available *** estimates in the first five‐year reviews regarding the Indian

hot‐rolled steel industry indicated that Indian production capacity was *** short tons and production

was *** short tons in 2006.  First Five‐Year Reviews at Table IV‐23.

59 CR/PR at Table IV‐11.

60 CR/PR at Table IV‐11.

61 CR/PR at Table IV‐11.

62 CR/PR at Table IV‐11.  The reporting Indian producers’ exports as a share of total shipments

were *** in interim 2013.  CR/PR at Table IV‐11.  In the original investigation (in 2000), this industry’s

(Continued...)
 

15

accounted for the majority of the reporting Indian producers’ shipments during the period of

review, exports accounted for a significant and increasing volume and share of their shipments

between 2009 and 2012.63  Both responding Indian producers indicated that they produce

downstream products on the same equipment used to produce hot‐rolled steel, namely ***.64

According to Global Trade Atlas data, exports of hot‐rolled steel from India increased

irregularly from 1.5 million short tons in 2007 to 1.8 million short tons in 2012.65  Available

information shows that India has been a *** of hot‐rolled steel during the period of review.66  

Finally, Indian exports of hot‐rolled steel face import barriers in a number of third‐country

markets during the period of review.67  Based on the record, including the substantial unused  

capacity, large volumes of exports, and import barriers, we do not find that subject imports

from India would likely have no discernible adverse impact on the domestic industry if the

orders were revoked.

Indonesia.

68  In the original investigations, the subject imports of hot‐rolled steel from

Indonesia increased from 38,163 short tons in 1998 to 259,166 short tons in 2000.69  Subject

imports from Indonesia virtually left the U.S. market after 2001.70  There have been no subject

imports from Indonesia reported during the current period of review.71  The share of the

quantity of apparent U.S. consumption accounted for by subject imports from Indonesia was

0.4 percent in 2000, and zero or less than 0.05 percent from 2001 to 2012.72

                                                                                                                                                                              

(...Continued)

reported exports as a share of total shipments were *** percent of its total shipments and in 2006,

India’s reported exports as a share of total shipments were *** percent.  First Five‐Year Reviews at

Tables IV‐20 and IV‐21.

63 CR/PR at Table IV‐11. Reported home market shipments as a share of total shipments

fluctuated slightly during the period of review, ranging from a low of *** in 2012; reported internal

consumption as a share of total shipments declined irregularly from *** in 2012.  Reported inventories

accounted for a smaller share of total shipments, *** in 2012.  Id. 64 CR at IV‐29; PR at IV‐20.

65 CR/PR at Table IV‐10.  The markets accounting for the largest volume of Indian exports of hot‐

rolled steel in 2012 were the United Arab Emirates (293,703 short tons), Belgium (261,442 short tons),

Spain (212,509 short tons), and Saudi Arabia (140,060 short tons).  Id. 66 CR/PR at Table IV‐9.  India’s net import balance *** short tons in 2012.  Id. 67 CR at IV‐24; PR at IV‐17.  Indian exports of hot‐rolled steel have been subject to antidumping

and countervailing duty orders in Canada since 2001; an antidumping duty order in Indonesia since

2008; an antidumping duty order in Thailand since 2003; and a 2013 safeguard measure in Thailand that

will remain in place until February 26, 2016.  Id. 68 Commissioners Broadbent and Kieff do not join this discussion on Indonesia.  They find that  

subject imports from Indonesia would likely have no discernible adverse impact on the domestic

industry in the event of revocation.  See Additional and Dissenting Views of Commissioners Meredith M.

Broadbent and F. Scott Kieff.

69 CR/PR at Table I‐1.

70 CR/PR at Table I‐1.  Subject imports from Indonesia were 10,726 short tons in 2001, and

except for a small volume (5 short tons) in 2004 did not enter the U.S. market again.  Id. 71 CR/PR at Tables I‐1 and IV‐4.

72 CR/PR at Table I‐1.
 

16

No Indonesian producer reported data to the Commission on its hot‐rolled steel

operations for the period of review.73  Thus, the limited data in the record regarding hot‐rolled

steel production in Indonesia is derived from the original investigations and other available

industry sources.  According to ***, Indonesian capacity is estimated at *** short tons in 2009

and 2010, and *** short tons in 2011 and 2012; production has ranged from a low of *** short

tons in 2012.74  Therefore, according to the available *** data, Indonesia had an estimated

unused capacity of *** short tons in 2012.75

Based on information in its annual report, PT Krakatau’s production capacity and

production for hot‐rolled steel were 2.6 million short tons and 2.02 million short tons,

respectively, in 2012; it has plans to increase its capacity through its joint venture with Posco.76  

PT Krakatau also reportedly held a 41 percent share of the Indonesian market for hot‐rolled

steel in 2012.77  The other known hot‐rolled steel producer in Indonesia, PT Gunung Raja Paksi,

is estimated to have hot‐rolled steel production capacity of 265,000 short tons.78

According to Global Trade Atlas data, exports of hot‐rolled steel from Indonesia declined

from 327,456 short tons in 2007 to 19,065 short tons in 2012.79  Available information shows

that Indonesia is increasingly a *** of hot‐rolled steel.80  Finally, Indonesian exports of hot‐

rolled steel faced one import barrier in a third country during the period of review.81  Based on

the record, including evidence of unused capacity and a planned increase in capacity, we do not

find that subject imports from Indonesia would likely have no discernible adverse impact on the

domestic industry if the orders were revoked.

                                                      

73 CR at IV‐31; PR at IV‐20.  The record indicates that there are two Indonesian hot‐rolled steel

producers – PT Krakatau and PT Gunung Raja Paksi.  PT Krakatau responded to the Commission’s

questionnaire in the original investigations but neither firm responded in the first five‐year reviews.  Id. 74 CR/PR at Table IV‐13. 75 Derived from CR/PR at Table IV‐13.

76 CR at IV‐31; PR at IV‐20‐21.  PT Krakatau’s production of hot‐rolled steel was reported to have

increased by 4.3 percent from 2011 to 2012.  Id.  PT Krakatau has a joint venture with Posco (Korea),

with the first stage of production of 3 million metric tons of plate and slab steel scheduled for

completion in late 2013 and the second stage scheduled to commence production of hot‐rolled steel in

2015.  Id.  We note that the Commission did not receive a questionnaire response from PT Krakatau that

may have provided more details about the timing and magnitude of these reported plans for increases

in the production of hot‐rolled steel.  In the original investigations, PT Krakatau reported its production

capacity was *** in 2000.  First Five‐Year Review at Table IV‐27.  PT Krakatau’s exports and inventory as

a share of its total shipments was ***, respectively, in 2000.  Id. 77 CR at IV‐31; PR at IV‐20.

78 CR at IV‐32; PR at IV‐21.

79 CR/PR at Table IV‐14.  The markets accounting for the largest volume of Indonesian exports of

hot‐rolled steel in 2012 were Malaysia (11,572 short tons), Vietnam (4,926 short tons), and Australia

(1,895 short tons).  Id. 80 CR/PR at Table IV‐13.  Indonesia’s net import balance *** short tons in 2012.  Id. 81 CR at IV‐32; PR at IV‐21.  Indonesian exports of hot‐rolled steel face an antidumping duty

order in Thailand imposed in 2003.  Id.
 

17

Taiwan.  In the original investigations, subject imports of hot‐rolled steel from Taiwan

increased from 224,058 short tons in 1998 to 724,854 short tons in 2000.82  During the first five‐

year reviews, subject imports from Taiwan remained in the U.S. market at lower levels.83  

During the current period of review, subject imports from Taiwan remained in the U.S. market

at relatively low levels, fluctuating from a low of 45 short tons in 2010 to a high of 2,483 short

tons in 2011, and were 560 short tons in 2012.84  The share of the quantity of apparent U.S.

consumption accounted for by subject imports from Taiwan was 1.0 percent in 2000, 0.1

percent in 2001, and zero or less than 0.05 percent from 2002 to 2012. 85

Four firms – China Steel, Chung Hung, Dragon Steel, and Shang Chen – accounting for

virtually all Taiwanese production of hot‐rolled steel, responded to the Commission’s

questionnaire in these reviews.86  Taiwanese capacity and production fluctuated between years

but increased overall from 2007 to 2012.87  Taiwanese capacity was *** in 2012.88  Production

also fluctuated between years and increased overall from *** short tons in 2007 to *** short

tons in 2012. 89  Taiwanese capacity utilization ranged from a high of *** in 2012.90

During the period of review, exports of hot‐rolled steel producers in Taiwan as a share

of their total shipments ranged from a low of *** in 2012; in the original investigation (in 2000)

and in the first five‐year review (2006), Taiwan’s exports as a share of total shipments were

***, respectively.91  While exports account for a significant share of the Taiwanese producers’

shipments, internal consumption increased overall and by 2012 accounted for the majority of

the producers’ total shipments.92 One Taiwanese producer reported that it produced

nonsubject products on the same hot‐strip/Steckel mill and all responding producers produced

                                                      

82 CR/PR at Table I‐1.

83 CR/PR at Table I‐1.   Subject imports from Taiwan were 42,144 short tons in 2001, and

fluctuated from a low of 107 short tons in 2003 to a high of 7,305 short tons in 2006.  Id. 84 CR/PR at Table I‐1.  Subject imports from Taiwan were 492 short tons in interim 2012 and 26

short tons in interim 2013.  Id. at Table IV‐1.

85 CR/PR at Table I‐1.

86 CR at IV‐35 and 36; PR at IV‐24.  In the first five‐year reviews, three Taiwanese producers

(China Steel, Chung Hung, and Shang Shing), accounting for all of Taiwanese production, provided

responses to the Commission’s questionnaire. China Steel and the predecessor to Chung Hung, Yieh

Loong, also provided data in the original investigations.  CR at IV‐35; PR at IV‐24.

87 CR/PR at Table IV‐17.

88 CR/PR at Table IV‐17.  Hot‐rolled steel capacity in Taiwan increased from 2009 to 2011 due to

***.  CR at IV‐39; PR at IV‐28.

89 CR/PR at Table IV‐17.

90 CR/PR at Table IV‐17.  Taiwanese capacity utilization was *** in interim 2012 and *** in

interim 2013.  Id. 91 CR/PR at Table IV‐17; First Five‐Year Review at Tables IV‐43 and IV‐44.  Taiwan’s exports as a

share of its total shipments were *** in interim 2013.  CR/PR at Table IV‐17.

92 CR/PR at Table IV‐17.  Internal consumption as a share of total shipments increased irregularly

from *** in 2012; conversely, home market shipments as a share of total shipments declined during the

period of review, from *** in 2012.  Inventories as a ratio of total shipments accounted for a smaller

ratio, within a *** range from 2007 to 2012.  Id.
 

18

downstream products.93   Available information shows that Taiwan is increasingly a *** of hot‐

rolled steel.94  Finally, Taiwanese exports of hot‐rolled steel faced import barriers in a number

of third‐country markets during the period of review.95  Based on the record, including the

excess capacity, increasing export orientation, and existence of third‐country import barriers,

we do not find that subject imports from Taiwan would likely have no discernible adverse

impact on the domestic industry if the orders were revoked.

Thailand.  In the original investigations, subject imports of hot‐rolled steel from Thailand

increased from 18,050 short tons in 1998 to 233,762 short tons in 2000.96  During the first five‐

year reviews, subject imports from Thailand remained in the U.S. market.97  During the current

period of review, subject imports from Thailand were 2,171 short tons in 2007, increased to

5,632 short tons in 2008, and then declined to and remained at zero in each year and interim

period thereafter.98  The share of the quantity of apparent U.S. consumption accounted for by

subject imports from Thailand was 0.3 percent in 2000, ranged from 0.1 percent to 0.2 percent

during the first five‐year reviews, and was less than 0.05 percent during the current review

period.99

One firm (SSI) estimated that it accounted for all Thai production of hot‐rolled steel in

2012 and responded to the Commission’s questionnaire in these reviews.100  However, based

on staff’s estimate, SSI accounted for *** of the hot strip rolling capacity in Thailand in 2012.101

Thus, the record regarding hot‐rolled steel production in Thailand is derived from the original

investigations, the first five‐year reviews, and other available industry sources, in addition to

the *** questionnaire response.  According to ***, the Thai industry’s production capacity

increased from *** short tons in 2009 to *** short tons in 2010 and remained at that level in

2011 and 2012; production increased from *** short tons in 2009 to *** short tons in 2012.102  

                                                      

93 CR at IV‐42; PR at IV‐29.

94 CR/PR at Table IV‐15.  Taiwan’s net export balance *** short tons in 2012.  Id.  According to

Global Trade Atlas data, the markets accounting for the largest volume of Taiwanese exports of hot‐

rolled steel in 2012 were Japan (617,023 short tons), Vietnam (525,377 short tons), Malaysia (445,478

short tons), South Korea (426,746 short tons), Indonesia (254,487 short tons), and Thailand (198,464

short tons).  CR/PR at Table IV‐16.

95 CR at IV‐36; PR at IV‐25.  Taiwanese exports of hot‐rolled steel have been subject to an

antidumping duty order in Australia since 2012; an antidumping duty order in Canada since 2001; an

antidumping duty order in Indonesia since 2008; and an antidumping duty order in Thailand since 2003.

96 CR/PR at Table I‐1.

97 CR/PR at Table I‐1.  Subject imports from Thailand fluctuated from a low of 15,847 short tons

in 2001 to a high of 155,824 short tons in 2006.  Id. 98 CR/PR at Table I‐1 and IV‐1.

99 CR/PR at Table I‐1.

100 CR at IV‐44 and 45; PR at IV‐30.

101 CR at IV‐45, n.55; PR at IV‐30, n.55.  G Steel and GJ Steel ceased production in August 2012;

on March 20, 2013, GJ Steel announced that it had restarted its mill operations.  G Steel remains closed.

102 CR/PR at Table IV‐19.
 

19

Thus, according to *** data, Thailand had unused capacity of approximately *** short tons in

2012.103

Reported SSI capacity was *** in 2012.104  Reported SSI production was *** in 2012.105  

SSI capacity utilization, which was *** in 2000, ranged during the period of review from a low of

***, and was *** in 2012.106

During the period of review, SSI’s exports of hot‐rolled steel as a share of its total

shipments declined from a high of *** in 2012.107  SSI’s reported home market shipments have

accounted for the majority of total shipments during the period of review.108   SSI reported that

it ***.109

According to Global Trade Atlas data, exports of hot‐rolled steel from Thailand declined

from 916,973 short tons in 2007 to 26,785 short tons in 2012.110  Available information shows

that Thailand was a *** of hot‐rolled steel during the period of review.111  Finally, Thai exports

of hot‐rolled steel faced one import barrier in third‐country markets during the period of

review.112  Based on the record, including the substantial unused capacity, we do not find that

subject imports from Thailand would likely have no discernible adverse impact on the domestic

industry if the orders were revoked.

Ukraine.  In the original investigations, subject imports from Ukraine increased from

126,648 short tons in 1998 to 213,764 short tons in 2000.113  During the first five‐year reviews,

subject imports from Ukraine remained in the U.S. market at lower levels.114  During the current

period of review, subject imports from Ukraine entered the U.S. market only in 2008 (19 short

tons) and 2012 (806 short tons).115  The share of the quantity of apparent U.S. consumption

                                                      

103 Derived from CR/PR at Table IV‐19.

104 CR/PR at Table IV‐21.

105 CR/PR at Table IV‐21.

106 CR/PR at Table IV‐21.  SSI capacity utilization was *** in interim 2013.  Id. 107 CR/PR at Table IV‐21.  SSI’s exports as a share of its total shipments were *** in interim 2013.  

Id.  In the original investigation (in 2000), Thailand’s exports as a share of total shipments were ***.  

First Five‐Year Review at Table IV‐47.

108 CR/PR at Table IV‐21.   SSI’s home market shipments as a share of total shipments fluctuated

slightly during the period of review, ranging from a low of  *** in 2012; they were *** in interim 2013.  

Inventories as a ratio of total shipments decreased irregularly from *** in 2012.  Id. 109 CR at IV‐51; PR at IV‐34.

110 CR/PR at Table IV‐20.  The markets accounting for the largest volume of Thai exports of hot‐

rolled steel in 2012 were Saudi Arabia (9,091 short tons), Laos (7,899 short tons), Malaysia (5,121 short

tons), and Myanmar (3,299 short tons).  Id. 111 CR/PR at Table IV‐19.  Thailand’s net import balance *** short tons in 2012.  Id. 112 CR at IV‐46; PR at IV‐31.  Thai exports of hot‐rolled steel have been subject to an antidumping

duty order in Indonesia since 2008.  Id. 113 CR/PR at Table I‐1. 114 CR/PR at Table I‐1.  Subject imports from Ukraine were 25,694 short tons in 2001, and

fluctuated from a low of zero in 2004 and 2006 to a high of 1,558 short tons in 2005.  Id. 115 CR/PR at Table I‐1.  There were no subject imports from Ukraine reported for either interim

2012 or interim 2013.  Id. at Table IV‐1.
 

20

accounted for by subject imports from Ukraine was 0.3 percent in 2000, and zero or less than

0.05 percent during the first five‐year reviews and the current reviews.116

No producer in Ukraine reported data to the Commission on its hot‐rolled steel

operations for the period of review.117  Thus, the limited data in the record regarding hot‐rolled

steel production in Ukraine are derived from the original investigations, the prior reviews, and

other available industry sources.  *** estimates indicate that Ukrainian capacity remained

constant at *** short tons from 2009 to 2012.118 Production fluctuated from a low of *** short

tons in 2009 to a high of *** short tons in 2011, and was *** short tons in 2012.119

According to Global Trade Atlas data, exports of hot‐rolled steel from Ukraine fluctuated

on an annual basis and declined from 4.1 million short tons in 2007 to 3.0 million short tons in

2012.120  Available information shows that Ukraine continues to be a *** of hot‐rolled steel.121   

Finally, exports of hot‐rolled steel from the Ukraine faced two import barriers in third‐country

markets during the period of review.122  Based on the record, we do not find that subject

imports from Ukraine would likely have no discernible adverse impact on the domestic industry

if the orders were revoked.

C. Likelihood of a Reasonable Overlap of Competition

The Commission generally has considered four factors intended to provide a framework

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

product.123  Only a “reasonable overlap” of competition is required.124  In five‐year reviews, the

                                                      

116 CR/PR at Table I‐1. 117 CR at IV‐52; PR at IV‐34.  In the original investigations, the Commission received

questionnaire responses from two Ukrainian producers of hot‐rolled steel:  Ilyich and Zaporizhstal.  In

the first five‐year reviews and the current reviews, the Commission issued questionnaires to the same

two producers of subject merchandise in Ukraine; neither firm responded to the Commission’s

questionnaire in either review.  Id. 118 CR/PR at Table IV‐22.    119 CR/PR at Table IV‐22.  In the original investigations, Ukrainian producers reported their

production capacity was *** in 2000.  Available *** estimates in the first five‐year reviews regarding the

Ukrainian hot‐rolled steel industry indicated that production capacity was *** short tons and production

was *** short tons in 2006.  First Five‐Year Reviews at Table IV‐52.    120 CR/PR at Table IV‐23.  The markets accounting for the largest volume of Ukrainian exports of

hot‐rolled steel in 2012 were Turkey (638,265 short tons), Russia (419,966 short tons), Poland (354,854

short tons), Bulgaria (216,305 short tons), and Greece (158,538 short tons).  Id.  In the original

investigations, Ukrainian producers’ exports as a share of their total shipments was *** in 2000.  Based

on the available data in the first five‐year reviews, Ukraine exports of hot‐rolled steel accounted for ***

of Ukraine’s total commercial production in 2006.  First Five‐Year Reviews at Table IV‐51. 121 CR/PR at Table IV‐22.  Ukraine’s net export balance was *** short tons in 2012.  Id. 122 CR at IV‐52; PR at IV‐34.  Exports of hot‐rolled steel from the Ukraine have been subject to an

antidumping duty order in Canada since 2001 and an antidumping duty order in Thailand since 2003.  Id. 123 The four factors generally considered by the Commission in assessing whether imports

compete with each other and with the domestic like product are as follows:  (1) the degree of fungibility

between subject imports from different countries and between subject imports and the domestic like

(Continued...)
 

21

relevant inquiry is whether there likely would be competition even if none currently exists

because the subject imports are absent from the U.S. market.125

Fungibility.   In both the original investigations and first five‐year reviews, the

Commission found that, while there were some quality differences and differences in product

mix, there was general interchangeability between subject imports and between subject

imports and the domestic like product.126  The record in these reviews again indicates that

domestically produced and imported hot‐rolled steel can be used in the same applications.127  

Subject imports and domestic product share the same essential chemical and physical

properties.  Hot‐rolled steel is generally manufactured to standard specifications, including

those established by ASTM.128

All responding U.S. producers, a plurality of U.S. importers, and most purchasers

reported that domestic and imported products are always or frequently interchangeable.129  

The majority of producers and U.S. importers that compared subject imports from different

sources also found them to be always or frequently interchangeable with one another.130  

However, responses from purchasers were mixed; while most reported that hot‐rolled steel

was always or frequently interchangeable for most country comparisons, a relatively large

number of purchasers reported that hot‐rolled steel from different sources was sometimes

interchangeable.131

                                                                                                                                                                              

(...Continued)

product, including consideration of specific customer requirements and other quality‐related questions;

(2) the presence of sales or offers to sell in the same geographical markets of imports from different

countries and the domestic like product; (3) the existence of common or similar channels of distribution

for subject imports from different countries and the domestic like product; and (4) whether subject

imports are simultaneously present in the market with one another and the domestic like product.  See,

e.g., Wieland Werke, AG v. United States, 718 F. Supp. 50 (Ct. Int’l Trade 1989).

124 See Mukand Ltd. v. United States, 937 F. Supp. 910, 916 (Ct. Int’l Trade 1996); Wieland

Werke, 718 F. Supp. at 52 (“Completely overlapping markets are not required.”); United States Steel

Group v. United States, 873 F. Supp.  673, 685 (Ct. Int’l Trade 1994), aff’d, 96 F.3d 1352 (Fed. Cir. 1996).  

We note, however, that there have been investigations where the Commission has found an insufficient

overlap in competition and has declined to cumulate subject imports.  See, e.g., Live Cattle from Canada

and Mexico, Inv. Nos. 701‐TA‐386 and 731‐TA‐812‐13 (Preliminary), USITC Pub. 3155 at 15 (Feb. 1999),

aff’d sub nom, Ranchers‐Cattlemen Action Legal Foundation v. United States, 74 F. Supp. 2d 1353 (Ct.

Int’l Trade 1999); Static Random Access Memory Semiconductors from the Republic of Korea and Taiwan,

Inv. Nos. 731‐TA‐761‐62 (Final), USITC Pub. 3098 at 13‐15 (Apr. 1998).

125 See generally, Chefline Corp. v. United States, 219 F. Supp. 2d 1313, 1314 (Ct. Int’l Trade

2002).

126 Original Determinations, USITC Pub. 3446 at 11‐12 and 14; First Five‐Year Reviews, USITC

Pub. 3956 at 15 and 16.

127 CR at II‐39; PR at II‐26.

128 CR at I‐32 and V‐1; PR at I‐26 and V‐1.

129 CR at II‐39 and Table II‐13; PR at II‐26 and Table II‐13.

130 CR at II‐39 and Table II‐13; PR at II‐26 and Table II‐13.

131 CR at II‐39 and Table II‐13; PR at II‐26 and Table II‐13.
 

22

Channels of Distribution.   In both the original determinations and first five‐year reviews,

the majority of both domestically produced and imported hot‐rolled steel was shipped to

distributors/processors/service centers.132  In these reviews, hot‐rolled steel is shipped to

distributors, processors, and service centers; pipe and tube producers; and other end

users/manufacturers, including automobile assemblers and suppliers.133  U.S. producers’ U.S.

shipments were fairly evenly split between distributors/service centers (45.4 percent) and

other end users (43.2 percent) in 2007 but had shifted with a higher percentage of shipments

being directed to other end users (45.4 percent) compared to distributors/services centers

(39.0 percent) in 2012.134  Subject imports were infrequent during the period of review;135 all

sales reported of hot‐rolled steel from Ukraine and India, and most from Taiwan, were shipped

to distributors/service centers; all sales reported of subject imports from China were to other

end users; and all sales reported of subject imports from Thailand were to tubular product

manufacturers.136

Simultaneous Presence and Geographic Overlap.  In both the original investigations and

first five‐year reviews, U.S. producers and importers reported competing in the same

geographic market areas and imports from each of the subject countries had been present in

the U.S. market during at least some portion of the period of review.137  In the current reviews,

there was no subject source whose imports were present in all months of any year and import

levels were low.138 U.S. producers reported nationwide sales and imports from all subject

sources entered through Texas ports.139  Subject imports (when present) and domestic product

thus have been sold in the same geographic markets.   

Conclusion.  The record indicates that U.S.‐produced hot‐rolled steel and subject

imports from all sources generally are fungible.  Although subject imports were infrequent and

at low levels during the period of review, we have previously found that subject imports will

likely enter the U.S. market at levels sufficient to have a discernible adverse impact on the

domestic industry if the orders are revoked.  Therefore, based on the record, including  

evidence from the original investigations and first five‐year reviews, we find that upon

revocation the domestic like product and the subject imports would likely have similar channels

of distribution, geographic overlaps in sales, and simultaneous presence in the U.S. market.  

Consequently, we find that there likely will be a reasonable overlap in competition between the

                                                      

132 Original Determinations, USITC Pub. 3446 at 12 and 13; First Five‐Year Reviews, USITC Pub.

3956 at 16.

133 CR/PR at II‐1.

134 CR/PR at Table II‐1.

135 Data for China, India and Thailand were reported only in one year, for Taiwan and Ukraine

only in three reporting periods, and no data were reported for Indonesia.  CR/PR at II‐1.

136 CR/PR at Table II‐1.

137 Original Determinations, USITC Pub. 3446 at 12‐14; First Five‐Year Reviews, USITC Pub. 3956

at 16 and Table IV‐5.

138 CR/PR at Tables I‐1 and IV‐5.

139 CR at IV‐14 and IV‐15; PR at IV‐10.
 

23

domestic like product and subject imports from each country as well as among subject imports

from each country upon revocation.140

D. Likely Conditions of Competition  

In determining whether to exercise our discretion to cumulate subject imports, we

assess whether subject imports from China, India, Indonesia, Taiwan, Thailand, and Ukraine

would be likely to compete under similar or different conditions in the U.S. market if the orders

were revoked.  We acknowledge that some differences exist among the hot‐rolled steel

industries in the subject countries, but we find that imports from each subject country would

be likely to compete under similar conditions of competition in the U.S. market if the orders

were revoked.  Therefore, we reject respondents’ arguments that we should exercise our

discretion to analyze subject imports from India, Taiwan, or Thailand separately from subject

hot‐rolled steel imports from any of the other subject countries.

Indian, Taiwan, and Thai respondents have presented arguments contending that

imports from each of these countries would likely compete under different conditions than

those pertaining to any other subject countries.141  Each of these respondents primarily relies

on the same competitive behavior – focus on home markets (including the growing automotive

industry), internal consumption, and exports to regional markets – as the conditions that make

the likely behavior of its industry different from the behavior of the industries in the other

subject countries.  The evidence in the record, however, does not support their claims that

differences, if any, would likely be significant.142

As our discussion of no discernible adverse impact indicates, the hot‐rolled steel

industry in each of the subject countries has ample excess capacity, with each subject industry

(except that in Ukraine) increasing its capacity over the period of review.143  Moreover, the

capacity levels of the industry in China is extremely large and the industry in India is large,

having increased substantially during the period of review.144  All six subject countries export

                                                      

140 Commissioners Broadbent and Kieff do not reach the question of whether a reasonable

overlap of competition between subject imports from Indonesia and other subject imports or the

domestic like product would be likely upon revocation. They concur with all other findings and

conclusions regarding the likelihood of a reasonable overlap of competition between the domestic like

product and subject imports from China, India, Taiwan, and Thailand, and among subject imports from

those countries as well. 141 See, e.g., Essar/JSW Prehearing Brief at 10; Essar/JSW Posthearing Brief at 7‐14; Shang Chen

Prehearing Brief at 12‐24; Shang Chen Posthearing Brief at 7‐11; SSI Prehearing Brief at 3‐19; SSI

Posthearing Brief at 2‐11.

142 In the first five‐year reviews, the Commission found that there were no significant

distinctions in the likely conditions of competition between subject imports from China, India, Indonesia,

Taiwan, Thailand, and Ukraine, and therefore exercised its discretion to cumulate subject imports from

these six countries.  First Five‐Year Review, USITC Pub. 3956 at 18‐20.

143 CR/PR at Table IV‐6.  Excess capacity for hot‐rolled steel ranged from *** short tons to ***

short tons for five of the six countries and was an enormous *** short tons for China in 2012.  Id. 144 See CR/PR at Table IV‐6.
 

24

hot‐rolled steel.145 Both India and Thailand were net importers of hot‐rolled steel in 2012 (as

was Indonesia) and respondents from those countries maintain that their focus is on their

home market, particularly the growing automotive industries.  Notwithstanding that a majority

of shipments of the industries in India, Taiwan, and Thailand were to the home market and/or

internally consumed during the period of review, Indian and Taiwanese producers exported an

increasing share of total shipments over the period of review, and Indian and Thai producers

had substantial volumes of excess capacity.146

Given the highly fungible nature of hot‐rolled steel, we find that imports of hot‐rolled

steel from each of the subject countries would likely compete directly with one another and the

domestic like product in the event of revocation.  Accordingly, we do not find different

conditions of competition sufficient to warrant our declining to exercise our discretion to

cumulate subject imports from China, India, Indonesia, Taiwan, Thailand, and Ukraine.147   

E. Conclusion

We find that the no discernible adverse impact exception to cumulation does not apply

and that there would likely be a reasonable overlap of competition between subject imports

from each country and the domestic like product as well as among subject imports from each

country.  We also determine that subject imports from China, India, Indonesia, Taiwan,

Thailand, and Ukraine would be likely to compete under similar conditions of competition.148  

Accordingly, for the reasons discussed above, we exercise our discretion to cumulate subject

imports from China, India, Indonesia, Taiwan, Thailand, and Ukraine.149

                                                      

145 CR/PR at Table IV‐6 (Exports by subject countries in 2012 were China:  10.7 million short tons

in 2012; India:  1.8 million short tons; Indonesia:  19,000 short tons; Taiwan:  ***; Thailand:  27,000

short tons; and Ukraine:  3.0 million short tons).

146 CR/PR at Tables IV‐9, 11, 17, and 19. 147 Commissioners Broadbent and Kieff do not reach the question of whether subject imports

from Indonesia would likely compete under similar or different conditions in the U.S. market upon

revocation. They concur with all other findings and conclusions that subject imports from China, India,

Taiwan, Thailand, and Ukraine would likely complete under similar conditions of competition in the U.S.

market upon revocation.

148 Commissioner Pinkert explains his analysis of other considerations as follows.  Where, in a

five‐year review, he does not find that imports of the subject merchandise would be likely to have no

discernible adverse impact on the domestic industry in the event of revocation, and finds that such

imports would be likely to compete with each other and with the domestic like product in the U.S.

market, he cumulates them unless there is a condition or propensity – not merely a trend – that is likely

to persist for a reasonably foreseeable time and that significantly limits competition such that

cumulation is not warranted.  He finds that there is no evidence on this record of such a condition or

propensity with respect to imports from any of the subject countries.  Consequently, he has cumulated

all such imports.

149 For the reasons discussed above and in their separate views, Commissioners Broadbent and

Kieff exercise their discretion to cumulate subject imports from China, India, Taiwan, Thailand, and

Ukraine.
 

25

IV. Whether Revocation of the Antidumping and Countervailing Duty Orders

Would Likely Lead to Continuation or Recurrence of Material Injury

Within a Reasonably Foreseeable Time  

A. Legal Standards

In a five‐year review conducted under section 751(c) of the Tariff Act, Commerce will

revoke an antidumping or countervailing duty order unless: (1) it makes a determination that

dumping or subsidization is likely to continue or recur and (2) the Commission makes a

determination that revocation of the antidumping or countervailing duty order “would be likely

to lead to continuation or recurrence of material injury within a reasonably foreseeable

time.”150  The SAA states that “under the likelihood standard, the Commission will engage in a

counterfactual analysis; it must decide the likely impact in the reasonably foreseeable future of

an important change in the status quo – the revocation or termination of a proceeding and the

elimination of its restraining effects on volumes and prices of imports.”151  Thus, the likelihood

standard is prospective in nature.152  The U.S. Court of International Trade has found that

“likely,” as used in the five‐year review provisions of the Act, means “probable,” and the

Commission applies that standard in five‐year reviews.153  

The statute states that “the Commission shall consider that the effects of revocation or

termination may not be imminent, but may manifest themselves only over a longer period of

time.”154 According to the SAA, a “‘reasonably foreseeable time’ will vary from case‐to‐case, but

                                                       

150 19 U.S.C. § 1675a(a).

151 SAA at 883‐84.  The SAA states that “{t}he likelihood of injury standard applies regardless of

the nature of the Commission’s original determination (material injury, threat of material injury, or

material retardation of an industry).  Likewise, the standard applies to suspended investigations that

were never completed.”  Id. at 883.

152 While the SAA states that “a separate determination regarding current material injury is not

necessary,” it indicates that “the Commission may consider relevant factors such as current and likely

continued depressed shipment levels and current and likely continued {sic} prices for the domestic like

product in the U.S. market in making its determination of the likelihood of continuation or recurrence of

material injury if the order is revoked.”  SAA at 884.

153 See NMB Singapore Ltd. v. United States, 288 F. Supp. 2d 1306, 1352 (Ct. Int’l Trade 2003)

(“‘likely’ means probable within the context of 19 U.S.C. § 1675(c) and 19 U.S.C. § 1675a(a)”), aff’d

mem., 140 Fed. Appx. 268 (Fed. Cir. 2005); Nippon Steel Corp. v. United States, 26 CIT 1416, 1419 (2002)

(same); Usinor Industeel, S.A. v. United States, 26 CIT 1402, 1404 nn.3, 6 (2002) (“more likely than not”

standard is “consistent with the court’s opinion;” “the court has not interpreted ‘likely’ to imply any

particular degree of ‘certainty’”); Indorama Chemicals (Thailand) Ltd. v. United States, 26 CIT 1059, 1070

(2002) (“standard is based on a likelihood of continuation or recurrence of injury, not a certainty”);

Usinor v. United States, 26 CIT 767, 794 (2002) (“‘likely’ is tantamount to ‘probable,’ not merely

‘possible’”).

154 19 U.S.C. § 1675a(a)(5).
 

26

normally will exceed the ‘imminent’ timeframe applicable in a threat of injury analysis in

original investigations.”155

Although the standard in a five‐year review is not the same as the standard applied in an

original investigation, it contains some of the same fundamental elements.  The statute

provides that the Commission is to “consider the likely volume, price effect, and impact of

imports of the subject merchandise on the industry if the orders are revoked or the suspended

investigation is terminated.”156  It directs the Commission to take into account its prior injury

determination, whether any improvement in the state of the industry is related to the order or

the suspension agreement under review, whether the industry is vulnerable to material injury if

the orders are revoked or a suspension agreement is terminated, and any findings by

Commerce regarding duty absorption pursuant to 19 U.S.C. § 1675(a)(4).157  The statute further

provides that the presence or absence of any factor that the Commission is required to consider

shall not necessarily give decisive guidance with respect to the Commission’s determination.158

In evaluating the likely volume of imports of subject merchandise if the orders under

review are revoked and/or a suspended investigation is terminated, the Commission is directed

to consider whether the likely volume of imports would be significant either in absolute terms

or relative to production or consumption in the United States.159  In doing so, the Commission

must consider “all relevant economic factors,” including four enumerated factors:  (1) any likely

increase in production capacity or existing unused production capacity in the exporting country;

(2) existing inventories of the subject merchandise, or likely increases in inventories; (3) the

existence of barriers to the importation of the subject merchandise into countries other than

the United States; and (4) the potential for product shifting if production facilities in the foreign

country, which can be used to produce the subject merchandise, are currently being used to

produce other products.160

In evaluating the likely price effects of subject imports if the orders under review are

revoked and/or a suspended investigation is terminated, the Commission is directed to

consider whether there is likely to be significant underselling by the subject imports as

compared to the domestic like product and whether the subject imports are likely to enter the

                                                      

155 SAA at 887.  Among the factors that the Commission should consider in this regard are “the

fungibility or differentiation within the product in question, the level of substitutability between the

imported and domestic products, the channels of distribution used, the methods of contracting (such as

spot sales or long‐term contracts), and lead times for delivery of goods, as well as other factors that may

only manifest themselves in the longer term, such as planned investment and the shifting of production

facilities.”  Id. 156 19 U.S.C. § 1675a(a)(1).

157 19 U.S.C. § 1675a(a)(1).  Commerce has not issued any duty absorption findings with respect

to hot‐rolled steel from China, India, Indonesia, Taiwan, Thailand, and Ukraine.  CR at I‐20, n.22; PR at I‐

17, n.22.

158 19 U.S.C. § 1675a(a)(5).  Although the Commission must consider all factors, no one factor is

necessarily dispositive.  SAA at 886.

159 19 U.S.C. § 1675a(a)(2).

160 19 U.S.C. § 1675a(a)(2)(A‐D).
 

27

United States at prices that otherwise would have a significant depressing or suppressing effect

on the price of the domestic like product.161

In evaluating the likely impact of imports of subject merchandise if the orders under

review are revoked and/or a suspended investigation is terminated, the Commission is directed

to consider all relevant economic factors that are likely to have a bearing on the state of the

industry in the United States, including but not limited to the following:  (1) likely declines in

output, sales, market share, profits, productivity, return on investments, and utilization of

capacity; (2) likely negative effects on cash flow, inventories, employment, wages, growth,

ability to raise capital, and investment; and (3) likely negative effects on the existing

development and production efforts of the industry, including efforts to develop a derivative or

more advanced version of the domestic like product.162  All relevant economic factors are to be

considered within the context of the business cycle and the conditions of competition that are

distinctive to the industry.  As instructed by the statute, we have considered the extent to

which any improvement in the state of the domestic industry is related to the orders under

review and whether the industry is vulnerable to material injury upon revocation.163

B. Conditions of Competition and the Business Cycle

In evaluating the likely impact of the subject imports on the domestic industry if an

order is revoked, the statute directs the Commission to consider all relevant economic factors

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

the affected industry.”164

1. Findings in the Original Investigations and Prior Reviews

Original Investigations.  In the original determinations, the Commission first determined

that the captive production provision applied.165  The Commission indicated that, thus, it would

“focus our analysis primarily on the merchant market for hot‐rolled steel products in

considering market share and financial performance of the domestic industry.”166

                                                      

161 See 19 U.S.C. § 1675a(a)(3).  The SAA states that “{c}onsistent with its practice in

investigations, in considering the likely price effects of imports in the event of revocation and

termination, the Commission may rely on circumstantial, as well as direct, evidence of the adverse

effects of unfairly traded imports on domestic prices.”  SAA at 886.

162 19 U.S.C. § 1675a(a)(4).

163 The SAA states that in assessing whether the domestic industry is vulnerable to injury if the

order is revoked, 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 may also demonstrate that an industry is facing difficulties from a variety of

sources and is vulnerable to dumped or subsidized imports.”  SAA at 885.

164 19 U.S.C. § 1675a(a)(4).

165 The statutory captive production provision does not apply to five‐year reviews.  See, e.g.,

Certain Hot‐Rolled Flat‐Rolled Carbon‐Quality Steel Products from Brazil, Japan, and Russia, Inv. Nos.

701‐TA‐384 and 731‐TA‐806‐808 (Review), USITC Pub. 3767 (April 2005) at 29 n.165.

166 Original Determinations, USITC Pub. 3446 at 15 and 16.
 

28

The Commission identified several other pertinent conditions of competition.167  With

respect to demand, it observed that demand for hot‐rolled steel is derived from demand for

downstream products, such as pipes and tubes, automobiles, trucks, applications, and

machinery.  It stated that, during the period of investigation, apparent consumption both in the

merchant market and overall had declined.168

With respect to supply, the Commission found the domestic industry consisted of

integrated producers using basic oxygen furnaces (“BOFs”) and non‐integrated producers,

which used electric arc furnaces (“EAFs”) or purchased, rather than produced, their slab needs.  

Domestic producers steadily increased capacity between 1998 and 2000, despite the fact that

bankruptcy affected numerous firms, thereby removing an estimated *** percent of capacity

from the domestic industry in 2000.  The Commission recognized that although the source of

imports changed during the period of investigation, imports remained an important segment of

the market.169

The Commission found there were no effective substitutes for hot‐rolled steel and that

there was a fair degree of substitutability among hot‐rolled steel products from various

countries, and also between subject imports and the domestic like product.  Finally, the

Commission observed that service centers, processors, and distributors were important

purchasers of hot‐rolled steel and that most sales of both domestically produced hot‐rolled

steel and subject imports were made in the spot market.170

First Five‐Year Reviews.  In the first five‐year reviews, the Commission found that while

many of the conditions of competition in the original investigations continued to exist, there

were some differences which were relevant to its determinations.171

Demand for hot‐rolled steel continued to depend on the level of demand for certain

downstream uses and had slowed due to decreased demand in the automotive and residential

housing markets.  In 2006, approximately 60 percent of total domestic shipments of certain

hot‐rolled steel was either consumed internally within domestic mills or transferred to affiliated

companies for further processing.  These intra‐company transfers were primarily used in the

production of cold‐rolled steel and pipe and tube products.  For domestic commercial market

shipments of hot‐rolled steel, the automotive sector accounted for approximately 49 percent of  

shipments, with approximately 38 percent shipped to the construction sector; remaining

shipments were to other sectors, such as to the agricultural sector and to the manufacturers of

machinery, industrial equipment, and tools.172

Regarding supply, domestic producers continued to supply over 90 percent of the U.S.

hot‐rolled steel market; the industry still consisted of both integrated producers and

                                                      

167 See Original Determinations, USITC Pub. 3446 at 16‐19.

168 See Original Determinations, USITC Pub. 3446 at 16‐19.

169 See Original Determinations, USITC Pub. 3446 at 16‐19.

170 See Original Determinations, USITC Pub. 3446 at 16‐19. 171 See First Five‐Year Reviews, USITC Pub. 3956 at 26‐31.

172 First Five‐Year Reviews, USITC Pub. 3956 at 26 and 27.
 

29

nonintegrated or scrap‐based producers (“minimills”); and the industry continued to use

substantially the same principal technology for producing hot‐rolled steel – the hot‐strip mill.

The industry had restructured since the original investigations.  Bankruptcies,

consolidations, and reorganizations had changed the composition of domestic producers, and

allowed domestic producers to reduce their production costs and increase their productivity. 

Thus, while hot‐rolled steel production remained capital intensive, the domestic industry

appeared better able to adjust output and prices in response to changes in the market

environment over the course of the business cycle than during the original investigations.  In

addition, a number of investments had been undertaken or were planned that would add new

capacity to the domestic industry.173

The Commission continued to find hot‐rolled steel from different sources to be broadly

interchangeable and price to be an important factor in purchasing decisions, as it was in the

original investigations. While the majority of sales by domestic producers continued to be on a

spot basis, many domestic producers reported that, since 2001, the percentage of contract

sales relative to spot sales had increased; contracts had become shorter, shifting away from

being multi‐year to annual (or shorter) contracts, particularly for sales to the automotive sector.  

Finally, the Commission observed that demand and supply of hot‐rolled steel outside the

United States increased during the review period, with the largest consumption growth in

China.174

2. Current Reviews

  The following conditions of competition inform our determinations in the current

reviews.

a) Demand Conditions

As the Commission found in prior proceedings, U.S. demand for hot‐rolled steel is a

function of the demand for the downstream products that incorporate hot‐rolled steel. These

include a vast array of applications in the automotive, automobile parts, appliance, and

construction industries.175  As has been the case in prior proceedings, the majority of U.S. hot‐

rolled steel production is internally consumed, with the remaining shipments sold in the

merchant market.  In 2012, approximately 58 percent of total domestic shipments of certain

hot‐rolled steel was either consumed internally within domestic mills or transferred to affiliated

companies for further processing.176  The primary use for these intra‐company transfers is in the

production of cut‐to‐length plate, cold‐rolled and/or galvanized or plated products, and pipe

                                                      

173 First Five‐Year Reviews, USITC Pub. 3956 at 27‐29. 174 First Five‐Year Reviews, USITC Pub. 3956 at 29‐31.  The Commission noted that although

China had been a net importer of hot‐rolled steel, its substantial increases in capacity had slowed

imports into China of hot‐rolled steel and resulted in China becoming a net exporter of hot‐rolled steel

in the latter part of the period of review.  Id. at 31.

175 CR at II‐14; PR at II‐10.

176 CR/PR at Table III‐7.
 

30

and tube products.177  Thus, demand for hot‐rolled steel also is driven by the demand in the

market sectors for these finished downstream products.

For U.S. market shipments of hot‐rolled steel, the automotive sector accounted for

approximately 41.4 percent of domestic shipments, with approximately 20.4 percent shipped to

the construction sector, 23.5 percent to companies for conversion and processing (e.g., into

pipes and tubes), and the remainder to container (6.7 percent), appliance (4.5 percent), and

other sectors.178  Based on Commission questionnaire responses, U.S. producers reported in

2012 that 39.0 percent of their total U.S. shipments were to distributors/service centers, 15.6

percent to manufacturers of tubular products, and 45.4 percent to other end users.179

Demand for hot‐rolled steel in the United States tends to follow broad demand trends in

the U.S. economy, which drives specific trends in the automotive, construction, and energy

sectors.180  As a result, steel demand expands and contracts when the economy does.

  Over the period of review, apparent U.S. consumption declined overall by 4.1 percent

from 62.6 million short tons in 2007 to 60.0 million short tons in 2012.181 Apparent U.S.

                                                      

177 CR at I‐30; PR at I‐25.  Hot‐rolled steel is the only product that can be used to make cold‐

rolled steel, which in turn may be further processed into galvanized steel or tin‐ and chromium‐coated

steel sheets.

178 CR at II‐17; PR at II‐11.  In the first five‐year reviews, the Commission also collected data on

the market sectors for the downstream products produced from hot‐rolled steel.  For commercial

shipments of cold‐rolled steel in 2006, the automotive sector accounted for approximately 48 percent of

domestic shipments, followed by the appliance/utensils/cutlery sector (approximately 14 percent), the

electrical equipment sector (approximately 11 percent), and the containers/packaging/shipping material

sector (approximately 10 percent).  First Five‐Year Review at II‐16.  For commercial shipments of

galvanized steel in 2006, the automotive sector accounted for approximately 64 percent of domestic

shipments, followed by the construction/contractors’ products sector (approximately 28 percent), the

appliance/utensils/cutlery sector (approximately 6 percent), and the electrical equipment sector

(approximately 1 percent).  The vast majority of tin‐ and chromium‐coated steel was shipped to the

containers/packaging/shipping material sector.  Id. 179 CR/PR at Table II‐1.  Internal consumption and transfers to related firms, which accounted for

58 percent of total U.S. producers’ shipments, are included in these U.S. shipments data.  There were

limited subject imports, but importers from nonsubject countries reported in 2012 that 59.4 percent of

their total U.S. shipments were to distributors/service centers, 14.9 percent to manufacturers of tubular

products, and 25.7 percent to other end users.  Id. 180 CR at II‐15‐16; PR at II‐10‐12.  While there may be different business cycles for the different

end use industries, the majority of producers, importers, and purchasers reported that there were not  

business cycles or conditions of competition distinctive to the hot‐rolled steel industry.  CR at II‐20; PR at

II‐14.  Fourteen of 34 responding purchasers reported affirmatively that the hot‐rolled steel industry is

subject to business cycles, with 8 of 28 responding purchasers reporting that the industry is subject to

distinctive conditions of competition.  Distinctive conditions of competition identified included excess

capacity, particularly in China, increased competition from U.S. producers and importers, changes in

input costs, and price sensitivity to demand.  Id. 181 CR/PR at Tables I‐1 and C‐1.  Service center inventories of flat‐rolled steel (which include hot‐

rolled steel as well as nonsubject cold‐rolled steel and coated steel) reportedly were at high levels in

(Continued...)
 

31

consumption of hot‐rolled steel, which fluctuated annually during the 2001‐2006 period,

declined substantially to a low of 38.0 million short tons in 2009, as a recession in the United

States caused gross domestic product (GDP) to drop during the latter portion of 2008 and

2009.182  GDP growth resumed in the fourth quarter of 2009, and generally continued for the

rest of the period of review, although growth was more sluggish and fairly modest in

automotive sales and in construction spending.183  Apparent U.S. consumption of hot‐rolled

steel increased in each year from 2010 to 2012, but remained at a level below that for the 2007

peak.184  Apparent U.S. consumption was 3.3 percent lower in interim 2013 compared with

interim 2012.185

Responses from producers, importers, and purchasers were mixed regarding whether

they anticipated likely increases or fluctuations in demand.186  *** forecasts consumption in

North America to steadily increase by almost *** annually from 2014 to 2017.187  Domestic

producers reported that lightweighting steel for use in automobile production will likely reduce

hot‐rolled steel demand in the United States *** and will offset other factors that would tend

to increase demand such as an improving economy.188  Moreover, responding purchasers have

indicated that the recession and higher fuel prices caused consumers to shift to lighter, more

fuel‐efficient vehicles which use less hot‐rolled steel, and that they expect this shift in vehicle

types to be permanent for many consumers.189

                                                                                                                                                                              

(...Continued)

January 2007, declining by over 4 million short tons until mid‐2009, increasing by about 2 million short

tons by January 2011 and have remained at about that level for the rest of the period of review.  CR/PR

at Figure III‐2.

182 CR/PR at Table I‐1 and Figure II‐1.

183 CR/PR at Figures II‐1‐3; CR at II‐17‐19; PR at II‐10‐12.

184 CR/PR at Tables I‐1 and C‐1.

185 CR/PR at Tables I‐1 and C‐1.

186 CR at II‐22‐23 and Table II‐5; PR at II‐15‐16 and Table II‐5.  When asked about anticipated

changes in demand for hot‐rolled steel in the U.S. market, increases in demand were reported by 5 of 11

responding producers, 8 of 26 responding importers, 12 of 35 responding purchasers, and all 7

responding foreign producers; fluctuations in demand were reported by 4 responding producers, 12

responding importers, and 17 responding purchasers; and a decrease in demand was reported by only

one purchaser.  Id. 187 CR/PR at Table IV‐27.

188 CR at I‐32; PR at I‐26.  As a result of the increasing importance of lightweighting, steel

producers  strive to produce advanced higher‐strength steels in thinner gauges to substitute for regular‐

strength hot‐rolled or even cold‐rolled steel in thicknesses of 2 mm or less.  Automotive producers use

the thinner higher‐strength steels, and substitute other materials for steel, to reduce a vehicle’s

structural weight by as much as 39 percent, or “lightweight” vehicles.  Automotive producers

increasingly seek to reduce the weight of vehicles to meet regulatory requirements such as the U.S.

Corporate Average Fuel Economy (CAFE) requirements.  CR at I‐31; PR at I‐26.

189 CR at II‐22; PR at II‐15.
 

32

b) Supply Conditions

During the period of review, domestic producers continued to supply over 90 percent of

the total U.S. hot‐rolled steel market and over 85 percent of the merchant market, with the

remainder supplied by subject and nonsubject imports.190  The composition of the industry –

both integrated producers and nonintegrated or scrap‐based producers (“minimills”) – has not

changed.191  Nor have there been substantial changes in the principal technology for producing

hot‐rolled steel.192  The majority of hot‐rolled steel produced is internally consumed or

transferred to an affiliated company to make cold‐rolled steel and/or galvanized or plated

products, formed and welded to make pipe, or cut to length to produce discrete plate or

sheet.193

The consolidation and restructuring of the domestic steel industry continued during the

period of review, but to a lesser extent than occurred between the original investigations and

the first reviews.  During the period of review, 14 U.S. producers of hot‐rolled steel accounted

for over 95 percent of the U.S. production, whereas 16 U.S. producers of hot‐rolled steel

accounted for virtually all U.S. production in 2006 and 21 firms accounted for over 90 percent

of the U.S. production of hot‐rolled steel in 2000 at the time of the original investigations.194

                                                      

190 During the period of review, domestic producers’ share of apparent U.S. consumption

fluctuated within a narrow range between 93.6 percent and 94.6 percent of the total market and

between 85.3 percent and 87.6 percent of the merchant market.  CR/PR at Tables I‐1, I‐12, and C‐1.

191 The integrated producers generally use a basic oxygen furnace (BOF) to produce molten steel

primarily from raw materials iron ore and coke and a limited amount of scrap, and nonintegrated or

scrap‐based producers (“minimills”) use electric arc furnaces (EAF) to produce molten steel by melting

scrap metal supplemented with primary iron products.  CR at I‐32‐39; PR at I‐27‐31.  Each of these types

of operations has a different inherent cost structure:  an integrated producer typically has higher fixed

costs and higher value added whereas a mini‐mill generally has higher raw material costs but less value

added.  CR at I‐33; PR at I‐27.

192 The industry continues to develop improvements in the process of producing hot‐rolled steel.  

In the melting stage, two such improvements include the Conarc (i.e., combines both the integrated and

EAF processes into a single production unit) and Corex technologies (i.e., allows integrated mills to smelt

iron ore using mostly coal instead of expensive coke).  CR at I‐36‐37; PR at I‐29.  In the rolling stage,

Nucor continues to improve a process, “strip casting” (trademarked as “Castrip”), in which liquid steel is

directly cast into a strip less than 2mm thick, eliminating the need for slabs; Nucor commenced

operation on a second more advanced unit in 2009.  Nucor has the exclusive license in the United States

to use this process.  CR at  I‐38 and n. 48; PR at I‐30 and n. 48.

193 CR at I‐30; PR at I‐25.

194 CR at I‐41; PR at I‐33.  The five largest hot‐rolled steel producers accounted for *** of hot‐

rolled steel production in 2012 were:  ***.  CR/PR at Table I‐8.  The consolidations during the period of

review have included:  Beta Steel and Duferco Farrell acquired by NLMK; Lone Star’s hot‐rolled

operations shut down by U.S. Steel; and WCI Steel, Esmark, and Sparrow Point operations acquired by

Severstal in 2008, sold to RG Steel in 2011, and closed and sold to liquidators in 2012.  CR/PR at Figure I‐

1.
 

33

Several domestic steel producers idled mills temporarily and closed operations

permanently, while one domestic producer filed for bankruptcy.195   The domestic industry’s

capacity was 6.9 percent lower in 2012 than it was in 2007.196 As evident during the prior

reviews, while hot‐rolled steel production remains capital intensive, domestic producers have

been able to reduce their production costs and increase their productivity.197

In these reviews, a number of investments have been undertaken or are planned that

will add new capacity to the domestic industry.  Between January 2007 and June 2013, two

firms began production of hot‐rolled steel:  SeverCorr (later Severstal Columbus) in October

2007, and ThyssenKrupp in July 2010.198  In addition, a proposed new steel mill, Big River Steel

in Arkansas, with a reported groundbreaking planned for the first quarter of 2014, will have an

annual capacity of 1.7 million short tons.199   

Imports from the cumulated subject sources had only a minimal presence in the U.S.

market, as imports from nonsubject sources maintained their presence and increased slightly

overall during the period of review.200

c) Substitutability and Other Conditions

While there are some quality differences and differences in product mix, domestically

produced and imported hot‐rolled steel generally are interchangeable,201  share the same

                                                      

195 RG Steel ceased production at its Wheeling, West Virginia facility in March 2009 and at its

Sparrows Point, Maryland and Warren, Ohio facilities in May 2012 when it entered into bankruptcy

proceedings.  *** during the period of review.  CR at III‐11 and Table III‐2; PR at III‐4 and Table III‐2.

196 CR/PR at Table C‐1.

197 Other factory costs, as a ratio to net sales, decreased from 27.3 percent in 2007 to 20.8

percent in 2012.  CR/PR at Table III‐11.  Productivity increased by 1.4 percent from 2007 to 2012.  Id. at

Table C‐1.

198 CR at III‐11; PR at III‐4.  In December 2013, ArcelorMittal SA and Nippon Steel & Sumitomo

Metal Corp. agreed to purchase ThyssenKrupp AG’s Calvert, Alabama facility for $1.55 billion subject to

antitrust regulatory approval.  CR/PR at Table III‐1.

199 CR at I‐42, n.63; PR at I‐33, n.63.

200 Subject imports’ share of the U.S. market on a cumulated basis was less than 0.05 percent in

every period examined in these reviews.  CR/PR at Tables I‐1 and C‐1.  Subject imports’ share of the U.S.

commercial market on a cumulated basis was 0.1 percent in 2007, and then less than 0.05 percent in

every period examined in these reviews.  Id. at Table I‐12.  The market share of imports from nonsubject

sources, which was 5.3 percent in 2007, increased irregularly to a period high of 6.3 percent in 2011 and

2012.  CR/PR at Tables I‐1 and C‐1.  Nonsubject imports’ share of the U.S. commercial market, which was

12.4 percent in 2007, increased irregularly to 14.2 percent in 2012.  Id. at Table I‐12.  In 2012, the two

largest sources of nonsubject hot‐rolled steel imports were Canada, and then Korea, followed distantly

by the third‐largest source, imports from Mexico.  CR/PR at Table IV‐2.

201 CR at II‐25 and II‐39, and Table II‐13; PR at II‐17, II‐26, and Table II‐13.  All responding U.S.

producers, a plurality of U.S. importers, and most purchasers reported that domestic and imported

products are “always” or “frequently” interchangeable.   The majority of producers and importers that

compared subject imports from different sources also found them to be “always” or “frequently”

(Continued...)
 

34

essential chemical and physical properties, and are used in the same applications.  Hot‐rolled

steel is generally manufactured to standard specifications, including those established by

ASTM.202  The degree of substitutability depends on the characteristics and requirements for a

specific application or end use and not necessarily on whether it is domestically produced or

imported.  The majority of responding purchasers tended to buy from sources regardless of

country of origin, indicating that they sometimes or never made their purchasing decision

based on country of origin.203  In comparisons between the U.S. product and product from each

subject country, responses generally were split between ranking the U.S. product superior to

the subject product and ranking it comparable.204

Moreover, the general importance of price in purchasing decisions has not changed

since the time of the original investigations.205  In these reviews, price was reported as one of

the top three most important factors in purchasing decisions by the largest number of

purchasers, followed by quality.206  The majority of purchasers indicated that they required

certain quality characteristics, which are considered readily available from U.S. producers and

to a lesser extent from suppliers in all subject countries.207  In light of the high degree of

interchangeability and comparable quality of hot‐rolled steel from different sources, price will

likely continue to be the principal factor influencing purchasing decisions in the reasonably

foreseeable future.

                                                                                                                                                                              

(...Continued)

interchangeable with one another.   However, responses from purchasers were mixed; while most

purchasers reported that hot‐rolled steel was “always” or “frequently” interchangeable for most country

comparisons, a relatively large number of purchasers reported that product from different sources were

“sometimes” interchangeable.  Id. 202 CR at I‐32; PR at I‐26.

203 CR/PR at Table II‐7.  Some purchasers reported that country of origin is “always” or

“sometimes” important and indicated the reasons why, including “Buy American” policies, a preference

for U.S. hot‐rolled steel, sourcing completely from ***, and the importance of geographical proximity to

their manufacturing and assembly sites.  CR at II‐27; PR at II‐18‐19.  Ford Motor Company stated that it

purchases *** of its hot‐rolled steel for its North American operations from the United States and

Canada, since it cannot risk delivery delays which could ***.   Ford’s Statement at 1‐2.

204 CR/PR at Table II‐12.

205 See Original Determinations, USITC Pub. 3446 at 21.

206 CR/PR at Table II‐8.  When asked to rank the top three factors influencing their purchasing

decisions, the largest number of purchasers (32 of 36 firms) cited price, and the second largest number

(30 of 36 firms) cited quality.  Id.  Quality was the most frequently cited most important factor (cited by

14 purchasers), with price the second most frequently listed leading factor (cited by 12 purchasers).  Id.  

When asked how often they purchased hot‐rolled steel offered at the lowest price, six of 37 purchasers

reported “always,” 18 reported “usually,” 10 reported “sometimes,” three reported “rarely,” and one

reported “never.”  CR at II‐29 and II‐30; PR at II‐19 and II‐20.  In rating 18 factors in terms of their

importance to purchasing decisions, the factors deemed “very important” by the most purchasers were

product consistency and reliability of supply (35 purchasers), price, availability, and quality meets

industry standards (34 purchasers), and delivery time (32 purchasers).  CR/PR at Table II‐10.

207 CR/PR at Table II‐11.
 

35

While the majority of sales by domestic producers and all sales of subject imports

continue to be on a spot basis, a substantial share of sales by domestic producers are on a

short‐term contract basis.208  Raw materials, as a share of cost of goods sold for domestic

producers of hot‐rolled steel, increased irregularly from 61.2 percent in 2007 to 70.0 percent in

2011, before decreasing slightly to 69.4 percent in 2012.209  Nine of 12 responding producers

indicated that they expected that raw material prices would continue to be volatile.210  Many

contracts provide that a surcharge may be added to sales to account for increases in energy or

raw material costs.211

Both demand and supply of hot‐rolled steel outside the United States increased during

the review period.212  All of the major consuming regions increased consumption relatively

steadily during this period with the exception of Europe, where consumption steadily

decreased during 2011‐13 as weak demand persisted in that region.213  Consumption is

expected to rise steadily both globally and for all regions during the 2014‐2017 period.214

C. Revocation of the Antidumping and Countervailing Duty Orders Are Likely to

Lead to the Continuation or Recurrence of Material Injury to the Domestic

Industry within a Reasonably Foreseeable Time215

1. Likely Volume of Subject Imports

a) The Original Investigations

In the original determinations, the Commission found that despite declines in apparent

domestic consumption in both the merchant market and overall, cumulated subject imports

rose significantly during the period of investigation; between 1998 and 2000, the volume of

subject imports increased by 203.4 percent.216  Subject imports’ market share rose from 1.9

percent of apparent domestic consumption and 4.4 percent of the merchant market in 1998 to

5.9 percent of apparent domestic consumption and 14.8 percent of the merchant market in

2000.  The Commission found that domestic shipments – whether total, merchant market, or a

specific segment of the market (e.g., minimill shipments) – either did not keep pace with

increases in subject imports or declined as subject imports increased.  The Commission also

                                                      

208 CR at V‐9 and 10; PR at V‐7.

209 CR/PR at V‐2.

210 CR at V‐5; PR at V‐3. 211 CR at V‐6; PR at V‐4. 212 CR/PR at Table IV‐24 and 26.  Global consumption increased during 2009‐2013 by *** (***

short tons).  China alone accounts for about half of the increase (*** short tons) but its consumption

increase was less than its production increase (*** short tons) during this period.  Id.

213 CR at IV‐57 and 58; PR at IV‐38.

214 CR/PR at Table IV‐27.

215 Commissioners Broadbent and Kieff join the likely volume, like price effects, and likely impact

analyses below for the five subject countries they cumulate.

216 See Original Determinations, USITC Pub. 3446 at 19‐21.
 

36

recognized that inventories remained high at the end of the period of investigation and

continued to exert downward pressure on orders for the domestic like product.  Accordingly,

the Commission found that subject import volume, both in absolute terms and relative to

consumption in the United States, was significant.217

b) First Five‐Year Reviews

In the first five‐year reviews, the Commission found that the volume and market share

of cumulated subject imports from China, India, Indonesia, Taiwan, Thailand, and Ukraine fell

dramatically as a result of the imposition of the orders.218  The Commission found that the

information available in the first five‐year reviews indicated that the hot‐rolled steel industries

in these six subject countries, on a cumulated basis, had significant and substantially increasing

production capacity, considerable unused capacity, and that they exported substantial and

increasing volumes of hot‐rolled steel.219  It added that, despite subject producers’ plans to

invest in additional capacity, their production had not kept pace with already existing capacity,

resulting in large quantities of excess capacity.220

Moreover, not only did the industries in the six subject countries have substantial excess

capacity, even based on conservative estimates, but they also exported substantial and

increasing volumes of hot‐rolled steel in the first five‐year reviews.221  The Commission also

cited the attractiveness of the relatively open U.S. market.  It found that higher U.S. prices

would serve as an incentive for producers in the subject countries to direct exports currently

shipped to other markets to the U.S. market if the orders were revoked.  Finally, the

Commission observed that hot‐rolled steel exports from each of these six subject countries had

been subject to numerous antidumping duty orders, tariffs, and related trade barriers in other

markets during the first review period, which provided an incentive to direct export shipments

to the U.S. market.222

   

                                                      

217 Original Determinations, USITC Pub. 3446 at 19‐21.

218 See First Five‐Year Review, USITC Pub. 3956 at 31‐35.

219 The Commission noted that the lack of participation by producers from certain subject

countries (China, India, Indonesia, and Ukraine) had prevented it from assembling a single consistent

and comprehensive set of capacity data for subject hot‐rolled steel producers in the six subject

countries.  First Five‐Year Reviews, USITC Pub. 3956 at 32.

220 First Five‐Year Reviews, USITC Pub. 3956 at 32 and 33. 221 First Five‐Year Reviews, USITC Pub. 3956 at 33 and 34.  Specifically, China accounted for a

large share of the increases in capacity.  Its shift from being a net importer to being a net exporter in the

first five‐year reviews had a two‐fold effect on the industries in many of these subject countries:  they

had seen their exports to China decline substantially and China had started to export to their home and

other third‐country markets.  While India was a net importer of hot‐rolled steel, its industry still

exported substantial volumes, including more than doubling its exports to the European Union from

2005 to 2006.  Thai exports had shifted markets from year to year in what seemed to be an absence of

stable customer relationships rather than consistently supplying the same markets.  Id. 222 First Five‐Year Reviews, USITC Pub. 3956 at 34 and 35.
 

37

c) The Current Reviews

At the end of the original period of investigation, volume and market share of

cumulated subject imports from China, India, Indonesia, Taiwan, Thailand, and Ukraine fell

dramatically as a result of the imposition of the orders.  They remained at substantially lower

levels during the period examined in the prior reviews.  The volume of cumulated subject

imports for these six countries declined from 2.8 million short tons in 2000 to 188,075 short

tons in 2001, after imposition of the orders.223  During the current period of review, these

cumulated subject imports ranged from a low for the period of 254 short tons in 2009 to a high

for the period of 21,169 short tons in 2007; cumulated subject import volume was 3,784 short

tons in 2012.224  The market share of these cumulated subject imports was virtually zero for

every year and interim period in these reviews.225  We find that the lack of subject imports in

the U.S. market during the period of review, which continues a trend apparent during the prior

reviews, is a function of the discipline of the orders.

As discussed above, the Commission received complete coverage from foreign

producers in Taiwan, but coverage was not complete for foreign producers in India and

Thailand; no foreign producers in China, Indonesia, or Ukraine responded to the Commission

questionnaires.226  While the lack of participation by producers from certain subject countries

has prevented the Commission from assembling a single consistent and comprehensive set of

capacity data for subject hot‐rolled steel producers in these six countries, the Commission has  

good available published data to supplement the limited available foreign producer

questionnaire data for assessing subject producer capacity, production, capacity utilization, and

shipment patterns.

The information available in these five‐year reviews indicates that the hot‐rolled steel

industries in these six countries, on a cumulated basis, have significant and substantially

increasing production capacity, considerable unused capacity, and that they export substantial

volumes of hot‐rolled steel.  Cumulated production capacity for these six countries, as reported

to the Commission in the original investigations, was 49.0 million short tons in 2000.227  The

cumulated production capacity in 2012 has increased almost tenfold to *** short tons, based

on the questionnaire responses from the industry in Taiwan and on published data estimates

for the other five subject countries.228  Moreover, there are increases in this already vast

capacity planned for 2014 and 2015.229

                                                      

223 CR/PR at Table I‐1.

224 CR/PR at Table I‐1.  Cumulated subject imports were 2,256 short tons in interim 2012 and

1,507 short tons in interim 2013.  Id. at Table C‐1.

225 CR/PR at Table I‐1.

226 CR at I‐19; PR at I‐16.

227 First Five‐Year Reviews, USITC Pub. 3956, calculated from Tables IV‐14, IV‐20, IV‐27, IV‐43, IV‐

47, and IV‐51.

228 Calculated from CR/PR at Table IV‐6.  The cumulated capacity, based on the most

conservative data (questionnaire responses for Taiwan and the two under‐reporting countries ‐‐ India

and Thailand; published data for China, Indonesia, and Ukraine), still is immense at *** short tons.  

(Continued...)
 

38

Despite plans to invest in additional capacity, production has not kept pace with already

existing capacity, resulting in large quantities of excess capacity.  Combined production for

these six countries, as reported to the Commission in the original investigations, was 47.8

million short tons in 2000, leaving excess capacity of 1.2 million short tons.230  Based on the

questionnaire responses from the industry in Taiwan and on published data estimates for the

other five subject countries, production in 2012 has increased to *** short tons, leaving excess

capacity a staggering *** short tons.231

Not only do these six subject countries have substantial cumulated excess capacity, even

based on conservative estimates, but they also export substantial volumes of hot‐rolled steel.  

Combined export volumes were *** short tons in 2012.232

China, which accounted for an enormous share of the increases in capacity over the

period of review, shifted during the prior reviews from being a net importer to a net exporter of

hot‐rolled steel.233  As the Commission recognized in the prior reviews, China’s shift has had a

two‐fold effect on many of these subject countries:  they have seen their exports to China

decline and now have China exporting to their home and other third‐country markets.234  As

evident in the Global Trade Atlas data, China’s exports to Thailand have increased from 196,133

short tons in 2007 to 760,121 short tons in 2012.235  As discussed above in the discernible

adverse impact section (III.B.), both India and Thailand are net importers of hot‐rolled steel, yet

the industries in these countries have increased their capacity during the period of review and

had substantial excess capacity in 2012 (approximately six million short tons for each

country).236  The Thai Respondent  (SSI) indicated that it shifted its focus to the high‐end steel

products so it could service the growing Thai automotive industry, which has been obtaining

such specialized products from imported sources.237  But SSI also indicated that the other Thai

                                                                                                                                                                              

(...Continued)

Calculated from CR/PR at Table IV‐6.  The conservative data estimates are under‐reported by about one‐

half for India and Thailand because, as noted above, the conservative data are based on questionnaire

responses with less than complete coverage for these two countries.

229 See CR at IV‐31, IV‐32, IV‐49 and Table IV‐31; PR at IV‐20, IV‐21, IV‐33, and Table IV‐31.  See,

e.g., AMUSA Prehearing Brief at 7‐10, 18‐22, 25‐26, 30‐34, 41‐45, and 49‐51.

230 First Five‐Year Reviews, calculated from Tables IV‐14, IV‐20, IV‐27, IV‐43, IV‐47 and IV‐51.

231 Calculated from CR/PR at Table IV‐6.  The cumulated production, based on the most

conservative data (questionnaire responses for Taiwan and the two under‐reporting countries ‐‐ India

and Thailand; published data for China, Indonesia, and Ukraine), is *** short tons, and excess capacity is

a staggering *** short tons.  Calculated from CR/PR at Table IV‐6.

232 Calculated from CR/PR at Table IV‐6 (based on questionnaire responses from the industry in

Taiwan and on published data estimates for the other five subject countries).

233 First Five‐Year Reviews, USITC Pub. 3956 at 33 and Table ***.

234 See, e.g., CR/PR at Tables IV‐8 and IV‐16.

235 CR/PR at Table IV‐8.  China also exports substantial volumes of hot‐rolled steel to India

(867,240 short tons in 2012); Chinese exports to both Taiwan and Indonesia also were substantial in

2012 at 166,599 short tons and 123,880 short tons, respectively.  Id. 236 CR/PR at Table IV‐6.

237 SSI Prehearing Brief at 21‐27.
 

39

producers (which reportedly account for about half of Thai capacity) could only produce the

low‐end, commodity steel products.238   The Indian Respondents made similar claims about

focusing on servicing the home automotive industry’s demands for specialized steel.  Yet,

despite being a net importer, India already exports substantial volumes of hot‐rolled steel and

the responding producers reported substantially increasing exports as a share of their total

shipments from *** in 2012.239  Taiwanese exports are substantial; as a share of total

shipments, they increased from *** in 2012; moreover, excess capacity in Taiwan increased

during the period of review as production did not keep pace with increases in capacity.240  

Consequently, despite respondents’ claims of home market focus, each of the subject industries

exports hot‐rolled steel to at least some extent.  Moreover, the presence of excess capacity, as

well as the extensive presence of Chinese exports in Asian markets, will provide them with both

the means and the incentive to direct exports to the large U.S. market upon revocation.

The attractiveness of the relatively open U.S. market, and its relatively higher prices,

provide further incentives for subject producers to divert exports currently shipped to other

markets to the U.S. market if the orders are revoked.  Prices for hot‐rolled steel in the United

States generally are appreciably higher than those in most other markets.241   

Hot‐rolled steel exports from each of these six subject countries have been subject to

numerous antidumping duty orders, tariffs, and related trade barriers in other markets during

the period of review as discussed above in section III.B.242  These orders, tariffs, and barriers

provide an incentive to direct export shipments to the U.S. market.243 244

Given the large amount of excess hot‐rolled steel capacity available in these six subject

countries, and the large volume of exports by these countries on a cumulated basis, we

                                                      

238 SSI Prehearing Brief at 23.

239 CR/PR at Table IV‐11.

240 CR/PR at Table IV‐17.

241 CR/PR at Tables IV‐28 and IV‐29.  For example, in September 2013, based on MEPS data, spot

prices per short ton for hot‐rolled steel were:  ***.  Id. at Table IV‐29.  ***.  Id. at Table IV‐28.

242 CR at IV‐18, IV‐24, IV‐32, IV‐36, IV‐46, and IV‐52; PR at IV‐13, IV‐17, IV‐21, IV‐25, IV‐31, and

IV‐34.

243 We also have examined inventories of the subject merchandise.  The information available

concerning hot‐rolled steel inventories in these countries indicates that inventory levels were generally

stable and at moderate levels relative to shipments during these reviews, with the exception of higher

inventory levels as a share of shipments reported by the subject Thai producer.  CR/PR at Tables IV‐11,

IV‐17, and IV‐21.  Thai producers reported that their inventories as a ratio to shipments ranged from a

period low of *** in 2011.  Id. at Table IV‐21.

244 We also examined the potential for product shifting.  During the period of review only ***

producer reported producing a very small quantity of nonsubject products in the same hot‐strip mills at

which it produces subject hot‐rolled steel.  CR at IV‐42 and IV‐43; PR at IV‐29.  While reporting subject

producers from India and Taiwan internally consume some of the subject merchandise they produce for

further processing into downstream products such as cold‐rolled steel or tubular goods, the record

contains no information suggesting why hot‐rolled steel producers would have an economic incentive to

shift production from such higher‐value product to the subject merchandise.  See CR/PR at Tables IV‐12

and 18; CR at IV‐51; PR at IV‐34.
 

40

conclude that if the orders were revoked the volume and market share of cumulated subject

imports from China, India, Indonesia, Taiwan, Thailand, and Ukraine would likely be significant

within a reasonably foreseeable time.245

2. Likely Price Effects  

a) The Original Investigations

In the original determinations, the Commission found that price is an important factor in

purchasing decisions.246  During the period of investigation, the Commission observed that

prices declined sharply first as the volume of imports from Brazil, Japan, and Russia entered the

market, began to rise after orders were imposed on those imports, but then fell sharply to

generally their lowest levels.  Subject imports consistently undersold the domestic like product

throughout most of the period of investigation.  The Commission found that limited price

recovery occurred during the same quarters that subject import volume increased sharply and

subject imports undersold the domestic like product, which it found indicated that subject

imports significantly suppressed prices in late 1999 and in early 2000.  Additionally, inventory

overhangs, to which subject imports contributed, continued to exert negative influence on

domestic prices.  Accordingly, the Commission found that subject imports had significant

adverse effects on domestic prices during the period of investigation.247

b) First Five‐Year Reviews

In the first five‐year reviews, the Commission recognized that in light of the high degree

of interchangeability and comparable quality of hot‐rolled steel from different sources, the

general importance of price in purchasing decisions had not changed since the time of the

original investigations.248  The Commission found that U.S. prices for hot‐rolled steel increased

substantially for all products over the period of review but had flattened or declined at the end

of the review period.  Even with the orders in place and the limited price comparisons available

due to the diminished volume of subject imports, imports from these six subject countries

undersold the domestic like product in 17 of 37 quarterly comparisons.  In light of the

underselling in the first reviews and data from the original investigations, the Commission

concluded that there would likely be significant price underselling should the orders under

review be revoked.  In light of its findings that significant quantities of hot‐rolled steel likely

would enter the US. market and the price‐sensitive nature of the market for hot‐rolled steel,

the Commission concluded that the subject imports would also likely have price‐depressing or

price‐suppressing effects.249

                                                      

245 Commissioners Broadbent and Kieff reach the same conclusion for cumulated subject

imports from China, India, Taiwan, Thailand and Ukraine.

246 See Original Determinations, USITC Pub. 3446 at 21 and 22.

247 See Original Determinations, USITC Pub. 3446 at 21 and 22.

248 See First Five‐Year Review, USITC Pub. 3956 at 35‐38.

249 See First Five‐Year Review, USITC Pub. 3956 at 35‐38.
 

41

c) The Current Reviews

We recognize, as discussed above, that subject imports of the same characteristics and

requirements are substitutable for the domestic like product.250  Subject imports and domestic

product share the same essential chemical and physical properties.  Hot‐rolled steel is generally

manufactured to standard specifications, including those established by ASTM.251  Moreover,

the general importance of price in purchasing decisions has not changed since the time of the

original investigations.252  In these reviews, price was reported as one of the top three most

important factors in purchasing decisions by the largest number of purchasers, followed by

quality.253  The majority of purchasers indicated that they required certain quality

characteristics, which are considered readily available from U.S. producers and to a lesser

extent from suppliers in all subject countries.254  In light of the high degree of interchangeability

and comparable quality of hot‐rolled steel from different sources, price will likely continue to

be the principal factor influencing purchasing decisions in the reasonably foreseeable future.  

Thus, sustained underselling by even a relatively moderate amount of subject imports is likely

to have significant price‐suppressing or price‐depressing effects.

The record in these current reviews contains limited pricing comparisons.  The

Commission collected pricing data on sales of four products.255  Thirteen U.S. producers

provided usable pricing data, which represented 35.3 percent of U.S. commercial market

shipments of U.S. produced hot‐rolled steel.256  Three importers provided usable pricing data,

which represented *** of imported product from India and *** of imported product from

Thailand.257   No pricing data were received for sales of imports from China, Indonesia, Taiwan,

or Ukraine.258

U.S. prices for domestically produced hot‐rolled steel fluctuated during the period of

review.  In general, prices peaked in mid‐2008, decreasing sharply between the third and fourth

                                                      

250 CR at II‐25 and II‐39, and Table II‐13; PR at II‐17 and II‐26, and Table II‐13.

251 CR at I‐32; PR at I‐26.

252 See Original Determinations, USITC Pub. 3446 at 21.

253 CR/PR at Table II‐8.  When asked to rank the top three factors influencing their purchasing

decisions, the largest number of purchasers (32 of 36 firms) cited price, and the second largest number

(30 of 36 firms) cited quality.  Id.  Quality was the most frequently cited most important factor (cited by

14 purchasers), with price the second most frequently listed leading factor (cited by 12 purchasers).  Id.  

When asked how often they purchased hot‐rolled steel offered at the lowest price, six of 37 purchasers

reported “always,” 18 reported “usually,” 10 reported “sometimes,” three reported “rarely,” and one

reported “never.”  CR at II‐29 and II‐30; PR at II‐19 and II‐20.  In rating 18 factors in terms of their

importance to purchasing decisions, the factors deemed “very important” by the most purchasers were

product consistency and reliability of supply  (35 purchasers), price, availability, and quality meets

industry standards (34 purchasers), and delivery time (32 purchasers).  CR/PR at Table II‐10.

254 CR/PR at Table II‐11.

255 CR at V‐11‐12, and Tables V‐3, V‐4 and V‐5; PR at V‐8, and Tables V‐3, V‐4 and V‐5.

256 CR at V‐12; PR at V‐8.

257 CR at V‐12; PR at V‐8.

258 CR at V‐12; PR at V‐8.
 

42

quarters of 2008 and the second quarter of 2009. Prices then increased until the second

quarter of 2011, and have declined irregularly for the remaining quarters of the period of

review.259  Prices for all four domestic products showed similar trends.  Despite a general

decline during the two most recent years, prices were higher in the most recent quarter (the

second quarter of 2013) for all four products than they were in the first quarter of 2007.260

We find that the significantly increased volumes of cumulated subject imports likely

following revocation of the orders would likely have significant adverse price effects on the

domestic like product.  In the original investigations, subject imports from these six countries

undersold the domestic like product in 139 of 201, or 69 percent, of the quarterly

comparisons.261  In the first five‐year reviews, even with the orders in place, and indicative of

the price‐sensitive nature of hot‐rolled steel, imports from the six subject countries undersold

the domestic like product in 17 of 37 quarterly comparisons.262  In these reviews, there was a

total of only four reported price comparisons between the domestic product and subject

product; subject imports oversold the domestic like product in all comparisons.263  The far

greater number of comparisons in the first reviews, with the orders in place, and in the original

investigations, without the orders in place, provide evidence of underselling that is more

probative than the limited comparisons in these reviews.

A comparison of average unit values (AUVs) of subject industries’ exports and domestic

product provide an additional indicator of current relative prices.  The record indicates that

export shipment AUVs of producers in China, India, Indonesia, Taiwan, Thailand, and Ukraine

were generally lower than the U.S. producers’ commercial shipment AUVs in 2012.264  

Questionnaire responses show that domestic producers’ AUVs for commercial shipments in the

U.S. market were $673 per short ton in 2012, while the AUVs for hot‐rolled steel export

shipments for these six countries ranged from $431 per short ton to $*** per short ton for

China, India, Taiwan, and Ukraine, with only higher AUVs for the more limited exports in 2012

by Indonesia and Thailand.265  These AUV differentials provide some additional support for the

                                                      

259 See  CR/PR at Tables V‐3, V‐4 and V‐5, and Figures V‐4‐7.

260 See  CR/PR at Tables V‐3, V‐4 and V‐5, and Figures V‐4‐7.

261 First Five‐Year Reviews at Table V‐7.  In the original investigations, subject imports undersold

the U.S. product in the following quarterly comparisons:  China, in 35 of 58 comparisons; India, in 29 of

38 comparisons; Indonesia, in 20 of 22 comparisons; Taiwan, in 15 of 37 comparisons; Thailand, in 12 of

18 comparisons; and Ukraine, in 28 of 28 comparisons.  Id.

262 First Five‐Year Reviews at Tables V‐3 ‐ V‐7 and Figures V‐4 ‐ V‐7.

263 CR/PR at Table V‐7.  Three comparisons involved imports from India and one involved

imports from Thailand.

264 We are mindful that the use of AUVs for establishing price trends or comparisons may

present product mix issues in that divergent values may reflect different merchandise rather than

differences in price.  Accord Allegheny Ludlum Corp. v. United States, 287 F.3d 1365, 1373‐74 (Fed. Cir.

2002).

265 CR/PR at Tables III‐11, IV‐8, IV‐10, IV‐11, IV‐14, IV‐17, IV‐20, IV‐21 and IV‐23.  In 2012, export

shipment AUVs were:  $562, China; *** (questionnaire responses) or $559, India; $737, Indonesia; ***

(Continued...)
 

43

view that the predominant underselling by subject imports from these six countries observed

during the original investigations would return if the orders are revoked.

Moreover, as discussed above, there is an incentive for subject producers to ship to the

U.S. market, because subject producers likely would be able to receive a higher price in the U.S.

market relative to many third‐country markets, even as they would undersell the U.S. product

to increase sales.  We consequently conclude that there will likely be significant price

underselling should the orders under review be revoked.

Because price is important to purchasing decisions, the presence of significant quantities

of subject imports that are likely to enter the United States after revocation of the orders under

review and that are likely to undersell the domestically produced product will force domestic

hot‐rolled steel producers to either lower prices or lose sales.  In light of these considerations

and the price‐sensitive nature of the market for hot‐rolled steel, we conclude that the subject

imports will also likely have price‐depressing or price‐suppressing effects.266

3. Likely Impact

a) The Original Investigations

In the original determinations, the domestic industry’s financial performance was poor

throughout most of the period of investigation, with several domestic producers entering

Chapter 11 bankruptcy proceedings and two ceasing operations altogether, despite increases in

both commercial shipments and production for downstream processing.267  The Commission

recognized that the industry’s performance in the early portion of the period of investigation

reflected the adverse effects of unfairly traded hot‐rolled steel imports from Brazil, Japan, and

Russia and that the industry had gained some benefit from the import relief imposed on such

imports.  It found that this improvement did not last and that virtually every financial and

production indicator was lower in interim 2001 than in interim 2000.  While the Commission

recognized that the industry’s condition was affected by a decline in consumption, it also found

that domestic shipments and production contracted at a time when overall apparent

consumption was still strong and while rapidly increasing subject imports gained sales from the

domestic industry largely through underselling.  The Commission concluded that there have

been significant increases in the volume and market share of subject imports, and that the

subject imports undersold the domestic like product and had a significant suppressing and

depressing effect on domestic prices, resulting in a decline in the overall condition of the

industry.  Thus, it found that the subject imports had a significant adverse impact on the

domestic industry.268

                                                                                                                                                                              

(...Continued)

(questionnaire responses), Taiwan; *** (questionnaire responses) or $689, Thailand; and $431, Ukraine.  

Id. 266 Commissioners Broadbent and Kieff make the same conclusion for cumulated subject imports

from China, India, Taiwan, Thailand and Ukraine.

267 See Original Determinations, USITC Pub. 3446 at 23‐26.

268 See Original Determinations, USITC Pub. 3446 at 23‐26.
 

44

b) First Five‐Year Reviews

In the first five‐year reviews, the Commission recognized that, at the beginning of the

review period, an improvement in the condition of the domestic industry was inhibited, in part,

by a U.S. economic recession in 2001 and a resultant decrease in apparent U.S. consumption.269  

As apparent U.S. consumption improved and U.S. prices rose sharply, the domestic industry’s

condition improved substantially after 2003.  The Commission found that the industry made

great strides in improving its efficiency and productivity through consolidation, restructuring,

and reductions in labor and legacy costs, and that these improvements were evident in the

condition of the industry from 2004 to 2006.  Softening demand after its peak in 2004, and flat

or declining prices in 2006‐2007, however resulted in substantial declines in most performance

indicators in the first half of 2007.270

The Commission recognized that the majority of U.S. hot‐rolled steel production was

internally consumed to produce downstream products, and while the captive production

provision does not apply to five‐year reviews, the Commission found it appropriate to consider

the merchant market data as a relevant condition of competition.  The Commission

acknowledged the domestic producers’ concerns about the appropriate methodology for

valuing internal consumption of hot‐rolled steel.  The Commission noted that the trends in

reported industry data were the same regardless of the methodology used, even though the

absolute amount of profitability differed.271 272

Given the industry’s performance since 2004, the Commission did not find that the

domestic industry was currently in a vulnerable or weakened state as contemplated by the

statute.  Nonetheless, the Commission recognized that the industry experienced substantial

declines in performance in the first half of 2007.273

The Commission concluded that cumulated subject import volumes with respect to

China, India, Indonesia, Taiwan, Thailand, and Ukraine would likely increase to significant levels,

have significant price‐depressing or price‐suppressing effects, and adversely affect the

industry’s performance in the reasonably foreseeable future if the orders under review were

revoked.  The Commission consequently found that revocation of the orders regarding subject

                                                      

269 See First Five‐Year Reviews, USITC Pub. 3956 at 38‐42.

270 See First Five‐Year Reviews, USITC Pub. 3956 at 38 and 39.

271 First Five‐Year Reviews, USITC Pub. 3956 at 39‐41.  The Commission found it was not

appropriate to value internal consumption only at cost, which had the effect of not allocating any profit

or loss to the 60‐65 percent of production that was internally consumed.  Because of the high share of

internal consumption, the Commission considered the financial data that included downstream

profitability in the reviews, but gave primary weight to the traditional constructed fair market value

data.  Id. at 40 and 41.

272 Commissioner Pinkert placed equal weight on the traditional constructed FMV methodology

and the constructed cost plus downstream methodology in the first five‐year reviews.  First Five‐Year

Reviews, USITC Pub. 3956 at 41, n.237.

273 See First Five‐Year Reviews, USITC Pub. 3956 at 41 and 42.
 

45

imports from China, India, Indonesia, Taiwan, Thailand, and Ukraine would likely have a

significant adverse impact on the domestic industry.274

c) The Current Reviews275 276

                                                      

274 See First Five‐Year Reviews, USITC Pub. 3956 at 42.

275 Section 752(a)(6) of the Act states that “the Commission may consider the magnitude of the

margin of dumping or the magnitude of the net countervailable subsidy” in making its determination in

a five‐year review.  19 U.S.C. § 1675a(a)(6).  The statute defines the “magnitude of the margin of

dumping” to be used by the Commission in five‐year reviews as “the dumping margin or margins

determined by the administering authority under section 1675a(c)(3) of this title.”  19 U.S.C.

§ 1677(35)(C)(iv).  See also SAA at 887. Commerce expedited its determinations in all of these reviews

and found likely weighted‐average dumping margins as follows:  China – likely dumping margins of 12.34

percent for Baoshan Iron & Steel, Baosteel Group International Trade, and Shanghai Baosteel Group;

31.09 percent for Angang Group Hong Kong, Angang Group International Trade, and New Iron & Steel;

57.19 percent for Bengang Steel Plates, Benxi Iron & Steel Group, and Benxi Iron & Steel Group

International Economic & Trade; 65.59 percent for Panzhihua Iron & Steel and Wuhan Iron & Steel

Group; and 90.83 percent for all others; India –likely subsidy rates of 539.89 percent for Essar, 563.50

percent for Ispat, 549.88 percent for SAIL, 540.78 percent for Tata Steel, and 547.71 percent for all

others; and likely dumping margins of 36.53 percent for Essar, 44.40 percent for Ispat Industries, and

38.72 percent for all others;  Indonesia ‐‐ likely subsidy rates of 10.21 percent for P.T. Krakatau Steel and

all others, and likely dumping margins of 47.86 percent for P.T. Krakatau Steel and  all others; Taiwan ‐‐ 

likely dumping margins of 29.14 percent for An Feng Steel and China Steel/Yieh Loong, and 20.28

percent for all others; Thailand ‐‐ likely subsidy rates of 2.38 percent for SSI and all others, and likely

dumping margins of 7.35 percent for SSI, 20.30 percent for Siam Strip Mill and 4.41 percent for all

others; and Ukraine ‐‐ likely dumping margins of 90.33 percent for all others.  CR/PR at Tables I‐6 and I‐

7; 78 Fed. Reg. 16252 (March 14, 2013); 78 Fed. Reg. 15703 (March 12, 2013).

276 In addition, the statute provides that “if a countervailable subsidy is involved, the

Commission shall consider information regarding the nature of the countervailable subsidy and whether

the subsidy is a subsidy described in Article 3 or 6.1 of the Subsidies Agreement.”  19 U.S.C. § 1675a(6).  

In its unpublished Issues and Decision Memorandum issued in these reviews, Commerce described eight

programs with respect to hot‐rolled steel from India and found four (Advance Licenses, Duty Entitlement

Passbook Scheme, Export Promotion of Capital Goods Scheme, Pre‐Shipment and Post‐Shipment Export

Financing) fall within the meaning of Articles 3 and had insufficient evidence to determine whether the

other programs fell within the meaning of Article 6.1.  Commerce described two programs with respect

to hot‐rolled steel from Indonesia, and found that neither fell within the meaning of Article 3 and had

insufficient evidence to determine whether they fell within the meaning of Article 6.1.  Commerce

described five programs with respect to hot‐rolled steel from Thailand, and found that one of these

programs (IPA Section 36(1)) falls within the meaning of Article 3 and had insufficient evidence to

determine whether the other programs fell within the meaning of Article 6.1.  Issues and Decisions

Memorandum for Final Results of Expedited Second Sunset Reviews of the Countervailing Duty Orders on

Certain Hot‐Rolled Carbon Steel Flat Products from India and Indonesia; Issues and Decisions

Memorandum for Final Results of Expedited Second Sunset Reviews of the Countervailing Duty Orders on

Certain Hot‐Rolled Carbon Steel Flat Products from Thailand (March 5, 2013).
 

46

Over the period of review, the condition of the domestic industry was affected by the

U.S. economic downturn, which resulted in declines in virtually every indicator in the latter part

of 2008 and 2009.277  As apparent U.S. consumption improved and U.S. prices rose after 2009,

the domestic industry’s condition improved substantially, but did not return to the peak

reached in 2008.  During the review period, the industry continued improving its efficiency and

productivity through some consolidation, some sales of existing mills and some additional

restructuring, following the major restructuring evident in the first five‐year reviews.  These

improvements were evident in the condition of the industry from 2007 to 2008, and its ability

to weather the recessionary environment of 2009.  While the industry experienced consistent

profitability and improving performance after 2009, flat or declining prices in 2012 have

resulted in declines in most performance indicators in 2012 and in the first half of 2013.

The domestic industry’s capacity fluctuated from year to year and declined overall by

6.9 percent from 2007 to 2012.278  Production declined substantially from 2007 to 2009,

rebounded in 2010, and despite steadily increasing from 2010 to 2012, was 6.1 percent lower in

2012 than the peak level in 2007.279  Capacity utilization fluctuated within a narrow range from

year to year, except for a period low of 52.9 percent in 2009.280

The domestic industry’s U.S. shipments, both on a total and commercial basis, showed

patterns similar to those for production.  Total U.S. shipments declined substantially from 2007

to 2009, rebounded in 2010, and increased steadily from 2010 to 2012; total U.S. shipments in

2012 were 5.1 percent lower than the peak level in 2007.  Commercial U.S. shipments followed

the same annual trends.281  Inventories relative to U.S. shipments remained at relatively low

levels, ranging from a period high of 3.8 percent in 2009 to a period low of 1.8 percent in 2008,

                                                      

277 CR at III‐39 and Tables III‐7, III‐11 and E‐1; PR at III‐16‐17 and Tables III‐7, III‐11 and E‐1.

278 CR/PR at Tables III‐4 and C‐1.  The domestic industry’s production capacity was 80.4 million

short tons in 2007, 72.8 million short tons in 2008, 70.4 million short tons in 2009 and 2010, 72.5 million

short tons in 2011, 74.8 million short tons in 2012, 37.0 million short tons in interim 2012, and 37.5

million short tons in interim 2013.  Id. 279 CR/PR at Tables III‐4 and C‐1.  The domestic industry’s production was 60.7 million short tons

in 2007, 54.0 million short tons in 2008, 37.2 million short tons in 2009, 51.7 million short tons in 2010,

54.2 million short tons in 2011, 57.0 million short tons in 2012, 29.4 million short tons in interim 2012,

and 28.6 million short tons in interim 2013.  Id. 280 CR/PR at Tables III‐4 and C‐1.  The domestic industry’s capacity utilization was 75.5 percent in

2007, 74.2 percent in 2008, 52.9 percent in 2009, 73.4 percent in 2010, 74.8 percent in 2011, 76.2

percent in 2012, 79.4 percent in interim 2012, and 76.1 percent in interim 2013.  Id. 281 CR/PR at Tables III‐7 and C‐1.  The domestic industry’s total U.S. shipments were 59.2 million

short tons in 2007, 53.6 million short tons in 2008, 35.7 million short tons in 2009, 50.0 million short

tons in 2010, 53.0 million short tons in 2011, 56.2 million short tons in 2012, 29.0 million short tons in

interim 2012, and 28.2 million short tons in interim 2013.  Id.  Total U.S. shipments were 2.7 percent

lower in interim 2013 than in interim 2012.  Id.  The domestic industry’s commercial shipments were

23.6 million short tons in 2007, 21.1 million short tons in 2008, 13.2 million short tons in 2009, 19.8

million short tons in 2010, 21.8 million short tons in 2011, 23.1 million short tons in 2012, 12.1 million

short tons in interim 2012, and 11.8 million short tons in interim 2013.  Id.
 

47

and were 2.9 percent in 2012.282  Although the domestic industry accounted for the majority of

apparent U.S. consumption, its market share declined slightly over the period of review.283

The number of production and related workers employed in the domestic industry, and

the hours worked, followed the same trends as production and U.S. shipments, fluctuating from

year to year and declining slightly overall from 2007 to 2012.284 The industry’s productivity

followed the same trend but increased overall from 1,283 short tons per 1,000 hours in 2007 to

1,300 short tons per 1,000 hours in 2012, notwithstanding a period low of 1,067 short tons per

1,000 hours in 2009.285  Wages paid increased only slightly despite a substantial increase in

hourly wages over the period of review.286

As discussed above, the majority of U.S. hot‐rolled steel production is internally

consumed to produce downstream products.287  In the original investigations, the Commission

found that the captive production provision applied and focused its analysis primarily on the

merchant market in considering the market share and financial performance of the domestic

industry (but also considered overall domestic industry data).288  The captive production

provision does not apply to five‐year reviews.289  However, as we did in the prior reviews, we

find it appropriate to consider the merchant market data as a relevant condition of

competition.290 291

                                                      

282 CR/PR at Table III‐8 and C‐1.

283 CR/PR at Tables I‐1 and C‐1.  The U.S. industry’s market share was 94.6 percent in 2007, 93.7

percent in 2008, 94.0 percent in 2009, 94.3 percent in 2010, 93.7 percent in 2011, and 93.6 percent in

2012; the U.S. industry’s market share was 93.7 percent in interim 2012 and 94.3 percent in interim

2013. Id.  The U.S. industry’s share of the commercial (merchant) market was 87.6 percent in 2007, 85.3

percent in 2008, 85.3 percent in 2009, 86.7 percent in 2010, 86.1 percent in 2011, and 85.8 percent in

2012; the U.S. industry’s share of the commercial (merchant) market was 86.1 percent in interim 2012

and 87.5 percent in interim  2013.  CR/PR at Table I‐12.

284 CR/PR at Tables III‐10 and C‐1.

285 CR/PR at Tables III‐10 and C‐1.

286 CR/PR at Tables III‐10 and C‐1.

287 Because internal consumption accounts for 95 percent of non‐commercial sales (internal

consumption and transfers to related parties), we will refer to all non‐commercial sales as internal

consumption.  We note that both valuation methodologies (traditional constructed fair market value

(FMV) and constructed downstream profitability) apply to both internal consumption and transfers to

related parties.

288 See Original Determinations, USITC Pub. 3446 at 15‐16.

289 See, e.g.,Certain Hot‐Rolled Flat‐Rolled Carbon‐Quality Steel Products from Brazil, Japan, and

Russia, Inv. Nos. 701‐TA‐384 and 731‐TA‐806‐808 (Review), USITC Pub. 3767 (April 2005) at 29 n.165.  

See also Titanium Metals Corporation v. United States, 155 F. Supp. 2d 750, 760‐62 (Ct. Int’l Trade 2001).

290 Domestic Producers contend that the traditional methodology for analysis of financial data

understates the vulnerability of the domestic industry because it overstates the profits attributable to

the production of hot‐rolled steel and thus the domestic industry’s operating income; they urge the

Commission to rely on the alternative cost plus downstream profit valuation methodology as a more

accurate view of industry performance.  See, e.g., AMUSA Prehearing Brief at 96 and 98‐99; U.S. Steel

Prehearing Brief at 103‐105; Nucor Prehearing Brief at 17‐18.

(Continued...)
 

48

The financial performance of the domestic industry displayed substantial fluctuations

during the period of review.  From 2007 to 2008, the domestic industry was profitable and

improved significantly as it reached its peak performance level for the period of review.292  

However, due to the economic downturn in late 2008 and 2009, the domestic industry

recorded a substantial operating loss in 2009 as all trade and financial performance indicators

plummeted; 11 of 14 producers reported operating losses.293  The industry’s profitability

                                                                                                                                                                              

(...Continued)

An evaluation of profitability of products internally consumed is necessarily somewhat artificial

because the internally consumed products are, by definition, not sold in the market in their initial form;

rather, they are used to manufacture downstream products that are frequently not part of the domestic

like product (as in this case).  The Commission has traditionally examined profitability of products

internally consumed on a constructed FMV basis because the FMV measure is tied to actual prices of the

domestic like product sold in the commercial market.  A profit measure of the domestic like product

based on the profitability of a downstream product would at least to a certain degree be the function of

production operations and market conditions that pertain to a product that is not the domestic like

product.  Internal consumption accounts for about 60 percent of hot‐rolled steel production.  Because of

this high share, we have considered the financial data that include the cost plus downstream

profitability in these reviews.  However, we have given primary weight to the traditional constructed

FMV data.  In addition, because we find that the degree of internal consumption in this industry is an

important condition of competition, we also rely on available data reflecting the industry’s commercial

market performance.  We note, however, that the trends in reported industry data are the same

regardless of the methodology used, even though the absolute amount of profitability differs.

291 Although the profitability trends suggested by the two methodologies are similar,

Commissioner Pinkert wishes to note that he has given full consideration to the results of both the

constructed FMV methodology and the constructed cost plus downstream profitability methodology.  

He finds this appropriate given the unique characteristics of the hot‐rolled steel industry, especially that

internal consumption consistently accounts for roughly 60 percent of production.

292 The domestic industry’s operating income/losses (based on the traditional constructed FMV

methodology) was $2.9 billion in 2007, $5.5 billion in 2008, negative $1.8 billion in 2009, $1.2 billion in

2010, $3.1 billion in 2011, $2.4 billion in 2012, $1.9 billion in interim 2012, and $941.1 million in interim

2013.  CR/PR at Table III‐11.  The domestic industry’s operating income/losses (based on the constructed

cost plus downstream profitability methodology) was $2.1 billion in 2007, $3.5 billion in 2008, negative

$1.7 billion in 2009, $1.2 billion in 2010, $2.0 billion in 2011, $1.5 billion in 2012, $1.2 billion in interim

2012, and $720.9 million in interim 2013.  Id. at Table E‐1.  The domestic industry’s operating

income/losses for commercial market sales (constructed FMV based on commercial sales as a share of

total sales, COGS, and SG&A) was $1.2 billion in 2007, $2.3 billion in 2008, negative $478.0 million in

2009, $ 426.8 million in 2010, $1.4 billion in 2011, $1.1 billion in 2012, $820.1 million in interim 2012,

and $402.5 million in interim 2013.  Calculated from CR/PR at Table III‐11.

293 The domestic industry’s ratio of operating income/losses to net sales (based on the

traditional constructed FMV methodology) was 8.6 percent in 2007, 13.1 percent in 2008, negative 9.1

percent in 2009, 3.7 percent in 2010, 8.2 percent in 2011, 6.3 percent in 2012, 9.3 percent in interim

2012, and 5.3 percent in interim 2013.  CR/PR at Table III‐11.  The domestic industry’s ratio of operating

income/losses to net sales (based on the constructed cost plus downstream profitability methodology)

was 6.5 percent in 2007, 8.8 percent in 2008, negative 8.4 percent in 2009, 3.8 percent in 2010, 5.3

percent in 2011, 4.2 percent in 2012, 6.1 percent in interim 2012, and 4.1 percent in interim 2013.  Id. at

(Continued...)
 

49

improved in tandem with increases in apparent U.S. consumption and prices in 2010 and 2011,

and declined in 2012 in tandem with lower prices even as demand continued to improve.294

The industry continued to experience significant profitability and positive operating

performance in 2012 and interim 2013, even though to a lesser extent than in 2008.  It

experienced lower profitability and operating performance in 2012 compared with 2011, as

well as in interim 2013 compared with interim 2012.295  The industry’s capital expenditures

fluctuated from year to year, and were lower in 2012 than the period peak in 2007.296 Research

and development expenses, which were much lower than capital expenditures, also fluctuated

from year to year, and were lower in 2012 than in all but two years of the period of review.297

Given the industry’s performance since 2009, we do not find that the domestic industry

is currently in a vulnerable or weakened state as contemplated by the statute.298   Nonetheless,

we recognize that it experienced declines in performance in 2012 and in the first half of 2013.

The industry, however, is not in such a strong condition, nor are likely demand

conditions sufficiently positive, that the industry could withstand significantly increased low‐

priced subject imports without likely sustaining significant adverse effects.  We have concluded

that cumulated subject import volumes will likely increase to significant levels and have

significant price‐depressing or price‐suppressing effects in the reasonably foreseeable future if

the orders under review were revoked.  Because subject imports are interchangeable for the

domestic like product and price is an important factor in purchasing decisions, such increases in

subject import volume would likely have the effect of exacerbating the declines in production,

                                                                                                                                                                              

(...Continued)

Table E‐1.  The domestic industry’s ratio of operating income/losses to net sales for commercial market

sales was 8.9 percent in 2007, 13.5 percent in 2008, negative 6.1 percent in 2009, 3.4 percent in 2010,

8.8 percent in 2011, 7.0 percent in 2012, 9.4 percent in interim 2012, and 5.3 percent in interim 2013.  

Calculated from CR/PR at Table III‐11.

294 CR/PR at Tables III‐11 and E‐1.

295 CR/PR at Tables III‐11 and E‐1.

296 CR/PR at Table III‐14.  Four U.S. producers, ***, accounted for *** of total industry capital

expenditures in 2012.  CR at III‐46; PR at III‐21.

297 CR/PR at Table III‐14.  Five U.S. producers reported research and development expenses, with

three firms, ***, accounting for the majority of spending.  CR at III‐46; PR at III‐21.

298 Domestic Producers cited to a report presented to the OECD Steel Committee, finding that

the global steel industry requires a minimum 16 percent margin for earnings before interest, taxes,

depreciation, and amortization (EBITDA) “to be economically sustainable in the long term.”

“Overcapacities in the Steel Industry, McKinsey & Company, OECD Steel Committee: 74th Session, Paris

(July 2, 2013).  They noted that the domestic industry’s EBITDA margin in 2012 was just 7.9 percent, less

than half of the minimum required for long‐term health.  See, e.g., AMUSA Prehearing Brief at 96‐97;

U.S. Steel Prehearing Brief at 101‐106; U.S. Steel Posthearing Brief at 2; Nucor Prehearing Brief at 11‐13;

Nucor Posthearing Brief at 3; SDI Prehearing Brief at 13‐14.  We give limited weight to the conclusions of

this report.  We note that the study is not specific to the U.S. hot‐rolled steel operations, or even hot‐

rolled steel operations worldwide, but rather involves the total operations of selected steelmakers

worldwide and that EBITDA is not a measure approved under GAAP because it omits costs in calculating

profitability.  CR at III‐43, n.21; PR at III‐18, n.21.
 

50

shipments, market share, and financial performance that the domestic industry sustained at the

end of the period of review.

Additionally, the likely aggressive pricing of the subject imports will force the domestic

industry to cut prices for the domestic like product or lose sales.  Under either scenario, the

domestic industry’s revenues will likely decline significantly in light of the anticipated volume of

subject imports.  This, in turn, will likely lead to declines in the industry’s operating

performance.

Respondents advance several arguments suggesting that the domestic hot‐rolled steel

industry is insulated from the effects of subject imports, emphasizing the industry’s internal

consumption of hot‐rolled steel, its sales to key segments of purchasers (e.g., the automotive

industry) that have a preference for domestic steel, and that U.S. producers themselves

account for an appreciable volume of nonsubject imports from Canada and Korea.299  In

considering these arguments, we recognize that the domestic hot‐rolled steel industry may not

compete directly with subject imports for every shipment that it makes.  However, this does

not detract from our finding that there would likely be substantial volumes of subject imports

at low prices that would compete with the domestic product in the U.S. market upon

revocation.  During the original investigations, the domestic industry internally consumed an

even higher share of its shipments than it did during the period of review.  This, however, did

not insulate it from the injurious effects of subject imports.300  Additionally, while some

purchasers, such as automotive manufacturers, may have a preference for local sourcing of hot‐

rolled steel, spot market prices for hot‐rolled steel becomes a ***.301  Finally, the evidence

demonstrates that a substantial share of the imports from Canada and Korea are not controlled

by the domestic industry, and there is no evidence to suggest that nonsubject imports,

regardless of source, do not compete with subject imports and the domestic like product.302  

Consequently, consideration of factors other than subject imports does not detract from

our finding that revocation of the orders regarding subject imports from China, India, Indonesia,

Taiwan, Thailand, and Ukraine will likely have a significant adverse impact on the domestic

industry.  We therefore determine that revocation of the countervailing duty and the

antidumping duty orders on hot‐rolled steel from these six countries will likely lead to

continuation or recurrence of material injury to the domestic hot‐rolled steel industry within a

reasonably foreseeable time.303

                                                      

299 See, e.g., Essar/JSW Prehearing Brief at 5‐10; Essar/JSW Posthearing Brief at 12‐14; Shang

Chen Prehearing Brief at 2‐12; Shang Chen Posthearing Brief at 2‐5 and 13; SSI Prehearing Brief at 35‐36

and 38‐39.

300 See Original Determinations, USITC Pub. 3446 at 15‐16 and 23‐26.

301 See AMUSA’s Posthearing Brief at 12 and Exh. 10, paras. 8 and 9. (***).  Compare Ford Motor

Company’s Prehearing Brief at 1 (“Ford seeks revocation of the orders because revocation will promote

competition....”).

302 See CR at IV‐6, nn.5 and 6; PR at IV‐5, nn.5 and 6.

303 Commissioners Broadbent and Kieff make the same conclusion for cumulated subject imports

from China, India, Taiwan, Thailand, and Ukraine.
 

51

V. Conclusion

For the foregoing reasons, we determine that revocation of the countervailing duty

orders on hot‐rolled steel from India, Indonesia, and Thailand, and that revocation of the

antidumping duty orders on hot‐rolled steel from China, India, Indonesia, Taiwan, Thailand, and

Ukraine would be likely to lead to continuation or recurrence of material injury to an industry in

the United States within a reasonably foreseeable time.304

                                                       

304 Commissioners Broadbent and Kieff determine that revocation of the countervailing duty

orders on hot‐rolled steel from India and Thailand, and that revocation of the antidumping duty orders

on hot‐rolled steel from China, India, Taiwan, Thailand, and Ukraine would be likely to lead to

continuation or recurrence of material injury to an industry in the United States within a reasonably

foreseeable time.  They also determine that revocation of the countervailing duty order and the

antidumping duty order on hot‐rolled steel from Indonesia would not be likely to lead to continuation or

recurrence of material injury to an industry in the United States within a reasonably foreseeable time.  

See Separate and Dissenting Views of Commissioners Meredith M. Broadbent and F. Scott Kieff.

 

53

Separate and Dissenting Views of  

Commissioners Meredith M. Broadbent and F. Scott Kieff

Based on the record in these five‐year reviews, we determine under section 751(c) of

the Tariff Act, that revocation of the countervailing duty order and the antidumping duty order

on hot‐rolled steel from Indonesia would not be likely to lead to continuation or recurrence of

material injury to an industry in the United States within a reasonably foreseeable time.  

In reaching these determinations on revocation of the orders on hot‐rolled steel from

Indonesia, we join and adoptsectionsI, II, III.A, and IV.A‐B of the majority Views.

I. Cumulation

We find that subject imports from Indonesia are likely to have no discernible adverse

impact on the domestic industry in the event of revocation of the orders. During the original

investigations, the highest level of subject imports of hot‐rolled steel from Indonesia, 301,264

short tons in 1999, accounted for 0.4 percent of apparent U.S. consumption.1 Subject imports

from Indonesia have not entered the U.S. market since 2001, with the exception of five short

tons entering in 2004.2

Indonesia currently has two producers of hot‐rolled steel, although the largest firm,

Krakatau, makes up the vast majority of the industry’s capacity and production.3 The

Indonesian industry’s capacity is the smallest of all subject countries and has remained at levels

comparable to those that prevailed during the original investigations.4 According to ***,

Indonesian capacity is estimated at *** short tons in 2009 and 2010, and *** short tons in 2011

and 2012; production has ranged from a *** short tons in 2010 to a *** short tons in 2011, and

was *** short tons in 2012.5  

                                                        1 CR/PR at Table I‐1. 2 Id.

3 CR at IV‐31‐32, PR at IV‐20‐21. 4 Indonesia’s capacity was *** short tons in 2000, the last year of the original period of

investigation. Memorandum INV‐Y‐141 at Table VII‐4. Indonesia’s capacity was *** short tons in 2006,

the last year of the previous review period. Memorandum INV‐EE‐136 at Table IV‐27. Of the five other

subject countries, the smallest industry is in Ukraine with capacity of *** short tons. CR/PR at Table IV‐6. 5 CR/PR at Table IV‐13. The *** to the two firms’ combined hot‐rolled steel capacity as reported

publically by each firm. Krakatau reportedly has a hot‐rolled steel capacity of 2.6 million short tons,

while PT Gunung Raja Paksi has a hot‐rolled steel capacity of 265,000 short tons. CR at IV‐31‐32, PR at

IV‐20‐21.  

There is evidence on the record that Krakatau may add an additional one million short tons to its

hot‐rolled capacity by 2015. CR at IV‐31‐32, PR at IV‐21; AMUSA Posthearing Brief at 40. However, this

will still leave Indonesia’s industry as by far the smallest among subject countries, and as discussed

below, it is likely that this capacity will be dedicated to its home market shipments.
 

54

During the original period of investigation and first period of review, the industry’s total

export shipments never exceeded 800,000 short tons or fell below 200,000 short tons, and

were shipped to a variety of markets all over the world.6 Therefore, exports remained a

secondary outlet for the Indonesian industry’s production prior to the current period of review,

but the industry was in a position to increase shipments to markets such as the United States,

as it did during the original period of investigation.  

Since that time, the small Indonesian hot‐rolled steel industry has transformed from a

modest exporter into an industry that is dedicated almost entirely to its home market. Exports

fell from 327,456 short tons in 2007 to 110,703 short tons in 2009, a period of declining global

demand, but then fell further to 19,690 short tons in 2010, 32,498 short tons in 2011, and

19,065 short tons in 2012 even as demand in global markets recovered throughout those

years.7 The virtual disappearance of Indonesia’s exports between 2009 and 2012 coincided with

a *** percent increase in Indonesia’s home market consumption, and consumption was ***

percent larger than Indonesia’s production in 2012.8 As Indonesia has become a net importer of

hot‐rolled steel during the period of review, its limited export shipments have been almost

entirely shipped to neighboring Asian countries.9

While subject imports from Indonesia generally undersold the domestic product in the

original investigations,10 in view of the factors discussed above, we do not see enough specific

evidence to have the requisite level of confidence that the volume of subject imports from

Indonesia going forward will likely be significant. For all of these reasons, we find that subject

imports from Indonesia are likely to have no discernible adverse impact on the domestic

industry within a reasonably foreseeable time in the event of revocation of the antidumping

duty order on subject imports from Indonesia, and, accordingly we conclude that the statute

precludes cumulation of subject imports from Indonesia with other subject imports.

                                                       6 Memorandum INV‐Y‐141 at Table VII‐4; Memorandum INV‐EE‐136 at Table IV‐29. The United

States accounted for the majority of Indonesia’s exports in 2000, but not in 1998 or 1999, the peak year

for Indonesia’s global exports and U.S. imports from Indonesia. Memorandum INV‐Y‐141 at Table VII‐4;

CR/PR at Table I‐1. Likewise, Indonesia exported to a variety of partners during the first period of review,

and was not focused primarily on any region or partner. Memorandum INVE‐EE‐136 at Table IV‐29. 7 CR/PR at Table IV‐14 and Table IV‐26. As a share of production, Indonesia’s exports decreased

from *** percent in 2009 to *** percent in 2012. CR/PR at Table IV‐13.

8 CR/PR at Table II‐4.

9 CR/PR at Table IV‐14.  In 2012, its top four partners were Malaysia, Vietnam, Australia, and

Singapore, which accounted for 98.7 percent of its export shipments. Id. 10 CR at V‐23, PR at V‐18.
 

55

II. Revocation of the Countervailing and Antidumping Duty Orders Are Not

Likely to Lead to the Continuation or Recurrence of Material Injury to the

Domestic Industry within a Reasonably Foreseeable Time

A. Volume of Subject Imports

As discussed in our no discernible adverse impact finding, prior to the imposition of

these orders the volume of subject imports from Indonesia did not exceed 0.4 percent of total

apparent U.S. consumption. Since the orders were imposed, subject imports from Indonesia

have been absent from the U.S. market, except for a few short tons in 2004.  

Indonesia remains by far the smallest industry relative to other subject industries, and

its entire production capacity in 2012 is estimated to be equivalent to *** of apparent U.S.

consumption in that year.11 Production capacity in Indonesia was higher at the end of this

period of review than at the end of the original period of investigation or at the end of the prior

review period; however, growth in Indonesia’s capacity has been outpaced by growth in

demand within Indonesia’s home market. ***.12 Home market consumption increased from

*** short tons in 2001 to *** short tons in 2005 during the first review period.13 During the

current review period, Indonesian consumption increased from *** short tons in 2009 (*** to

Indonesian capacity) to *** short tons in 2012 (or *** higher than the industry’s capacity in

2012).14  

The strong increase in Indonesia’s domestic demand has solidified the industry’s focus

on its home market, as evidenced by a decline in the industry’s export orientation from already

low levels. Even at the peak of exports to the U.S. market during the original period of

investigation, total exports accounted for *** percent of the industry’s total shipments.  During

this period of review, exports steadily declined from levels well below those reached during the

original period of review. By 2012, exports accounted for *** of production.15 Exports declined

significantly and consistently though exports of hot‐rolled steel from Indonesia were subject to

few restrictions.16 In addition, the record indicates that the industry has had unused capacity

throughout the period of review;17 however, the presence of unused capacity in Indonesia did

not lead the industry to become more export‐oriented, even as demand in global markets

recovered. Therefore, the industry in Indonesia has been increasingly focused on its domestic

market despite its unused capacity and few third‐country import restrictions faced throughout

                                                        11 CR/PR at Table C‐1, Table IV‐13. 12 CR at IV‐72, PR at IV‐41.

13 Memorandum INV‐EE‐136 at Table IV‐28. 14 CR/PR at Table II‐4.

15 CR/PR at Table IV‐13.

16 CR at IV‐32, PR at IV‐21 (Thailand imposed antidumping duties in 2003). 17 CR/PR at Table IV‐13.
 

56

the period of review, suggesting the industry has not been producing to sell in export markets

at any price.

Domestic Producers argue that the industry in Indonesia was able to increase exports to

the U.S. market rapidly during the original period of investigation, despite its relatively small

capacity, and that the industry has grown larger since the original investigation period.18

Domestic Producers note that capacity utilization in Indonesia is reportedly low and that the

industry’s unused capacity would represent a significantly higher share of the U.S. market than

subject imports from Indonesia were able to claim during the original period of investigation.19

Domestic Producers argue that the industry in Indonesia remains interested in exports but has

been unable to exploit export opportunities in Asia because of slack demand and competition

from China.20  

We note that exports from Indonesia declined in the wake of the recent recession but

have declined further despite the subsequent recovery. The industry has had unused capacity

throughout the period of review but has not used that excess capacity to produce for export at

any price. Based on this record and the relatively small size of the industry, we do not find it

likely that the volume of subject imports from Indonesia would be significant upon revocation.

B. Price Effects of the Subject Imports

Subject imports from Indonesia undersold the domestic like product in most product‐

specific comparisons during the original period of investigation, by margins ranging from ***

percent.21 During the first period of review, subject imports from Indonesia generally oversold

the domestic like product and by substantial margins.22 The record in this second period

contains no product‐specific pricing comparisons for hot‐rolled steel from Indonesia.23

Domestic Producers argue that subject imports from Indonesia would be drawn into the

U.S. market by the prospect of higher prices, and underselling would be the mechanism by

which subject imports gain sales.24 We do not discount the possibility that subject imports from

Indonesia would undersell the domestic like product upon revocation. However, given the likely

small volume of subject imports from Indonesia upon revocation, we find that revocation would

not likely lead to significant underselling or significant price depression or suppression within a

reasonably foreseeable time.

                                                       18 AMUSA Prehearing Brief at 24‐25.

19 AMUSA Prehearing Brief at 25‐26.

20 AMUSA Prehearing Brief at 26‐27. 21 CR at V‐23, PR at V‐18.   22 CR at V‐24, PR at V‐18.

23 CR/PR at Table V‐6.

24 AMUSA Prehearing Brief at 28‐29.
 

57

C. Impact of the Subject Imports

Although we have noted recent declines in the domestic industry’s performance, we do

not find the domestic industry vulnerable.25 Given that we do not find it likely that there will be

a significant volume of subject imports from Indonesia or that there will likely be significant

price effects from these imports, and given our findings regarding the likely condition of the

domestic industry, we find that revocation of these orders on subject imports from Indonesia is

not likely to lead to a significant adverse impact on the domestic industry within a reasonably

foreseeable time.  

III. Conclusion

For the reasons stated above, we determine that revocation of the countervailing and

antidumping duty orders on imports of hot‐rolled steel from Indonesia would not be likely to

lead to continuation or recurrence of material injury to an industry in the United States within a

reasonably foreseeable time.  

                                                        25 See majority Views at section IV.C.3.c.

  

I‐1

PART I: INTRODUCTION

BACKGROUND

On November 1, 2012, the U.S. International Trade Commission (“Commission” or

“USITC”) gave notice, pursuant to section 751(c) of the Tariff Act of 1930, as amended (“the

Act”),1 that it had instituted reviews to determine whether revocation of the countervailing

duty orders on hot‐rolled steel products (“hot‐rolled steel”) from India, Indonesia, and Thailand,

and the antidumping duty orders on hot‐rolled steel from China, India, Indonesia, Taiwan,

Thailand, and Ukraine would likely lead to the continuation or recurrence of material injury to a

domestic industry.2 3 On February 4, 2013, the Commission determined that it would conduct

full reviews pursuant to section 751(c)(5) of the Act. 4 The following tabulation presents

information relating to the background and schedule of this proceeding:5

  

   

                                                            

1 19 U.S.C. 1675(c). 2 Hot‐Rolled Steel Products From China, India, Indonesia, Taiwan, Thailand, and Ukraine; Institution of

Five‐Year Reviews Concerning the Countervailing Duty Orders on Hot‐ Rolled Steel Products From India,

Indonesia, and Thailand and Antidumping Duty Orders on Hot‐ Rolled Steel Products From China, India,

Indonesia, Taiwan, Thailand, and Ukraine, 77 FR 66078, November 1, 2012. All interested parties were

requested to respond to this notice by submitting the information requested by the Commission.

3 In accordance with section 751(c) of the Act, the U.S. Department of Commerce (“Commerce”)

published a notice of initiation of five‐year reviews of the subject antidumping and countervailing duty

orders concurrently with the Commission’s notice of institution. Initiation of Five‐Year (‘‘Sunset’’)

Review, 77 FR 66439, November 5, 2012. 4 Hot‐Rolled Steel Products From China, India, Indonesia, Taiwan, Thailand, and Ukraine; Notice of

Commission Determination To Conduct Full Five‐year Reviews, 34 FR 11901, February 20, 2013. The

Commission determined that the responses from both domestic interested parties and respondent

interested parties were adequate in the reviews of the orders for Taiwan and Thailand, and inadequate

with respect to the orders for China, India, Indonesia, and Ukraine. However, the Commission

determined to conduct full reviews with respect to the orders on hot‐rolled steel from China, India,

Indonesia, and Ukraine in order to promote administrative efficiency in light of its decision to conduct

full reviews with respect to the orders on hot‐rolled steel from Taiwan and Thailand. 5 The Commission’s notice of institution, notice to conduct full reviews, scheduling notice, and

statement on adequacy are referenced in appendix A and may also be found at the Commission’s web

site (internet address www.usitc.gov). Commissioners’ votes on whether to conduct expedited or full

reviews may also be found at the web site. Appendix B presents the witnesses appearing at the

Commission’s hearing.
  

I‐2

Effective date Action 

November 29, 2001 

Commerce’s antidumping duty orders on hot-rolled steel from China, Taiwan, 

Thailand, and Ukraine (66 FR 59559, 59561, 59562, and 59563) 

December 3, 2001 

Commerce’s antidumping and countervailing duty orders on hot-rolled steel from 

India and Indonesia and Commerce’s countervailing duty orders on hot-rolled steel 

from Thailand (66 FR 60192, 60194, 60197, and 60198) 

August 1, 2006 Commission’s institution of first five-year reviews (71 FR 43521) 

August 1, 2006 Commerce’s initiation of first five-year reviews (71 FR 43443) 

December 27, 2007 

Commerce’s continuation of antidumping duty and countervailing duty orders on 

hot–rolled carbon steel flat products from India, Indonesia, China, Taiwan, 

Thailand, and Ukraine (72 FR 73316) 

November 1, 2012 Commission’s institution of five-year reviews (77 FR 66078) 

November 1, 2012 Commerce’s initiation of five-year reviews (77 FR 66439, November 5, 2012) 

February 4, 2013 

Commission’s determinations to conduct full five-year reviews (78 FR 11901, 

February 20, 2013) 

March 12, 2013 

Commerce’s final results of expedited five-year reviews of the antidumping duty 

orders (78 FR 15073) 

March 14, 2013 

Commerce’s final results of expedited five-year reviews of the countervailing duty 

orders (78 FR 16252) 

April 16, 2013 Commission’s scheduling of the reviews (78 FR 24435, April 25, 2013) 

October 21, 2013 Commission’s revised scheduling of the reviews (78 FR 64008, October 25, 2013) 

October 31, 2013 Commission’s hearing 

December 17, 2013 Commission’s vote 

January 15, 2014 Commission’s determinations and views 

The original investigations

The original investigations resulted from petitions filed on November 13, 2000, by

counsel on behalf of Bethlehem Steel Corp. (“Bethlehem”); Gallatin Steel Corp. (“Gallatin”);

IPSCO Steel, Inc. (“IPSCO”); LTV Steel Co., Inc.; National Steel Corp. (“National”); Nucor Corp.

(“Nucor”); Steel Dynamics, Inc. (“SDI”); U.S. Steel Group; Weirton Steel Corp. (“Weirton”); and

the labor union representing the organized workers at Weirton (the Independent Steelworkers

Union). The original investigations included hot‐rolled steel from Argentina, China, India,

Indonesia, Kazakhstan, Netherlands, Romania, South Africa, Taiwan, Thailand, and Ukraine.

Commerce issued a series of final affirmative determinations regarding countervailable

subsidies and sales at less than fair value (“LTFV”) between July and October 2001.6 In August

                                                            

6 Notice of Final Determination of Sales at Less Than Fair Value: Certain Hot‐Rolled Carbon Steel Flat

Products From Argentina, 66 FR 37001, July 16, 2001; Notice of Final Determination of Sales at Less Than

Fair Value: Certain Hot‐Rolled Carbon Steel Flat Products from South Africa, 66 FR 37002, July 16, 2001;

Final Affirmative Countervailing Duty Determination: Certain Hot‐Rolled Carbon Steel Flat Products From

(continued...)
  

I‐3

2001, the Commission determined that an industry in the United States was materially injured

by reason of imports from Argentina of hot‐rolled steel that were found by Commerce to be

subsidized by the Government of Argentina and sold in the United States at LTFV, and by reason

of imports from South Africa of hot‐rolled steel that were found by Commerce to be sold in the

United States at LTFV.7 In November 2001, the Commission determined that an industry in the

United States was materially injured by reason of imports from India, Indonesia, South Africa,

and Thailand of hot‐rolled steel that was found by Commerce to be subsidized by the

Governments of India, Indonesia, South Africa, and Thailand, and also by reason of imports

from China, India, Indonesia, Kazakhstan, Netherlands, Romania, Taiwan, Thailand, and Ukraine

of hot‐rolled steel that was found by Commerce to be sold in the United States at LTFV.8 After

receipt of the Commission’s determinations, Commerce issued countervailing duty orders on

imports of hot‐rolled steel from Argentina, India, Indonesia, South Africa, and Thailand,9 and

                                                            

(...continued)

Argentina, 66 FR 37007, July 16, 2001; Notice of Final Determination of Sales at Less Than Fair Value:

Certain Hot‐Rolled Carbon Steel Flat Products From Taiwan, 66 FR 49618, September 28, 2011; Final

Affirmative Countervailing Duty Determination: Certain Hot‐Rolled Carbon Steel Flat Products From

Indonesia, 66 FR 49637, September 28, 2001; Final Affirmative Countervailing Duty Determination:

Certain Hot‐Rolled Carbon Steel Flat Products From India, 66 FR 49635, September 28, 2001; Final

Determination of Sales at Less Than Fair Value: Certain Hot‐Rolled Carbon Steel Flat Products From the

People’s Republic of China, 66 FR 49632, September 28, 2001; Notice of Final Determination of Sales at

Less Than Fair Value: Certain Hot‐Rolled Carbon Steel Flat Products From Indonesia, 66 FR 49628,

September 28, 2001; Notice of Final Determination of Antidumping Duty Investigation: Certain Hot‐

Rolled Carbon Steel Flat Products from Romania, 66 FR 49625, September 28, 2001; Notice of Final

Determination of Sales at Less Than Fair Value; Certain Hot‐Rolled Carbon Steel Flat Products From

Thailand, 66 FR 49622, September 28, 2001; Notice of Final Determination of Sales at Less Than Fair

Value: Certain Hot‐Rolled Carbon Steel Flat Products From Kazakhstan, 66 FR 50397, October 3, 2001;

Notice of Final Determination of Sales at Less Than Fair Value: Certain Hot‐Rolled Carbon Steel Flat

Products From Ukraine, 66 FR 50401, October 3, 2001; Notice of Final Determination of Sales at Less

Than Fair Value: Certain Hot‐Rolled Carbon Steel Flat Products From India, 66 FR 50406, October 3, 2001;

Notice of Final Determination of Sales at Less Than Fair Value; Certain Hot‐Rolled Carbon Steel Flat

Products From The Netherlands, 66 FR 50408, October 3, 2001; Final Affirmative Countervailing Duty

Determination: Certain Hot‐Rolled Carbon Steel Flat Products From Thailand, 66 FR 50410, October 3,

2001; Final Affirmative Countervailing Duty Determination: Certain Hot‐Rolled Carbon Steel Flat Products

from South Africa, 66 FR 50412, October 3, 2001. 7 Hot‐Rolled Steel Products from Argentina and South Africa: Investigation No. 701‐TA‐404 (Final) and

Investigations Nos. 731‐TA‐898 and 905 (Final), USITC Publication 3446, August 2001, p. 1.

8 Hot‐Rolled Steel Products From China, India, Indonesia, Kazakhstan, The Netherlands, Romania,

South Africa, Taiwan, Thailand, and Ukraine: Investigations Nos. 701‐TA‐405‐408 (Final) and

Investigations Nos. 731‐TA‐899‐904 and 906‐908 (Final), USITC Publication 3468, November 2001, p. 1.

9 66 FR 47173, September 11, 2001 (Argentina) and 66 FR 60197, 60198, and 60201, December 3,

2001 (India, Indonesia, South Africa, and Thailand).
  

I‐4

antidumping duty orders on imports of hot‐rolled steel from Argentina, China, India, Indonesia,

Kazakhstan, Netherlands, Romania, South Africa, Taiwan, Thailand, and Ukraine.10

Subsequent five‐year reviews  

On June 27, 2007, Commerce published its final results concerning the antidumping

duty order on hot‐rolled steel from the Netherlands.11 In those final results, Commerce revoked

the order, effective November 29, 2006. Accordingly, the Commission terminated its five‐year

review regarding hot‐rolled steel from the Netherlands, effective June 27, 2007.12  

In October 2007, the Commission completed full five‐year reviews of the remaining

subject orders and determined that revocation of the countervailing duty orders on hot‐rolled

steel products from India, Indonesia, and Thailand and the antidumping duty orders on hot‐

rolled steel products from China, India, Indonesia, Taiwan, Thailand, and Ukraine would be

likely to lead to continuation or recurrence of material injury to an industry in the United States

within a reasonably foreseeable time. The Commission also determined that revocation of the

countervailing duty orders on hot‐rolled steel products from Argentina and South Africa and the

antidumping duty orders on hot‐rolled steel products from Argentina, Kazakhstan, Romania,

and South Africa would not be likely to lead to continuation or recurrence of material injury to

an industry in the United States within a reasonably foreseeable time.13 Following affirmative

determinations in the first five‐year reviews by Commerce and the Commission,14 Commerce

issued a continuation of the antidumping duty orders on imports of hot‐rolled steel from India,

Indonesia, China, Taiwan, Thailand, and Ukraine, and countervailing duty orders on imports of

hot‐rolled steel from India, Indonesia, and Thailand, effective December 27, 2007.15

                                                            

10 66 FR 48242, Sepember 19, 2001 (Argentina and South Africa); 66 FR 58435, November 21, 2001

(Kazakhstan); 66 FR 59559, 59561, 59562, 59563, 59565, 59566, November 29, 2001 (China,

Netherlands, Romania, Taiwan, Thailand, and Ukraine); and 66 FR 60192 and 90194, December 3, 2001

(India and Indonesia). 11 Certain Hot–Rolled Carbon Steel Flat Products from the Netherlands; Final Results of the Sunset

Review of Antidumping Duty Order and Revocation of the Order, 72 FR 35220, June 27, 2007. 12 Hot‐Rolled Steel Products From the Netherlands, 72 FR 40322, July 24, 2007.

13 Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐

908 (Review), USITC Publication 3956, October 2007. 14 Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, 72 FR 61676, October 31, 2007.

15 Certain Hot‐Rolled Carbon Steel Flat Products from India, Indonesia, the People’s Republic of China,

Taiwan, Thailand, and Ukraine: Continuation of Antidumping Duty and Countervailing Duty Orders, 72 FR

73316, December 27, 2007.
  

I‐5

SUMMARY DATA

Table I‐1 presents a summary of data from the original investigations, the first reviews,

and the current full five‐year reviews. 16  

                                                            

16 The tabulation below presents the imports from, and respective shares of apparent U.S.

consumption quantity (1998‐2006) of the countries for which orders have been revoked:  

Item 1998 1999 2000 2001 2002 2003 2004 2005 2006

Imports from‐‐         

  Argentina       

     Quantity 0 116,950 118,920 26,753 4,058 0 0 0 198

     Value 0 29,765 34,192 6,067 1,330 0 0 0 181

     Share of U.S.

consumption quantity 0.0 0.2 0.2 (

1

) (

1

) 0.0 0.0 0.0 (

1

)

   Kazakhstan:        

     Quantity 130,329 123,132 192,470 14,604 0 0 0 0 0

     Value 34,306 24,727 45,070 2,640 0 0 0 0 0

     Share of U.S.

consumption quantity 0.2 0.2 0.3 (

1

) 0.0 0.0 0.0 0.0 0.0

   Netherlands:        

     Quantity 440,866 505,601 562,597 377,909 356,860 184,586 274,734 306,093 336,709

     Value 147,432 153,495 179,591 105,489 124,859 59,810 130,328 153,606 176,248

     Share of U.S.

consumption quantity 0.6 0.7 0.8 0.6 0.5 0.3 0.4 0.5 0.5

   Romania:       

     Quantity 128,253 384,458 410,796 56,869 103,512 32,895 17,802 0 12,892

     Value 32,896 80,543 104,291 11,607 26,269 8,745 10,227 0 6,933

     Share of U.S.

consumption quantity 0.2 0.5 0.6 0.1 0.2 (

1

) (

1

) 0.0 (

1

)

   South Africa:        

     Quantity 80,434 173,044 167,773 4,903 112,066 28,647 10,355 90 9,829

     Value 22,321 40,440 47,229 1,344 30,914 8,013 5,510 67 4,361

     Share of U.S.

consumption quantity 0.1 0.2 0.2 (

1

) 0.2 (

1

) (

1

) (

1

) (

1

) 1 Less than 0.05 percent

Source: Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South Africa, Taiwan,

Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐908 (Review), USITC Publication

3956, October 2007, pp. I‐5‐8.
  

I‐6

Table I-1 

Hot-rolled steel: Comparative data from the original investigations, first reviews, and current reviews, 

1998-2012 

(Quantity in short tons, value in 1,000 dollars, unit values in dollars per short ton, share/ratios in percent)

Calendar Year 

Item 1998 1999 2000 2001 2002 2003 2004 2005 2006 

U.S. consumption quantity: 

Amount 73,969,211 71,395,689 72,535,753 63,734,503 67,915,736 67,332,264 73,344,264 66,937,489 73,188,204

U.S. producers' share 84.1 91.1 89.9 95.4 93.1 96.0 93.0 94.2 91.2

U.S. importers' share: 

 China 0.1 0.7 0.7 0.1 0.0 0.0 0.0 0.0 0.0

 India 0.1 0.7 1.2 0.1 0.0 0.0 0.0 0.0 0.1

 Indonesia 0.1 0.4 0.4 0.0 0.0 0.0 0.0 0.0 0.0

 Taiwan 0.3 0.6 1.0 0.1 0.0 0.0 0.0 0.0 0.0

 Thailand 0.0 0.1 0.3 0.0 0.2 0.1 0.1 0.1 0.2

 Ukraine 0.2 0.1 0.3 0.0 0.0 0.0 0.0 0.0 0.0

 Subtotal subject sources1 0.8 2.5 3.9 0.3 0.2 0.1 0.2 0.1 0.3

 All other sources1 15.1 6.4 6.2 4.3 6.7 4.0 6.9 5.7 8.5

 Total imports 15.9 8.9 10.1 4.6 6.9 4.0 7.0 5.8 8.8

U.S. imports from: 

 China: 

 Quantity 102,588 467,380 485,299 42,184 47 28 6,456 418 3,851

 Value 26,626 106,648 139,475 10,206 16 23 4,056 249 2,218

 Unit value 260 228 287 242 346 817 628 596 576

 India: 

 Quantity 109,941 504,155 876,264 51,480 5,919 0 11,392 6,618 62,234

 Value 30,062 119,121 253,991 12,309 1,857 0 7,819 4,951 32,418

 Unit value 273 236 290 239 314 --- 686 748 521

 Indonesia: 

 Quantity 38,163 301,264 259,166 10,726 0 0 5 0 0

 Value 11,021 69,343 74,574 2,576 0 0 5 0 0

 Unit value 289 230 288 240 --- --- 944 --- ---

 Taiwan: 

 Quantity 224,058 428,939 724,854 42,144 1,153 107 1,381 142 7,305

 Value 61,858 104,003 222,532 11,578 363 116 929 136 4,583

 Unit value 276 242 307 275 315 1,083 673 959 627

 Thailand: 

 Quantity 18,050 38,637 233,762 15,847 139,856 34,162 93,414 43,289 155,824

 Value 5,521 10,422 70,070 4,836 43,463 10,927 51,045 21,948 81,498

 Unit value 306 270 300 305 311 320 546 507 523

 Ukraine: 

 Quantity 126,648 72,907 213,764 25,694 612 11 0 1,558 0

 Value 27,280 13,146 50,012 5,318 202 6 0 1,689 0

 Unit value 215 180 234 207 330 545 --- 1,084 ---

Table continued on next page. 
  

I‐7

Table I-1--Continued

Calendar Year 

Item 2007 2008 2009 2010 2011 2012 

U.S. consumption quantity: 

Amount 62,549,603 57,229,936 37,966,100 53,075,072 56,543,057 59,970,608

U.S. producers' share 94.6 93.7 94.0 94.3 93.7 93.6

U.S. importers' share: 

 China 0.0 0.0 0.0 0.0 0.0 0.0

 India 0.0 0.0 0.0 0.0 0.0 0.0

 Indonesia 0.0 0.0 0.0 0.0 0.0 0.0

 Taiwan 0.0 0.0 0.0 0.0 0.0 0.0

 Thailand 0.0 0.0 0.0 0.0 0.0 0.0

 Ukraine 0.0 0.0 0.0 0.0 0.0 0.0

 Subtotal subject sources1 0.0 0.0 0.0 0.0 0.0 0.0

 All other sources1 5.3 6.3 6.0 5.7 6.3 6.3

 Total imports 5.4 6.3 6.0 5.7 6.3 6.4

U.S. imports from: 

 China: 

 Quantity 1,093 247 159 1,631 541 2,419

 Value 732 222 172 1,469 649 3,027

 Unit value 670 897 1,085 900 1,200 1,251

 India: 

 Quantity 17,665 185 0 0 0 0

 Value 10,464 291 0 0 0 0

 Unit value 592 1,571 --- --- --- ---

 Indonesia: 

 Quantity 0 0 0 0 0 0

 Value 0 0 0 0 0 0

 Unit value --- --- --- --- --- ---

 Taiwan: 

 Quantity 241 655 95 45 2,483 560

 Value 142 484 101 39 1,976 414

 Unit value 590 739 1,065 877 796 739

 Thailand: 

 Quantity 2,171 5,632 0 0 0 0

 Value 1,075 4,685 0 0 0 0

 Unit value 495 832 --- --- --- ---

 Ukraine: 

 Quantity 0 19 0 0 0 806

 Value 0 44 0 0 0 624

 Unit value --- 2,316 --- --- --- 774
  

I‐8

Table I-1--Continued

Hot-rolled steel: Comparative data from the original investigations, first reviews, and current reviews, 

1998-2012 

(Quantity in short tons, value in 1,000 dollars, unit values in dollars per short ton, share/ratios in percent)

Calendar Year 

Item 1998 1999 2000 2001 2002 2003 2004 2005 2006 

 Subtotal, subject sources:1 

 Quantity 619,448 1,813,282 2,793,109 188,075 147,587 34,308 112,648 52,025 229,214

 Value 162,368 422,683 810,654 46,824 45,901 11,072 63,854 28,973 120,717

 Unit value 262 233 290 249 311 323 567 557 527

 All other sources:1 

 Quantity 11,134,789 4,558,953 4,523,514 2,760,169 4,522,145 2,668,949 5,032,647 3,816,805 6,213,360

 Value 3,123,925 1,256,189 1,374,562 732,667 1,380,001 871,276 2,561,246 2,092,750 3,238,957

 Unit value 281 276 304 265 305 326 509 548 521

 Total: 

 Quantity 11,754,237 6,372,235 7,316,623 2,948,244 4,669,732 2,703,257 5,145,295 3,868,830 6,442,574

 Value 3,286,293 1,678,872 2,185,216 779,491 1,425,902 882,348 2,625,100 2,121,723 3,359,674

 Unit value 280 263 299 264 305 326 510 548 521

U.S. producers: 

 Capacity quantity 73,468,340 75,462,035 76,397,442 76,209,185 72,131,725 79,050,475 79,548,531 80,937,517 81,625,989

 Production quantity 62,456,688 65,279,659 65,898,724 61,191,189 63,953,326 65,755,453 68,999,997 63,623,849 67,259,535

 Capacity utilization 85.0 86.5 86.3 80.3 88.7 83.2 86.7 78.6 82.4

U.S. shipments: 

 Quantity 62,214,973 65,023,453 65,219,129 60,786,259 63,246,004 64,629,007 68,198,969 63,068,660 66,745,630

 Value 20,137,306 18,455,603 19,522,683 15,907,830 19,326,100 19,265,233 35,876,504 33,826,995 37,677,886

 Unit value 324 284 299 262 306 298 526 536 564

Export shipments: 

 Quantity 173,764 360,825 608,378 429,896 484,860 1,347,738 701,037 717,152 562,380

 Value 58,960 114,386 198,031 143,067 162,679 396,423 378,642 393,604 331,743

 Unit value 339 317 326 333 336 294 540 549 590

Ending inventory quantity 2,463,228 2,365,945 2,410,466 2,402,874 1,868,338 1,700,334 1,800,323 1,633,160 1,610,876

Inventory/total shipments 3.9 3.6 3.7 3.9 2.9 2.6 2.6 2.6 2.4

Production workers 31,956 31,073 30,385 32,553 30,109 29,614 27,567 25,247 24,739

Hours worked (1,000) 71,732 69,932 69,208 69,086 64,247 62,783 61,203 54,892 54,137

Wages paid ($1,000) 1,746,327 1,731,700 1,737,694 1,795,750 1,705,625 1,833,951 1,871,916 1,723,671 1,778,044

Hourly wages 24.35 24.76 25.11 25.99 26.55 29.21 30.59 31.40 32.84

Productivity (short tons per 1,000 

hours) 

871 934 952 886 995 1,047 1,127 1,159 1,242

Net sales 

 Quantity 62,368,430 64,830,978 66,154,694 60,213,636 62,674,493 64,803,909 67,709,851 62,670,818 65,984,669 

 Value 20,279,125 18,454,261 19,882,231 15,768,995 19,152,783 19,274,792 35,633,304 33,576,733 37,242,158 

 Unit value 325 285 301 262 306 297 526 536 564 

Cost of goods sold 18,893,389 18,649,602 19,545,579 19,621,646 19,262,770 20,259,034 26,716,513 27,775,350 30,374,814 

Gross profit or (loss) 1,385,736 (195,341) 336,652 (3,852,651) (109,987) (984,242) 8,916,791 5,801,383 6,867,344 

SG&A 1,052,583 1,018,594 1,041,689 877,997 977,360 1,021,408 1,338,243 1,170,149 1,163,278 

Operating income or (loss) (value) 333,153 (1,213,935) (705,037) (4,730,648) (1,087,347) (2,005,650) 7,578,548 4,631,234 5,704,066 

Cost of goods sold/sales (percent) 93.2 101.1 98.3 124.4 100.6 105.1 75.0 82.7 81.6 

Operating income or (loss) 

(percent) 

1.6 (6.6) (3.5) (30.0) (5.7) (10.4) 21.3 13.8 15.3 

Notes continued on next page. 
  

I‐9

Table I-1--Continued

 Calendar Year 

Item 2007 2008 2009 2010 2011 2012 

 Subtotal, subject sources:1 

 Quantity 21,169 6,739 254 1,676 3,024 3,784

 Value 12,413 5,726 274 1,508 2,625 4,064

 Unit value 586 850 1,078 900 868 1,074

 All other sources:1 

 Quantity 3,327,507 3,618,209 2,273,854 3,035,620 3,535,471 3,806,535

 Value 1,819,256 2,880,457 1,215,906 1,867,911 2,578,646 2,598,160

 Unit value 547 796 535 615 729 683

 Total: 

 Quantity 3,348,676 3,624,948 2,274,108 3,037,296 3,538,495 3,810,320

 Value 1,831,669 2,886,183 1,216,179 1,869,419 2,581,271 2,602,224

 Unit value 547 796 535 615 729 683

U.S. producers: 

 Capacity quantity 80,382,246 72,818,689 70,408,591 70,418,659 72,451,936 74,840,642

 Production quantity 60,698,008 54,012,619 37,219,428 51,664,655 54,213,932 57,000,441

 Capacity utilization 75.5 74.2 52.9 73.4 74.8 76.2

U.S. shipments: 

 Quantity 59,200,927 53,604,988 35,691,992 50,037,776 53,004,562 56,160,288

 Value 32,495,072 41,211,894 18,824,753 30,200,356 37,461,193 37,279,750

 Unit value 549 769 527 604 707 664

Export shipments: 

 Quantity 1,456,322 1,249,300 1,101,366 1,522,803 1,054,556 822,525

 Value 792,319 1,050,565 551,028 926,180 794,300 587,861

 Unit value 544 841 500 608 753 715

Ending inventory quantity 1,785,483 943,817 1,369,887 1,473,964 1,627,207 1,644,836

Inventory/total shipments 2.9 1.7 3.7 2.9 3.0 2.9

Production workers 22,372 21,844 18,453 19,179 20,146 20,650

Hours worked (1,000) 47,316 45,956 34,894 42,020 42,435 43,840

Wages paid ($1,000) 1,559,477 1,606,431 1,147,072 1,427,443 1,500,221 1,582,994

Hourly wages 32.96 34.96 32.87 33.97 35.35 36.11

Productivity (short tons per 1,000 

hours) 

1,283 1,175 1,067 1,230 1,278 1,300

Net sales 

 Quantity 60,527,590 55,270,071 36,703,429 51,427,742 53,739,873 56,359,493 

 Value 33,293,097 42,058,970 19,683,182 31,093,634 38,038,929 37,637,053 

 Unit value 550 761 536 605 708 668 

Cost of goods sold 29,566,504 35,663,365 20,821,586 29,225,993 33,992,832 34,244,450 

Gross profit or (loss) 3,726,593 6,395,607 (1,138,405) 1,867,641 4,046,097 3,392,604 

SG&A 874,510 878,826 644,733 717,369 909,680 1,009,994 

Operating income or (loss) (value) 2,852,083 5,516,780 (1,783,137) 1,150,272 3,136,417 2,382,610 

Cost of goods sold/sales (percent) 88.8 84.8 105.8 94.0 89.4 91.0 

Operating income or (loss) 

(percent) 

8.6 13.1 (9.1) 3.7 8.2 6.3 
  

I‐10

Table I-1--Continued

Hot-rolled steel: Comparative data from the original investigations, first reviews, and current 

reviews, 1998-2012 

Note.--Staff adjusted 2009-June 2013 imports from India to reflect non-hot-rolled steel imports. *** which ***. 

1

 Commerce published notice of its final results in the five-year review concerning the antidumping duty order on hotrolled steel from the Netherlands on June 27, 2007 (72 FR 35220). In those final results, Commerce revoked the 

order effective November 29, 2006. Accordingly, the Commission terminated its five-year review regarding hot-rolled 

steel from the Netherlands effective June 27, 2007 (72 FR 40322, July 24, 2007). Also in 2007, the Commission 

determined that revocation of the countervailing duty orders on hot-rolled steel products from Argentina and South 

Africa and the antidumping duty orders on hot-rolled steel products from Argentina, Kazakhstan, Romania, and South 

Africa would not be likely to lead to continuation or recurrence of material injury to an industry in the United States 

within a reasonably foreseeable time. Subsequently in 2007, Commerce revoked the orders for these countries. 

Therefore, data concerning Argentina, Kazakhstan, Netherlands, Romania, and South Africa are not presented as 

subject merchandise but are aggregated with the data from other nonsubject countries. 

Source: Compiled from data submitted in response to Commission questionnaires, adjusted Commerce statistics, 

Hot-Rolled Steel Products From China, India, Indonesia, Kazakhstan, The Netherlands, Romania, South Africa, 

Taiwan, Thailand, and Ukraine: Investigations Nos. 701-TA-405-408 (Final) and Investigations Nos. 731-TA-899-904 

and 906-908 (Final), USITC Publication 3468, November 2001, and Hot-Rolled Steel Products From Argentina, 

China, India, Indonesia, Kazakhstan, Romania, South Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701-

TA-404-408 and 731-TA-898-902 and 904-908 (Review), USITC Publication 3956, October 2007. 

RELATED INVESTIGATIONS

Previous and related Title VII investigations

The Commission has conducted a number of previous import relief investigations on

certain carbon steel products or substantially similar merchandise. Table I‐2 presents data on

previous and related title VII investigations for hot‐rolled steel.
  

I‐11

Table I-2 

Hot-rolled steel: Previous and related investigations, 1982-2013 

Original investigation First review Second review

Current status

Date1 Number Country Outcome Date1 Outcome Date1 Outcome

1982 701-TA-94 Belgium Affirmative2 - - - - Petition withdrawn 

10/29/82 

1982 701-TA-95 Brazil Negative2 - - - - - 

1982 701-TA-96 France Affirmative2 - - - - Petition withdrawn 

10/29/82 

1982 701-TA-97 Italy Affirmative2 - - - - Petition withdrawn 

10/29/82 

1982 701-TA-98 Luxembourg Negative2 - - - - - 

1982 701-TA-99 Netherlands Negative - - - - - 

1982 701-TA-100 United Kingdom Negative2 - - - - - 

1982 701-TA-101 Germany Affirmative2 - - - - Petition withdrawn 

10/29/82 

1982 701-TA-156 Spain Negative2 - - - - - 

1982 701-TA-171 Korea Affirmative - - - - ITA revoked 10/10/85

1982 731-TA-61 Belgium Affirmative2 - - - - Terminated 11/10/82 

1982 731-TA-62 France Affirmative2 - - - - Terminated 11/10/82 

1982 731-TA-63 Italy Affirmative2 - - - - Terminated 11/10/82 

1982 731-TA-64 Luxembourg Negative2 - - - - - 

1982 731-TA-65 Netherlands Negative - - - - - 

1982 731-TA-66 United Kingdom - - - - - Petition withdrawn 

1/30/82 

1982 731-TA-67 Germany Affirmative2 - - - - Terminated 11/10/82 

1983 701-TA-206 Brazil Affirmative - - - - ITA revoked 9/5/85 

1984 731-TA-153 Brazil Affirmative - - - - ITA revoked 8/21/85 

1985 701-TA-227 Austria Negative - - - - - 

1985 701-TA-228 Sweden Negative - - - - - 

1985 701-TA-229 Venezuela Affirmative2 - - - - Terminated 7/19/85 

Table continued on next page. 

   
  

I‐12

Table I-2--Continued

Hot-rolled steel: Previous and related investigations, 1982-2013

Original investigation First review Second review

Current status

Date1 Number Date1 Outcome Date1 Outcome Date1 Outcome

1985 731-TA-219 Austria Negative - - - - -

1985 731-TA-220 Finland - - - - - Petition withdrawn 

1/18/85

1985 731-TA-221 Hungary Affirmative2 - - - - Petition withdrawn 

6/4/85

1985 731-TA-222 Romania Affirmative2 - - - - Terminated 7/19/85

1985 731-TA-223 Venezuela Affirmative2 - - - - Terminated 7/19/85

1992 701-TA-329 Belgium Negative - - - - -

1992 701-TA-330 Brazil Negative - - - - -

1992 701-TA-331 France Negative - - - - -

1992 701-TA-332 Germany Negative - - - - -

1992 701-TA-333 Italy Negative2 - - - - -

1992 701-TA-334 Korea Negative - - - - -

1992 701-TA-335 New Zealand Negative - - - - -

1992 731-TA-588 Belgium Negative - - - - -

1992 731-TA-589 Brazil Negative - - - - -

1992 731-TA-590 Canada Negative - - - - -

1992 731-TA-591 France Negative - - - - -

1992 731-TA-592 Germany Negative - - - - -

1992 731-TA-593 Italy Negative2 - - - - -

1992 731-TA-594 Japan Negative - - - - -

1992 731-TA-595 Korea Negative - - - - -

1992 731-TA-596 Netherlands Negative - - - - -

1998 701-TA-384 Brazil Affirmative 2004 Affirmative 2010 Negative Order not continued3

1998 731-TA-806 Brazil Affirmative 2004 Affirmative 2010 Negative Order not continued3

1998 731-TA-807 Japan Affirmative 2004 Affirmative 2010 Negative Order not continued3

1998 731-TA-808 Russia Affirmative 2004 Affirmative 2010 Affirmative Order in place

2000 701-TA-404 Argentina Affirmative 2006 Negative - - Order not continued4

2000 701-TA-405 India Affirmative 2006 Affirmative 2012 - Under review

2000 701-TA-406 Indonesia Affirmative 2006 Affirmative 2012 - Under review

Table continued on next page. 

   
  

I‐13

Table I-2--Continued

Hot-rolled steel: Previous and related investigations, 1982-2013

Original investigation First review Second review

Current status

Date1 Number Country Outcome Date1 Outcome Date1 Outcome

2000 701-TA-407 South Africa Affirmative 2006 Negative - - Order not continued4

2000 701-TA-408 Thailand Affirmative 2006 Affirmative 2012 - Under review

2000 731-TA-898 Argentina Affirmative 2006 Negative - - Order not continued4

2000 731-TA-899 China Affirmative 2006 Affirmative 2012 - Under review

2000 731-TA-900 India Affirmative 2006 Affirmative 2012 - Under review

2000 731-TA-901 Indonesia Affirmative 2006 Affirmative 2012 - Under review

2000 731-TA-902 Kazakhstan Affirmative 2006 Negative - - Order not continued4

2000 731-TA-903 Netherlands Affirmative 2006 Affirmative - - Terminated 6/27/075

2000 731-TA-904 Romania Affirmative 2006 Negative - - Order not continued4

2000 731-TA-905 South Africa Affirmative 2006 Negative - - Order not continued4

2000 731-TA-906 Taiwan Affirmative 2006 Affirmative 2012 - Under review

2000 731-TA-907 Thailand Affirmative 2006 Affirmative 2012 - Under review

2000 731-TA-908 Ukraine Affirmative 2006 Affirmative 2012 - Under review

1

 “Date” refers to the year in which the investigation or review was instituted by the Commission. 

2

 Preliminary determination. 

3

 Commerce published the revocation of the subject orders on June 21, 2011 (76 FR 36081). 

4

 Commerce published the revocation of the subject order on November 20, 2007 (72 FR 65293). 5

 Commerce published notice of its final results in the five-year review concerning the antidumping duty order on hot-rolled steel 

from the Netherlands on June 27, 2007 (72 FR 35220). In those final results, Commerce revoked the order effective November 29, 

2006. Accordingly, the Commission terminated its five-year review regarding hot-rolled steel from the Netherlands effective June 27, 

2007 (72 FR 40322, July 24, 2007). 

Source: Compiled from Commission determinations published in the Federal Register. 

Previous and related safeguard investigations

Hot‐rolled steel products have been the subject of both safeguard investigations and

other arrangements to limit the importation of steel products.17 In 1984, the Commission

determined that carbon and alloy steel sheet were being imported into the United States in

such increased quantities as to be a substantial cause of serious injury to the domestic industry

producing such articles, and recommended quantitative restrictions of imports for a period of

five years. President Reagan determined that import relief under section 201 of the Trade Act

                                                            

17 A more detailed description of such measures since 1980 appears in the staff report for the first

review of the orders on hot‐rolled steel from Brazil, Japan, and Russia. Certain Hot‐Rolled Flat‐Rolled

Carbon‐Quality Steel Products From Brazil, Japan, and Russia: Investigations Nos. 701‐TA‐384 and 731‐

TA‐806‐808 (Review), USITC Publication 3767, April 2005, pp. I‐9‐10.
  

I‐14

of 1974 was not in the national interest. At the President’s direction, quantitative limitations

under voluntary restraint agreements (“VRAs”) for a five‐year period ending September 30,

1989, were negotiated. In July 1989, the VRAs were extended for two and one half years until

March 31, 1992.

In 2001, the Commission determined that certain carbon and alloy steel, including hot‐

rolled steel, was being imported into the United States in such increased quantities as to be a

substantial cause of serious injury to the domestic industry producing such articles, and

recommended additional duties on imports for a period of four years.18 On March 5, 2002,

President George W. Bush announced the implementation of steel safeguard measures. Import

relief relating to hot‐rolled steel consisted of an additional tariff for a period of three years and

one day (30 percent ad valorem on imports in the first year, 24 percent in the second year, and

18 percent in the third year).19 Following receipt of the Commission’s mid‐term monitoring

report in September 2003, and after seeking information from the U.S. Secretary of Commerce

and U.S. Secretary of Labor, President Bush determined that the effectiveness of the action

taken had been impaired by changed circumstances. Therefore, he terminated the U.S.

measure with respect to increased tariffs on December 4, 2003.20

STATUTORY CRITERIA AND ORGANIZATION OF THE REPORT

Statutory criteria

Section 751(c) of the Act requires Commerce and the Commission to conduct a review

no later than five years after the issuance of an antidumping or countervailing duty order or the

suspension of an investigation to determine whether revocation of the order or termination of

the suspended investigation “would be likely to lead to continuation or recurrence of dumping

or a countervailable subsidy (as the case may be) and of material injury.”

Section 752(a) of the Act provides that in making its determination of likelihood of

continuation or recurrence of material injury‐‐ 

(1) IN GENERAL.‐‐ . . . the Commission shall determine whether revocation of an

order, or termination of a suspended investigation, would be likely to lead to

continuation or recurrence of material injury within a reasonably foreseeable

time. The Commission shall consider the likely volume, price effect, and impact

                                                            

18 Steel; Import Investigations, 66 FR 67304, December 28, 2001.

19 Presidential Proclamation 7529 of March 5, 2002, To Facilitate Positive Adjustment to Competition

From Imports of Certain Steel Products, 67 FR 10553, March 7, 2002. The President also instructed the

Secretaries of Commerce and the Treasury to establish a system of import licensing to facilitate steel

import monitoring.

20 Presidential Proclamation 7741 of December 4, 2003, To Provide for the Termination of Action

Taken With Regard to Imports of Certain Steel Products, 68 FR 68483, December 8, 2003. Import

licensing, however, remained in place through March 21, 2005, and continues in modified form at this

time.
  

I‐15

of imports of the subject merchandise on the industry if the order is revoked or

the suspended investigation is terminated. The Commission shall take into

account‐‐ 

(A) its prior injury determinations, including the volume, price

effect, and impact of imports of the subject merchandise on the industry

before the order was issued or the suspension agreement was accepted,

(B) whether any improvement in the state of the industry is

related to the order or the suspension agreement,

(C) whether the industry is vulnerable to material injury if the

order is revoked or the suspension agreement is terminated, and  

(D) in an antidumping proceeding . . ., (Commerce’s findings)

regarding duty absorption . . ..

(2) VOLUME.‐‐In evaluating the likely volume of imports of the subject  

merchandise if the order is revoked or the suspended investigation is terminated,

the Commission shall consider whether the likely volume of imports of the

subject merchandise would be significant if the order is revoked or the

suspended investigation is terminated, either in absolute terms or relative to

production or consumption in the United States. In so doing, the Commission

shall consider all relevant economic factors, including‐‐ 

(A) any likely increase in production capacity or existing unused

production capacity in the exporting country,  

(B) existing inventories of the subject merchandise, or likely

increases in inventories,  

(C) the existence of barriers to the importation of such

merchandise into countries other than the United States, and  

(D) the potential for product‐shifting if production facilities in

the foreign country, which can be used to produce the subject

merchandise, are currently being used to produce other products.

(3) PRICE.‐‐In evaluating the likely price effects of imports of the subject

merchandise if the order is revoked or the suspended investigation is terminated,

the Commission shall consider whether‐‐ 

(A) there is likely to be significant price underselling by imports

of the subject merchandise as compared to domestic like products, and  

(B) imports of the subject merchandise are likely to enter the

United States at prices that otherwise would have a significant

depressing or suppressing effect on the price of domestic like products.

(4) IMPACT ON THE INDUSTRY.‐‐In evaluating the likely impact of imports of the

subject merchandise on the industry if the order is revoked or the suspended

investigation is terminated, the Commission shall consider all relevant economic

factors which are likely to have a bearing on the state of the industry in the

United States, including, but not limited to–
  

I‐16

(A) likely declines in output, sales, market share, profits,

productivity, return on investments, and utilization of capacity,  

(B) likely negative effects on cash flow, inventories, employment,

wages, growth, ability to raise capital, and investment, and  

(C) likely negative effects on the existing development and

production efforts of the industry, including efforts to develop a

derivative or more advanced version of the domestic like product.

The Commission shall evaluate all such relevant economic factors . . . within the

context of the business cycle and the conditions of competition that are

distinctive to the affected industry.

Section 752(a)(6) of the Act states further that in making its determination, “the

Commission may consider the magnitude of the margin of dumping or the magnitude of the net

countervailable subsidy. If a countervailable subsidy is involved, the Commission shall consider

information regarding the nature of the countervailable subsidy and whether the subsidy is a

subsidy described in Article 3 or 6.1 of the Subsidies Agreement.”  

Organization of the report

Information obtained during the course of the reviews that relates to the statutory

criteria is presented throughout this report.21 A summary of trade and financial data for hot‐

rolled steel as collected in the reviews is presented in Appendix C. U.S. industry data are based

on the questionnaire responses of 14 U.S. producers of hot‐rolled steel that are believed to

have accounted for more than 95 percent of U.S. production of hot‐rolled steel during January

2007 ‐ June 2013. U.S. import data and related information are based on Commerce’s official

import statistics as adjusted and the questionnaire responses of 32 U.S. importers of hot‐rolled

steel that are believed to have accounted for approximately two‐thirds of total U.S. imports

during January 2007‐June 2013. Foreign industry data and related information are based on the

questionnaire responses of two producers of hot‐rolled steel in India (accounting for ***

percent of total production in India in 2012), four producers in Taiwan (accounting for virtually

all production in Taiwan in 2012), and one producer in Thailand (accounting for all or nearly all

total production in Thailand in 2012). No questionnaire responses were received from

producers of hot‐rolled steel in China, Indonesia, and Ukraine. Responses by U.S. producers,

importers, purchasers, and foreign producers of hot‐rolled steel to a series of questions

concerning the significance of the existing antidumping and countervailing duty orders and the

likely effects of revocation of such orders are presented in appendix D. Appendix E presents the

industry’s financial results using a second valuation methodology for internal consumption and

transfers to related firms: the underlying cost of the hot‐rolled steel plus an amount of the

                                                            

21 Data have been updated to include all revisions received after the issuance of the prehearing

report.
  

I‐17

gross profit of downstream products as allocated based on relative cost (“cost plus allocated

gross profit of downstream products”).

COMMERCE’S REVIEWS

Administrative reviews22

The following tables present information on Commerce’s administrative reviews of the

subject orders.23 Commerce did not initiate any antidumping duty order administrative reviews

for China, Indonesia, Taiwan, and Ukraine, and did not initiate any countervailing duty order

administrative reviews for Indonesia and Thailand.

India

Since the issuance of the countervailing duty order on subject imports of hot‐rolled steel

from India, Commerce has conducted six administrative reviews of the order. The results of the

administrative reviews are shown in the following table:

                                                            

22 Commerce has issued no duty absorption findings with respect to product from the subject

countries.   23 For previously reviewed or investigated companies not included in an administrative review, the

cash deposit rate continues to be the company‐specific rate published for the most recent period.
  

I‐18

Table I-3 

Hot-rolled steel: Administrative reviews of the countervailing duty order for India 

Date results published Period of review Producer or exporter Margin 

May 13, 2004 

(69 FR 26549) 4/20/2001 - 12/31/2001 

Essar 1.69

All others 16.10

May 13, 2004 

(69 FR 26549) 1/1/2002 - 12/31/2002 

Essar 16.88

All others 16.10

May 17, 2006 

(71 FR 28665) 1/1/2004 - 12/31/2004 

Essar 4.56

All others 16.10

July 14, 2008 

(73 FR 40295) 1/1/2006 – 12/31/2006 

Essar1

 23.64

Ispat Industries 15.27

JSW Steel 484.41

Tata Steel 27.22

February 11, 2011 

(76 FR 7811) 1/1/2007 - 12/31/2007 Essar 22.19

December 14, 2011 

(76 FR 77775) 1/1/2008 – 12/31/2008 Tata Steel 102.74

1

 Amended October 21, 2011 (76 FR 65498). 

Source: Cited Federal Register notices. 

Since the issuance of the antidumping duty order on subject imports of hot‐rolled from

India, Commerce has conducted four administrative reviews of the order. The results of the

administrative reviews are shown in the following table:

Table I-4 

Hot-rolled steel: Administrative review of the antidumping duty order for India 

Date results published Period of review Producer or exporter Margin 

June 28, 2004 

(69 FR 36060) 5/3/2001 - 11/30/2002 

Essar 0.00

All others 23.87

June 5, 2008 

(FR 73 31961) 12/1/2005 – 11/30/2006 

Ispat 0.00

Tata Steel 0.09

JSW 0.24

Essar1 9.01

April 20, 2009 

(74 FR 17951) 12/1/2006 – 11/30/2007 Essar 5.01

May 14, 2010 

(75 FR 27297) 12/1/2007 – 11/30/2008 Essar 28.25

1

 Amended July 13, 2012 (77 FR 41374). 

Source: Cited Federal Register notice. 
  

I‐19

Thailand

Since the issuance of the antidumping duty order on subject imports of hot‐rolled from

Thailand, Commerce has conducted five administrative reviews of the order. The results of

administrative reviews are shown in the following table:

Table I-5 

Hot-rolled steel: Administrative reviews of the antidumping duty order for Thailand 

Date results published Period of review Producer or exporter Margin 

April 13, 2004 

(69 FR 19388) 5/3/2001 - 10/31/2002 

Sahaviriya Steel 0.00

All others 3.86

May 17, 2006 

(71 FR 28659) 11/1/2003 - 10/31/2004 

Sahaviriya Steel 0.00

All others 3.86

May 17, 2007 

(72 FR 27802) 11/1/2004 – 10/31/2005 NSM 8.23

June 12, 2008 

(73 FR 33396) 11/1/2005 – 10/31/2006 G Steel 6.40

December 10, 2009 

(74 FR 65518) 11/1/2007 – 10/31/2008 G Steel 20.30

Source: Cited Federal Register notices. 

Changed circumstances review

Commerce has conducted one changed circumstances review with respect to hot‐rolled

steel from Thailand. On May 17, 2006, Commerce revoked in part the antidumping duty order

on certain hot‐rolled steel from Thailand with respect to Sahaviriya Steel Industries Public

Company Limited (“Sahaviriya Steel” or “SSI”) after having determined that Sahaviriya Steel sold

the merchandise at not less than normal value (‘‘NV’’) for a period of at least three consecutive

years.24 In April 2008, Commerce initiated a changed circumstances review to determine

whether SSI had resumed dumping hot‐rolled steel and whether the antidumping order should

                                                            

24 The second administrative review (period of review of November 1, 2002 through October 31,

2003) was rescinded on April 7, 2004, and therefore no antidumping duty margin was calculated. See

Certain Hot‐Rolled Carbon Steel Flat Products from Thailand: Rescission of Antidumping Duty

Administrative Review, 69 FR 18349 (April 7, 2004). Commerce’s regulations provide that the

Department need not conduct an administrative review of an intervening year before deciding to revoke

an order as long as shipments, ‘‘during each of the three (or five) years, there were exports to the

United States in commercial quantities of the subject merchandise to which a revocation or termination

will apply.’’ The second period of review constituted the intervening year, and therefore Commerce

concluded Sahaviriya Steel met the requirement of not selling at less than normal value for three

consecutive years. Certain Hot‐Rolled Carbon Steel Flat Products From Thailand; Preliminary Results of

Antidumping Duty Administrative Review and Intent to Revoke and Rescind in Part, 70 FR 73197,

December 9, 2005.
  

I‐20

be reinstated for hot‐rolled steel from Thailand manufactured and exported by Sahaviriya

Steel.25 Having found that hot‐rolled steel from Thailand manufactured and exported by

Sahaviriya Steel was being sold at less than NV, Commerce reinstated Sahaviriya Steel in the

antidumping duty order, effective May 15, 2009.26

Five‐year reviews

Commerce has issued the final results of its expedited reviews with respect to all subject

countries.27 Table I‐6 presents the countervailable subsidy margins/dumping margins calculated

by Commerce in its original investigations, first reviews, and second reviews. Table I‐7 presents

the dumping margins for producers/exporters calculated by Commerce in its original

investigations, first reviews, and second reviews. Commerce found the following programs to

be countervailable:28

India

 Advance Licenses

 Duty Entitlement Passbook Scheme

 Export Promotion of Capital Goods Scheme

 Loans from the Steel Development Fund ("SDF'') Fund

 The GOI's Forgiveness of SDF Loans Issued to SAIL

 Loan Guarantees from the GOI

Indonesia

 GOIA Equity Infusions

 Two‐Step Loan

                                                            

25 Initiation of Antidumping Duty Changed Circumstances Review: Certain Hot–Rolled Carbon Steel

Flat Products from Thailand, 73 FR 18766, April 7, 2008.

26 Certain Hot–Rolled Carbon Steel Flat Products from Thailand: Final Results of Antidumping Duty

Changed Circumstances Review and Reinstatement in the Antidumping Duty Order, 74 FR 22885, May

15, 2009.

27 Certain Hot‐Rolled Carbon Steel Flat Products from India, Indonesia, the People’s Republic of China,

Taiwan, Thailand, and Ukraine; Final Results of the Expedited Second Sunset Reviews of the Antidumping

Duty Orders, 78 FR 15703, March 12, 2013. Certain Hot‐Rolled Carbon Steel Flat Products from India,

Indonesia, and Thailand: Final Results of Expedited Sunset Reviews, 78 FR 16252, March 14, 2013.

28 Decision Memorandum for the Final Results of the Expedited Second Sunset Reviews of the

Countervailing Duty Orders on Certain Hot‐rolled Carbon Steel Flat Products from India and Indonesia to

Paul Piquado, Assistant Secretary for Import Administration, March 5, 2013, and Decision Memorandum

for the Final Results of the Expedited Second Sunset Reviews of the Countervailing Duty Order on Certain

Hot‐rolled Carbon Steel Flat Products from Thailand to Paul Piquado, Assistant Secretary for Import

Administration, March 5, 2013.
  

I‐21

Thailand

 IPA Section 36(1)

 IPA Section 28

 IPA Section 30

 IPA Section 35(3)

 Provision of electricity for less than adequate remuneration

Table I-6 

Hot-rolled steel: Commerce’s original, first, and second five-year review countervailable subsidy 

margins for producers/exporters, by subject country 

Producer/exporter 

Original margin 

(percent) 

First five-year review 

margin (percent) 

Second five-year 

review margin 

(percent) 

India1

Essar 8.28 12.90 539.89 

Ispat 31.89 36.51 563.50 

SAIL 18.27 22.89 549.88 

Tata Steel 9.17 13.79 540.78 

All others 16.10 20.72 547.71 

Indonesia2

P.T. Krakatau Steel 10.21 10.21 10.21 

All others 10.21 10.21 10.21 

Thailand3

Sahaviriya Steel 2.38 2.38 2.38 

All others 2.38 2.38 2.38 1

 Countervailing duty order, 66 FR 60198, December 3, 2001; final results of first expedited sunset review, 71 FR 

70960, December 7, 2006; final results of second expedited sunset review, 78 FR 16252, March 14, 2013. 2

 Countervailing duty order, 66 FR 60198, December 3, 2001; final results of first expedited sunset review, 71 FR 

70960, December 7, 2006; final results of second expedited sunset review, 78 FR 16252, March 14, 2013. 3

 Countervailing duty order, 66 FR 60197, December 3, 2001; final results of first expedited sunset review, 71 FR 

70960, December 7, 2006; final results of second expedited sunset review, 78 FR 16252, March 14, 2013. 

Source: Cited Federal Register notices. 
  

I‐22

Table I-7 

Hot-rolled steel: Commerce’s original, first, and second five-year review dumping margins for 

producers/exporters, by subject country 

Producer/exporter 

Original margin 

(percent) 

First five-year 

review margin 

(percent) 

Second five-year 

review margin 

(percent) 

China1

Angang GroupHong Kong Co., Ltd. 90.83 31.09 31.09 

Angang Group International Trade Corp. 69.85 31.09 31.09 

Baoshan Iron & Steel Co., Ltd. 90.83 12.39 12.34 

Baosteel Group International Trade Corp. 90.83 12.39 12.34 

Bengang Steel Plates Co., Ltd. 90.83 57.19 57.19 

Benxi Iron & Steel Group Co., Ltd. 90.83 57.19 57.19 

Benxi Iron & Steel Group International 

Economic & Trade Co., Ltd. 90.83 57.19 57.19 

New Iron & Steel Co., Ltd. 90.83 31.09 31.09 

Panzhihua Iron & Steel (Group) Co. 65.59 65.59 65.59 

Shanghai Baosteel Group Corp. 64.20 12.39 12.34 

Wuhan Iron & Steel Group Corp. 65.59 65.59 65.59 

All others 90.83 90.83 90.83 

India2

Ispat Industries 44.40 44.40 44.40 

Essar 36.53 36.53 36.53 

All others 38.72 38.72 38.72 

Indonesia3

PT Krakatau Steel 47.86 47.86 47.86 

All others 47.86 47.86 47.86 

Taiwan4

An Feng Steel 29.14 29.14 29.14 

China Steel/Yieh Loong 29.14 29.14 29.14 

All others 20.28 20.28 20.28 

Thailand5

Sahaviriya Steel 3.86 (6) 7.35 

Siam Strip Mill 19.72 20.30 20.30 

All others 3.86 4.44 4.41 

Ukraine7

All others 90.33 90.33 90.33 

Notes continued on next page. 
  

I‐23

Table I-7--Continued

Hot-rolled steel: Commerce’s original, first, and second five-year review dumping margins for 

producers/exporters, by subject country 

1

 Antidumping duty order, 66 FR 59561, November 29, 2001; final results of first expedited sunset review, 71 FR 

70506, December 5, 2006; and final results of second expedited sunset review, 78 FR 15703, March 12, 2013. 2

 Antidumping duty order, 66 FR 60192, December 3, 2001; final results of first expedited sunset review, 71 FR 

70506, December 5, 2006; and final results of second expedited sunset review, 78 FR 15703, March 12, 2013. 3

 Antidumping duty order, 66 FR 60192, December 3, 2001; final results of first expedited sunset review, 71 FR 

70506, December 5, 2006; and final results of second expedited sunset review, 78 FR 15703, March 12, 2013. 4 Antidumping duty order, 66 FR 59563, November 29, 2001; final results of first expedited sunset review, 71 FR 

70506, December 5, 2006; and final results of second expedited sunset review, 78 FR 15703, March 12, 2013. 5

 Antidumping duty order, 66 FR 59562, November 29, 2001; final results of first expedited sunset review, 71 FR 

70506, December 5, 2006; and final results of second expedited sunset review, 78 FR 15703, March 12, 2013. 6

 Antidumping order revoked with respect to SSI. 71 FR 28659, May 17, 2006. 

7

 Antidumping duty order, 66 FR 59559, November 29, 2001; final results of first expedited sunset review, 71 FR 

70506, December 5, 2006; and final results of second expedited sunset review, 78 FR 15703, March 12, 2013. 

Source: Cited Federal Register notices. 

THE SUBJECT MERCHANDISE

Commerce’s scope

Commerce has defined the scope of these reviews as follows:29

...certain hot‐rolled carbon steel flat products of a rectangular shape, of a width

of 0.5 inch or greater, neither clad, plated, nor coated with metal and whether or not

painted, varnished, or coated with plastics or other non‐metallic substances, in coils

(whether or not in successively superimposed layers), regardless of thickness, and in

straight lengths, of a thickness of less than 4.75 mm and of a width measuring at least

10 times the thickness. Universal mill plate (i.e., flat‐rolled products rolled on four faces

or in a closed box pass, of a width exceeding 150 mm, but not exceeding 1250 mm, and

of a thickness of not less than 4.0 mm, not in coils and without patterns in relief) of a

thickness not less than 4.0 mm is not included within the scope of the order.  

Specifically included in the scope of the order are vacuum‐degassed, fully stabilized

(commonly referred to as interstitial‐free (IF)) steels, high‐strength low‐alloy (HSLA) steels, and

the substrate for motor lamination steels. IF steels are recognized as low‐carbon steels with

                                                            

29 Certain Hot‐Rolled Carbon Steel Flat Products From India, Indonesia, the People’s Republic of China,

Taiwan, Thailand, and Ukraine; Final Results of the Expedited Second Sunset Reviews of the Antidumping

Duty Orders, 78 FR 15073, March 12, 2003; Issues and Decision Memorandum from Christian Marsh,

Deputy Assistant Secretary for Antidumping and Countervailing Duty Operations to Paul Piquado,

Assistant Secretary for Import Administration, March 5, 2013; Certain Hot‐Rolled Carbon Steel Flat

Products From India, Indonesia, and Thailand: Final Results of Expedited Sunset Reviews, 78 FR 16252,

March 14, 2013; and Issues and Decision Memorandum for the Final Results of the Expedited Second

Sunset Reviews of the Countervailing Duty Orders on Certain Hot‐rolled Carbon Steel Flat Products from

India and Indonesia to Paul Piquado, Assistant Secretary for Import Administration, March 5, 2013.
  

I‐24

micro‐alloying levels of elements such as titanium or niobium (also commonly referred to as

columbium), or both, added to stabilize carbon and nitrogen elements. HSLA steels are

recognized as steels with micro‐alloying levels of elements such as chromium, copper, niobium,

vanadium, and molybdenum. The substrate for motor lamination steels contains micro‐alloying

levels of elements such as silicon and aluminum.  

Steel products included in the scope of the order, regardless of definitions in the

Harmonized Tariff Schedule of the United States (“HTS”), are products in which: i) iron

predominates, by weight, over each of the other contained elements; ii) the carbon content is 2

percent or less, by weight; and iii) none of the elements listed below exceeds the quantity, by

weight, respectively indicated:

1.80 percent of manganese, or 0.40 percent of lead, or

2.25 percent of silicon, or 1.25 percent of nickel, or

1.00 percent of copper, or 0.30 percent of tungsten, or

0.50 percent of aluminum, or 0.10 percent of molybdenum, or

1.25 percent of chromium, or 0.10 percent of niobium, or

0.30 percent of cobalt, or 0.15 percent of vanadium, or

0.15 percent of zirconium.

All products that meet the physical and chemical descriptions provided above are within

the scope of the orders unless otherwise excluded.30

                                                            

30 The following products, by way of example, are outside or specifically excluded from the scope of

the orders:  

 Alloy hot‐rolled steel products in which at least one of the chemical elements exceeds those

listed above (including, American Society for Testing and Materials (‘‘ASTM’’) specifications A543,

A387, A514, A517, A506).  

 Society of Automotive Engineers (‘‘SAE’’)/American Iron & Steel Institute (‘‘AISI’’) grades of series

2300 and higher.  

 Ball bearing steels, as defined in the HTS (in additional U.S. note 1(h) to chapter 72).  

 Tool steels, as defined in the HTS (in additional U.S. note 1(e) to chapter 72).

 Silico‐manganese (as defined in the HTS) or silicon electrical steel with a silicon level exceeding

2.25 percent (as defined in subheading notes 1(e) and (with the above specification) 1(c) to

chapter 72, respectively).

 ASTM specifications A710 and A736.  

 USS Abrasion‐resistant steels (USS AR 400, USS AR 500).  

 All products (proprietary or otherwise) based on an alloy ASTM specification (sample

specifications: ASTM A506, A507).  

 Non‐rectangular shapes, not in coils, which are the result of having been processed by cutting or

stamping and which have assumed the character of articles or products classified outside chapter

72 of the HTS.
  

I‐25

Tariff treatment

Hot‐rolled steel31 is classifiable in the HTS under headings 7208, 7210, 7211, 7212, 7225,

and 7226.32 In 1999, prior to the filing of the original petition, U.S. tariffs on hot‐rolled steel

ranged as high as 4.8 percent ad valorem. As a result of staged duty rate reductions that began

in 1995, U.S. tariffs on hot‐rolled steel were eliminated by 2004. Goods imported into the

United States under all of the HTS numbers applicable to these reviews are currently free of

duty under the column 1 general rate of duty.

THE PRODUCT

Description and applications

Steel is generally defined as a combination of carbon and iron that is usefully malleable

as first cast, and in which iron predominates, by weight, over each of the other contained

elements and the carbon content is two percent or less, by weight.33 Carbon steel includes

most common grades of steel and generally is less expensive to produce than the various

grades of alloy steels, due primarily to the cost of the alloying elements.  

The majority of hot‐rolled steel production is consumed internally or transferred to

affiliates for downstream processing into cold‐rolled and/or galvanized or plated products, cut‐

to‐length plate, or welded pipe. The remainder is sold commercially to end users, service

centers, and to steel processors for conversion into downstream steel products, including cold‐

                                                            

31 Note 1(d) to chapter 72 of the HTS specifies that a product must be “usefully malleable” and not be

a ferrous material of heading 7203 in order to be classified as steel.

32 The merchandise subject to the orders is imported under the following HTS statistical reporting

numbers: 7208.10.1500, 7208.10.3000, 7208.10.6000, 7208.25.3000, 7208.25.6000, 7208.26.0030,

7208.26.0060, 7208.27.0030, 7208.27.0060, 7208.36.0030, 7208.36.0060, 7208.37.0030, 7208.37.0060,

7208.38.0015, 7208.38.0030, 7208.38.0090, 7208.39.0015, 7208.39.0030, 7208.39.0090, 7208.40.6030,

7208.40.6060, 7208.53.0000, 7208.54.0000, 7208.90.0000, 7211.14.0090, 7211.19.1500, 7211.19.2000,

7211.19.3000, 7211.19.4500, 7211.19.6000, 7211.19.7530, 7211.19.7560, and 7211.19.7590. Certain

hot‐rolled carbon steel flat products covered by the orders, including vacuum degassed fully stabilized,

high strength low alloy, and the substrate for motor lamination steel, may also enter under the following

tariff numbers: 7225.11.0000, 7225.19.0000, 7225.30.3050, 7225.30.7000, 7225.40.7000, 7225.99.0090,

7226.11.1000, 7226.11.9030, 7226.11.9060, 7226.19.1000, 7226.19.9000, 7226.91.5000, 7226.91.7000,

7226.91.8000, and 7226.99.0180. Subject merchandise may also enter under 7210.70.3000,

7210.90.9000, 7211.14.0030, 7212.40.1000, 7212.40.5000, and 7212.50.0000. Although the HTS

numbers are provided for convenience and customs purposes, the written product description remains

dispositive.

33 Harmonized Tariff Schedule of the United States (2011), chap. 72, note 1(d), Steel:  Ferrous

materials other than those of heading 7203 which (with the exception of certain types produced in the

form of castings) are usefully malleable and which contain by weight 2 percent or less of carbon.

However, chromium steels may contain higher proportions of carbon.
  

I‐26

rolled steel, coated steel, and pipe products. Information summarizing the channels of

distribution for hot‐rolled steel is presented in Part II.  

Steel may compete against other materials, such as aluminum, plastics, and advanced

composites. Hot‐rolled steel is used in general structural functional areas where surface finish

and light weight are not crucial. Such steel is well suited for and extensively used in automotive

applications such as body frames and wheels, tubing, and floor decks in steel construction. Hot‐

rolled steel also is used in transportation equipment (such as rail cars, ships, and barges), non‐

residential construction, appliances, heavy machinery, and machine parts. Interstitial‐free (“IF”)

steel is low‐carbon steel having unique deep‐drawing ability on stamping presses.34 High

strength‐low alloy (“HSLA”) steels are used in structural applications for the construction,

automotive, machinery, and equipment industries where strength and other attributes are

important.

Although uses of hot‐rolled steel include applications where surface finish and light

weight have historically not been crucial, “lightweighting” is becoming increasingly important.

As a result, producers are striving to produce higher‐strength steel in thinner gauges to

substitute for regular‐strength hot‐rolled or even for cold‐rolled steel in thicknesses of 2 mm or

less. In the automotive sector, lightweighting is important to meet regulatory requirements

such as the U.S. Corporate Average Fuel Economy (CAFE) requirements.35 Lightweighting uses

advanced high‐strength steels, which can reduce a vehicle’s structural weight by as much as 39

percent,36 and substitutes other materials for steel. Domestic interested parties stated that

lightweighting in automobile production has been reported to reduce hot‐rolled steel demand

in the United States *** and offsets other factors that would tend to increase demand such as

an improving economy.37  

Common material specifications for hot‐rolled steel include ASTM A1011, which applies

to products less than 0.230 inch in thickness, and ASTM A1018, which applies to material 0.230

inch or greater in thickness. Both specifications cover hot‐rolled carbon steel, including

commercial steel, drawing quality steel, high‐strength low‐alloy steel, and ultra‐high strength

steel sheet and strip, in coils and cut lengths (coils only for A1018).

                                                            

34 IF steels have very low amounts of interstitial elements (primarily carbon and nitrogen) with small

amounts of titanium or niobium added to tie up the remaining interstitial atoms. Without free

interstitial elements, these steels are very ductile and soft. American Iron and Steel Institute, “IF

(Interstitial‐Free Steel),” found at

http://www.steel.org/sitecore/content/Autosteel_org/Web%20Root/Research/AHSS%20Data%20Utiliza

tion/IF/Content.aspx . 35 “First enacted by Congress in 1975, the purpose of CAFE is to reduce energy consumption by

increasing the fuel economy of cars and light trucks.” National Highway Traffic Safety Administration,

“CAFÉ – Fuel Economy,” found at http://www.nhtsa.gov/fuel‐economy. 36 American Iron and Steel Institute, “”Beyond Strong:  Steel is Lightweight,” found at

http://www.steel.org/sitecore/content/Autosteel_org/Document%20Types/Beyond%20Strong/Beyond

%20Strong%20‐%20Steel%20is%20Lightweight.aspx.    37 ArcelorMittal’s posthearing brief, exh. 1, “Responses to Commission Questions,” p. 30.
  

I‐27

Manufacturing processes38

Broadly speaking, a producer of hot‐rolled steel may be considered to be: (1) an

integrated mill, producing steel from iron ore and a limited amount of scrap, and with a thick

slab casting and rolling operation);39 (2) a “mini” or electric furnace mill, producing steel from

purchased scrap and supplemented with primary iron products (scrap substitutes, usually with

a thin slab casting and rolling operation );40 or (3) a rolling‐only operation, with no on‐site

steelmaking, using slabs purchased from other steelmakers (usually imported).41 Each of these

three types of operations has an inherent cost structure that differs from the other two; an

integrated producer typically has the highest fixed costs and the highest value added in its cost

structure; a mini‐mill generally has higher raw material costs but less value added; and a rolling‐

only operation has the lowest value added but the highest raw material cost.

The manufacturing processes for hot‐rolled steel products are summarized below. In

general, the production of hot‐rolled steel encompasses three distinct stages:  (1) melting and

refining, (2) casting molten steel into semi‐finished forms, and (3) hot‐rolling semi‐finished

forms into flat‐rolled carbon steel mill products.

Basic steel production requires primary inputs such as coke, iron ore, limestone, and

steel scrap. Coke is a refined carbon product produced by baking coal to drive off volatile

matter, and is the principal fuel used to produce hot metal in blast furnaces. Iron ore is melted

to produce liquid metal. Limestone is used to flux the liquid metal, thus purifying it. Scrap is

used for a portion of the basic oxygen furnace charge; hot metal accounts for the remainder. In

addition, scrap is the primary input for electric arc furnace (“EAF”) production. Scrap contains

non‐ferrous tramp elements so production that uses a lower ratio of scrap to hot metal can

generate the clean, pure steel often required for certain value‐added applications.

                                                            

38 Unless otherwise indicated, the source for the information in this section is found in Hot‐Rolled

Flat‐Rolled Carbon‐Quality Steel Products from Brazil, Japan, and Russia, Invs Nos. 701‐TA‐384 and 731‐

TA‐806‐808 (Second Review), USITC Publication 4237, June 2011, pp. I‐26‐29.

39 Companies that are exclusively or predominately integrated include AK Steel, ArcelorMittal,

Severstal (Dearborn and Columbus), and U.S. Steel. Severstal (Wheeling), idled in 2009, was an

integrated mill that also had an EAF. Information on mill steel making capabilities was compiled from

company websites and Metal Bulletin, Iron & Steel Works of the World Directory 2009, 18th edition,

January 2009.

40 Mills that predominately or exclusively use EAFs to produce steel include Gallatin, NLMK, North

Star, Nucor, SDI, and SSAB. Information on mill steel making capabilities was compiled from company

websites. 41 Rolling‐only operations include CSI, Evraz, and ThyssenKrupp. Information on rolling‐only

operations was compiled from company websites and a news article, OregonLive, “Evraz Portland Will

Fire Up Oregon Steel Mill Closed in 2009, Hiring 200,” October 17, 2012.  
  

I‐28

Melt stage

Steel for the manufacture of hot‐rolled steel products is produced from raw materials by

either an “integrated” or “nonintegrated” process. In an integrated process, iron ore, the

principal iron‐containing raw material is smelted in a blast furnace, using coke, usually

supplemented with coal, natural gas, or fuel oil, to produce molten pig iron, which is drained

into a large ladle and transported to an oxygen steelmaking furnace. The molten pig iron is

poured into a steelmaking furnace, together with a lesser amount of steel scrap and flux

materials such as burnt lime, burnt dolomite, and fluorspar. High‐purity oxygen is injected into

the furnace and reacts with dissolved carbon and other impurities in the charge materials,

raising the temperature to that necessary for further processing. Molten steel is poured or

“tapped” from the furnace to a ladle to be transported to a ladle metallurgy station and then to

casting.

The nonintegrated, or scrap‐based, process produces molten steel by melting scrap or

scrap substitutes in an EAF.42 Primary iron products, including cold pig iron, direct‐reduced iron

and hot‐briquetted iron, also are used as raw materials in electric‐arc furnace steelmaking.43

The charge materials are melted by electrical current passing through an arc between an

electrode and the material in the furnace. Oxygen is used to burn off impurities, but at a

fraction of the amounts used in oxygen steelmaking. After melting, the molten steel is tapped

into a ladle for further processing.

Whether integrated or nonintegrated, steelmakers typically utilize a secondary

steelmaking stage, also called a ladle metallurgy station. Shifting the final refining stages to the

ladle metallurgy station allows shorter cycles in the primary steelmaking vessel, effectively

raising steelmaking capacity. Special ladle treatments include desulfurization and vacuum

degassing, which improve steel cleanliness, formability, surface quality, chemistry, and

strength. Steelmakers employ additional techniques to refine the product further into extra‐

clean or low‐carbon steels. These refinements are needed to satisfy stringent surface or

internal quality, and mechanical properties.44 Steelmakers may adjust the chemical content by

                                                            

42 To control product quality further, newer thin‐slab flat‐rolled mills are using to various degrees

scrap substitutes such as direct‐reduced iron, hot‐briquetted iron, and iron carbide.

43 Because scrap is generally considered to be the main raw material for electric‐arc steelmaking and

these primary iron products reduce the amount of scrap needed, they are often referred to as “scrap

substitutes.” Their use depends upon their prices relative to that of scrap and upon particular end‐

product‐related requirements for material containing smaller amounts of undesirable elements than

does scrap. 44 The goals of secondary steelmaking include controlling gases (e.g., decreasing the concentration of

oxygen, hydrogen, and nitrogen, called “degassing”), reducing sulfur, removing undesirable nonmetallic

inclusions such as oxides and sulfides, changing the composition and/or shape of oxides and sulfides

that cannot be completely removed, and improving the mechanical properties of the finished steel.

American Iron and Steel Institute, “Secondary Refining,” found at

http://www.steel.org/~/media/Files/AISI/Making%20Steel/Article%20Files/learning_2ndrefining.pdf,

retrieved September 3, 2013.  
  

I‐29

adding alloying elements or by lowering the carbon content (decarburization), or adjusting the

temperature of the steel for optimum casting. While carbon content may be reduced further by

subsequent hydrogen annealing of the coiled steel, the steel’s essential characteristics are

established prior to the casting stage. Steelmakers continually seek process improvements and

two such improvements include the Conarc® and Corex® technologies. The Conarc® process

combines features of both the integrated and EAF processes in a single production unit, i.e. a

steelmaking furnace where oxygen is injected into the liquid metal to react with dissolved

carbon and other impurities and the electric furnace process which uses electricity to melt the

solid substances and superheat the bath to tapping temperature.45 Corex® technology allows

integrated mills to smelt iron ore using mostly coal instead of expensive coke.46

Slab casting stage

Following the production of molten steel with the desired properties, the steel is cast

into a form that can enter the rolling process. Continuous casters convert molten steel into

slabs for rolling into finished product and the vast majority of carbon sheet steels produced in

the United States are continuously cast.47 There are two broad categories of continuous casting

used by most U.S. and foreign integrated producers of hot‐rolled steel products:  conventional

or thick‐slab continuous casters and thin‐slab casters. Most U.S. integrated producers use the

conventional process, whereas most of the nonintegrated facilities use thin‐ or thinner‐slab

casting processes. Thin slab casting eliminates the need for a reheat furnace. Additional

differences between thin‐slab casting and conventional continuous‐strand slab casting include

the shape of the casting mold, the desired thickness of the slab, and the linkage of steel casting

with direct hot rolling.  

                                                            

45 SMS Siemag AG, “Steelmaking: Conarc®,” found at http://www.sms‐siemag.com/en/1520.html,

retrieved September 13, 2013.

46 Siemans AG, “Profitable and environmentally friendly ironmaking,” found at

http://www.industry.siemens.com/verticals/metals‐

industry/en/metals/ironmaking/corex/pages/home.aspx , retrieved September 13, 2013. 47 Continuous slab casting bypasses several steps of the conventional ingot casting process by casting

steel directly into semifinished shapes, called slabs, in the desired cross‐sectional dimensions. The many

benefits derived from this quicker casting method include increased yield, improved product quality,

and decreased energy consumption. American Iron and Steel Institute, “Continuous Casting of Steel:

Basic Principles,” found at

http://www.steel.org/Making%20Steel/How%20Its%20Made/Processes/Processes%20Info/Continuous

%20Casting%20of%20Steel%20‐%20Basic%20Principles.aspx, retrieved September 3, 2013. All or

virtually all of the crude steel produced by most of the subject countries is continuously cast with the

exceptions of India and Ukraine which use ingot casting for 29.4 and 45.9 percent of its crude steel (both

carbon and alloy) production, respectively. World Steel Association, Steel Statistical Yearbook 2012,

tables 3 and 4.
  

I‐30

Rolling stage

Hot‐rolled carbon steel flat products are produced on hot‐strip mills. Essential

components of a hot‐strip mill are a rolling mill, a run‐out table for cooling the hot‐rolled strip

after rolling, and equipment to coil the strip. Depending upon the planned capacity of the

operation, the thickness of the slabs entering the mill, and properties of the hot‐rolled coil to

be produced, there are many different configurations of hot‐strip mills. When rolling from a

thick slab, as described above, there is normally a slab heating furnace, a roughing train

consisting of several rolling stands (sets of rollers), typically four to five, that reduce the slab or

a single reversing stand in which the slab is passed back and forth through the stand and a

finishing train with an additional four to seven stands to further reduce the thickness and

impart the desired surface finish to the steel. The steel then exits the finishing train onto a

runout table where the product is subjected to a combination of water sprays, laminar jets,

and/or air cooling to remove mill scale and reduce the temperature of the steel. The steel is

then coiled at the end of the runout table. Hot‐rolled steel destined for the sheet market can be

either shipped as black band, or cleaned in an acid bath and sold as pickled band. These

products are used in non‐critical surface applications such as automotive frames and wheels,

construction products, pipe, off‐highway equipment, and guardrails.

“Thin” slabs are typically 2 to 3 inches in thickness, and are transferred directly from the

casting operation to the rolling mill. Because thin slabs require fewer rolling passes than thick

slabs, the roughing mill may be not be required and the finishing train may be a single,

reversing mill rather than a series of in‐line mills as described above. The reversing mill could be

of the “Steckel” type, which coils the strip between passes in special furnaces on each side of

the mill, to reduce heat loss.

Nucor has built two twin‐roll strip casting facilities that cast a solid strip approximately 2

mm thick directly from a pool of molten steel established between two counter‐rotating rolls.

The strip is fed directly into a single hot‐rolling mill for reduction to final thickness and then

along a cooling table to a coiler. The first of these new facilities started up in 2002 and the

second, more advanced unit, started up in 2009.48 Advantages claimed for the twin‐roll strip

casting process in comparison to conventional thick‐slab or thin‐slab processing include the

capability to economically produce hot‐rolled steel 1 to 2 mm in thickness, which can be used in

some applications as a substitute for more expensive cold‐rolled steel. In addition, a steel plant

                                                            

48 In 1988, BHP Steel of Australia and Ishikawajima‐Harima Heavy Industries (“IHI”) of Japan began a

collaborative effort to determine the commercial feasibility of twin‐roll strip casting of steel. BHP and IHI

needed a partner with the ability to commercialize the process (trademarked as “Castrip”) and in 2000

Nucor Corp. joined BHP and IHI to form Castrip LLC. Castrip LLC owns the technology and Nucor has the

exclusive license to the process in the United States. For more information on the Castrip® process, see

Castrip LLC’s website, found at www.castrip.com.  
  

I‐31

incorporating the twin‐roll strip casting practice may be built at a much lower capital cost, with

a lower economic capacity, than a conventional hot‐rolling plant.49

Subsequent operations

Hot‐rolled steel may undergo a number of subsequent processes before being used

internally by a steel producer or sold. Processing subsequent to hot‐rolling may include a

temper pass to improve surface finish, gauge tolerance, and coil tightness; pickling and light oil

coating;50 and operations that level, slit, or shear hot‐strip mill products to width or length. If

the hot‐rolled product is designated for cold‐reduction and coating, it is first pickled in a series

of acid baths, to remove surface oxides that result from exposure to water and the atmosphere.

The steel is then treated with an oil that is compatible with the mill’s cold‐reduction mill, cold‐

reduced,51 annealed, and temper passed. It might then be coated with a metallic coating.52

Pickling, oiling, tempering, leveling, slitting, or shearing can take place at the mill; alternatively,

a mill can arrange for these operations to be performed at a service center.  

Steel service centers serve as distributors of flat‐rolled steel products. Many service

centers maintain extensive inventories of a variety of steel products, providing availability and

inventory management services for customers of all sizes, including those with smaller

purchasing needs that must place low‐volume orders. Some service centers perform value‐

added processing, such as uncoiling, flattening, and cutting flat‐rolled products to length or

burning hundreds of intricate parts from a single sheet.  

                                                            

49 Castrip LLC, “The Castrip® Advantage,” found at

http://www.castrip.com./Advantage/advantage.html accessed September 3, 2013.

50 During the hot‐rolling process, exposure to water and air results in the formation of oxides on the

surface of the steel. Pickling involves passing the hot‐rolled product through a series of acid baths to

remove the oxides. The material is then dried and oiled to prevent reformation of oxides, and recoiled.

51 Cold‐reduction rolling involves a fairly large reduction in the thickness of the hot‐rolled material,

typically ranging from 25 to 90 percent. The term “cold‐rolling” refers to any process in which the

product is fed into a rolling mill at ambient temperature. Cold‐rolling can be performed for a variety of

reasons, including a desired reduction in product thickness, a need to impart specific mechanical

properties, or to impart a specific surface texture. A cold‐rolling mill typically has five to seven roll

stands.

52 Flat‐rolled steel products are coated with metals or nonmetallic substances to improve their

aesthetics, improve corrosion resistance, and anticipate the requirements of downstream forming

operations.
  

I‐32

DOMESTIC LIKE PRODUCT ISSUES

In its original determinations, the Commission defined the domestic like product as all

hot‐rolled steel products corresponding to Commerce’s scope and it defined the domestic

industry as all domestic producers of hot‐rolled steel.53 In the first reviews, the Commission

continued to define a single domestic like product coextensive with Commerce’s scope.54 In its

notice of institution in these current five‐year reviews, the Commission solicited comments

from interested parties regarding the appropriate domestic like product and domestic

industry.55 The domestic interested parties indicated in their response that they do not object

to the Commission’s like product and domestic industry definitions.56 Taiwan respondent

interested parties took no position in the adequacy phase, while Shang Chen Steel Co. Ltd

(“Shang Chen”) agreed with the Commission’s like product and domestic industry definitions.57

Thai respondent interested party Sahaviriya Steel indicated in its response that it agreed with

the Commission’s definitions, but may revisit the issue at a later stage of the proceeding.58 No

party requested that the Commission collect data concerning other possible domestic like

products in their comments on the Commission’s draft questionnaires. No other interested

party provided further comment on the domestic like product.

U.S. MARKET PARTICIPANTS

U.S. producers

During the original investigations, 21 firms supplied the Commission with information

on their U.S. operations with respect to hot‐rolled steel. These firms accounted for more than

                                                            

53 Hot‐Rolled Steel Products From Argentina and South Africa: Investigation No. 701‐TA‐404 (Final)

and Investigations Nos. 731‐TA‐898 and 905 (Final), USITC Publication 3446, August 2001, p. 6; Hot‐

Rolled Steel Products From China, India, Indonesia, Kazakhstan, The Netherlands, Romania, South Africa,

Taiwan, Thailand, and Ukraine: Investigations Nos. 701‐TA‐405‐408 (Final) and Investigations Nos. 731‐

TA‐899‐904 and 906‐908 (Final), USITC Publication 3468, November 2001, p. 3.

54 Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐

908 (Review), USITC Publication 3956, October 2007, p. 8. 55 Hot‐Rolled Steel Products From China, India, Indonesia, Taiwan, Thailand, and Ukraine; Institution

of Five‐Year Reviews Concerning the Countervailing Duty Orders on Hot‐ Rolled Steel Products From

India, Indonesia, and Thailand and Antidumping Duty Orders on Hot‐ Rolled Steel Products From China,

India, Indonesia, Taiwan, Thailand, and Ukraine, 77 FR 66078, November 1, 2012.

56 Domestic interested parties’ response to notice of institution, p. 28. See also, ArcelorMittal USA’s

prehearing brief, p. 5 and SDI, Gallatin, and SSAB’s prehearing brief, p. 2. 57 Shang Chen’s response to notice of institution, p. 18; China Steel’s response, p. 8; Chung Hung’s

response, p. 6; Dragon Steel’s response, p. 6

58 Sahaviriya Steel’s response, p.16. Sahaviriya Steel did not revisit the issue.
  

I‐33

90 percent of U.S. production of hot‐rolled steel in 2000.59 In the Commission’s first five‐year

reviews 16 mills, representing all commercial U.S. production of hot‐rolled steel in 2006,

provided the Commission with data on their hot‐rolled steel operations.60 61 In these current

proceedings, the Commission issued U.S. producers’ questionnaires to 22 firms, 14 of which

provided the Commission with information on their operations. These firms are believed to

account for more than 95 percent of U.S. production of hot‐rolled steel in January 2007‐June

2013.62 Table I‐8 presents a list of the responding domestic producers and each company’s

position on continuation of the orders, production locations(s), parent company, and share of

reported production of hot‐rolled steel in 2012.63  

                                                            

59 The 21 U.S. producers that supplied the Commission with usable questionnaire information during

the original investigations are: AK Steel Corp. (“AK Steel”); Beta Steel Corp. (“Beta Steel”); Bethlehem;

California Steel Industries, Inc. (“CSI”); Gallatin; Geneva Steel Co.; IPSCO; Ispat/Inland, Inc.; Lone Star

Steel Co.; LTV Steel Co., Inc.; National; Newport Steel Corp.; North Star BHP Steel L.L.C.; Nucor; Rouge

Steel Co.; SDI; Tuscaloosa Steel Corp.; U.S. Steel; WCI Steel, Inc. (“WCI”); Weirton; and Wheeling‐

Pittsburgh Steel Corp. (“WPS”).

60 These 16 U.S. producers were AK Steel, Beta Steel, CSI, Duferco Farrell, Evraz Oregon Steel Mills,

Gallatin, IPSCO, Lone Star, Mittal Steel USA, North Star Blue Scope Steel, Nucor, Severstal, SDI, U.S. Steel,

WCI, and WPS.

61 Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐

908 (Review), USITC Publication 3956, October 2007, p. I‐38.

62 Domestic production is understated as data for RG Steel ***. “RG Steel to idle its 3 plants; looking

for a buyer,” Reuters, March 25, 2012, found at http://www.reuters.com/article/2012/05/24/us‐rgsteel‐

plants‐idUKBRE84N1GI20120524.

Domestic interested parties’ note that as much of the equipment has been disassembled or

removed, it is virtually impossible for Sparrows Point to restart production. The facility in Wheeling, WV

with its relatively new EAF equipment could be restarted with sufficient demand and the Warren, OH

facility requires a large amount of capital investment in the blast furnace also reducing the likelihood of

restarting that facility. Hearing transcript, pp. 83‐84 (Longhi, Ferriola, and McCall).

63 In addition, a proposed new steel mill, Big River Steel (Osceola, Arkansas), with a reported

groundbreaking likely in first quarter of 2014, will have an annual capacity of 1.7 million tons and will

produce hot‐rolled, cold‐rolled, galvanized grain‐ and non‐grain oriented electrical steels, and substrate

for pipe.
  

I‐34

Table I-8 

Hot-rolled steel: U.S. producers, positions on orders, U.S. production locations, parent company, 

and shares of 2012 reported U.S. production 

Firm Position on orders U.S. production 

locations 

Parent Company Share of 

production 

(percent) 

AK Steel *** Ashland, KY 

Butler, PA 

Middletown, OH 

AK Steel (U.S.) ***

ArcelorMittal *** Burns Habor, IN 

Cleveland, OH 

East Chicago, IN 

Riverdale, IL 

ArcelorMittal S.A. (Luxembourg) ***

CSI *** Fontana, CA ***% JFE Steel (Japan) 

***% Vale S.A. (Brazil) 

***

EVRAZ *** Portland, OR Evraz Plc. (Luxembourg) ***

Gallatin *** Ghent, KY ***% ArcelorMittalDofasco (Canada)

***% Gerdau North America (U.S.) 

***

NLMK *** Farrell, PA Top Gun Investment Corp. II (U.S.)1 ***

North Star *** Delta, OH ***% NSS Ventures (U.S.) 

***% BlueScope Steel (Australia) 

***

Nucor *** Blytheville, AR 

Trinity, AL 

Tuscaloosa, AL 

Crawfordsville, IN 

Huger, SC 

Nucor (U.S.) ***

RG Steel N/A Sparrows Point, MD

Warren, OH 

Wheeling, WV 

RG Steel (U.S.)2 ***

Severstal *** Columbus, MS 

Dearborn, MI 

Severstal U.S. Holdings (U.S.)3 ***

SSAB *** Muscatine, IA 

Axis, AL 

SSAB AD (Sweden) ***

SDI *** Butler, IN Steel Dynamics (U.S.) ***

ThyssenKrupp *** Calvert, AL ThyssenKrupp (Germany)4 ***

U.S. Steel *** Fairfield, AL 

Granite City, IL 

Gary, IN 

Ecorse, MI 

Dravosburg, PA 

U.S. Steel (U.S.) ***

Total 100.0

1

 Top Gun Investment Corp. II is a wholly owned by NLMK Overseas Holdings, which is in turn a wholly owned subsidiary of NLMK 

(Russia). "NLMK sold its share in Top Gun Investment Corp. II." AK&M, found at 

http://www.akm.ru/eng/news/2011/may/06/ns3542870.htm. 

2

 Facilities in Wheeling, WV, Warren, OH and Sparrows Point, MD were acquired in March 2011 from Severstal by Renco Group to 

create RG Steel. Hot-rolled steel production at RG Wheeling ceased in 2009, while RG Sparrows Point and RG Warren ceased hotrolled steel production in 2012 (as noted earlier, data for RG Steel ***). In May 2013, RG Steel declared Chapter 11 bankruptcy. "RG 

Steel Seeks Bankruptcy Protection, Plans to Sell Mills", Bloomberg, May 31, 2012, found at http://www.bloomberg.com/news/2012-

05-31/wp-steel-venture-llc-files-for-bankruptcy-in-delaware.html. 

3

 Severstal North America is a wholly-owned subsidiary of Russian-based OAO Severstal, found at 

http://www.severstalna.com/eng/about/corporate_profile/index.phtml. 4

 ThyssenKrupp Steel USA is a subsidiary of ThyssenKrupp Steel Americas, LLC, which is in turn a subsidiary of ThyssenKrupp 

A.G. (Germany), found at http://www.thyssenkrupp.com/en/standorte/detail.html&orga_id=170573. 

Source: Compiled from data submitted in response to Commission questionnaires. 
  

I‐35

Several U.S. producers are related to foreign producers or U.S. importers of hot‐rolled

steel. ArcelorMittal is related to exporters of hot‐rolled steel throughout the world (e.g.,

Belgium, Canada, France, Germany, and Spain). In addition, ArcelorMittal is related to several

foreign producers of hot‐rolled steel in subject and nonsubject countries, including ***.

California Steel Industries is related to *** importer/exporter and foreign producer JFE Steel

(Japan). Evraz is related to *** importer/exporters in Italy, Czech Republic, and South Africa and

foreign producer Evraz Regina (Canada). Gallatin is related to foreign producer ArcelorMittal

Dofasco (Canada). NLMK is related to *** importer/exporter and domestic producer NLMK

Indiana (U.S.). North Star is related to *** importers/exporters Cargill Metals Supply Chain

(U.S.) and BlueScope America (U.S.), as well as to foreign producers New Zealand Steel (New

Zealand), BlueScope Steel (Australia), and BlueScope Steel Western Port Works (Australia).

Nucor is related to *** importer/exporter Nucor Trading USA (U.S.). Severstal Dearborn and

Severstal Columbus are related to foreign producer OAO Severstal (Russia). SSAB Americas is

related to *** importers/exporters SSAB AB (Sweden), also a related foreign producer, and

SSAB Inc. (U.S.). ThyssenKrupp is related to *** importers ThyssenKrupp Steel North America

(U.S.), ThyssenKrupp Steel Services Trading (U.S.), and ThyssenKrupp Steel Europe (Germany),

also a foreign producer. In addition, ThyssenKrupp is related to foreign producer Hoesch

Hohenlimburg (Germany). U.S. Steel is related to *** importers/exporters USS‐Posco Industries

(U.S.), United Spiral Pipe (U.S.), and U.S. Steel Canada. In addition, U.S. Steel is related to

foreign producers U.S. Steel Canada and U.S. Steel Kosice (Slovak Republic). As discussed in Part

III, no domestic producers imported or purchased from importers subject merchandise.

Figure I‐1 illustrates the changes in company/mill ownership that have occurred since

the original investigations.
  

I‐36

Figure I-1 

Hot-rolled steel: Openings, closings, and consolidations of U.S. mills, 2000, 2007, and 2013 

U.S. mills in 2000 U.S. mills in 2007 U.S. mills in 2013 

AK Steel AK Steel AK Steel 

 

Acme Steel ArcelorMittal 

During 2002-2007, Acme 

Steel, Bethlehem Steel, LTV 

Steel, and Weirton Steel were 

acquired by the International 

Steel Group (ISG), Ispat 

International N.V. (parent 

company of Ispat Inland) 

acquired LNM Holdings N.V. 

and merged with ISG creating 

Mittal Steel Co., N.V., and 

Mittal Steel merged with 

Arcelor creating ArcelorMittal 

ArcelorMittal USA 

The merger of Arcelor and Mittal 

required the divestment of 

Bethlehem Steel's Sparrows 

Point, MD operations. The 

Sparrows Point operations are 

sold to Severstal in 2008. 

 

 

Bethlehem Steel 

 

Ispat Inland 

 

 

LTV Steel 

 

Weirton Steel 

 

CSI CSI CSI 

Oregon Steel Mills Evraz Oregon Steel Mills Evraz Oregon Steel Mills 

 

Geneva Steel 

Closed in 2004 and core 

assets sold to firms in 

China 

 

 

Gallatin Steel 

Joint venture between 

Dofasco Canada, 

Inc.(owned by Arcelor) 

and Co-Steel (a Canadian 

company) 

Gallatin Steel 

As a result of merger of Mittal 

Steel and Arcelor, and the 

acquisition of Co-Steel by 

Brazil-based Gerdau, Gallatin 

is now a joint venture between 

ArcelorMittal and Gerdau. 

Gallatin Steel 

Joint venture between 

ArcelorMittal and Gerdau. 

 

 

Gulf States Steel 

Closed in 2000 

 

Figure continued on next page.   
  

I‐37

Figure I-1--Continued

Hot-rolled steel: Openings, closings, and consolidations of U.S. mills, 2000, 2007, and 2013

U.S. mills in 2000 U.S. mills in 2007 U.S. mills in 2013

Beta Steel Beta Steel 

NLMK 

 

 

Duferco Farrell 

Duferco Farrell 

Owned by joint venture 

between Duferco and NLMK 

in 2007 

 

 

Newport Steel 

Closed in 2001 

 

North Star/BHP 

North Star Blue Scope 

North Star Blue Scope 

separated from BHP in 2002 

North Star Blue Scope 

 

 

Nucor 

Nucor Nucor 

 

 

Trico Steel 

Corus Tuscaloosa 

 

IPSCO SSAB SSAB 

 

 

Steel Dynamics Steel Dynamics Steel Dynamics 

 

 ThyssenKrupp 

New company began production 

in 2010 

 

Lone Star 

U.S. Steel 

Shut down Lone Star's hotrolled operations in 2007 

U.S. Steel 

 

 

National Steel 

USX 

 

WCI Steel WCI Steel 

WCI, Esmark, and the Sparrows 

Point, MD operations owned by 

ArcelorMittal are acquired by 

Severstal in 2008 and sold to RG 

Steel in 2011. RG Steel's 

operations are closed in 2012 

and subsequently sold to 

liquidators. 

 

 

Wheeling-Pittsburgh Steel Esmark 

Source: Compiled from information obtained from company websites, news articles, and Metal Bulletin Books, Iron & 

Steel Works of the World, 14th edition, 2001.
  

I‐38

U.S. importers

In the original investigations, 25 U.S. importing firms supplied the Commission with

usable information on their operations involving the importation of hot‐rolled steel. Of the

responding U.S. importers, two (Bethlehem and U.S. Steel), were themselves domestic

producers; two others, ***, were sister companies to domestic producers; four were U.S.

subsidiaries of foreign producers in Argentina, India, the Netherlands, and South Africa; and six

others were related to foreign producers in Canada, Germany, Japan, and the United Kingdom.  

In the Commission’s first five‐year review, 52 firms supplied usable import data. Of the

responding U.S. importers, two (Duferco Farrell and Lone Star), were themselves domestic

producers; six others, *** were related to domestic producers; four were U.S. subsidiaries of

foreign producers in Kazakhstan, Romania, and South Africa.

In the current proceedings, the Commission issued U.S. importers’ questionnaires to 78

firms believed to be importers of hot‐rolled steel, as well as to all U.S. producers of hot‐rolled

steel. Usable questionnaire responses were received from 32 firms, accounting for

approximately two‐thirds of total U.S. imports during January 2007‐June 2013. Table I‐9 lists all

responding U.S. importers of hot‐rolled steel from subject countries and other sources, their

locations, and their shares of reported U.S. imports in 2012.  
  

I‐39

Table I-9 

Hot-rolled steel: U.S. importers, U.S. headquarters, parent company, source(s) of imports, and 

shares of imports in 2012 

Share of reported 2012 

imports (percent) 

Firm Headquarters Parent Source (s) of 

imports 

Subject Other Total

Ahmsa International San Antonio, TX Altos Hornos De Mexico *** *** *** ***

ArcelorMittal Dofasco Hamilton, ON Arcelormittal (Luxembourg) *** *** *** ***

ArcelorMittal International Chicago, IL Arcelormittal (Luxembourg) *** *** *** ***

Cargill Hopkins, MN None *** *** *** ***

Commercial Metals Irving, TX None *** *** *** ***

Companhia Siderugica 

(CSN) 

Terre Haute, IN CSN (Brazil) *** *** *** ***

Coutinho & Ferrostaal Houston, TX Groupo Villacero (Mexico) *** *** *** ***

Essar Steel Algoma Sault Ste. Marie, 

ON 

Algoma Holding B.V. 

(Netherlands) 

*** *** *** ***

Evraz Portland, OR Evraz plc (Luxembourg) *** *** *** ***

Honda Trading America Marysville, OH Honda Trading (Japan) 

American Honda Motor (U.S.) 

*** *** *** ***

JFE Shoji Trade America Long Beach, CA JFE Shoji Trade (Japan) *** *** *** ***

Kloeckner Metals 

Corporation 

Poswell, GA Kloeckner & Co SE Group *** *** *** ***

Macsteel International 

USA 

White Plains, NY Macsteel International 

Trading 

*** *** *** ***

Marubeni - Itochu Steel 

America 

New York, NY Marubeni-Itochu Steel 

(Japan) 

*** *** *** ***

Metal One America Rosemont, IL Metal One Holding (U.S.) *** *** *** ***

Metallia USA Fort Lee , NJ None *** *** *** ***

Mitsui USA New York, NY Mitsui & Co. (Japan) *** *** *** ***

Nippon Steel Trading 

America 

Chicago, IL Nippon Steel Trading Co. 

(Japan) 

*** *** *** ***

Noble Americas Stamford, CT Noble Group (Hong Kong) *** *** *** ***

Nucor Trading USA Los Angeles, CA Nucor (U.S.) *** *** *** ***

Salzgitter Mannesmann Houston, TX Salzgitter Mannesmann 

International (Germany) 

*** *** *** ***

Samuel, Son & Co. Mississuuga, ON None *** *** *** ***

SSAB Moon Twp, PA SSAB (Sweden) *** *** *** ***

Stemcor Usa New York, NY Stemcor Holdings (U.K.) *** *** *** ***

Sunbelt Group Houston, TX Russel Metals (Canada) *** *** *** ***

Taisei International US Huntington Beach, 

CA 

None *** *** *** ***

Tata Steel International 

(Americas) 

Schaumburg, IL Tata Steel International 

(Americas) Holdings (U.S.) 

*** *** *** ***

Ternium International USA Houston, TX Ternium, S.A. (Luxembourg) *** *** *** ***

ThyssenKrupp Materials 

NA 

Southfield, MI Thyssenkrupp North America 

(U.S.) 

*** *** *** ***

Toyota Tsusho America Georgetown, KY Toyota Tsusho (Japan) *** *** *** ***

U.S. Steel Pittsburgh, PA None *** *** *** ***

USS-POSCO Industries Pittsburg, CA Pitcal/U.S. Steel (U.S.)PoscoCalifornia (U.S.) *** *** *** ***

Total 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires.
  

I‐40

U.S. purchasers

Purchaser questionnaires were issued to 65 purchasers.64 Responses were received

from 43 of these firms, 38 of which provided useable data. In addition, the Commission

received a few purchaser questionnaires from firms that were not issued the questionnaire.

These include some responses from domestic producers and importers.65 These purchasers

accounted for 10.8 million tons of steel purchased in the United States in 2012. The majority

(86.2 percent) was purchased from domestic producers and 13.8 percent from nonsubject

import sources. Although one purchaser indicated that it bought some hot‐rolled steel from

***, this accounted for less than 0.1 percent of total reported purchases.

APPARENT U.S. CONSUMPTION

Data concerning apparent U.S. consumption of hot‐rolled steel during 2007‐12, January‐

June 2012, and January‐June 2013 are shown in table I‐10 and figure I‐2. Apparent U.S.

consumption, by quantity, declined in 2008 and, more steeply, in 2009.66 Apparent U.S.

consumption increased in 2010, 2011, and 2012, but still was 4.1 percent lower in 2012 than in

2007. Apparent U.S. consumption by quantity was 3.3 percent lower in interim 2013 compared

with interim 2012.

                                                            

64 In particular, four purchaser questionnaires were received from firms that are owned by ***. ***.

65 Eleven of the responding purchasers identified themselves as processors/service centers, 6 as

tubular products producers, 5 as distributors, 5 as auto manufacturers, 2 as machinery and equipment

producers, 2 as construction equipment producers, 2 as consumer and household goods producers, and

11 as “other” purchasers.

66 Domestic interested parties noted that following the economic crisis in late 2008, consumption

declined in 2009 to a 15‐year low. Hearing transcript, p. 60 (Mull).
  

I‐41

Table I-10 

Hot-rolled steel: U.S. shipments of domestic product, U.S. shipments of imports, and apparent U.S. 

consumption, 2007-12, January-June 2012, and January-June 2013

 Calendar Year January-June

Item 2007 2008 2009 2010 2011 2012 2012 2013

Quantity (short tons)

U.S. producers' open 

market shipments 

23,565,143 21,099,573 13,197,735 19,786,108 21,843,481 23,050,999 12,062,344 11,782,752

U.S. producers' captive 

U.S. market shipments 

35,635,784 32,505,415 22,494,257 30,251,668 31,161,081 33,109,289 16,924,363 16,426,866

 Subtotal, U.S. 

producers' shipments 

59,200,927 53,604,988 35,691,992 50,037,776 53,004,562 56,160,288 28,986,707 28,209,618

U.S. imports from-- 

 China 1,093 247 159 1,631 541 2,419 1,763 1,481

 India 17,665 185 0 0 0 0 0 0

 Indonesia 0 0 0 0 0 0 0 0

 Taiwan 241 655 95 45 2,483 560 492 26

 Thailand 2,171 5,632 0 0 0 0 0 0

 Ukraine 0 19 0 0 0 806 0 0

 Subtotal, subject 21,169 6,739 254 1,676 3,024 3,784 2,256 1,507

 All other sources 3,327,507 3,618,209 2,273,854 3,035,620 3,535,471 3,806,535 1,947,026 1,688,597

 Total imports 3,348,676 3,624,948 2,274,108 3,037,296 3,538,495 3,810,320 1,949,281 1,690,104

Open market U.S. 

consumption 

26,913,819 24,724,521 15,471,843 22,823,404 25,381,976 26,861,319 14,011,625 13,472,856

Apparent U.S. 

consumption 

62,549,603 57,229,936 37,966,100 53,075,072 56,543,057 59,970,608 30,935,988 29,899,722

 Value ($1,000)

U.S. producers' open 

market shipments 

12,961,021 16,555,589 6,949,810 11,905,660 15,651,177 15,396,698 8,441,332 7,326,018

U.S. producers' captive 

U.S. market shipments 

19,534,051 24,656,305 11,874,943 18,294,696 21,810,016 21,883,052 11,777,898 10,163,176

 Subtotal, U.S. 

producers' shipments 

32,495,072 41,211,894 18,824,753 30,200,356 37,461,193 37,279,750 20,219,230 17,489,194

U.S. imports from-- 

 China 732 222 172 1,469 649 3,027 2,040 1,683

 India 10,464 291 0 0 0 0 0 0

 Indonesia 0 0 0 0 0 0 0 0

 Taiwan 142 484 101 39 1,976 414 358 19

 Thailand 1,075 4,685 0 0 0 0 0 0

 Ukraine 0 44 0 0 0 624 0 0

 Subtotal, subject 12,413 5,726 274 1,508 2,625 4,064 2,398 1,702

 All other sources 1,819,256 2,880,457 1,215,906 1,867,911 2,578,646 2,598,160 1,372,570 1,145,933

 Total imports 1,831,669 2,886,183 1,216,179 1,869,419 2,581,271 2,602,224 1,374,968 1,147,635

Open market U.S. 

consumption 

14,792,690 19,441,772 8,165,989 13,775,079 18,232,448 17,998,922 9,816,300 8,473,653

Apparent U.S. 

consumption 

34,326,741 44,098,077 20,040,932 32,069,775 40,042,464 39,881,974 21,594,198 18,636,829

Note.--Staff adjusted imports from India to reflect non-hot-rolled steel imports. *** which ***. 

Source: Compiled from data submitted in response to Commission questionnaires and adjusted Commerce statistics.
  

I‐42

Figure I-2 

Hot-rolled steel: Apparent U.S. consumption, by sources, 2007-12, January-June 2012, and 

January-June 2013 

Source: Compiled from data submitted in response to Commission questionnaires and adjusted Commerce statistics. 

U.S. MARKET SHARES

Total U.S. market share data are presented in table I‐11, while table I‐12 presents open‐

market consumption and market shares. The share of apparent U.S. consumption held by U.S.

producers fluctuated during 2007‐12, ending slightly lower overall. Domestic producers

accounted for between 85.3 and 87.6 percent of open‐market consumption, by quantity and

between 93.7 and 94.6 percent of total consumption, by quantity during 2007‐12, January‐June

2012, and January‐June 2013. U.S. imports of hot‐rolled steel from subject countries accounted

for less than 0.1 percent of open‐market consumption and 0.1 percent of total apparent U.S.

consumption during 2007‐12, January‐June 2012, and January‐June 2013.

0

10,000,000

20,000,000

30,000,000

40,000,000

50,000,000

60,000,000

70,000,000

2007 2008 2009 2010 2011 2012 Jan‐June

2012

Jan‐June

2013

Short tons

U.S. shipments (Open) U.S. shipments (Captive) Subject All others
  

I‐43

Table I-11 

Hot-rolled steel: Total U.S. consumption and market shares, 2007-12, January-June 2012, and JanuaryJune 2013

Calendar Year January-June

Item 2007 2008 2009 2010 2011 2012 2012 2013

 Quantity (short tons)

Apparent U.S. consumption 62,549,603 57,229,936 37,966,100 53,075,072 56,543,057 59,970,608 30,935,988 29,899,722

 Value ($1,000)

Apparent U.S. consumption 34,326,741 44,098,077 20,040,932 32,069,775 40,042,464 39,881,974 21,594,198 18,636,829

 Share of quantity (percent)

U.S. producers' shipments 94.6 93.7 94.0 94.3 93.7 93.6 93.7 94.3

U.S. imports from-- 

 China (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

)

 India (

1

) (

1

) 0.0 0.0 0.0 0.0 0.0 0.0

 Indonesia 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

 Taiwan (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

)

 Thailand (

1

) (

1

) 0.0 0.0 0.0 0.0 0.0 0.0

 Ukraine 0.0 (

1

) 0.0 0.0 0.0 (

1

) 0.0 0.0

 Subtotal, subject (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

)

 All other sources 5.3 6.3 6.0 5.7 6.3 6.3 6.3 5.6

 Total imports 4.3 5.3 5.0 4.7 5.3 5.3 5.3 4.6

 Share of value (percent)

U.S. producers' shipments 94.7 93.5 93.9 94.2 93.6 93.5 93.6 93.8

U.S. imports from-- 

 China (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

)

 India (

1

) (

1

) 0.0 0.0 0.0 0.0 0.0 0.0

 Indonesia 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

 Taiwan (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

)

 Thailand (

1

) (

1

) 0.0 0.0 0.0 0.0 0.0 0.0

 Ukraine 0.0 (

1

) 0.0 0.0 0.0 (

1

) 0.0 0.0

 Subtotal, subject (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

) (

1

)

 All other sources 5.3 6.5 6.1 5.8 6.4 6.5 6.4 6.1

 Total imports 4.3 5.5 5.1 4.8 5.4 5.5 5.4 5.1

1

 Less than 0.05 percent. 

Note.--Staff adjusted imports from India to reflect non-hot-rolled steel imports. *** which ***. 

Source: Compiled from data submitted in response to Commission questionnaires and adjusted Commerce statistics. 
  

I‐44

Table I-12 

Hot-rolled steel: Open-market U.S. consumption and market shares, 2007-12, January-June 2012, and 

January-June 2013

 Calendar Year January-June

Item 2007 2008 2009 2010 2011 2012 2012 2013

 Quantity (short tons)

Open market apparent 

U.S. consumption 

26,913,819 24,724,521 15,471,843 22,823,404 25,381,976 26,861,319 14,011,625 13,472,856

 Value ($1,000)

Open market apparent 

U.S. consumption 

14,792,690 19,441,772 8,165,989 13,775,079 18,232,448 17,998,922 9,816,300 8,473,653

 Share of quantity (percent)

U.S. producers' 

shipments 

87.6 85.3 85.3 86.7 86.1 85.8 86.1 87.5

U.S. imports from-- 

 China (1) (1) (1) (1) (1) (1) (1) (1)

 India 0.1 (1) 0.0 0.0 0.0 0.0 0.0 0.0

 Indonesia 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

 Taiwan (1) (1) (1) (1) (1) (1) (1) (1)

 Thailand (1) (1) 0.0 0.0 0.0 0.0 0.0 0.0

 Ukraine 0.0 (1) 0.0 0.0 0.0 (1) 0.0 0.0

 Subtotal, subject 0.1 (1) (1) (1) (1) (1) (1) (1)

 All other sources 12.4 14.6 14.7 13.3 13.9 14.2 13.9 12.5

 Total imports 12.4 14.7 14.7 13.3 13.9 14.2 13.9 12.5

 Share of value (percent)

U.S. producers' 

shipments 

87.6 85.2 85.1 86.4 85.8 85.5 86.0 86.5

U.S. imports from-- 

 China (1) (1) (1) (1) (1) (1) (1) (1)

 India 0.1 (1) 0.0 0.0 0.0 0.0 0.0 0.0

 Indonesia 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

 Taiwan (1) (1) (1) (1) (1) (1) (1) (1)

 Thailand (1) (1) 0.0 0.0 0.0 0.0 0.0 0.0

 Ukraine 0.0 (1) 0.0 0.0 0.0 (1) 0.0 0.0

 Subtotal, subject 0.1 (1) (1) (1) (1) (1) (1) (1)

 All other sources 12.3 14.8 14.9 13.6 14.1 14.4 14.0 13.5

 Total imports 12.4 14.8 14.9 13.6 14.2 14.5 14.0 13.5

1

 Less than 0.05 percent. 

Note.--Staff adjusted imports from India to reflect non-hot-rolled steel imports. *** which ***. 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐1

PART II: CONDITIONS OF COMPETITION IN THE U.S. MARKET

U.S. MARKET CHARACTERISTICS

Hot‐rolled steel is an input used in a variety of end‐use goods including downstream

steel products (e.g., cold‐rolled and corrosion‐resistant steel), pipes and tubes, construction

materials, autos, and appliances. Since 2007, the hot‐rolled steel market has been affected by

the continuing growth of China as a producer and consumer of hot‐rolled steel, the economic

downturn and gradual recovery in the United States and abroad, and fluctuating availability and

pricing of raw material inputs.

Channels of distribution

The majority (between 55.0 and 58.5 percent during 2007‐12) of domestically produced

hot‐rolled steel is used internally by U.S. producers for the production of cold‐rolled steel,

coated steel, and welded pipe. Commercial shipments within the United States accounted for

more than one‐third of U.S. producers’ hot‐rolled steel shipments (35.9 to 40.5 percent during

2007‐12). The remainder was transferred to related firms or exported.

Hot‐rolled steel is shipped to distributors, processors, and service centers; pipe and tube

producers; and other end users/manufacturers, including automobile assemblers and suppliers.

As presented in table II‐1, between 42.5 and 50.4 percent of U.S. shipments were sold to “end

users other than tube product manufacturers,” 37.9 to 45.4 percent of sales are to service

centers/distributors, and the remaining 10.8 to 16.9 percent were sold to tubular product

manufacturers. Sales of subject imports were infrequent; data for China, India, and Thailand

were reported only in one year, for Taiwan and Ukraine only in three reporting periods, and no

data were reported for Indonesia. All sales of hot‐rolled steel from Ukraine and most sales of

hot‐rolled steel from Taiwan and nonsubject countries were sold to distributors.
II‐2

Table II-1 

Hot-rolled steel: U.S. producers’ and U.S. importers’ U.S. shipments by sources and channels of 

distribution, 2007-12, and January-June 2013 

Item 

2007 2008 2009 2010 2011 2012 

Jan.-

June 

2013

Share of U.S. shipments (percent)

U.S. producers’ U.S. shipments of hot-rolled steel to:

Distributors/service centers 45.4 42.3 38.8 39.1 39.3 39.0 37.9 

Tubular products manufacturers 11.4 15.2 10.8 13.7 15.3 15.6 16.9 

Other end users 43.2 42.5 50.4 47.2 45.4 45.4 45.2 

U.S. importers’ U.S. shipments of hot-rolled steel from China to:

Distributors/service centers -- -- -- -- *** -- -- 

Tubular products manufacturers -- -- -- -- *** -- -- 

Other end users -- -- -- -- *** -- -- 

U.S. importers’ U.S. shipments of hot-rolled steel from India to:

Distributors/service centers *** -- -- -- -- -- -- 

Tubular products manufacturers *** -- -- -- -- -- -- 

Other end users *** -- -- -- -- -- -- 

U.S. importers’ U.S. shipments of hot-rolled steel from Taiwan to:

Distributors/service centers -- -- -- -- *** *** *** 

Tubular products manufacturers -- -- -- -- *** *** *** 

Other end users -- -- -- -- *** *** *** 

U.S. importers’ U.S. shipments of hot-rolled steel from Thailand to:

Distributors/service centers *** -- -- -- -- -- -- 

Tubular products manufacturers *** -- -- -- -- -- -- 

Other end users *** -- -- -- -- -- -- 

U.S. importers’ U.S. shipments of hot-rolled steel from Ukraine to:

Distributors/service centers *** -- -- -- *** *** -- 

Tubular products manufacturers *** -- -- -- *** *** -- 

Other end users *** -- -- -- *** *** -- 

U.S. importers’ U.S. shipments of hot-rolled steel from all other countries to:

Distributors/service centers 57.9 51.0 56.7 57.1 62.5 59.4 62.2 

Tubular products manufacturers 21.2 29.5 29.6 23.8 16.9 14.9 13.3 

Other end users 20.9 19.5 13.6 19.0 20.6 25.7 24.5 

Note.--Numbers may not add to 100.0 because of rounding. 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐3

Geographic distribution  

Producers and importers were requested to provide information on the specific

geographic market areas served by their firm. Table II‐2 presents geographic market areas

served by producers and importers. Seven U.S. producers supply hot‐rolled steel nationally. In

total, all 13 responding U.S. producers reported sales of hot‐rolled steel in the Midwest, and 10

reported sales in all other regions in the contiguous United States, with the exception of the

Pacific Coast, in which 9 producers reported selling hot‐rolled steel. Although few importers

reported shipments of hot‐rolled steel from the subject countries to any regions; the majority

of such shipments are concentrated in the Central Southwest and the Pacific Coast.  

Table II-2 

Hot-rolled steel: Geographic market areas in the United States served by U.S. producers and 

importers, by number of responding firms 

Region Northeast Midwest Southeast

Central 

Southwest Mountains 

Pacific 

Coast Other1

U.S. producers 10 13 10 10 10 9 1 

China 1 1 1 1 1 1 0 

India 0 0 0 1 0 0 0 

Indonesia -- -- -- -- -- -- -- 

Taiwan 1 1 1 2 0 3 0 

Thailand 0 0 0 0 0 1 0 

Ukraine 0 0 0 2 0 0 0 

1

 All other U.S. markets, including AK, HI, PR, and VI. 

Source: Compiled from data submitted in response to Commission questionnaires.

Domestic producers of hot‐rolled steel reported selling on average 38.5 percent of their

commercial shipments within 100 miles of their production facility, 56.0 percent between 100

and 1,000 miles from the facility, and 5.5 percent more than 1,000 miles from the facility. Only

one importer of subject product reported shipping distances, with the majority of its product

being shipped within 100 miles of its point of importation or warehouse. Shipments by country

and by distance are presented in table II‐3.  

Table II-3 

Hot-rolled steel: Shipments by country and by distance reported by U.S. producers and importers1

Item 0 to 100 miles 101-1,000 miles Over 1,000 miles 

U.S. producers 38.5 56.0 5.5 

Ukraine *** *** *** 

1 No data were reported for imports from China, India, Indonesia, Taiwan, and Thailand. 

Source: Compiled from data submitted in response to Commission questionnaires.
II‐4

SUPPLY AND DEMAND CONSIDERATIONS

Supply

Domestic production

Based on available information, staff believes that U.S. hot‐rolled steel producers have

the capability to respond to changes in demand with moderate changes in shipments of U.S.‐

produced hot‐rolled steel to the U.S. market in the short term. Factors contributing to this

degree of responsiveness of supply are a moderate level of excess capacity, little ability to use

inventories, few alternative markets, and the ability to switch to and from producing other

products on the same equipment and machinery.  

Industry capacity

During 2007‐09, U.S. producers’ hot‐rolled steel capacity decreased by 12.4 percent

(from 80.4 million short tons to 70.4 million short tons), then increased by 6.3 percent by 2012

(74.8 million short tons). Part of this increase is due to ThyssenKrupp Steel USA’s carbon steel

plant which opened in 2010 in Alabama. Total hot‐rolled steel production capacity was 37.5

million short tons in the first half of 2013, compared with 37.0 million short tons in the first half

of 2012. U.S. producers’ reported capacity utilization for hot‐rolled steel decreased during

2007‐09 as well, from 75.5 percent to 52.9 percent, reflecting, in part, depressed demand due

to the 2008‐09 economic downturn, but recovered to 76.2 percent by 2012. Capacity utilization

was 76.1 percent in the first half of 2013, compared with 79.4 percent in the first half of 2012.

This level of capacity utilization indicates that U.S. producers of hot‐rolled steel have some

available capacity with which they could increase production of hot‐rolled steel in the short

term in the event of a price change.

Producer inventory levels  

U.S. producers reported making more than 99 percent of their sales on a made‐to‐order

basis and that hot‐rolled steel is held in inventory by service centers, so inventories held by

producers are relatively small. U.S. producers’ end‐of‐period inventories, as a share of U.S.

producers’ total shipments, ranged between 1.7 (2008) and 3.7 percent (2009) during 2007‐12,

and generally have been slightly less than 3 percent.1 These relatively small levels of inventories

suggest that U.S. producers may have some limited ability to use inventories to respond to

price changes.  

Alternative markets  

All 11 responding domestic producers reported Canada and/or Mexico among their top

export destinations. Additionally, one producer noted Chile as a top destination, whereas a

 

1 As a share of commercial shipments, ending inventories ranged between 4.5 (2008) and 10.4 (2009)

percent during 2007‐12, and were between 7 and 8 percent in 2007 and 2010‐12.
II‐5

second producer reported South America in general as one of its main export destinations.

Domestic producers’ export shares (exports as a percentage of total shipments) were

approximately 2.4 percent in 2007‐08, increasing to around 3.0 percent in 2009‐10, but then

decreased to 1.4 percent by 2012. The export share was slightly higher in the first half of 2013

compared with the first half of 2012 (1.5 percent vs. 1.3 percent, respectively). During 2012,

these exports totaled 822,525 short tons, approximately 56 percent of total exports in 2007.

This indicates that domestic hot‐rolled steel producers are somewhat constrained in their

ability to shift shipments between the United States and other markets in response to price

changes.

In their questionnaire responses, most U.S. producers reported that they find it difficult

to shift product to markets outside of the United States. Although most of the 13 responding

hot‐rolled steel producers reported that they exported some hot‐rolled steel, they generally

indicated that it is difficult to shift from shipping domestically to exporting. High transportation

costs, along with exchange rate concerns, competition with countries which are oversupplied,

decreased overseas pricing and the resulting loss in profitability, and trade barriers such as

tariffs and non‐tariff barriers reportedly impede their ability to export.  Domestic importers

(e.g., trading companies) reported similar barriers, though *** also reported that lead times

could play a factor in impeding U.S. exports of hot‐rolled steel.

Production alternatives  

Eight of 13 responding producers indicated that they were unable to switch production

from hot‐rolled steel to other products. Five reported being able to switch production (***).

*** stated that it can switch between hot‐rolled steel and cold‐rolled or corrosion‐resistant

steel, and between *** with minimal time or monetary costs; the product mix is dictated by

demand, pricing, profit margins and capacity utilization. *** also reported being able to switch

to downstream products. *** could produce coil and plate in the place of hot‐rolled steel, but

*** noted that even though the switch would require little effort, it would not occur unless all

of its facilities were running at full capacity and selective production was required.  

Supply changes

A majority of responding producers (8 of 13) and importers (18 of 24) noted that U.S.

supply conditions had not changed since 2007.However, two of the three responding foreign

producers did report changes. Changes reported by more than one questionnaire respondent

included: the opening of new mills by Severstal and ThyssenKrupp; the closing of the Sparrows

Point, Maryland and Warren, Ohio facilities; increases in the cost of ocean freight; and changes

in exchange rate, which have made sales to the U.S. market less competitive with other

markets. Nineteen of 38 responding purchasers reported that supply conditions in the hot‐

rolled steel market had changed since 2007; most of these reported that U.S. production has

increased.2

 

2 In the Commission’s most recent reviews concerning hot‐rolled steel, several purchasers noted a

tight supply of domestic steel during the recession. One purchaser indicated that at the bottom of the

economic cycle, 19 of 28 U.S. blast furnaces were idled, and, though they started up again in 2009, steel
II‐6

Supply constraints  

Four of 12 responding producers indicated that they had refused, declined, or been

unable to supply hot‐rolled steel since January 2007.3  Additionally, *** reported that they did

not provide all of the hot‐rolled steel a purchaser may have requested ahead of price increases

or to build up the purchasers’ inventories.4

  *** used controlled order entry in 2008 due to the

spike in demand and *** operated beyond its production capacity during certain months of

2008 and still could not supply all its customers’ requests. *** had a production shortage ***.

*** did so because ***. Importer *** stated that “Domestic suppliers have had difficulty

meeting demand periodically. There have been periods of significant missed deliveries

(September 2009 ‐ August 2010 as well as March ‐ August 2012). Overall delivery performance

has declined significantly since 2006. Additionally, mills have refused to supply certain widths of

high strength steel without charging a premium for slit loss.”  Importer *** additionally noted

that purchasers were offered restricted quantities in mid‐2007.

Subject imports  

Since 2007, U.S. imports have accounted for less than 7 percent of apparent U.S.

consumption (and less than 15 percent of open market consumption) of hot‐rolled steel.

According to Customs data, less than one percent of total hot‐rolled steel imports were

accounted for by shipments from subject countries.5  The Commission received foreign

producer questionnaire responses from six producers.6 Industry publications can provide some

insight, however, into the supply from the other subject country hot‐rolled steel industries.  

China

The hot‐rolled steel industry in China is by far the largest among the six subject

countries. Capacity in China to produce hot‐rolled steel increased by *** short tons between

2009 and 2012, from *** short tons to *** short tons (table II‐4). Production of hot‐rolled steel

 

for the automotive sector was in tight supply while the “Cash for Clunkers” program was in effect. Other

purchasers noted short supply earlier in the period, with one noting that it faced controlled order

placement several times in 2005‐08. One purchaser included a document which noted that the domestic

industry was short on supply, with record‐low inventories and limited import supply (which would

contribute to increased prices in 2008). Hot‐Rolled Flat‐rolled Carbon‐Quality Steel Products from Brazil,

Japan, and Russia, Investigation Nos. 701‐TA‐384 and 731‐TA‐806‐806 (Second Review), USITC

Publication 4237, June 2011.

3 This includes placing customers on allocation or “controlled order entry,” declining to accept

customers or renew existing customers, delivering less than the quantity promised, or failing to meet

timely shipment commitments. 4 For example, *** indicated that a purchaser may request an entire quarter’s worth of that

purchaser’s hot‐rolled steel requirements, which it could not supply. *** indicated it has not had to

allocate shipment for reasons such as this since 2008. 5 In fact, in 2009, during the economic recession, imports from subject countries totaled 254 short

tons.  

6 Qualitative answers for foreign producer ***.  As such, these responses will be counted as one

response ***.
II‐7

in China increased by *** in that time. Hot‐rolled steel consumption in China also increased

during that period, by *** short tons; its exports of hot‐rolled steel increased by 5.8 million

short tons. *** estimates that by 2015 China’s production of hot‐rolled steel will be *** short

tons, while its consumption will be *** short tons.7

   

India

India has the second‐largest hot‐rolled steel industry among the subject countries. Its

production capacity increased from *** short tons in 2009 to *** short tons in 2012. Its

production also increased during that time, from *** short tons to *** short tons. India’s home

market apparent consumption of hot‐rolled steel increased from *** short tons to *** short

tons in 2009‐12. *** estimates that in 2015 India’s production of hot‐rolled steel (*** short

tons) will continue to be less than its consumption (*** short tons).8

   

The Commission received data from two producers of hot‐rolled steel in India.  These

producers indicated that their capacity increased from *** short tons in 2007 to *** short tons

in 2012, while their production increased from *** short tons to *** short tons over that

period.  *** of their shipments of hot‐rolled steel were to ***.   

Indonesia

Indonesia has the smallest hot‐rolled steel industry among the subject countries. Its

production capacity increased from *** short tons in 2009 to *** short tons in 2012. Its

production decreased by *** percent during that time, however. *** estimates that by 2015

Indonesia’s capacity will increase to *** short tons, it sproduction of hot‐rolled steel will be ***

short tons, and its consumption will be *** short tons.9  

Taiwan

The hot‐rolled steel industry in Taiwan increased its production capacity from *** short

tons in 2009 to *** short tons in 2012. Its production also increased during that time, from ***

short tons to *** short tons. Apparent gross consumption of hot‐rolled sheet and coil plate in

Taiwan increased from *** short tons in 2009 to *** short tons in 2012. *** estimates that by

2015, Taiwan’s hot‐rolled steel capacity will ***, production of hot‐rolled steel will be *** short

tons, while its consumption will be *** short tons.10

Based upon questionnaire responses of three firms which accounted for all hot‐rolled

steel production in Taiwan, capacity increased from *** short tons in 2007 to *** short tons in

2012.  Over the same period, the industry in Taiwan’s production increased irregularly, first

decreasing from *** short tons in 2007 to *** short tons in 2009, then increasing to *** short

tons in 2012.  Since 2007, however, the industry in Taiwan has shifted from ***.

 

 

7 Based upon data from ***.     8 Based upon data from ***.

9 Based upon data from ***.     10 Based upon data from ***.    
II‐8

Table II-4 

Hot-rolled steel: Subject country capacity, production, capacity utilization, consumption in its 

home market, world exports, U.S. imports, and top export markets, 2009, 2012, and forecasted 

2015 

Year 

Production 

capacity 

(thousand 

short tons) 

Production 

(thousand 

short tons) 

Capacity 

utilization 

(percent)

Home market 

consumption

(thousand 

short tons) 

World 

exports1

(thousand

short tons) 

U.S. 

imports2 

(thousand

short tons) 

Top export 

markets 

China: 

2009 *** *** *** *** 4,874 0.2 China’s main export 

markets included 

Korea, India, 

Vietnam, and 

Thailand. 

2012 *** *** *** *** 10,684 2 

2015 

(forecast) *** *** *** *** -- -- 

India: 

2009 *** *** *** *** 508 0 India’s main export 

markets included 

Belgium, the United 

Arab Emirates, and 

Spain. 

2012 *** *** *** *** 1,758 0 

2015 

(forecast) *** *** *** *** -- -- 

Indonesia:

2009 *** *** *** *** 111 0 

Indonesia’s main 

export markets 

included Malaysia 

and Vietnam, along 

with Singapore, the 

Netherlands and 

Australia in 2007-09.

2012 *** *** *** *** 19 0 

2015 

(forecast) *** *** *** *** -- -- 

Taiwan: 

2009 *** *** *** *** 2,933 0.1 Taiwan’s main 

export markets 

included Japan, 

Vietnam, Korea, and 

Malaysia. 

2012 *** *** *** *** 3,393 0.6 

2015 

(forecast) *** *** *** *** -- -- 

Thailand: 

2009 *** *** *** *** 333 0 Thailand’s main 

export markets 

included Saudi 

Arabia, India, 

Vietnam, and 

Indonesia. 

2012 *** *** *** *** 27 0 

2015 

(forecast) *** *** *** *** -- -- 

Table continued on the next page. 
II‐9

Table II-4--Continued

Hot-rolled steel: Subject country capacity, production, capacity utilization, consumption in its 

home market, world exports, U.S. imports, and top export markets, 2009, 2012, and forecasted 

2015 

Year 

Production 

capacity 

(thousand 

short tons) 

Production 

(thousand 

short tons) 

Capacity 

utilization 

(percent)

Home market 

consumption

(thousand 

short tons) 

World 

exports 

(thousand

short tons)

U.S. 

imports1 

(thousand

short tons) 

Top export 

markets 

Ukraine: 

2009 *** *** *** *** 3,031 0 Ukraine’s main 

export markets 

included Turkey, 

Russia, and 

Poland. 

2012 *** *** *** *** 3,022 0.8 

2015 

(forecast) *** *** *** *** -- -- 1

 Other export market export data are from Global Trade Atlas. China’s world export figures include data for boron-containing hotrolled steel. 

2

 U.S. imports are from official Commerce statistics. 

Source: ***, Department of Commerce, and Global Trade Atlas. 

Thailand

The production capacity of the hot‐rolled steel industry in Thailand increased from ***

short tons in 2009 to *** short tons in 2010, and has maintained that capacity level. Its

production also increased during that time, from *** short tons to *** short tons. Apparent

gross consumption of hot‐rolled sheet and coil plate in Thailand increased from *** short tons

in 2009 to *** short tons in 2012 and is forecasted to increase to *** short tons in 2015. By

2015, *** estimates that Thailand’s production of hot‐rolled steel will be *** short tons, while

its capacity is projected to remain at the *** short ton level but its consumption increases to

*** short tons.

Two of the three hot‐rolled steel producers in Thailand have shut down since 2007, and

their production status is uncertain, although GJ Steel is reportedly currently operating at less

than 50 percent capacity and that it might achieve 50 percent by end of 2013.11  The third

producer, ***, completed a Commission questionnaire.  Based on its responses, its reported

capacity decreased irregularly from *** short tons in 2007 to *** short tons in 2012 after

having reached *** short tons in 2011.  Its production increased from *** short tons in 2007 to

*** short tons in 2012.  The *** of its shipments are destined for ***.

Ukraine

The hot‐rolled steel industry in Ukraine maintained a constant production capacity of

*** short tons in 2009‐12 and is expected to ***. Its production increased from *** short tons

in 2009 to *** short tons in 2011 before decreasing to *** short tons in 2012. Production is

expected to increase to *** short tons through 2015, according to ***. Apparent gross

consumption of hot‐rolled sheet and coil plate in Ukraine increased from *** short tons in 2009

 

11 Hearing transcript, p. 231 (LaFrankie) and respondent interested party SSI’s posthearing brief, exh.

1, p. 19.
II‐10

before increasing to *** short tons in 2012. *** estimates that by 2015 Ukraine’s consumption

of hot‐rolled steel will decrease *** short tons.12

Nonsubject imports

Nonsubject imports accounted for more than 99 percent of imports of hot‐rolled steel in

2007‐12, and 6.0 percent of apparent U.S. consumption (including captive consumption). Over

that period, nonsubject imports’ share of apparent U.S. consumption fluctuated between 5.3

and 6.3 percent, and was 5.6 percent in January‐June 2013. The leading nonsubject sources for

U.S. imports of hot‐rolled steel were Canada, Korea, Australia, Mexico, the Netherlands, and,

for 2012, Russia.  

Demand

U.S. demand

Based on available information, hot‐rolled steel purchasers are likely to respond to

changes in the price of hot‐rolled steel with relatively small changes in their purchases of hot‐

rolled steel. The main contributing factors to the low responsiveness of demand are the low

cost share and the lack of commercially viable substitute products.  

Demand determinants and end uses

U.S. demand for hot‐rolled steel depends on the level of demand for downstream

products using hot‐rolled steel products. Some hot‐rolled steel is sold to service centers which

may further process it to customer specifications, while other hot‐rolled steel is used in a

diverse array of industries such as automobiles, auto parts, appliances, and construction either

directly or via its downstream derivatives. Various importers, producers, and foreign producers

reported the use of hot‐rolled steel in construction and energy tubular products, construction

equipment, automotive parts, and wind towers. In prior Commission investigations, other end

use products noted by industry participants have included agricultural equipment, beam

assemblies, brake components, boilers, bumpers, conduit, cranes, dishwashers, electrical

housings, guard rails, hollow structural shapes, hydraulic tanks, industrial machinery, lawn

mower decks, pilings, platforms, refrigerators, shelving racks, shipbuilding machinery, steel

grating, tin mill products, torque converter covers, and washing machines.13  

The majority of firms reported no changes in end uses, however 5 of 13 responding

producers, 1 of 25 responding importers,14 7 of 33 responding purchasers, and 1 of 7

responding foreign producers reported that there have been changes in end uses since 2007.

Producers reported demand changes including: reduced demand in coated material and new

construction; greater demand for heavy product for oil field applications; and a market shift

 

12 Based upon data from ***.    13 Hot‐Rolled Flat‐Rolled Carbon‐Quality Steel Products from Brazil, Japan, and Russia, Investigation

Nos. 701‐TA‐384 and 731‐TA‐806‐806 (Second Review), USITC Publication 4237, June 2011. 14 The importer reporting demand changes reported that its mill’s capacity has increased.
II‐11

toward more customized, higher quality products. One importer noted that there has been a

shift toward lighter hot‐rolled steel.  Purchasers reported demand changes resulting from the

economic downturn, the redesign of products to use plastics, increased usage in solar panels

and OCTG, and increased tonnage from vehicle sales (which has been offset by fewer

component parts using hot‐rolled steel). Foreign producers reporting demand changes noted

selling higher‐value products and focusing on exports to the Middle East, EU, and Africa.  

In general, demand for hot‐rolled steel is driven by the level of activity in the U.S.

economy. Following a steep decline in 2008, the United States was recovering from the recent

recession. U.S. GDP increased in each quarter beginning in July‐September 2009, by rates

between 0.1 and 4.1 percent with the exception of the first quarter of 2011 (figure II‐1). Blue

Chip Economic Indicators forecasts that real GDP will grow by *** percent for full‐year 2013

(including *** percent in the third quarter and *** percent in the fourth quarter) and ***

percent in 2014.15  

As in the previous reviews regarding hot‐rolled steel in 2010‐11 demand for hot‐rolled

steel is influenced particularly by the automotive, construction, and energy sectors.16 Producers

reported that approximately twice as much of the hot‐rolled steel they produce is sold into the

automotive industry compared with the construction industry, though the majority of their

sales are made to other sectors (primarily to service centers but also to various other sectors,  

such as pipe, energy, containters, appliances, and agriculture). Importers reported a higher

proportion shipped to the construction industry than the automotive industry, but the majority

of these shipments were made to distributors, as well as to other sectors.  

Data from the American Iron and Steel Institute (“AISI”) indicate a ratio similar to that

reported by domestic producers for shipments destined for the automotive and construction

sectors. 17  For shipments made in 2010 to industries which AISI members could track, 40.3

percent were shipped to the automotive sector, 21.7 to the construction sector, 17.4 percent to

companies for conversion and processing (e.g., into pipes and tubes), and the remainder to

container (11.4 percent), appliance (5.8 percent), and other sectors.18   

 

15 Blue Chip Economic Indicators, October 7, 2013.

16 See, e.g., hearing transcript, pp. 51 (Longhi) and 147‐148 (Scherrbaum).  Hot‐Rolled Flat‐Rolled

Carbon‐Quality Steel Products from Brazil, Japan, and Russia, Investigation Nos. 701‐TA‐384 and 731‐TA‐

806‐806 (Second Review), USITC Publication 4237, June 2011, pp. II‐12‐13. 17 Domestic producers were also asked about the end‐use industries which the hot‐rolled steel they

produce are ultimately destined for. Producer responses regarding the end‐use application of the hot‐

rolled steel they manufacture varied greatly.  Ten of 12 responding producers had commercial

shipments destined for the automotive sector, with shares ranging between *** and *** percent; 11

producers had shipments destined for the construction sector, with shares ranging between *** and

*** percent.  The automotive sector was the largest end‐use sector for the commercial shipments of

***.  The construction sector was the largest end‐use sector for the commercial shipments of ***.  The

pipe and tube/energy sector was the largest end‐use sector for the commercial shipments of ***.  Other

specific end‐use applications reported as separate shipment categories for producers included

agricultural uses, appliances, equipment manufacturing, machinery, racking, storage tanks/cylinders,

truck trailers, and wind towers.

18 These shares are aggregations which include not only the direct uses of hot‐rolled sheet and plates

in coils, but also the downstream uses including hot‐rolled and cold‐rolled strip, cold‐rolled sheets, black
II‐12

Figure II-1

GDP: Percent changes in real gross domestic product, seasonally adjusted on an annual basis, by 

quarters, January 2007-September 2013 

Source: Bureau of Economic Analysis, U.S. Department of Commerce. 

Auto and light truck sales declined in 2007 and 2008 (figure II‐2). Sales have been

generally increasing since early 2009, and they experienced a surge in July and August 2009 due

to the “Cash for Clunkers” incentive program.

Figure II-2 

U.S. automotive sales: Automobile and light truck retail sales, monthly, on a seasonally adjusted, 

annualized basis, January 2007-September 2013 

Source: Bureau of Economic Analysis, U.S. Department of Commerce.

 

plate, hot‐dipped galvanized sheets, electrogalvanized sheets, sheets with other coatings, tin plate, tin‐

free steel, and tin coated sheets.
II‐13

Residential construction spending decreased between 2007 and the middle of 2009,

remained near that level until the beginning of 2012, and has increased gradually from that

time (figure II‐3). Non‐residential construction spending increased until the start of 2009, then

decreased until the start of 2011, and increased through the end of 2012. It has been increasing

each month after a small decline in January 2013. Neither residential nor non‐residential

construction spending has fully recovered; spending levels in June 2013 were 39.2 and 8.1

percent below their respective January 2007 levels.  

Figure II-3 

U.S. construction spending: Residential and non-residential spending, monthly, on a seasonally 

adjusted, annualized basis, January 2007-August 2013 

Source: U.S. Census Bureau.

Since hot‐rolled steel is used to produce a variety of welded tubular products, demand

for hot‐rolled steel is driven partially by the demand for welded pipe in the construction and

energy sectors. Shipments of welded pipe19 decreased from *** short tons in 2007 to *** short

tons in 2008 and *** short tons in 2009, before increasing to *** short tons in 2010 and ***

short tons in 2011. In 2012, however, these shipments decreased by *** percent to *** short

tons.   

The Baker‐Hughes rig count is another measure of pipe demand in the energy sector.20

The number of rigs increased from 1,700 at the start of 2007 to over 2,000 in late 2008,

decreased to under 1,000 in the first half of 2009, rose to over 2,000 at the end of 2011, and

then returned to approximately 1,750 rigs throughout 2013.21  

 

19 Continuous and ERW pipe, as reported by Metal Bulletin Research.

20 A greater number of rigs drilling for natural gas and/or oil will increase demand for OCTG; greater

demand for welded casing and tubing will cause a related increase in the demand for hot‐rolled steel. 21 Baker‐Hughes North America Rotary Rig Count, retrieved November 19, 2013.  
II‐14

Seasonality and business cycles

Industry participants generally agree that the hot‐rolled steel industry experiences

recurrent expansions and contractions. U.S. industry representatives have referred to the steel

industry as being cyclical in nature. As noted above, demand for hot‐rolled steel tends to follow

the broad demand trends in the U.S. economy.  

U.S. producers, importers, and purchasers were asked if the hot‐rolled steel market was

subject to business cycles or conditions of competition distinctive to the hot‐rolled steel

industry. Regarding business cycles, 8 of 14 responding producers and 16 of 24 responding

importers reported “no.” When asked what these business cycle determinants were, industry

participants who reported that there were distinctive cycles noted those in the automotive,

construction, and energy industries, as well as an “inventory cycle,” as noted by one

participant. The majority of producers (8 of 11) and importers (16 of 20) reported that hot‐

rolled steel was not subject to distinctive conditions of competition.  Of the 34 responding

purchasers, 14 reported “yes” to business cycles, while 8 of 28 reported “yes” to distinctive

conditions of competition. Firms identified distinctive conditions of competition including:

buildup of excess capacity, particularly in China; increased competition from U.S. producers and

importers; changes in input costs as well as demand affect price; and price sensitivity to

demand.  

Producers, importers, and purchasers were also asked if business cycles or conditions of

competition distinctive to the hot‐rolled steel industry have changed since 2007. Three of 9

producers, 8 of 17 importers, and 11 of 21 purchasers identified changes in conditions of

competition or business cycles since 2007. Changes reported included: increased volatility of  

pricing and demand; increased volatility in the price of inputs; decreased in U.S. capacity due to

RG Steel’s plant closures; and reduced demand due to the economic downturn.  

Apparent consumption

Available data indicate that apparent U.S. consumption of hot‐rolled steel decreased by

39.3 percent between 2007 and 2009 (from 62.5 million short tons to 38.0 million short tons),

then increased through 2012 (to 60.0 million short tons ‐ a 58.0 percent increase). Overall,

apparent consumption was 4.0 percent lower in 2012 compared with 2007.  

Demand perceptions

When asked how demand for hot‐rolled steel has changed within the United States

since January 2007, a majority of firms reported fluctuating demand (table II‐5). Most

responding U.S. producers (8 of 14)22 reported that demand for hot‐rolled steel had fluctuated

since 2007, noting demand was relatively high in 2007 but declined with the economic

 

22 One producer reported both that demand had fluctuated and demand had decreased.  
II‐15

downturn which started in 2008. Since 2010 there has been some recovery, although demand

remains low in a number of sectors.23 A majority of responding importers (14 of 26) and  

purchasers (25 of 37) also reported demand fluctuations as a result of the economic downturn

and the relatively slow recovery.24 Demand perceptions among foreign producers varied: two

reported that U.S. demand has fluctuated, and one each reported demand increasing,

fluctuating, and decreasing U.S. demand for hot‐rolled steel.

Table II-5 

Hot-rolled steel: U.S. producer, importer, and purchaser responses regarding demand since 2007 

and anticipated demand through 2014 for hot-rolled steel in the United States. 

Item 

Number of firms reporting 

Increase No Change Decrease Fluctuate 

Demand since 2007: 

 U.S. producers 3 0 3 8 

 Importers 1 4 7 14 

 Foreign producers 2 1 1 3 

 Purchasers 0 4 8 25 

Anticipated demand through 2014: 

 U.S. producers 6 3 0 4 

 Importers 8 6 0 12 

 Foreign producers 7 0 0 0 

 Purchasers 12 5 1 17 

Source: Compiled from data submitted in response to Commission questionnaires.

Purchasers were also asked to describe how demand for their end‐use products had

changed since 2007. Most (17 of 27) reported that demand for the end‐use products had

fluctuated, five noted an increase, two noted a decrease, and three stated that it had not

changed. A large majority of responding purchasers (23 of 27) noted that these changes had  

affected their demand for hot‐rolled steel. The most common reason for changes in demand

purchasers reported was the overall economy. Purchaser *** also noted that demand for

lighter, more fuel‐efficient cars which use less hot‐rolled steel than full‐size trucks will fluctuate

inversely with the price of gas; however the recession also caused purchasers to shift to more

fuel efficient vehicles, and it expects that this shift in vehicle types is permanent for many

consumers.

When asked about anticipated changes in demand for hot‐rolled steel in the United

States, 5 of 11 responding producers,25 8 of 26 responding importers, 12 of 35 responding

purchasers, and all 7 responding foreign producers responded that they anticipate increasing

demand; 4 producers, 12 importers, and 17 purchasers anticipate fluctuating demand; and only

 

23 Of the two producers reporting increased demand, one did not explain the reason why it believed

so. The other reported that “demand has recovered but not yet to levels pre‐GFC. Recovery in

automotive, agriculture and general manufacturing drivers. Construction demand slow recovering.”

24 The one importer reporting increased demand reported that “construction demand is stable.”

25 One producer reported both that demand had fluctuated and demand had decreased.  
II‐16

one purchaser anticipates decreasing demand.26 A large majority of responses indicated that

general economic trends would be the reason for these anticipated changes.  

Substitute products

Substitutes for hot‐rolled steel are limited. Six of 11 responding U.S. producers, 5 of 23

responding importers, and 1 of 6 foreign producers listed one or more substitute products for

hot‐rolled steel. Substitutes which they listed include: other types of steel or downstream steel

products (e.g., alloy, cold‐rolled, galvanized/coated steel, merchant bar, steel studs and hot‐

rolled plate), and other types of materials (e.g., aluminum, composites, concrete, non‐ferrous

materials, and plastics). Thirteen of the 35 responding purchasers reported that there were

substitutes for hot‐rolled steel which included downstream products (e.g., seamless pipe),

wood, stainless steel, and PVC in addition to those substitutes reported by the producers,

importers, and foreign producers.

Substitution depends greatly upon the intended end use for the hot‐rolled steel. End

uses for which other steel products could be used included stamping, building components,

pipe/tube, cut‐to‐length plate, automotive parts, electrical paneling, tanks, and household

appliances. Other non‐steel substitutes could be used in auto parts, water transmission, pipes,

poles, signs, and wood‐framed/concrete buildings.

U.S. producers, importers, purchasers, and foreign producers were asked if the price of

substitutes affected the price of hot‐rolled steel. Five of eight responding U.S. producers, all

three responding importers, the only responding foreign producer, and 11 of 12 responding

purchasers reported that the price of substitutes had no effect on the price of hot‐rolled steel.

Some firms delineated in which instances substitutes could influence price of hot‐rolled steel: in

auto parts, stainless steel/aluminum reduces weight but the high cost prohibits its use; plastics

used for hydraulic tanks reduce both weight and cost; cold‐rolled steel will become a substitute

for hot‐rolled steel as the price spread between the two shrinks; and, in general, prices of some

plastics, aluminum and composite fiber materials will make them more attractive relative to

hot‐rolled steel.

None of the U.S. producers, importers, or foreign producers reported that there had

been changes in substitutes for hot‐rolled steel since 2007. Two purchasers reported changes in

substitutes since 2007; one of these purchasers explained that customers have recently

increased their interest in ultra high strength steel.

No producers or foreign producers reported expecting changes in substitutes for hot‐

rolled steel. Two importers and three purchasers reported that they expect changes in

substitutes: two expect EPA mileage requirements will cause lighter weight substitutes to be

developed and one was investigating the use of aluminum in some applications.27  

 

26 The one purchaser (***) expecting reduced demand in the future reported that CAFE standards to

increase fuel economy will cause demand for hot‐rolled steel to fall.   27 The others responded that they expected only minor changes in substitutes.
II‐17

Cost share

The cost share of final end‐use products for which hot‐rolled steel accounts depends

upon the end use in which it is used. Producers, importers, and purchasers were asked to

estimate the percentage of the total cost of the end product accounted for by the cost of the

hot‐rolled steel. Five producers, one importer, and 24 purchasers provided useable estimates of

cost shares, which ranged from 1 percent of costs to over 90 percent of costs.28 Products with

80 percent or more of the cost attributable to hot‐rolled steel included the following (shares in

percent): automotive stamping (91.3); hot band (90); web plates (90); cold‐rolled sheet (86);

tubular and pipe products (85, 81.5, 80); slit coil (84); blanks and sheets (83); galvanized

products (82); body reinforcements (80); poles (80); power train components (80); and steel

grating (80). Other products that purchasers listed in which the cost of hot‐rolled steel was over

half of the total cost include: pole piling (78); line pipe (75); structural tube (75); cold‐rolled

strip (73); base plates (70); vehicle frames/parts (70); stampings (65); tin mill products (63); and

plate (60). Products for which hot‐rolled steel was half or less of production cost included: auto

shell/fuel tank plate (50); OCTG (50); hydraulic tanks (47); cab components (46); mower decks

(45); steel tubing (44); auto frames/stampings/brackets (40); steel frame buildings (34);

magnetrons (10); and dishwashers, refrigerators, and washing machines (1).

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported hot‐rolled steel depends

upon such factors as relative prices, quality (e.g., formability, performance, surface quality,

etc.), and conditions of sale (e.g., price discounts/rebates, lead times between order and

delivery dates, payment terms, product services, etc.). Based on available data, staff believes

that overall there is a moderate to high degree of substitutability between domestically

produced hot‐rolled steel and hot‐rolled steel imported from the subject countries.  

Purchaser characteristics

The Commission issued questionnaires to 65 purchasers. Responses were received from

43 of these firms, 38 of which provided useable data; unsolicited questionnaires29 were also

received.30 Responding purchasers accounted for 10.8 million short tons of hot‐rolled steel

purchased in the United States in 2012. The majority of this steel (86.2 percent) was purchased

from domestic producers while 13.8 percent was purchased from nonsubject import sources.

 

28 Purchaser responses were used in presenting cost share information, as their responses appeared

more consistent and reasonable.

29 In addition, the Commission received a few purchaser questionnaires from firms that were not

issued the questionnaire. These include some responses from domestic producers and importers. In

particular, four purchaser questionnaires were received from firms that are owned by ***. ***.   30 Eleven of the responding purchasers identified themselves as processors/service centers, 8 as

tubular products producers, 5 as distributors, 5 as auto manufacturers, 2 as machinery and equipment

producers, 2 as construction equipment producers, 2 as consumer and household goods producers, and

10 as “other” purchasers.
II‐18

Although one purchaser indicated that it bought some hot‐rolled steel from ***, this accounted

for less than 0.1 percent of total reported purchases.  

Nineteen purchasers buy hot‐rolled steel on a daily basis, six on a weekly basis, six on a

monthly basis, one annually, and six on some other basis (typically “as‐needed”). Only one

purchaser (***) reported it expects to change its purchasing pattern in the near future. It

reported that it preferred longer contracts but as demand increased recently it had to accept

shorter contracts. Now, however, steel producers are willing to make contracts for up to two

years long. Purchasers reported contacting between 1 and 14 suppliers before purchasing hot‐

rolled steel, but on average between 2 and 5 suppliers are contacted.

Knowledge of country sources

Purchasers were asked to indicate the countries of origin for which they have actual hot‐

rolled steel marketing/pricing knowledge. All 38 responding purchasers were familiar with U.S.‐ 

produced hot‐rolled steel, 5 were familiar with product from China, 4 were familiar with

product from India, 1 was familiar with product from Indonesia, 2 were familiar with product

from Taiwan, 1 was familiar with product from Thailand, 1 was familiar with product from

Ukraine, and 11 were familiar with hot‐rolled steel from other countries including Brazil,

Canada, Germany, Italy, Japan, Korea, Mexico, Netherlands, New Zealand, and the UK.  

Purchasers were also asked how frequently they and their customers made purchasing

decisions based on the country of origin or the manufacturer of hot‐rolled steel (table II‐7). The

majority of purchasers reported that they “sometimes” or “never”  make purchase decisions

based on country of origin and an even greater majority of their customers “sometimes” or

“never” make hot‐rolled steel purchasing decisions based on country of origin. Of the seven

purchasers that reported that the country of origin is “always” important, and explained why,

one stated that it does so to comply with “Buy American” policies, another noted a preference

for U.S. hot‐rolled steel, and a third stated that hot‐rolled steel of U.S. origin is better for NAFTA

duties.  A fourth (***), reported that its hot‐rolled steel purchases are sourced completely from

***.  The fifth purchaser, ***, (along with ***, which reported that it “sometimes” bases its

purchasing decisions on country of origin), stated that the geographical proximity to their

manufacturing and assembly sites are very important.  Ford stated that it purchases *** of its

hot‐rolled steel for its North American operations from the United States and Canada, since it

cannot risk delivery delays which could ***.31 The ability to meet just‐in‐time requirements,

offer technical support on short notice, and have shorter supply chain lead times/transit times

were among the reasons for this preference.  

 

31 Purchaser Ford’s prehearing brief, pp. 1‐2.
II‐19

Table II-7 

Hot-rolled steel: Purchaser responses to questions regarding the origin of their purchases 

Purchaser/customer decision Always Usually Sometimes Never 

Purchaser makes purchase decision based 

on country of origin 7 5 14 12 

Purchaser makes purchase decision based 

on the manufacturer 14 9 8 7 

Purchaser’s customer makes purchase 

decision based on country of origin 0 5 19 10 

Purchaser’s customer makes purchase 

decision based on the manufacturer 0 5 13 16 

Source: Compiled from data submitted in response to Commission questionnaires. 

The manufacturer of the hot‐rolled steel is reportedly more important to the purchaser

than country of origin, with a majority of purchasers indicating that their decisions are “always”

or “usually” based on the manufacturer.  Quality, price, product mix, proximity, delivery

performance, potential for claims, packaging, certifications/qualification, availability, and

service were noted as reasons for making decisions based on the producer, though quality‐

related factors were the reasons most often noted by those purchasers.   

A large majority of purchasers reported that their customers “sometimes” or “never”

make a purchasing decision based on the manufacturer or country of origin of the hot‐rolled

steel that they buy.  Twenty‐one purchasers provided reasons why their customers make

decisions based on the country of origin, however.  Eleven of these purchasers noted

specifically that their customers may require domestic product, either due to laws requiring

domestic content, or to meet customer/job specifications or requirements; two others noted

that some customers simply prefer domestic product.

Factors affecting purchasing decisions

Major factors in purchasing

Purchasers were asked to identify the three most important factors considered by their

firm in deciding from which firm to buy hot‐rolled steel (table II‐8). Price was reported to be

one of the top three factors reported by 32 of 36 of the responding purchasers, and quality was

reported to be one of the top three factors reported by 30 firms. Quality was the most

frequently cited most important factor (cited by 14 purchasers) followed by price (12

purchasers), quality and price were the most frequently reported second‐most important factor

(12 purchasers each), and delivery time/lead times/on‐time delivery was the most frequently

reported third‐most important factor (9 purchasers).  
II‐20

Table II-8 

Hot-rolled steel: Ranking of factors used in purchasing decisions as reported by U.S. purchasers, 

by number of reporting firms 

Factor First Second Third Total 

Price 12 12 8 32 

Quality 14 12 4 30 

Availability/production schedule 2 5 7 14 

Delivery time/lead time/on-time delivery 0 4 9 13 

Product line/range 3 1 3 7 

Contract/traditional supplier/customer 

mandated supplier 3 1 1 5 

Other1 2 1 4 7 1

 Other factors include: ability to meet technical requirements and API compliant and capable for the first factors; 

fixed price for the second factor; and agrees to the purchaser’s customers’ terms and conditions, consistency of 

product and delivery, capacity, and delivery performance/availability as the third factors. 

Source: Compiled from data submitted in response to Commission questionnaires. 

Purchasers were asked how often they purchase the hot‐rolled steel that is offered at

the lowest price; of the 37 purchasers which responded, 18 firms indicated “usually,” 10 firms

indicated “sometimes,” 6 firms indicated “always,” 3 firms indicated “rarely,” and 1 firm

indicated “never.”32 Thirty‐one purchasers listed reasons why they purchased higher‐priced

hot‐rolled steel even though lower‐priced hot‐rolled steel was available. Reasons indicated by

purchasers included: adherence to specifications, availability, “Buy American” purchasing

requirements, coil dimensions, “the cost involved in changing manufacturing process caused by

using a different supplier even if the product is the same,” ***, delivery/reliability of supply,

logistics/proximity, lead time, order quantity requirements, other products or technology

offered by the supplier, quality, traditional supplier/contract/customer approval, and

transportation costs.

Purchasing patterns

Purchasers were asked a number of questions about whether their purchasing patterns

for hot‐rolled steel from subject and nonsubject sources had changed since 2007 (table II‐9).

Most purchasers reported that they had not purchased product from subject countries. The

purchasers that reported changes in their purchases of hot‐rolled steel from subject countries

reported that it had decreased. In contrast, most purchasers (21 of 36) reported purchasing

from nonsubject countries, with nine of these reporting constant purchases and eight reporting

fluctuating purchases.  

 

32 One of the 37 firms responding reported that it both “usually” and “sometimes” purchased the

lowest priced product.  The firm that reported that it “never” buys steel offered at the lowest price is

***.
II‐21

Table II-9 

Hot-rolled steel: Changes in purchase patterns from U.S., subject, and nonsubject countries, 

since 2007 

Source of purchases 

Did not 

purchase Decreased Increased Constant Fluctuated

United States 1 2 7 17 11 

China 36 0 0 0 0 

India 34 2 0 0 0 

Indonesia 36 0 0 0 0 

Taiwan 35 1 0 0 0 

Thailand 35 1 0 0 0 

Ukraine 35 1 0 0 0 

All other countries 15 1 3 9 8 

Source: Compiled from data submitted in response to Commission questionnaires. 

Importance of specified purchase factors

Purchasers were asked to rate the importance of 20 factors when making their

purchasing decisions (table II‐10). The factors listed as “very important” by at least half of the

responding firms were product consistency and reliability of supply (35 purchasers each);

availability, price, quality meets industry standards, (34 each); delivery time (32); U.S.

transportation costs (22); and technical support (19). Most purchasers reported that exchange

rate fluctuations (28) and international transportation cost (23) were not important factors, and

almost half (17) reported extension of credit was not important.

Table II-10 

Hot-rolled steel: Importance of purchase factors, as reported by U.S. purchasers, by number of 

responding firms 

Factor Very important Somewhat important Not important 

Availability 34 2 0 

Contract with supplier 17 8 11 

Delivery terms 16 20 0 

Delivery time 32 4 0 

Discounts offered 14 19 3 

Exchange rate fluctuations 1 7 28 

Extension of credit 9 10 17 

International transportation costs 3 10 23 

Minimum qty requirements 13 19 4 

Packaging 8 21 7 

Price 34 2 0 

Product consistency 35 1 0 

Proximity of supplier 15 18 3 

Quality meets industry standards 34 2 0 

Quality exceeds industry standards 13 17 6 

Product range 11 22 3 

Raw material price indexing 6 20 10 

Reliability of supply 35 1 0 

Technical support/service 19 16 1 

U.S. transportation costs 22 14 0 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐22

Factors determining quality

Purchasers were also asked to report whether seven distinct product characteristics of

the hot‐rolled steel they purchase were required.  Also, if a characteristic was required, they

were asked whether they would consider purchasing hot‐rolled steel from the United States

and the subject countries based on these characteristics. As shown in table II‐11, all of

responding purchasers found that hot‐rolled steel from the United States tends to have each of

these seven characteristics. In contrast, for China, India, Indonesia, and Thailand, approximately

half of the purchasers reported that they would not purchase from these countries based on

these factors. The only factors in which more than half the responding purchasers reported that

they would purchase from these countries were on the basis of coil‐to‐coil and batch‐to‐batch

consistency (China and India); surface quality (Thailand); tight gauge control (Thailand); and

formability (Thailand). Purchasers more frequently reported that they would purchase from

Ukraine than those that would not purchase from Ukraine based on surface quality, tight gauge

control, cut edge, tight chemistry tolerances, and formability, but in all these cases only one

more would purchase than would not. Most responding purchasers reported that they would

purchase product from Taiwan, for all 7 factors, and in some cases twice as many reported that

they would purchase for this factor than would decide not to purchase from Taiwan for this

reason.  

  

Table II-11 

Hot-rolled steel: Information on certain quality factors required by U.S. purchasers, by factor and 

by source1

Quality factor is required?

 Yes

If so, would you purchase from: 

U.S. China India Indonesia Taiwan Thailand Ukraine 

Y N Y N Y N Y N Y N Y N Y N

Surface quality 27 28 0 8 9 7 8 6 7 11 4 7 5 6 5 

Tight gauge control 30 30 0 8 9 7 8 7 6 10 5 7 6 7 6 

Steel cleanliness 31 32 0 8 10 7 9 7 7 10 6 7 7 7 7 

Coil-to-coil and batch-to-batch 

consistency 29 29 0 8 6 7 6 5 5 8 5 5 5 5 5 

Cut-edge 21 22 0 7 7 6 6 5 6 9 5 5 6 6 5 

Tight chemistry tolerances 24 25 0 7 8 6 7 5 6 9 5 5 6 6 5 

Formability 29 29 0 8 9 7 8 6 7 11 5 6 7 7 6 

1

 Purchasers were asked whether they require any of the listed product characteristics in the hot-rolled steel that they 

purchase and, if so, whether they would consider purchasing hot-rolled steel from the countries listed (taking into 

account that factor). Data in the table represent the number of purchasers for each factor. 

Source: Compiled from data submitted in response to Commission questionnaires.

Three of the 37 responding purchasers reported that certain grades/types/sizes of hot‐

rolled steel were available from only one source (either domestic or foreign). *** stated that

the availability of the specific grade/type/sized depends upon the specific end use. Purchaser

*** reported that ***. Finally, purchaser *** listed several types of steel that are available only

from one source, but did not indicate the source.  
II‐23

Supplier certification

Thirty of 38 responding purchasers reported they require their suppliers to become

certified or pre‐qualified for all the hot‐rolled steel that they purchase.33 Factors considered in

certification or prequalification include: certification (ISO, ASTM, and or TS certification, conflict

minerals certification); customer supplier specification; delivery/reliability of supply/ logistics;

factors related to the producing firm (financials, service, safety record, repeatable production

process, track record, adherence to published production schedules, relationship, technical

support, performance and location); price; product range(demonstrate trials for each

size/grade purchased); quality (chemical, mechanical and physical properties, meets quality

specification, quality system certification, supply chain management); and trials of material

from new suppliers (manufacturing trials, lab tests, stamping, welding, and paint trials). The

time to qualify a new supplier ranged from one day to one year; most purchasers reported that

it took three months or less to qualify a new supplier.34

Thirty‐five of the 37 responding purchasers indicated that no domestic or foreign

producer had failed in its attempts to certify or qualify hot‐rolled steel nor had any producers

lost their approved status since 2007. Of the two firms that reported that firms had failed to be

certified or lost their certification, one reported ***. The other purchaser reported that

qualification depended on the product and the end use.35   

Lead times

Most U.S. producers and importers reported that the vast majority (and in many cases

all) of their sales are produced to order rather than being sold from inventory. More than 99

percent of U.S. producers’ sales were sold on a produced‐to‐order basis. The majority of U.S.

producers making hot‐rolled steel on a produced‐to‐order basis reported lead times of four to

six weeks;36 for those limited number of firms that reported sales from inventories, lead times

ranged from 2 days to 2 weeks.

Comparisons of domestic products, subject imports, and nonsubject imports

Purchasers were asked a number of questions comparing hot‐rolled steel produced in

the United States, subject countries, and nonsubject countries. First, purchasers were asked to

provide a country‐by‐country comparison for 18 of the 20 factors for which they were asked to

rate the importance, presented above in table II‐10.37  

 

33 One purchaser reported both that it required certification for 5 percent of its purchases as well as

all its purchases it has been included as requiring certification for 100 percent of its purchases.

34 Three purchasers that reported certification was not needed, nonetheless, reported time required

for certification, all these required 2 months or less.

35 One firm reported that no producers were disqualified but reported some qualify for only some

grades and sizes.   36 Lead times ranged between 2 and 8 weeks for 11 of the 12 responding producers. *** indicated

that produced‐to‐order sales have a lead time of 120 days.

37 They were not asked for responses for exchange rate fluctuations and international shipping costs.
II‐24

When comparing the U.S. product to the Chinese product, most responding purchasers

reported that the U.S. product was superior to the Chinese product for delivery time, proximity

of the supplier, and reliability of supply (table II‐12). Most responding purchasers reported that

the U.S. and Chinese products were comparable with respect to minimum quantity

requirements, packaging, product consistency, product range, and quality meets industry

standards. For the 10 remaining factors, responses were mixed.  

Table II-12 

Hot-rolled steel: Purchasers’ comparisons between U.S.-produced and imported product1

Factor 

U.S. vs. 

China U.S vs. India 

U.S vs. 

Indonesia U.S. vs. Taiwan 

S C I S C I S C I S C I 

Availability 4 4 0 4 2 1 2 2 0 4 2 0

Contract with supplier 3 4 1 3 2 2 2 1 1 3 2 1

Delivery terms 4 1 3 3 1 3 2 0 2 4 0 2

Delivery time 6 0 3 5 0 3 3 0 2 4 1 2

Discounts offered 4 4 0 4 2 1 3 1 0 4 2 0

Extension of credit 4 3 1 4 2 1 3 0 1 4 1 1

Minimum quantity requirements 3 5 0 3 4 0 2 2 0 3 3 0

Packaging 3 5 0 3 4 0 1 2 0 2 4 0

Price1 2 4 2 2 3 2 2 1 1 2 4 0

Product consistency 3 5 1 3 3 1 2 2 0 3 3 0

Product range 3 5 1 3 3 1 2 2 0 3 3 0

Proximity of supplier 6 0 3 5 0 3 3 0 2 5 0 2

Quality meets industry standards 3 5 0 3 4 0 2 2 0 3 3 0

Quality exceeds industry standards 3 3 2 3 2 2 2 1 1 3 2 1

Raw material pricing index 4 3 1 4 2 1 3 0 1 4 1 1

Reliability of supply 5 1 2 4 1 2 2 0 2 4 0 2

Technical support/service 4 3 1 3 3 1 2 1 1 3 2 1

U.S. transportation costs 4 1 3 3 2 2 2 0 2 3 1 2

Table continued on next page. 
II‐25

Table II-12--Continued

Hot-rolled steel: Purchasers’ comparisons between U.S.-produced and imported product1

Factor 

U.S. vs. Thailand U.S vs. Ukraine 

U.S vs. nonsubject 

countries 

S C I S C I S C I 

Availability 4 2 0 3 2 0 4 8 5

Contract with supplier 3 2 1 2 2 1 5 9 3

Delivery terms 4 0 2 2 1 2 7 6 4

Delivery time 5 0 2 4 0 2 6 6 5

Discounts offered 4 2 0 3 2 0 2 15 0

Extension of credit 4 1 1 3 1 1 0 16 1

Minimum quantity requirements 4 2 0 2 3 0 0 14 3

Packaging 3 3 0 2 3 0 1 15 1

Price1 2 2 2 2 1 2 5 8 4

Product consistency 4 2 0 3 2 0 0 17 0

Product range 4 2 0 3 2 0 5 10 2

Proximity of supplier 5 0 2 4 0 2 6 6 5

Quality meets industry standards 3 3 0 3 2 0 0 17 0

Quality exceeds industry standards 3 2 1 3 1 1 0 16 1

Raw material pricing index 4 0 1 3 1 1 3 13 1

Reliability of supply 4 0 2 3 0 2 1 11 4

Technical support/service 4 1 1 3 1 1 4 13 0

U.S. transportation costs 3 1 2 2 1 2 3 11 3 1

 A rating of superior means that price/U.S. transportation costs is generally lower. For example, if a firm reported 

“U.S. superior,” it meant that the U.S. product was generally priced lower than the imported product. 

Note.--S=first listed country’s product is superior; C=both countries’ products are comparable; I=first list country’s 

product is inferior. 

Source: Compiled from data submitted in response to Commission questionnaires. 

Most responding purchasers reported U.S. product was superior to Indian product for

availability, delivery time, discounts offered, extension of credit, proximity of supplier, raw

material pricing index, and reliability of supply. They also indicated that the U.S. and Indian

products were comparable for minimum quantity requirements, packaging and quality meets

industry standards. Responses were mixed for the remaining eight factors.  

A majority of responding purchasers reported U.S. product was superior to Indonesian

product for delivery time, discounts offered, extension of credit, proximity of supplier, and raw

material pricing index. For the remaining 13 factors, responses were mixed.  

With respect to product imported from Taiwan, most responding purchasers reported

that U.S. product was superior for availability, delivery terms, delivery time, discounts offered,

extension of credit, proximity of the supplier, raw material pricing index, and reliability of

supply. They also indicated that the two were comparable for packaging and price. Responses

were mixed with respect to the remaining eight factors.  

Most responding purchasers reported that U.S. product was superior to product

imported from Thailand for most (12) factors, while responses were mixed for the remaining

factors (including contract with supplier, packaging, price, quality meets industry standard,

quality exceeds industry standard, and U.S. transportation costs).  
II‐26

A majority of purchasers indicated that U.S. product was superior to product from

Ukraine for most (12) factors, and that U.S. hot‐rolled steel and that imported from Ukraine

were comparable for minimum quantity requirements and packaging. Responses were mixed

for the remaining four factors: contract with supplier, delivery terms, price, and U.S.

transportation costs.  

Comparisons between the U.S. and nonsubject products were provided by 17

purchasers. Most responding purchasers reported that U.S. and nonsubject product were

comparable for 13 of the 18 factors. For the other factors (i.e., availability, delivery terms,

delivery time, price, and proximity of supplier), responses were mixed.38  

Interchangeability

U.S.‐produced hot‐rolled steel generally can be used in the same applications as imports

from the six subject countries as well as other countries. As shown in table II‐13, all responding

U.S. producers reported that the domestic and imported products are “always” or “frequently”

interchangeable. A plurality of importers also reported that U.S. and imported product was

“always” or “frequently” interchangeable. While most purchasers reported that imported

product was “always” or “frequently” interchangeable with domestic hot‐rolled steel, a greater

number of purchasers indicated that product was only “sometimes” or “never” interchangeable

when compared with producers and importers indicating so. Factors cited that may limit

interchangeability included: chemical and mechanical requirements, coil size, lead times,

limited availability for some size ranges and grades, packaging, and quality (including surface

quality).39  

 

38 Purchasers were requested to compare product from subject and nonsubject countries with

product from other subject and nonsubject countries. Only one firm compared product from a subject

country (China) with product from any other countries (Canada and Mexico). It reported that Canadian

product was superior to Chinese product for all factors, and that Mexican product was superior to

Chinese product for all factors except availability, price, and product range.

39 One importer reported differences by country or origin, reporting that Ukrainian product has a

reputation of limited/inferior quality. One purchaser reported on interchangeability from subject

countries, for U.S. compared to China, Taiwan, and Thailand it reported quality concerns.  
II‐27

Table II-13 

Hot-rolled steel: Perceived interchangeability between hot-rolled steel produced in the United 

States and in other countries, by country pairs 

Country pair 

Number of U.S. 

producers reporting 

Number of U.S. 

importers reporting 

Number of U.S. 

purchasers reporting 

A F S N A F S N A F S N 

U.S. vs. subject countries: 

 U.S. vs. China 9 3 0 0 7 7 3 0 6 5 5 2 

 U.S. vs. India 9 3 0 0 7 5 5 0 5 4 4 1 

 U.S. vs. Indonesia 9 3 0 0 7 5 4 0 5 2 3 1 

 U.S. vs. Taiwan 9 3 0 0 7 7 3 0 5 4 6 1 

 U.S. vs. Thailand 9 3 0 0 7 6 3 0 5 3 5 1 

 U.S. vs. Ukraine 9 3 0 0 6 5 4 0 5 3 6 1 

Subject vs. subject 

countries: 

 China vs. India 7 2 0 0 6 7 2 0 4 4 4 1 

 China vs. Indonesia 7 2 0 0 6 6 3 0 4 2 3 1 

 China vs. Taiwan 7 2 0 0 6 8 1 0 4 4 4 1 

 China vs. Thailand 7 2 0 0 6 7 1 0 4 2 4 1 

 China vs. Ukraine 7 1 1 0 6 5 3 0 4 2 4 1 

 India vs. Indonesia 7 2 0 0 5 6 2 1 4 2 3 1 

 India vs. Taiwan 7 2 0 0 5 5 3 0 4 4 4 1 

 India vs. Thailand 7 2 0 0 5 5 3 0 4 2 4 1 

 India vs. Ukraine 7 1 1 0 5 4 4 0 4 2 4 1 

 Indonesia vs. Taiwan 7 2 0 0 5 5 3 0 4 3 4 1 

 Indonesia vs. Thailand 7 2 0 0 5 5 3 0 4 2 4 1 

 Indonesia vs. Ukraine 7 1 1 0 5 4 4 0 4 2 3 1 

 Taiwan vs. Thailand 7 2 0 0 4 6 2 0 4 3 3 1 

 Taiwan vs. Ukraine 7 1 1 0 5 4 4 0 4 2 4 1 

 Thailand vs. Ukraine 7 1 1 0 5 4 4 0 4 2 4 1 

Comparisons with 

nonsubject countries: 

 U.S. vs. nonsubject 9 3 0 0 8 12 4 0 6 12 9 1 

 China vs. nonsubject 7 1 1 0 7 5 2 0 4 3 6 1 

 India vs. nonsubject 7 1 1 0 7 5 2 0 4 3 6 1 

 Indonesia vs. nonsubject 7 1 1 0 7 5 2 0 4 2 6 1 

 Taiwan vs. nonsubject 7 1 1 0 7 6 1 0 4 3 6 1 

 Thailand vs. nonsubject 7 1 1 0 7 6 1 0 4 2 5 1 

 Ukraine vs. nonsubject 7 1 1 0 6 5 2 0 4 2 6 1 

Note.—A=Always, F=Frequently, S=Sometimes, N=Never. 

Source: Compiled from data submitted in response to Commission questionnaires. 

A majority of U.S. producers, importers, and purchasers agreed that subject imported

products were “always” or “frequently” interchangeable with product from all other subject

countries. Most U.S. producers and importers reported product from the United States and

subject countries was “always” or “frequently” interchangeable with product from nonsubject

countries. Purchasers comparisons of subject and nonsubject product was almost evenly
II‐28

divided between those reporting that product from most subject countries was “always” or

“frequently” interchangeable with that from nonsubject countries and those reporting product

from subject countries was only “sometimes” or “never” interchangeable with product from

nonsubject countries.

Foreign producers were asked if the hot‐rolled steel they produce and sell to their home

market is interchangeable with that sold in the United States or third‐country markets. Four of

the five responding foreign producers reported that the products were interchangeable. The

other foreign producer (***) reported that most exports were specialty products rather than

commercial grades.

  

Differences other than price

Producers, importers, and purchasers were also asked to assess how often differences

other than price were significant in sales of hot‐rolled steel from the United States, subject, and

nonsubject countries. As seen in table II‐14, most producers reported that there were “never”

differences other than price for product from each of the country pairs, whereas most

importers reported there were “sometimes” or “never” differences other than price. Purchaser

responses were more varied. Half or more responding purchasers reported that there were

“always” or “frequently” differences other than price between U.S. and subject imported hot‐

rolled steel from China, India, Taiwan, and other nonsubject countries. For all other country

pairs, a majority of responding purchasers reported that there were “sometimes” or “never”

differences other than price.  

Differences reported include: availability, logistics (transportation, customs,

warehousing, inventories, and cost of managing a long supply chain), material certifications,

product range, product support, quality, rule of law and enforceability of contracts, size range,

and thickness tolerances.40  

 

 

40 Thickness tolerances were only reported for product for Ukraine. Differences in quality,

transportation, production support and material certification were reported to be an issue for Chinese

product. These were the only subject countries specifically mentioned as different in the responses.
II‐29

Table II-14 

Hot-rolled steel: Significance of differences other than price between hot-rolled steel produced in 

the United States and in other countries, by country pair 

Country pair 

Number of U.S. 

producers reporting 

Number of U.S. 

importers reporting 

Number of U.S. 

purchasers reporting 

A F S N A F S N A F S N 

U.S. vs. subject countries: 

 U.S. vs. China 1 1 2 8 2 2 9 3 9 2 1 5 

 U.S. vs. India 1 1 3 7 2 2 9 3 6 2 1 5 

 U.S. vs. Indonesia 1 1 3 7 2 2 10 2 4 1 1 5 

 U.S. vs. Taiwan 1 2 2 7 2 1 11 3 5 2 2 5 

 U.S. vs. Thailand 1 2 2 7 2 1 10 3 4 2 1 5 

 U.S. vs. Ukraine 1 3 1 7 3 1 9 3 4 1 2 5 

Subject vs. subject 

countries: 

 China vs. India 1 0 1 7 2 1 6 4 3 2 2 4 

 China vs. Indonesia 1 0 1 7 2 1 7 3 3 0 2 4 

 China vs. Taiwan 1 1 0 7 2 1 6 5 3 1 3 4 

 China vs. Thailand 1 0 1 7 2 1 6 4 3 1 2 4 

 China vs. Ukraine 1 1 0 7 2 2 6 3 3 0 2 4 

 India vs. Indonesia 1 0 1 7 2 0 6 4 3 0 1 5 

 India vs. Taiwan 1 1 0 7 2 0 6 4 3 1 3 4 

 India vs. Thailand 1 0 1 7 2 0 6 4 3 1 1 4 

 India vs. Ukraine 1 1 0 7 2 0 6 4 3 0 1 4 

 Indonesia vs. Taiwan 1 1 0 7 2 0 6 4 3 1 2 4 

 Indonesia vs. Thailand 1 0 1 7 2 0 6 4 3 1 1 4 

 Indonesia vs. Ukraine 1 1 0 7 2 1 6 3 3 0 1 4 

 Taiwan vs. Thailand 1 1 0 7 2 0 6 4 3 1 1 4 

 Taiwan vs. Ukraine 1 1 0 7 2 1 6 3 3 0 1 4 

 Thailand vs. Ukraine 1 1 0 7 2 1 6 3 3 0 1 4 

Comparisons with 

nonsubject countries: 

 U.S. vs. nonsubject 1 3 1 7 3 2 12 4 6 7 4 5 

 China vs. nonsubject 1 1 0 7 3 0 6 4 3 1 3 4 

 India vs. nonsubject 1 1 0 7 3 1 5 4 3 1 3 4 

 Indonesia vs. nonsubject 1 1 0 7 3 1 5 4 3 1 1 4 

 Taiwan vs. nonsubject 1 1 0 7 3 0 6 4 3 1 2 4 

 Thailand vs. nonsubject 1 1 0 7 3 0 6 4 3 1 1 4 

 Ukraine vs. nonsubject 1 1 1 6 4 0 5 4 3 1 1 4 

Note.—A=Always, F=Frequently, S=Sometimes, N=Never. 

Source: Compiled from data submitted in response to Commission questionnaires.
II‐30

ELASTICITY ESTIMATES

This section discusses elasticity estimates for the hot‐rolled steel market in the United

States.41

U.S. supply elasticity

The domestic supply elasticity for hot‐rolled steel measures the sensitivity of the

quantity supplied by U.S. producers to changes in the U.S. market price of hot‐rolled steel. The

elasticity of domestic supply depends on several factors including the level of excess capacity,

the ease with which producers can alter capacity, producers’ ability to shift to production of

other products, the low level of inventories, and a lack of many alternate markets for U.S.‐

produced hot‐rolled steel. Earlier analysis of these factors indicates that the U.S. industry has a

low to moderate ability to increase or decrease shipments to the U.S. market; an estimate in

the range of 2 to 4 is suggested.

U.S. demand elasticity

The U.S. demand elasticity for hot‐rolled steel measures the sensitivity of the overall

quantity demanded to a change in the U.S. market price of hot‐rolled steel. 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 hot‐rolled steel in the production of

any downstream products. Based on the available information, the aggregate demand for hot‐

rolled steel is likely to be moderately inelastic and in a range of ‐0.75 to ‐1.0. Purchasers would

not likely be very sensitive to changes in the price of hot‐rolled steel and would continue to

demand fairly constant quantities over a considerable range of prices.

Substitution elasticity

The elasticity of substitution depends upon the extent of product differentiation

between the domestic and imported products. Product differentiation, in turn, depends upon

such factors as quality and conditions of sale. Based on available information, the elasticity of

substitution between domestic and subject imports is likely to be moderate to high and in the

range of 3 to 5, with more specialized products falling in the lower part of this range.

 

41 Parties were encouraged to comment on these estimates in their prehearing briefs, but no party

responded specifically to this request.
  

III‐1

PART III: CONDITION OF THE U.S. INDUSTRY

OVERVIEW

As discussed in Part I, since the filing of the original petitions, the U.S. industry has

experienced substantial consolidation. Although new mills opened (including Severstal

Columbus in 2007 and ThyssenKrupp’s mill in Calvert, Alabama in 2010), several U.S. mills

closed. Mills in Sparrows Point, Maryland, Steubenville, Ohio, and Warren, Ohio, changed

ownership several times from ArcelorMittal to Severstal to RG Steel before being shut down and

sold to liquidators.  Following the economic crisis in 2008, the industry idled or curtailed

production at several mills and reduced employment. Table III‐1 summarizes important events

that have taken place in the U.S. industry since January 1, 2007.

Table III-1 

Hot-rolled steel: Important industry events since January 1, 2007

Period Company Event 

January 2007 Evraz (Russia) 

Acquisition: Evraz (Russia) acquires Oregon Steel Mills. The mill is 

renamed Evraz Oregon Steel Mills.

June 2007 U.S. Steel 

Acquisition: U.S. Steel acquires Lone Star Technologies, a pipe 

producer, with its EAFs and rolling mills used to produce hot-rolled 

steel.

July 2007 IPSCO 

Acquisition: SSAB acquires IPSCO including facilities in Mobile, AL 

and Montpelier, IA.

Third quarter 

2007 U.S. Steel 

Capacity reduction: U.S. Steel permanently shuts down the EAFs 

and rolling mills formerly owned by Lone Star Technologies.

October 2007 Severstal 

Capacity increase: Startup of SeverCorr, located near Columbus, 

MS. SeverCorr is a joint venture created in 2005 between Severstal 

and a group of steel industry executives headed by John Correnti, a 

former Nucor executive. 

November 2007 

Mittal Steel Co. 

N.V. 

Merger: Mittal Steel Co. N.V. and Arcelor merge creating 

ArcelorMittal. 

November 2007 Esmark 

Merger: Esmark Inc. (owner of steel service centers) merges with 

Wheeling-Pittsburgh Corp. (owner of steel mill in Steubenville, OH). 

Fourth quarter 

2007 NLMK (Russia) 

Ownership change: Duferco Farrell Corp.’s mills in Farrell, PA are 

acquired by the Duferco-NLMK Joint Venture Co. 

April 2008 Severstal 

Buy out: Severstal increases its ownership stake in SeverCorr to 85 

percent and buys out the management team of John Correnti. The 

plant is renamed Severstal Columbus. 

May 2008 ArcelorMittal 

Divestiture: OAO Severstal acquires the Sparrows Point, MD mill 

from ArcelorMittal. (renamed Severstal Sparrows Point, Inc.) 

July 2008 Severstal 

Acquisition: OAO Severstal acquires WCI Steel, Inc. including its 

mill in Warren, OH, and the facility is renamed Severstal Warren, Inc. 

August 2008 Severstal 

Acquisition: OAO Severstal acquires Esmark Inc. including the 

former Wheeling-Pittsburgh mill in Steubenville, OH (renamed 

Severstal Wheeling, Inc.). 

April 2009 Severstal Shutdown: Severstal idles the hot mill at its Steubenville, OH facility. 

Table continued on next page. 
  

III‐2

Table III-1--Continued

Hot-rolled steel: Important industry events since January 1, 2007 

Period Company Event 

October 2009 Beta Steel 

Acquisition: Beta Steel is acquired by NLMK and, in July 2010, 

renamed NLMK Indiana. 

February 2009 Severstal Shutdown: Severstal idles its Warren, OH operations 

April 2010 Severstal 

Production restart: Severstal restarts production at its Warren, OH 

facility. 

July 2010 ThyssenKrupp 

Capacity increase: ThyssenKrupp’s new facility in Calvert City, AL, 

begins production. 

March 2011 RG Steel 

Acquisition: RG Steel acquires the Sparrows Point, MD, Warren, 

OH, Steubenville, OH, and Wheeling, WV mills from OAO Severstal 

July 2011 

September 2011 NLMK (Russia) 

Acquisition: In July 2011, NLMK (Russia) acquires the Duferco 

Farrell’s interest in the Pennsylvania operations which are now wholly 

owned by NLMK (Russia). In September 2011, the company is 

renamed NLMK-Pennsylvania. 

May 2012 

RG Steel 

Bankruptcy: RG Steel files for Chapter 11 bankruptcy; production 

ceases. 

ThyssenKrupp 

Possible sale: ThyssenKrupp AG announces that it is mulling 

"strategic options" for its Alabama operations which could include 

either a sale or a partnership. Current economics no longer support 

its business of turning profits by shipping low-cost slab from Brazil to 

high-end markets in North America. That plan assumed low-cost slab 

production in Brazil and more robust demand in North America, but 

with production costs in Brazil rising and a slower-than-expected 

recovery in the United States, that strategy now leaves the company 

exposed to "considerable risks." 

July 2012 RG Steel 

Sale: RG Steel’s Steubenville, OH idled mill is purchased by Herman 

Strauss, Inc., a scrap processor.

September 2012 RG Steel 

Sale: RG Steel’s operations in Warren, OH and Sparrows Point, MD 

are sold. The Warren, OH operations were sold to CJ Betters 

Enterprises and reportedly the new owner is considering reopening 

the mill. The new owners of the Sparrows Point mill are joint venture 

partners Hilco Trading LLC (an industrial liquidator) and 

Environmental Liability Transfer Inc. 

December 2012 

RG Steel 

Possible liquidation: Nucor Corp. purchases parts of the cold mill at 

the Sparrows Point, MD facility and indicates that the acquired parts 

of the mill will be used as spare equipment at Nucor’s facilities. This 

purchase reportedly could rule out operation of Sparrows Point as a 

steelmaking operation since few buyers would be interested in 

operating the facility without the state-of-the-art cold mill. A planned 

auction of the entire facility either as a whole or piecemeal, scheduled 

for January 3, 2013, has since been canceled; instead, the remaining 

Sparrows Point production assets will be sold through a private 

treaty, or negotiated, sale process for immediate sale. 

ThyssenKrupp 

Accounting change: ThyssenKrupp announces that its Steel 

Americas operation, including its Alabama plant, is classified in its 

accounting statements as a discontinued operation for fiscal year 

2011/2012 due to the advanced status of its sale process 

Table continued on next page. 

 
  

III‐3

Table III-1--Continued

Hot-rolled steel: Important industry events since January 1, 2007 

Period Company Event 

March 2013 RG Steel 

Possible liquidation: A plan to remediate the former RG Steel 

Wheeling facility is announced after Ohio’s budgetary oversight board 

approved the release of $1 million from the Clean Ohio Assistance 

Fund. After remediation, the city intends to redevelop the property, 

turning it into a multimodal transfer and processing facility to support 

midstream shale gas operations. Construction on the facility should 

begin this summer, with operation set to start by the fourth quarter of 

2014, according to the fund’s project document. 

June 2013 RG Steel 

Sale: C.J. Betters Enterprises sells the assets of the former RG 

Steel’s Warren, OH operation to Hilco Trading LLC. 

July 2013 Big River Steel 

Possible capacity increase: John Correnti, a former Nucor 

executive, proposes building a new steel mill, Big River Steel, in 

Arkansas. The Arkansas Department of Environmental Quality holds 

hearings to consider granting an air permit to Big River. This permit 

process is one of the final major hurdles before construction of the 

proposed $1.1 billion steel mill. 

September 2013 RG Steel 

Possible liquidation: At the former RG Steel Warren, OH facility, 

demolition permits are approved for parts of the cold mill complex and 

applications for permits to demolish the hot mill are filed. The hot mill 

demolition applications are reportedly likely to be approved in the 

summer of 2014. 

November 2013 Big River Steel 

Possible capacity increase: The proposed new steel mill, Big River 

Steel, receives air permit approval in September 2013 but the 

approval is challenged by Nucor in October. A hearing on Nucor’s 

challenge will be held in February 2014. Reportedly the 

groundbreaking of Big River Steel is likely to be delayed until the first 

quarter of 2014 due to Nucor’s challenge but it is likely that the air 

permit will be upheld. Big River will have an annual capacity of 1.7 

million tons and will produce hot-rolled, cold-rolled, galvanized grainand non-grain oriented electrical steels, and substrate for pipe. 

December 2013 ThyssenKrupp 

Sale: ArcelorMittal SA and Nippon Steel & Sumitomo Metal Corp. 

have agreed to buy ThyssenKrupp AG’s Calvert, Alabama, facility for 

$1.55 billion subject to possible anti-trust regulatory approval.

Source: Compiled from information obtained from various news articles and company websites. 

Background

The information in this section of the report was compiled from responses of fourteen

firms to the Commission’s questionnaires. All established U.S. producers, which accounted for

more than 95 percent of U.S. production of hot‐rolled steel in January 2007 ‐ June 2013,

supplied information on their operations in these reviews and other proceedings on hot‐rolled

steel.1

 

1 Data for RG Steel ***, as noted in Part I of this report.
  

III‐4

Changes experienced by the industry  

Domestic producers were asked to indicate whether their firm 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 other reasons, including revision of labor agreements; or any other

change in the character of their operations or organization relating to the production of hot‐

rolled steel since 2007. All domestic producers that provided responses in these reviews

indicated that they had experienced such changes; their responses are presented in table III‐2.

Table III-2 

Hot-rolled steel: Changes in the character of U.S. operations since January 1, 2007 

* * * * * * * 

Anticipated changes in operations

The Commission asked domestic producers to report anticipated changes in the

character of their operations relating to the production of hot‐rolled steel. Their responses

appear in table III‐3.

Table III-3 

Hot-rolled steel: Anticipated changes in the character of U.S. operations 

* * * * * * * 

U.S. PRODUCTION, CAPACITY, AND CAPACITY UTILIZATION

Table III‐4 and figure III‐1 present U.S. producers’ production, capacity, and capacity

utilization. Capacity and production declined in 2008 and in 2009, and then increased in each

subsequent year, ending in 2012 6.9 percent and 6.1 percent lower than in 2007, respectively.  

Between January 2007 and June 2013, two firms began production of hot‐rolled steel:

SeverCorr (later Severstal Columbus) in October 2007 and ThyssenKrupp in July 2010. RG Steel,

in contrast, ceased production of hot‐rolled steel. RG Steel’s Wheeling, West Virginia facility

ceased production in April 2009 (while still owned and operated by Severstal) and in May 2012

RG Steel entered chapter 11 bankruptcy, ceasing operations at the firm’s facilities in Sparrows

Point, Maryland and Warren, Ohio.

The decline in both capacity and production in 2008 was largely due to ***. Production

declined at all but one firm in 2008 (***) and in 2009 (***) and then increased in 2010 at all

firms but ***. The largest increases and decreases in production during January 2007‐June

2013, involved the largest firms, in terms of capacity and production, ***.
  

III‐5

Table III-4 

Hot-rolled steel: U.S. producers’ production, capacity, and capacity utilization, 2007-12, JanuaryJune 2012, and January-June 2013 

Calendar year January-June

Item 2007 2008 2009 2010 2011 2012 2012 2013

Capacity 80,382,246 72,818,689 70,408,591 70,418,659 72,451,936 74,840,642 37,030,805 37,518,879

Production 60,698,008 54,012,619 37,219,428 51,664,655 54,213,932 57,000,441 29,394,056 28,554,588

Capacity utilization (percent) 75.5 74.2 52.9 73.4 74.8 76.2 79.4 76.1

Source: Compiled from data submitted in response to Commission questionnaires. 

Figure III-1 

Hot-rolled steel: U.S. producers’ production, capacity, and capacity utilization, 2007-12, JanuaryJune 2012, and January-June 2013 

Source: Table III-4.

Constraints on capacity

As shown in table III‐5, all of the responding U.S. producers but *** reported constraints

in the manufacturing process.  

Table III-5 

Hot-rolled steel: U.S. producers' constraints on capacity 

* * * * * * * 

0

10

20

30

40

50

60

70

80

0

10

20

30

40

50

60

70

80

90

2007 2008 2009 2010 2011 2012

Ratio

(percent)

Quantity

(millions of short tons)

Capacity Production Capacity utilization (percent)
  

III‐6

Alternative and downstream products

The Commission asked domestic producers to report production of other or

downstream products on the same equipment and machinery, and/or using the same

production and related workers employed to produce hot‐rolled steel. Seven companies (***)

indicated that they produce other products on their hot‐rolled steel equipment and

machinery.2 Six domestic producers (***) responded that they do not produce other products

on the same equipment and machinery used to make hot‐rolled steel.

Data on domestic producers’ capacity, production, and capacity utilization for

alternative steel products are presented in table III‐6. The reported capacity, production, and

capacity utilization for all six categories of steel products fluctuated, but were generally lower in

2012 than reported in 2007. In total, 9 firms reported production of slabs,3 7 reported

production of nonsubject products on their hot‐strip mill,4 10 reported production of cold‐

rolled steel,5 9 reported production of coated steel,6 5 reported production of steel plate cut

from coils,7 and 2 reported production of tubular products.8

 

2 ***.

3 ***.

4 ***.

5 ***.

6 ***.

7 ***.

8 ***.
  

III‐7

Table III-6 

Hot-rolled steel: U.S. producers' capacity, production, and capacity utilization for alternative and 

downstream products, 2007-12, January-June 2012, and January-June 2013 

Calendar year January-June

Item 2007 2008 2009 2010 2011 2012 2012 2013

Slab casting: 

 Capacity (short tons) 72,665,796 72,735,871 71,133,246 70,349,286 71,439,851 72,361,104 36,167,102 36,245,078

 Production (short tons) 59,473,192 55,783,790 38,286,833 53,308,878 55,214,547 57,928,458 29,828,907 28,996,204

 Capacity utilization (percent) 81.8 76.7 53.8 75.8 77.3 80.1 82.5 80.0

Hot strip/steckel mill: 

 Capacity (short tons) 83,891,871 76,304,439 73,946,591 74,294,465 78,915,848 81,858,616 40,414,737 40,822,120

 Production (short tons) 

 Subject 

60,509,810 54,030,305 37,248,434 51,688,632 54,242,830 56,994,440 29,356,655 28,575,087

 Nonsubject 3,543,011 3,403,119 2,057,675 3,223,572 5,299,154 5,226,870 2,901,167 2,722,923

 Total 64,052,821 57,433,424 39,306,109 54,912,204 59,541,984 62,221,310 32,257,822 31,298,010

 Capacity utilization 76.4 75.3 53.2 73.9 75.4 76.0 79.8 76.7

Cold-rolled steel: 

 Capacity (short tons) 46,787,655 43,725,814 39,349,751 38,971,775 40,050,775 40,537,654 20,060,414 20,425,792

 Production (short tons) 31,490,607 27,801,868 20,188,965 26,552,921 25,430,571 26,975,990 13,643,568 13,201,579

 Capacity utilization (percent) 67.3 63.6 51.3 68.1 63.5 66.5 68.0 64.6

Coated steel: 

 Capacity (short tons) 23,109,775 22,526,450 21,527,142 21,683,673 21,306,596 22,333,790 11,224,350 11,636,944

 Production (short tons) 17,795,051 15,284,638 11,044,269 15,255,360 14,753,422 15,966,500 8,093,778 7,954,380

 Capacity utilization (percent) 77.0 67.9 51.3 70.4 69.2 71.5 72.1 68.4

Steel plate (cut from coils): 

 Capacity (short tons) *** *** *** *** *** *** *** ***

 Production (short tons) *** *** *** *** *** *** *** ***

 Capacity utilization (percent) *** *** *** *** *** *** *** ***

Tubular products: 

 Capacity (short tons) *** *** *** *** *** *** *** ***

 Production (short tons) *** *** *** *** *** *** *** ***

 Capacity utilization (percent) *** *** *** *** *** *** *** ***

Note.—Subject production data in tables III-4 and III-6 differ due to rounding or minor reporting discrepancies. 

Source: Compiled from data submitted in response to Commission questionnaires. 
  

III‐8

U.S. PRODUCERS’ U.S. SHIPMENTS AND EXPORTS

Table III‐7 presents U.S. producers’ U.S. shipments, export shipments, and total

shipments. During 2007‐12, January‐June 2012, and January‐June 2013, more than one‐half of

U.S. producers’ total shipments were internally consumed, and more than one‐third was sold

commercially within the United States. The remaining shipments were divided between

transfers to related firms and export shipments, each accounting for less than 4 percent of total

shipments over 2007‐12, January‐June 2012, and January‐June 2013. All firms had commercial

shipments, ten firms (***) reported internal consumption, ten firms (***) reported transfers to

related firms, and all but two firms (***) had export shipments. The quantity of commercial

shipments and internal consumption followed the same trends between 2007 and 2012,

declining in 2008 and 2009, and then increasing in subsequent years, ending 2.2 percent and

5.3 percent lower in 2012, respectively, than in 2007. Both were also lower in interim 2013

compared with interim 2012.  

Average unit values for all forms of shipments followed the same trend between 2007

and 2012, rising to their highest levels in 2008 (reflecting rising values and declining quantities),

the falling to the lowest levels in 2009, and then increasing in 2010 and 2011, before declining

in 2012, albeit above average unit values in 2007. Average unit values for all forms of shipments

were lower in interim 2013 compared with interim 2012.
  

III‐9

Table III-7 

Hot-rolled steel: U.S. producers’ U.S. shipments, exports shipments, and total shipments, 2007-12, 

January-June 2012, and January-June 2013

Calendar year January-June

Item 2007 2008 2009 2010 2011 2012 2012 2013

Quantity (short tons)

Commercial shipments 23,565,143 21,099,573 13,197,735 19,786,108 21,843,481 23,050,999 12,062,344 11,782,752

Internal consumption 33,562,539 30,656,386 21,530,228 28,797,615 29,738,011 31,767,697 16,204,998 15,727,428

Transfers to related firms 2,073,245 1,849,029 964,029 1,454,053 1,423,070 1,341,592 719,365 699,438

 U.S. shipments 59,200,927 53,604,988 35,691,992 50,037,776 53,004,562 56,160,288 28,986,707 28,209,618

Export shipments 1,456,322 1,249,300 1,101,366 1,522,803 1,054,556 822,525 391,614 430,255

 Total shipments 60,657,249 54,854,288 36,793,358 51,560,579 54,059,118 56,982,813 29,378,321 28,639,873

 Value (1,000 dollars)

Commercial shipments 12,961,021 16,555,589 6,949,810 11,905,660 15,651,177 15,396,698 8,441,332 7,326,018

Internal consumption 18,378,353 23,144,125 11,346,587 17,400,239 20,774,935 20,991,035 11,279,828 9,739,055

Transfers to related firms 1,155,698 1,512,180 528,356 894,457 1,035,081 892,017 498,070 424,121

 U.S. shipments 32,495,072 41,211,894 18,824,753 30,200,356 37,461,193 37,279,750 20,219,230 17,489,194

Export shipments 792,319 1,050,565 551,028 926,180 794,300 587,861 295,512 278,856

 Total shipments 33,287,391 42,262,459 19,375,781 31,126,536 38,255,493 37,867,611 20,514,742 17,768,050

 Unit value (dollars per short ton) 

Commercial shipments 550 785 527 602 717 668 700 622

Internal consumption 548 755 527 604 699 661 696 619

Transfers to related firms 557 818 548 615 727 665 692 606

 U.S. shipments 549 769 527 604 707 664 698 620

Export shipments 544 841 500 608 753 715 755 648

 Total shipments 549 770 527 604 708 665 698 620

 Share of quantity (percent) 

Commercial shipments 38.8 38.5 35.9 38.4 40.4 40.5 41.1 41.1

Internal consumption 55.3 55.9 58.5 55.9 55.0 55.7 55.2 54.9

Transfers to related firms 3.4 3.4 2.6 2.8 2.6 2.4 2.4 2.4

 U.S. shipments 97.6 97.7 97.0 97.0 98.0 98.6 98.7 98.5

Export shipments 2.4 2.3 3.0 3.0 2.0 1.4 1.3 1.5

 Total shipments 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires. 
  

III‐10

U.S. PRODUCERS’ INVENTORIES

Table III‐8 presents U.S. producers’ end‐of‐period inventories and the ratio of these

inventories to U.S. producers’ production, U.S. commercial shipments, U.S. shipments, and total

shipments during 2007‐12, January‐June 2012, and January‐June 2013. The domestic industry’s

inventories declined in 2008 and then increased in subsequent years, ending 7.9 percent lower

in 2012 than in 2007. U.S. producers’ inventories were also lower in interim 2013 compared to

interim 2012. Throughout this period, the *** largest firms, in terms of both capacity and

production, (***) generally accounted for the largest quantity of inventories, and also

generated the largest increases and decreases in producer inventories. In addition to these

producers, *** had the largest increase in quantity of inventories in 2010.9

Table III-8 

Hot-rolled steel: U.S. producers’ inventories, 2007-12, January-June 2012, and January-June 2013 

Calendar year January-June

Item 2007 2008 2009 2010 2011 2012 2012 2013

Inventories (short tons) 1,785,483 943,817 1,369,887 1,473,964 1,627,207 1,644,836 1,642,943 1,558,942

Ratio to production 2.9 1.7 3.7 2.9 3.0 2.9 2.8 2.7

Ratio to U.S. commercial 

shipments (percent) 

7.6 4.5 10.4 7.4 7.4 7.1 6.8 6.6

Ratio to U.S. shipments 

(percent) 

3.0 1.8 3.8 2.9 3.1 2.9 2.8 2.8

Ratio to total shipments 

(percent) 

2.9 1.7 3.7 2.9 3.0 2.9 2.8 2.7

Source: Compiled from data submitted in response to Commission questionnaires. 

Steel inventories are held by numerous market participants, including producers, end

users, importers, and service centers. Steel service centers hold inventory and distribute steel

for industrial customers.10 Figure III‐2 illustrates the trends in steel service center shipments

and inventories of flat‐rolled steel (all forms except plate) since January 2007.  

 

9 This decline was due to inventories at ***. *** also had the largest decreases in 2011 and 2012

compared to other U.S. producers.

10 Compiled from data obtained from the Metal Service Center Institute, Data on shipments and

inventories of carbon flat‐rolled products (excluding plate). See:  http://www.msci.org/, retrieved

November 18, 2013.
  

III‐11

Figure III-2 

Carbon steel flat-rolled products (excluding plate): Steel service centers’ shipments and 

inventories, January 2007-September 2013 

Source: Compiled from Metal Service Center Institute data. 

U.S. PRODUCERS’ IMPORTS AND PURCHASES

Table III‐9 presents data on individual U.S. producers’ U.S. production and U.S imports of

hot‐rolled steel during 2007‐12, January‐June 2012, and January‐June 2013.  

No domestic producer directly imported, or purchased from importers, hot‐rolled steel

from the subject countries. Five firms directly imported from nonsubject sources, four firms

purchased hot‐rolled steel from other domestic producers,11 and two firms purchased from

other sources, believed to be U.S. distributors.

 

11 ***.

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

Jan‐07 Jan‐08 Jan‐09 Jan‐10 Jan‐11 Jan‐12 Jan‐13

Quantity (1,000 shoirt tons)

Monthly shipments Inventories
  

III‐12

Table III-9 

Hot-rolled steel: U.S. producers’ U.S. production, imports, and import ratios to U.S. production, 

2007-12, January-June 2012, and January-June 2013

* * * * * * * 

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

Table III‐10 shows U.S. producers’ employment‐related data during 2007‐12, January‐

June 2012, and January‐June 2013. The number of production and related workers (“PRWs”)

employed by the domestic hot‐rolled producers declined between 2007 and 2012 by 1,722 or

7.7 percent. A substantial number of the decline in PRWs between 2007 and 2012 (particularly

between 2008 and 2009) were attributable to producers with integrated mills. ***, with a

decline of *** PRWs, accounted for the largest overall decline in the number of PRWs between

2007‐12. Most of the decline was in ***. The next largest decline of PRWs was by *** which

***, which idled its mills during *** and had an unplanned outage at one of its facilities

between ***. In addition, *** accounted for the majority of the decline in PRWs in 2009, the

year in which employment was at its lowest level. The firm reported that this decline was ***.12

Table III-10 

Hot-rolled steel: Average number of production and related workers, hours worked, wages paid to 

such employees, hourly wages, productivity, and unit labor costs, 2007-12, January-June 2012, 

and January-June 2013 

Calendar year January-June

Item 2007 2008 2009 2010 2011 2012 2012 2013

PRWs (number) 22,372 21,844 18,453 19,179 20,146 20,650 20,469 20,839

Total hours worked 

(1,000 hours) 

47,316 45,956 34,894 42,020 42,435 43,840 21,432 22,648

Hours worked per PRW 

(hours) 

2,115 2,104 1,891 2,191 2,106 2,123 1,047 1,087

Wages paid ($1,000) 1,559,477 1,606,431 1,147,072 1,427,443 1,500,221 1,582,994 797,637 783,567

Hourly wages (dollars) 32.96 34.96 32.87 33.97 35.35 36.11 37.22 34.60

Productivity (short tons 

per 1,000 hours) 

 

1,283 1,175 1,067 1,230 1,278 

 

1,300 1,372 1,261 

Unit labor costs (per

short ton) 

25.69 29.74 30.82 27.63 27.67 27.77 27.14 27.44

Source: Compiled from data submitted in response to Commission questionnaires. 

 

12 Email from ***, August 27, 2013.
III‐13

FINANCIAL EXPERIENCE OF U.S. PRODUCERS

Background

Fourteen firms, which accounted for the majority of U.S. production of hot‐rolled steel

in 2012, provided useable financial data.13 As discussed earlier in Part III, these firms either

internally consumed or transferred to related parties a substantial portion of their hot‐rolled

steel to produce further manufactured products, such as cold‐rolled sheet, corrosion‐resistant

sheet, tin‐ and chromium‐coated steel sheet, and pipe and tube.  

On a quantity basis in 2012, approximately 55 percent of hot‐rolled steel was consumed

internally to manufacture downstream products, 42 percent was sold commercially, and 3

percent was transferred to related parties. The share of internal consumption is consistent with

previous reviews. As shown in the company‐specific table presented in this section of the

report, the relative importance of these categories to each U.S. firm was not uniform.

***, together accounted for *** percent, by quantity and value, of total sales of hot‐

rolled steel in 2012. The domestic steel industry has undergone further consolidation and

restructuring since the 2007 reviews, as described earlier in tables III‐1 and III‐2 in this part of

the report.14 In addition, Severstal Columbus commissioned a new facility in August 2007 and

began shipments in September of that year. ThyssenKrupp began operations in 2010,

registering sales beginning in fiscal year 2011.

Operations on hot‐rolled steel

Table III‐11 presents aggregated data on the U.S. producers’ overall operations in

relation to hot‐rolled steel for 2007‐12, January‐June 2012, and January‐June 2013.

Corresponding financial information by producer for selected items is presented in table III‐12.

As reflected in these tables, fair market values assigned to internal consumption and transfers

to related firms are based on commercial sales values adjusted for differences, if any, in the

cost of hot‐rolled steel consumed for commercial sales and the cost of hot‐rolled steel

consumed for internal consumption or transferred to related firms (“constructed fair market

value”).15 Appendix E presents the industry’s financial results using a second valuation

 

13 The firms (and their respective fiscal year ends, if other than December 31) are:  AK Steel,

ArcelorMittal, CSI, Evraz, Gallatin, NLMK (***) , North Star (***), Nucor, SDI, Severstal (reporting

separately for Columbus and Dearborn operations), Severstal/RG Wheeling, SSAB, ThyssenKrupp

(***), and U.S. Steel. Data for Severstal/RG Wheeling ***. ThyssenKrupp ***. Differences between

the trade and financial data are largely due to the timing differences of year‐end. The majority of

companies reported their results based on GAAP; *** reported their results based on IFRS. 14 For example, Evraz acquired Oregon Steel Mills, SSAB acquired the assets of IPSCO, and U.S. Steel

acquired (and closed) Lone Star Steel in 2007. ArcelorMittal sold its plant at Sparrows Point, Maryland to

Severstal in 2007, which also acquired WCI in Warren, Ohio in 2008. NLMK acquired Beta Steel in 2008.

Nucor bought its supplier of scrap raw materials in 2008, and has invested in projects that produce scrap

substitutes. Severstal sold its operations at Sparrows Point, Maryland; Wheeling, West Virginia; and

Warren, Ohio to RG Steel, which closed these mills in 2010‐12.   15 The Commission’s questionnaire provided instructions on how firms would construct fair market

value for their internal consumption and transfers. If there were no differences between the hot‐rolled

(continued...)
III‐14

methodology for internal consumption and transfers to related firms: the underlying cost of the

hot‐rolled steel plus an amount of the gross profit of downstream products as allocated based

on relative cost (“cost plus allocated gross profit of downstream products”).

                                                            

(...continued)

steel sold commercially and that consumed internally or transferred, the unit sales values should be

approximately the same. If there were differences (such as due to product mix, chemistry, physical, or

quality) between the hot‐rolled steel sold commercially and that consumed internally or transferred that

result in cost differences, then the per‐unit sales values were to be adjusted to compensate for the

differences. In most instances, the unit values of internal consumption and transfers of the reporting

companies were nearly the same as their commercial sales.
III‐15

Table III-11 

Hot-rolled steel: Results of operations of U.S. producers (valuation of consumption and transfers to related firms 

based on constructed fair market value), fiscal years 2007-12, January-June 2012, and January-June 2013 

Item

Fiscal year January-June 

2007 2008 2009 2010 2011 2012 2012 2013 

Quantity (short tons) 

Commercial sales 24,965,498 22,668,149 14,158,533 21,056,849 22,775,026 23,755,568 12,392,886 12,175,796 

Internal consumption 33,488,847 30,748,010 21,558,968 28,761,445 29,393,124 31,121,549 16,092,079 15,560,396 

Related co. transfers 2,073,245 1,853,912 985,928 1,609,447 1,571,723 1,482,376 786,044 742,810 

 Total net sales 60,527,590 55,270,071 36,703,429 51,427,741 53,739,873 56,359,493 29,271,009 28,479,002 

Value ($1,000) 

Commercial sales 13,777,075 17,332,445 7,809,854 12,685,975 16,217,990 15,990,302 8,686,215 7,577,540 

Internal consumption 18,360,325 23,208,724 11,331,685 17,407,362 20,660,366 20,647,851 11,252,284 9,690,815 

Related co. transfers 1,155,698 1,517,801 541,643 1,000,297 1,160,573 998,900 552,008 455,043 

 Total net sales 33,293,098 42,058,970 19,683,182 31,093,634 38,038,929 37,637,053 20,490,507 17,723,398 

COGS: 

 Raw materials 18,097,033 23,631,867 13,196,600 19,567,115 23,811,902 23,779,815 12,836,995 11,153,736 

 Direct labor 2,365,989 2,344,704 1,862,478 2,250,508 2,411,575 2,623,781 1,337,118 1,273,895 

 Other factory costs 9,103,482 9,686,793 5,762,508 7,408,369 7,769,355 7,840,854 3,914,267 3,902,368 

 Total COGS 29,566,504 35,663,364 20,821,586 29,225,992 33,992,832 34,244,450 18,088,380 16,329,999 

Gross profit 3,726,594 6,395,606 (1,138,404) 1,867,642 4,046,097 3,392,603 2,402,127 1,393,399 

SG&A expenses 874,510 878,826 644,733 717,369 909,680 1,009,994 490,201 452,258 

Operating income or 

(loss) 2,852,084 5,516,780 (1,783,137) 1,150,273 3,136,417 2,382,609 1,911,926 941,141 

Total other income/ 

(expense), net1

 (557,227) (811,451) (504,856) (397,647) (433,381) (505,299) (250,929) (309,873)

Net income or (loss) 2,294,857 4,705,329 (2,287,993) 752,626 2,703,036 1,877,310 1,660,997 631,268 

Depreciation/ 

amortization 883,585 862,714 943,704 1,004,576 878,342 892,578 442,218 453,147 

Cash flow 3,178,442 5,568,043 (1,344,289) 1,757,202 3,581,378 2,769,888 2,103,215 1,084,415 

Ratio to net sales (percent) 

COGS: 

 Raw materials 54.4 56.2 67.0 62.9 62.6 63.2 62.6 62.9 

 Direct labor 7.1 5.6 9.5 7.2 6.3 7.0 6.5 7.2 

 Other factory costs 27.3 23.0 29.3 23.8 20.4 20.8 19.1 22.0 

 Total COGS 88.8 84.8 105.8 94.0 89.4 91.0 88.3 92.1 

Gross profit 11.2 15.2 (5.8) 6.0 10.6 9.0 11.7 7.9 

SG&A expenses 2.6 2.1 3.3 2.3 2.4 2.7 2.4 2.6 

Operating income or 

(loss) 8.6 13.1 (9.1) 3.7 8.2 6.3 9.3 5.3 

Net income or (loss) 6.9 11.2 (11.6) 2.4 7.1 5.0 8.1 3.6 

Table continued on next page. 
III‐16

Table III-11--Continued

Hot-rolled steel: Results of operations of U.S. producers (valuation of consumption and transfers to 

related firms based on constructed fair market value), fiscal years 2007-12, January-June 2012, and 

January-June 2013

Item 

Fiscal year January-June 

2007 2008 2009 2010 2011 2012 2012 2013 

Average unit value (dollars per short ton) 

Commercial sales 552 765 552 602 712 673 701 622 

Internal consumption 548 755 526 605 703 663 699 623 

Related co. transfers 557 819 549 622 738 674 702 613 

 Total net sales 550 761 536 605 708 668 700 622 

Cost of goods sold: 

 Raw materials 299 428 360 380 443 422 439 392 

 Direct labor 39 42 51 44 45 47 46 45 

 Other factory costs 150 175 157 144 145 139 134 137 

 Total COGS 488 645 567 568 633 608 618 573 

Gross profit 62 116 (31) 36 75 60 82 49 

SG&A expenses 14 16 18 14 17 18 17 16 

Operating income or (loss) 47 100 (49) 22 58 42 65 33 

Number of firms reporting: 

Operating losses 3 *** 11 3 *** 3 *** 3 

Data 14 14 14 13 14 14 14 14 

1 Comprised mostly of interest expense. 

Note.--*** 

Source: Compiled from data submitted in response to Commission questionnaires.

Table III-12 

Hot-rolled steel: Results of operations of U.S. producers (valuation of consumption and transfers to 

related firms based on constructed fair market value), fiscal years 2007-12, January-June 2012, and 

January-June 2013 

* * * * * * * 

Net sales quantity and value

Total sales fell substantially from 2007 to a period low in 2009. Sales increased

thereafter and, although sales quantity in 2012 did not achieve the same level as in 2007, sales

value was higher, reflecting higher average unit values. Total sales quantity and value were

lower in January‐June 2013 compared with January‐June 2012, and average unit values were

lower as well.  

Table III‐12 shows that most of the reporting U.S. producers reported lower sales

quantities in 2008 compared to 2007 and in 2009 compared to 2008. Notwithstanding declines

in the total sales quantity in 2008, the value of the industry’s revenue reached its highest

absolute level in 2008 due to higher average sales value. Table III‐12 shows that most U.S.

producers reported substantially higher average sales values in 2008 than in 2007. Likewise, in

2008 U.S. producers collectively reported substantially higher average raw material costs. In

2009, this pattern reversed with almost all U.S. producers reporting sharp declines in average

sales values (the impact on profitability was partially offset by corresponding declines in
III‐17

average raw material costs). U.S. producers generally indicated that this pattern reflected

recession‐induced supply and demand conditions in 2009. Sales quantity rose from 2010 to

2012; sales value rose irregularly between those years. The average value of sales increased

from 2010 to 2011 and declined between 2011 and 2012. As shown in table III‐12, all U.S.

producers reported somewhat higher average sales values in 2011 compared to 2010 and most

reported lower average sales values in 2012 compared to 2011. Sales quantity, value, and

average unit value were lower in January‐June 2013 than in January‐June 2012; the pattern was

mixed among the firms.  

Operating costs and expenses

Raw material costs represent the single largest component of overall COGS, averaging

approximately 66.5 percent of total COGS on a cumulative basis during 2007‐12, and ranging

from 54.4 percent of sales value (in 2007) to 67.0 percent of sales value (in 2009). As shown in

table III‐12, average raw material costs, direct labor, and other factory costs (i.e., conversion

costs) vary from company to company. These costs generally reflect underlying differences in

steel production; e.g., the average raw material costs reported by ***, an integrated producer,

are consistently lower than those of ***, a scrap‐based producer, while its average other

factory costs are higher. This pattern is consistent with the lower relative cost of the more basic

raw materials consumed in integrated steel production and the corresponding higher cost to

convert these raw materials into steel. The highest average raw material costs were reported

by *** which do not have upstream steel production and instead purchase semi‐finished slabs

to produce hot‐rolled steel.  

While company‐specific patterns of change in average raw material costs were not

uniform throughout the entire period, table III‐12 shows that most U.S. producers reported

sharp increases in average raw material costs in 2008 compared to 2007 followed by declines in

2009. The average unit value of raw material costs rose steadily from the low point in 2009 to a

high point in 2011 and were slightly lower in full year 2012. Average raw material costs were

lower in January‐June 2013 compared to January‐June 2012.16

After raw materials, the largest component of reported COGS is other factory costs (26.0

percent) followed by direct labor (7.6 percent) on a cumulative basis from 2007 to 2012.

Company‐specific changes in average direct labor and other factory costs were mixed during

the period with some companies reporting their highest average direct labor and other factory

costs in 2008, while others reported the highest average value for these items in 2009. Changes

 

16 Changes in average sales value and average raw material costs generally tracked each other

between 2007 and 2012 and during the interim periods. The year‐to‐year difference in the change of

sales values versus raw material costs indicates whether the metal spread widened or narrowed. For

example, sales values increased by $211 per short ton from 2007 to 2008 while raw material costs

increased by $129 per short ton. Hence, the metal spread increased by $82 per short ton. The metal

spread narrowed by $157 per short ton between 2008 and 2009; widened by $47 and $40 per short ton

between 2009 and 2010 and between 2010 and 2011; narrowed by $19 per short ton between 2011 and

2012; and narrowed when comparing interim 2013 to interim 2012.  
III‐18

in other factory costs were generally inverse to changes in volume produced and sold. 17 As

shown in table III‐12, ***.

Non‐recurring charges

A number of companies included non‐recurring charges in COGS and SG&A expenses.18

These included inventory adjustments, impairment charges to the value of plant and

equipment (including closure charges), pensions, and “idle plant costs.” The amounts reported

by two firms in particular, ***, represent large absolute values and affected financial results on

a company‐specific basis. However, these and other smaller non‐recurring charges included in

COGS and SG&A expenses did not have a substantial impact on the industry’s overall operating

income (loss). With respect to net income, non‐recurring charges (“other expense”) were offset

by non‐recurring income (“other income”) items in most years.19

Profitability

Table III‐11 shows that the industry’s gross profit, on an absolute and relative basis, was

at its highest level in 2008. Notwithstanding variability in average direct labor and other factory

costs, changes in the industry’s gross profit margin primarily reflect the extent to which changes

in average raw material costs were or were not offset by corresponding changes in average

sales value. Operating income rose substantially from 2007 to 2008, was negative in 2009, and

then rose irregularly between 2010 and 2012. Both gross profit and operating income were

much lower in January‐June 2013 than in January‐June 2012. With the exception of 2009 (when

nearly all reporting firms operating at that time reported operating losses), a majority of the

reporting firms were consistently profitable. As shown in table III‐12 and with respect to the

operating results of other reporting producers, *** in each period of 2007‐12, January‐June

2012, and January‐June 2013. ***.20 ***. In contrast,***.21

 

17 All things being equal, given the substantially large declines in company‐specific sales and

production quantity in 2009 compared to 2008, average direct labor and other factory costs would be

expected to reach their highest level in 2009, reflecting much‐reduced fixed cost absorption in 2009.

18 ***. Questionnaire responses of U.S. producers, section III‐9.

19 ***.

20 ThyssenKrupp’s new mill in Calvert, Alabama began operations in 2010, and the firm reported sales

in its fiscal year ending September 2011. ***. Staff notes that under U.S. GAAP startup costs are

expensed immediately and that ***. 21 As may be seen from the data in table III‐11, net income and cash flow (net income plus

depreciation expenses) followed the trend of operating income. The financial services industry uses a

variety of alternative measures of profitability and cash flow. One of these is earnings before interest,

taxes, depreciation and amortization (“EBITDA”). This is usually expressed as a ratio to sales and may be

calculated from III‐11 as operating income plus depreciation (depreciation is typically included as part of

other factory costs and general and administrative expenses). EBITDA is not a measure approved under

GAAP because it omits costs in calculating profitability. EBITDA as a percentage of sales ranged from a

negative 6.0 percent in 2009 (versus the reporting firms’ operating ratio of a negative 10.7 percent) to a

positive 15.3 percent in 2008 (versus a positive 13.3 percent operating margin). Hence, EBITDA is about

2 to 4 percentage points higher than the operating income margin. The consulting group

(continued...)
III‐19

Variance analysis

A variance analysis for the operations of U.S. producers of hot‐rolled steel is presented

in table III‐13.22 The information for this variance analysis is derived from table III‐11. The

variance analysis for the reporting firms together indicates that the decrease in operating

income between 2007 and 2012 was mainly due to the unfavorable net cost/expense (unit

costs increased) variance that was greater than a favorable sales variance (unit sales values

increased). Between other full year periods these variances were mixed—the sales variance

was unfavorable between some years and the net cost/expense variance was favorable

between some years. Operating income was lower in January‐June 2013 than in January‐June

2012 due to an unfavorable price variance that was greater than a favorable net cost/expense

variance. The composition of net operating variance is summarized at the bottom of table III‐

13.  

                                                            

(...continued)

McKinsey&Company conducted and presented to the OECD Steel Committee a study of 84 large steel

firms worldwide. One question was, in the context of global overcapacity, what would be the financial

requirements of restructuring the worldwide steel industry, and particularly, what would be the

industry’s ability to raise finance capital externally. Assuming factors for debt service, cost of equity, and

the like, the McKinsey study concluded that the industry would need a benchmark level of 16 percent

EBITDA to be economically sustainable in the long‐term. However, it indicated that the average EBITDA

of 42 of these 84 firms has been less than the benchmark level during most of 2000‐12 (and before), and

that more than 80 percent of the 42 firms had failed to achieve that level during 2009‐11. The exception

was that between 32 percent and 39 percent of the industry had achieved 17 to 18 percent EBITDA only

in the period 2004‐07 as a result of an immense credit bubble for the global economy. See

McKinsey&Company, “Overcapacities in the steel industry,” OECD Steel Committee 74th session, Paris,

July 2, 2013, p. 14. It should be noted that the McKinsey study was of total operations of steelmakers

worldwide which may not be comparable to an examination of hot‐rolled operations of U.S. producers. 22 The Commission’s variance analysis is calculated in three parts:  Sales variance, cost of sales

variance (COGS variance), and SG&A expense variance. Each part consists of a price variance (in the case

of the sales variance) or a cost or expense variance (in the case of the COGS and SG&A expense

variance), and a volume variance. The sales or cost/expense variance is calculated as the change in unit

price  or per‐unit cost/expense times the new volume, while the volume variance is calculated as the

change in volume times the old unit price or per‐unit cost/expense. Summarized at the bottom of the

table, the price variance is from sales; the cost/expense variance is the sum of those items from COGS

and SG&A variances, respectively, and the volume variance is the sum of the volume components of the

net sales, COGS, and SG&A expense variances. The overall volume component of the variance analysis is

generally small.
III‐20

Table III-13 

Hot-rolled steel: Variance analysis on the financial results operations of U.S. producers (valuation of 

internal consumption and transfers to related firms based on constructed fair market value), fiscal 

years 2007-12, January-June 2012, and January-June 2013 

Item 

Between fiscal years Jan.-June

2007-12 2007-08 2008-09 2009-10 2010-11 2011-12 2012-13

Value ($1,000)

 Commercial sales: 

 Price variance 2,880,920 4,823,150 (3,015,997) 1,071,006 2,496,877 (925,927) (956,516)

 Volume variance (667,693) (1,267,780) (6,506,594) 3,805,115 1,035,138 698,239 (152,159)

 Commercial sales. 2,213,227 3,555,370 (9,522,591) 4,876,121 3,532,015 (227,688) (1,108,675)

 Internal consumption: 

 Price variance 3,585,402 6,351,068 (4,941,112) 2,289,958 2,870,691 (1,227,421) (1,189,693)

 Volume variance (1,297,876) (1,502,669) (6,935,927) 3,785,719 382,313 1,214,906 (371,776)

 Internal consumption 2,287,526 4,848,399 (11,877,039) 6,075,677 3,253,004 (12,515) (1,561,469)

 Transfers: 

 Price variance 172,573 484,367 (265,538) 116,109 183,722 (95,698) (66,603)

 Volume variance (329,371) (122,264) (710,620) 342,545 (23,446) (65,975) (30,362)

 Transfers (156,798) 362,103 (976,158) 458,654 160,276 (161,673) (96,965)

 Total net sales: 

 Price variance 6,636,610 11,657,761 (8,247,095) 3,514,151 5,547,361 (2,256,133) (2,212,682)

 Volume variance (2,292,655) (2,891,889) (14,128,693) 7,896,301 1,397,934 1,854,257 (554,427)

 Total net sales 4,343,955  (22,375,788) 11,410,452 6,945,295 (401,876) (2,767,109)

Cost of sales: 

 Cost variance (6,713,977) (8,665,052) 2,861,534 (51,412) (3,452,873) 1,405,407 1,268,951 

 Volume variance 2,036,031 2,568,192 11,980,244 (8,352,994) (1,313,967) (1,657,025) 489,430 

 Total cost (4,677,946) (6,096,860) 14,841,778 (8,404,406) (4,766,840) (251,618) 1,758,381 

Gross profit variance (333,991) 2,669,012 (7,534,010) 3,006,046 2,178,455 (653,494) (1,008,728)

SG&A expenses: 

 Expense variance (195,705) (80,277) (61,127) 186,011 (160,059) (55,970) 24,679 

 Volume variance 60,221 75,961 295,220 (258,647) (32,252) (44,344) 13,264 

 Total SG&A variance (135,484) (4,316) 234,093 (72,636) (192,311) (100,314) 37,943 

Operating income 

variance (469,475) 2,664,696 (7,299,917) 2,933,410 1,986,144 (753,808) (970,785)

Summarized as: 

 Price variance 6,636,610 11,657,761 (8,247,095) 3,514,151 5,547,361 (2,256,133) (2,212,682)

 Net cost/expense 

 variance (6,909,682) (8,745,329) 2,800,407 134,600 (3,612,932) 1,349,436 1,293,630 

 Net volume variance (196,402) (247,736) (1,853,229) (715,341) 51,715 152,889 (51,732)

Note: Unfavorable variances are shown in parentheses; all others are favorable. The data are comparable to changes in operating

income as presented in table III-10. 

Source: Compiled from data submitted in response to Commission questionnaires. 
III‐21

Capital expenditures and research and development expenses

Table III‐14 presents capital expenditures and research and development (“R&D”)

expenses by firm. Total capital expenditures declined between 2007 and 2008, fell sharply in

2009 but increased through 2011 before declining in 2012. Capital expenditures were lower

during January‐June 2013 than in the same period one year earlier. Capital expenditures ranged

from 28.2 percent in 2008 to a high of 101.8 percent in 2010 (and were a negative 48.9 percent

in 2009) when expressed as a ratio to operating income.23 Four U.S. producers, ***, accounted

for *** percent of the total in 2012. Total R&D expenses ranged from $*** in 2008 to $*** in

2009, and was lower in January‐June 2013 than in the same period one year earlier. R&D

expenses were reported by five firms, but three firms, ***, accounted the majority of R&D

spending.

***.24 *** capital expenditures and its R&D expenses have been focused on three

projects: one is its ***.25 The firm reported that each of the three would improve the firm’s

product mix, process efficiency, and overall competitiveness. CSI stated that it had

commissioned a ***.26 ***, described its capital expenditures as those “to maintain equipment

to sustain current level of operational performance.”27 *** stated that “our capital

expenditures related to the production of hot‐rolled steel are generally associated with

environmental compliance, safety, equipment or facility maintenance, and product quality.”28

*** reported that its spending was in “equal weights between modernization, maintenance,

and environmental.” ***. The capital expenditures reported by *** reflect the construction of

the company’s ***.29 ***, stated that “our capital expenditures are devoted primarily to

maintaining our current facilities and complying with environmental requirements.”

 

23 Calculated by dividing total capital expenditures (shown in table III‐14) by operating income

(shown in table III‐11, earlier).   24 ***.

25 ***.

26 ***.

27 ***.

28 ***.

29 ***.
III‐22

Table III-14 

Hot-rolled steel: Capital expenditures and research and development expenses of U.S. producers, 

by firm, 2007-12, January-June 2012, and January-June 2013

Item 

Fiscal years January-June 

2007 2008 2009 2010 2011 2012 2012 2013 

 Value ($1,000) 

Capital expenditures: 

 Total 1,718,461 1,554,619 871,549 1,170,595 1,418,839 990,601 525,984 275,808 

R&D expenses: 

 Total *** *** *** *** *** *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires. 

Assets and return on investment

Table III‐15 presents data on the U.S. producers’ total assets and their return on

investment (“ROI”). Operating income (table III‐11) was divided by total net assets resulting in

ROI. Total net assets increased by 15.9 percent from 2007 to 2012 and operating income

declined between those years by 16.5 percent. Because the increase in the value of investment

was greater than that of operating income, the ratio declined.

Table III-15 

Hot-rolled steel: U.S. producers’ total assets and return on investment, by firm, fiscal years 2007-12

Item 

Fiscal years 

2007 2008 2009 2010 2011 2012 

 Value ($1,000) 

Total assets

 Total 15,095,419 16,293,667 15,117,181 16,067,891 17,272,013 17,489,045 

Ratio of operating income to assets (percent) 

ROI 

 Average 18.9 33.9 (11.8) 7.2 18.2 13.6 1 Firm reported no data for either or both assets and operating income. Ratio calculated is not meaningful. 

Source: Compiled from data submitted in response to Commission questionnaires. 
  

IV‐1

PART IV: U.S. IMPORTS AND THE FOREIGN INDUSTRIES

U.S. IMPORTS

Overview

The Commission issued questionnaires to 78 firms believed to import hot‐rolled steel

between January 2007 and June 2013. Thirty‐two firms provided data and information in

response to the questionnaires, and 26 firms certified that they had not imported hot‐rolled

steel since January 1, 2007. Based on official Commerce statistics for imports of hot‐rolled steel,

importers’ questionnaire data accounted for approximately two‐thirds of U.S. imports of hot‐

rolled steel during January 2007‐June 2013, although less than one‐quarter of such imports

from subject countries during this period. Firms responding to the Commission’s questionnaire

accounted for the following shares of individual subject country’s subject imports (as a share of

official import statistics) during January 2007‐June 2013:

 no imports from Indonesia (per official import statistics);

 no imports from Ukraine;1

 less 1 percent of the subject imports from China;  

 approximately one‐quarter of the subject imports from Thailand;  

 approximately one‐half of the subject imports from Taiwan; and

 substantially all the subject imports from India.

In light of the data coverage by the Commission’s questionnaires, import data in this

report are based on official Commerce statistics for hot‐rolled steel.2 3  

                                                      

1 One firm, ***, reported imports from Ukraine during 2007‐12, however this firm was not identified

in proprietary Customs data as importer of record of imports from Ukraine. 2 Import data were based on the following HTS statistical reporting numbers:  HTS 7208.10.1500,

7208.10.3000, 7208.10.6000, 7208.25.3000, 7208.25.6000, 7208.26.0030, 7208.26.0060, 7208.27.0030,

7208.27.0060, 7208.36.0030, 7208.36.0060, 7208.37.0030, 7208.37.0060, 7208.38.0015, 7208.38.0030,

7208.38.0090, 7208.39.0015, 7208.39.0030, 7208.39.0090, 7208.40.6030, 7208.40.6060, 7208.53.0000,

7208.54.0000, 7208.90.0000, 7211.14.0090, 7211.19.1500, 7211.19.2000, 7211.19.3000, 7211.19.4500,

7211.19.6000, 7211.19.7530, 7211.19.7560, and 7211.19.7590. Import data do not include the following

HTS statistical reporting numbers that cover primarily coated or other forms of nonsubject merchandise:  

7210.70.3000, 7210.90.9000, 7211.14.0030, 7212.40.1000, 7212.40.5000, and 7212.50.0000. This

approach is consistent with that used in the most recent five‐year review concerning hot‐rolled steel.

Hot‐Rolled Flat‐Rolled Carbon‐Quality Steel Products from Brazil, Japan, and Russia, Investigation Nos.

701‐TA‐384 and 731‐TA‐806‐808 (Second Review), USITC Publication 4237, June 2011, p. IV‐1.

3 Data do not include minor volumes of micro‐alloy steel (estimated to account for less than 5

percent of U.S. hot‐rolled steel imports). See Hot‐Rolled Flat‐Rolled Carbon‐Quality Steel Products from

Brazil, Japan, and Russia, Investigation Nos. 701‐TA‐384 and 731‐TA‐806‐808 (Second Review), USITC

Publication 4237, June 2011, p. IV‐1.
  

IV‐2

No importers reported entering or withdrawing hot‐rolled steel from foreign trade

zones or bonded warehouses or importing under the temporary importation under bond

program.

Imports from subject and nonsubject countries

Table IV‐1 presents information on U.S. imports of hot‐rolled steel from each subject

country and all other sources in 2007‐12, January‐June 2012, and January‐June 2013. The

combined quantity of imports from subject imports experienced relatively wide fluctuations

from 2007 to 2012, with aggregate subject imports declining to only 254 short tons in 2009.

Imports from India accounted for the majority of imports from subject countries in 2007. 4

Imports from China and Taiwan were present in each period. Imports from India and Thailand

were only present in 2007‐08 and imports from Ukraine were only present in 2008 and 2012.

There were no imports from Indonesia between January 2007 and June 2013.  

The share of U.S. imports from subject countries, by quantity, did not exceed 0.6

percent during 2007‐12, January‐June 2012, and January‐June 2013, and the ratio to U.S.

production of hot‐rolled steel did not even reach 0.1 percent over the same period. Imports of

hot‐rolled steel from nonsubject countries, which accounted for virtually all U.S. imports of hot‐

rolled steel, ranged between 5.5 percent and 6.7 percent as a ratio to U.S. production. Imports

from nonsubject countries declined in 2009, consistent with the lower demand during the

general decline in the U.S. economy, as described further in Part II of this report. Imports from

nonsubject countries increased in each subsequent calendar year and were 14 percent higher in

2012 than in 2007. However, imports from nonsubject countries were lower in January‐June

2013 compared to January‐June 2012.

                                                      

4 Staff adjusted imports from India to reflect non‐hot‐rolled steel imports. *** which ***.
  

IV‐3

Table IV-1 

Hot-rolled steel: U.S. imports by source, 2007-12, January-June 2012, and January-June 2013

Item Calendar year January-June

2007 2008 2009 2010 2011 2012 2012 2013

Quantity (short tons)

China 1,093 247 159 1,631 541 2,419 1,763 1,481

India 17,665 185 0 0 0 0 0 0

Indonesia 0 0 0 0 0 0 0 0

Taiwan 241 655 95 45 2,483 560 492 26

Thailand 2,171 5,632 0 0 0 0 0 0

Ukraine 0 19 0 0 0 806 0 0

 Subtotal, subject 21,169 6,739 254 1,676 3,024 3,784 2,256 1,507

All others 3,327,507 3,618,209 2,273,854 3,035,620 3,535,471 3,806,535 1,947,026 1,688,597

 Total U.S. imports 3,348,676 3,624,948 2,274,108 3,037,296 3,538,495 3,810,320 1,949,281 1,690,104

 Value (1,000 dollars)

1

China 732 222 172 1,469 649 3,027 2,040 1,683

India 10,464 291 0 0 0 0 0 0

Indonesia 0 0 0 0 0 0 0 0

Taiwan 142 484 101 39 1,976 414 358 19

Thailand 1,075 4,685 0 0 0 0 0 0

Ukraine 0 44 0 0 0 624 0 0

 Subtotal, subject 12,413 5,726 274 1,508 2,625 4,064 2,398 1,702

All others 1,819,256 2,880,457 1,215,906 1,867,911 2,578,646 2,598,160 1,372,570 1,145,933

 Total U.S. imports 1,831,669 2,886,183 1,216,179 1,869,419 2,581,271 2,602,224 1,374,968 1,147,635

 Unit value (dollars per short ton)

China 670 897 1,085 900 1,200 1,251 1,157 1,136

India 592 1,571 -- -- -- -- -- --

Indonesia --- --- --- --- --- --- --- ---

Taiwan 590 739 1,065 877 796 739 728 726

Thailand 495 832 --- --- --- --- --- ---

Ukraine --- 2,316 --- --- --- 774 --- ---

 Average, subject 586 850 1,078 900 868 1,074 1,063 1,129

All others 547 796 535 615 729 683 705 679

 Average, total imports 547 796 535 615 729 683 705 679

 Share of quantity (percent)

China (

2

) (

2

) (

2

) 0.1 (

2

) 0.1 0.1 0.1

India 0.5 (

2

) 0.0 0.0 0.0 0.0 0.0 0.0

Indonesia 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Taiwan (

2

) (

2

) (

2

) (

2

) 0.1 (

2

) (

2

) (

2

)

Thailand 0.1 0.2 0.0 0.0 0.0 0.0 0.0 0.0

Ukraine 0.0 (

2

) 0.0 0.0 0.0 (

2

) 0.0 0.0

 Subtotal, subject 0.6 0.2 (

2

) 0.1 0.1 0.1 0.1 0.1

All others 99.4 99.8 100.0 99.9 99.9 99.9 99.9 99.9

 Total U.S. imports 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0

Table continued on next page.
  

IV‐4

Table IV-1 --Continued

Hot-rolled steel: U.S. imports by source, 2007-12, January-June 2012, and January-June 2013

Item Calendar year January-June

2007 2008 2009 2010 2011 2012 2012 2013

 Share of value (percent)

China (

2

) (

2

) (

2

) 0.1 (

2

) 0.1 0.1 0.1 

India 0.6 (

2

) 0.0 0.0 0.0 0.0 0.0 0.0 

Indonesia 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Taiwan (

2

) (

2

) (

2

) (

2

) 0.1 (

2

) (

2

) (

2

) 

Thailand 0.1 0.2 0.0 0.0 0.0 0.0 0.0 0.0 

Ukraine 0.0 (

2

) 0.0 0.0 0.0 (

2

) 0.0 0.0 

 Subtotal, subject 0.7 0.2 (

2

) 0.1 0.1 0.2 0.2 0.1 

All others 99.3 99.8 100.0 99.9 99.9 99.8 99.8 99.9 

 Total U.S. imports 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

 Ratio of imports to U.S. production (percent) 

China (

2

) (

2

) (

2

) (

2

) (

2

) (

2

) (

2

) (

2

) 

India (

2

) (

2

) 0.0 0.0 (

2

) 0.0 0.0 (

2

) 

Indonesia 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Taiwan (

2

) (

2

) (

2

) (

2

) (

2

) (

2

) (

2

) (

2

) 

Thailand (

2

) (

2

) 0.0 0.0 0.0 0.0 0.0 0.0 

Ukraine 0.0 (

2

) 0.0 0.0 0.0 (

2

) 0.0 0.0 

 Subtotal, subject (

2

) (

2

) (

2

) (

2

) (

2

) (

2

) (

2

) (

2

) 

All others 5.5 6.7 6.1 5.9 6.5 6.7 6.6 5.9 

 Total U.S. imports 5.5 6.7 6.1 5.9 6.5 6.7 6.6 5.9 1

 Landed, duty-paid. 

2

 Less than 0.05. 

Note.—***, which ***. 

Source: Compiled from official import statistics (imports) and data submitted in response to Commission 

questionnaires (U.S. production). 
  

IV‐5

Leading nonsubject sources of imports

During 2007‐12, January‐June 2012, and January‐June 2013, imports of hot‐rolled steel

entered the United States from a variety of sources other than the subject countries. The

leading nonsubject suppliers are shown in table IV‐2. The leading nonsubject sources were

Canada,5 followed by Korea.6 These two countries combined accounted for 53.4–60.4 percent

of imports of hot‐rolled steel from nonsubject sources between January 2007 and June 2013.7

  

Between 2011 and 2012, on a percentage basis, among the largest increases in U.S. imports of

hot‐rolled steel was from Japan, while among the largest declines was U.S. imports from

Australia. In August 2011, BlueScope Steel announced major restructuring of its Australian

operations including exiting the Australian export business.8 9 U.S. importer *** reported that

***.10 In 2013 Nippon Steel & Sumitomo Metals Corporation, which is headquartered in Japan,

entered a joint‐venture with BlueScope Steel which included BlueScope’s U.S. subsidiary

Steelscape, located in Rancho Cucamonga, California.11  

                                                      

5 According to proprietary Customs data, the largest importer of hot‐rolled steel from Canada was

***, accounting for approximately *** percent of total imports during 2007‐12 (ranging from low of ***

percent in 2007 to a high of *** percent in 2010). U.S. producers accounted for approximately ***

percent of hot‐rolled steel imported from Canada during 2007‐12 (ranging from low of *** percent in

2010 to high of *** percent in 2008).

6 *** accounted for approximately *** percent of total imports of hot‐rolled steel from Korea during

2007‐12 (ranging from low of *** percent in 2011 to a high of *** percent in 2007). The second largest

importer of hot‐rolled steel from Korea was ***, accounting for approximately *** percent of total

imports during 2007‐12. 7 These two countries were also the leading nonsubject sources in 2012, accounting for 32.6 percent

and 23.4 percent of total imports of hot‐rolled steel from nonsubject sources, respectively.

8 “BlueScope announces major restructure to Australian operations and reinforces commitment to

steel production in Australia,” BlueScope press release, August 22, 2011, found at

http://clients.weblink.com.au/clients/BlueScopeSteel2/article.asp?view=3359409.   9 BlueScope has several subsidiaries in the United States. See:

http://www.bluescopesteel.com/about‐us/where‐we‐are?country=USA&officetype=All   10 Email from ***, November 6, 2013. 11 “Welcome to Steelscape,” Steelscape website, found at http://www.steelscape.com/, and

“BlueScope FY2012 Financial Results Presentation,” p. 19, August 20, 2012, found at

http://www.bluescopesteel.com/media/29371/fy2012‐results‐presentation.pdf  
  

IV‐6

Table IV-2 

Hot-rolled steel: U.S. imports from leading nonsubject sources, 2007-12, January-June 2012, and 

January-June 2013

Item Calendar year January-June 

2007 2008 2009 2010 2011 2012 2012 2013 

 Quantity (short tons) 

Canada 1,360,068 1,453,945 915,378 1,136,378 1,305,102 1,241,558 677,671 621,547

Korea 601,910 708,491 457,915 503,680 727,265 889,349 435,798 280,684

Mexico 245,235 179,695 276,287 294,380 373,989 367,561 148,407 191,210

Russia 136,294 76,426 1,708 125,081 181,689 288,873 267,105 26,673

Netherlands 234,645 227,027 183,249 196,562 233,235 282,516 113,126 108,991

Japan 15,504 15,577 9,053 15,033 25,947 202,416 130,820 132,643

Australia 394,403 580,420 234,667 456,590 470,741 194,070 52,340 75,188

Germany 31,331 49,786 15,436 91,088 30,765 129,029 10,059 64,997

New Zealand 119,260 66,825 44,650 87,499 118,479 98,331 51,844 58,513

France 80,380 56,989 41,398 50,369 22,485 33,308 16,239 30,780

Belgium 12,348 17,297 21,133 19,339 8,817 26,370 7,691 7,407

Italy 279 40 44 208 13 19,575 19,438 110

Turkey 997 182,031 25,090 2,162 6,802 15,044 13,186 35,520

Brazil 50 46 148 512 3,503 9,736 870 42,334

 Subtotal 3,232,704 3,614,596 2,226,157 2,978,880 3,508,830 3,797,737 1,944,594 1,676,595

All others 94,803 3,613 47,697 56,739 26,641 8,798 2,431 12,001

 Total 3,327,507 3,618,209 2,273,854 3,035,620 3,535,471 3,806,535 1,947,026 1,688,597

 Value (1,000 dollars)

1

Canada 784,642 1,149,319 485,421 723,575 975,370 887,143 503,842 395,670

Korea 288,386 484,208 275,797 293,918 521,798 607,939 308,220 279,121

Mexico 131,536 138,748 128,700 181,595 268,827 231,287 101,233 113,059

Russia 69,061 72,989 1,751 69,708 134,668 188,493 174,846 14,624

Netherlands 127,467 157,925 86,662 117,127 173,020 184,209 76,862 63,204

Japan 10,263 13,666 10,897 14,636 21,133 133,208 86,579 79,488

Australia 205,815 460,803 115,540 264,133 322,492 113,367 32,904 42,830

Germany 18,710 36,980 8,665 60,869 25,118 106,434 8,005 46,209

New Zealand 67,876 50,613 21,322 53,409 85,985 66,651 36,706 36,217

France 50,031 43,206 22,907 31,150 17,539 25,144 12,528 19,653

Belgium 7,884 11,054 10,502 11,640 6,853 18,019 5,870 4,608

Italy 234 43 29 561 15 14,110 13,859 188

Turkey 588 258,317 10,864 1,525 5,222 10,102 8,696 20,836

Brazil 37 48 128 402 3,485 6,033 592 23,131

 Subtotal 1,762,532 2,877,918 1,179,184 1,824,247 2,561,528 2,592,139 1,370,744 1,138,838

All others 56,725 2,539 36,721 43,664 17,118 6,021 1,826 7,095

 Total 1,819,256 2,880,457 1,215,906 1,867,911 2,578,646 2,598,160 1,372,570 1,145,933

Table continued on next page. 

   
  

IV‐7

Table IV-2--Continued

Hot-rolled steel: U.S. imports from leading nonsubject sources, 2007-12, January-June 2012, and 

January-June 2013

Item Calendar year January-June 

2007 2008 2009 2010 2011 2012 2012 2013 

Unit value (dollars per short ton) 

Canada 577 790 530 637 747 715 743 637

Korea 479 683 602 584 717 684 707 994

Mexico 536 772 466 617 719 629 682 591

Russia 507 955 1,025 557 741 653 655 548

Netherlands 543 696 473 596 742 652 679 580

Japan 662 877 1,204 974 814 658 662 599

Australia 522 794 492 578 685 584 629 570

Germany 597 743 561 668 816 825 796 711

New Zealand 569 757 478 610 726 678 708 619

France 622 758 553 618 780 755 771 638

Belgium 639 639 497 602 777 683 763 622

Italy 839 1,064 675 2,699 1,190 721 713 1,714

Turkey 590 1,419 433 705 768 671 659 587

Brazil 733 1,047 863 785 995 620 681 546

 Average, subtotal 545 796 530 612 730 683 705 679

All others 598 703 770 770 643 684 751 591

 Average 547 796 535 615 729 683 705 679 1

 Landed, duty-paid. 

Note.--Due to rounding, figures may not add to the totals shown. 

Source: Compiled from official Commerce statistics. 

U.S. IMPORTERS’ IMPORTS SUBSEQUENT TO JUNE 30, 2013

The Commission requested importers to indicate whether they had imported or

arranged for the importation of hot‐rolled steel from subject for delivery after June 30, 2013.

Data on the actual and arranged imports of the fourteen responding importers are presented in

table IV‐3. One firm (***) reported arranged imports from a subject country, namely ***, while

three firms (***) accounted for the majority of the arranged imports from nonsubject

countries.  

Table IV-3 

Hot-rolled steel: U.S. importers’ orders for subsequent to June 30, 2013

* * * * * * * 

U.S. IMPORTERS’ INVENTORIES

Table IV‐4 presents data for inventories of U.S. imports of hot‐rolled steel from subject

countries and all other sources held in the United States. No importers reported inventories of

imports from subject countries, while 12 importers maintained inventories of imports from
  

IV‐8

nonsubject sources. Three importers (***) accounted for the majority of these inventories.***

accounted for *** of total reported hot‐rolled steel imports from nonsubject sources during

2007‐12. ***. ***.12 For example, ***.13

Table IV-4 

Hot-rolled steel: U.S. importers’ end-of-period inventories of imports, by source, 2007-12, JanuaryJune 2012, and January-June 2013

Calendar year January-June

Item 2007 2008 2009 2010 2011 2012 2012 2013

Imports from subject sources 

 Inventories (short tons) 0 0 0 0 0 0 0 0

 Ratio to U.S. imports (percent) --- --- --- --- --- --- --- ---

 Ratio to total shipments of imports 

(percent) 

--- --- --- --- --- --- --- ---

Imports from all other sources 

 Inventories (short tons) 104,415 196,483 93,521 150,875 116,182 122,657 72,917 111,535

 Ratio to U.S. imports (percent) 5.2 9.0 6.5 7.6 5.0 5.2 3.2 4.8

 Ratio to total shipments of imports 

(percent) 

5.0 9.4 6.1 7.8 4.9 5.0 3.1 4.7

Imports from all sources 

 Inventories (short tons) 104,415 196,483 93,521 150,875 116,182 122,657 72,917 111,535

 Ratio to U.S. imports (percent) 5.1 9.0 6.5 7.6 4.9 5.2 3.1 4.8

 Ratio to total shipments of imports 

(percent) 

4.9 9.4 6.1 7.8 4.9 5.0 3.1 4.7

Source: Compiled from data submitted in response to Commission questionnaires.

CUMULATION CONSIDERATIONS

In assessing whether imports should be cumulated, the Commission determines

whether U.S. imports from the subject countries would be likely to compete with each other

and with the domestic like product and has generally considered four factors, among others: (1)

fungibility, (2) presence of sales or offers to sell in the same geographical markets, (3) common

or similar channels of distribution, and (4) simultaneous presence in the market. Channels of

distribution and fungibility (interchangeability) are discussed in Part II of this report. Additional

information concerning geographical markets and simultaneous presence in the market is

presented below. For the purposes of its original determinations and first five‐year review

determinations, the Commission cumulated imports from China, India, Indonesia, Taiwan,

Thailand, and Ukraine.14

                                                      

12 U.S. Steel stated that it does not control where USS‐Posco gets its inputs, such as hot‐rolled steel.

Hearing transcript, p. 133 (Lighthizer).

13 Email from ***, August 12, 2013. 14 Hot‐Rolled Steel Products From China, India, Indonesia, Kazakhstan, The Netherlands, Romania,

South Africa, Taiwan, Thailand, and Ukraine:  Investigations Nos. 701‐TA‐405‐408 (Final) and

Investigations Nos. 731‐TA‐899‐904 and 906‐908 (Final), USITC Publication 3468, November 2001, p. 3,

and Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South

(continued...)
  

IV‐9

Domestic interested parties contend that that all countries should be cumulated.15 They

argue that the statutory prerequisites for cumulation are met, namely that subject imports

from each country are likely to have a discernible adverse impact on the U.S. market and

subject imports would be likely to compete with one another and the domestic like product.

Moreover, domestic interested parties note that given the unused capacity at each of the

subject countries, they could capture U.S. market share far surpassing the low discernible

adverse impact threshold, and each respondent claims the same competitive behavior for

unique market conditions but rather all six countries operate under similar conditions of

competition. In addition, they contend that no respondent has demonstrated how imports

from its country would not compete with other subject imports and as a result cause collective

harm to the domestic U.S. industry.

Indian respondents contend that subject imports from India should not be cumulated

with imports from other subject countries since imports from India are likely to remain low in

the event the orders on India are revoked and these imports will not have any adverse impact

on the domestic industry. Indian respondents argue that given the strong demand for hot‐rolled

steel in India, which is expected to continue into the foreseeable future, the fact that India is a

net importer of hot‐rolled steel, and that prices of hot‐rolled steel are higher in India than in

the United States, it is unlikely that imports of hot‐rolled steel from India will increase

significantly.16

Taiwan respondents argue that imports from Taiwan should not be cumulated as these

imports are likely to compete in the U.S. market under different conditions of competition.

Specifically, the industry in Taiwan markets hot‐rolled steel almost exclusively to home or Asian

markets where demand is strong and growing, Taiwan mills internally consume approximately

half of hot‐rolled steel production for downstream products, the Taiwan industry operates

close to effective full capacity, pricing patterns were significantly different from other subject

countries in the Commission’s previous proceeding, and the industry in Taiwan shipped no

subject merchandise to the United States during the period of review and is expected to

continue this pattern.17

Thai respondents contend that imports from Thailand should not be cumulated with

other subject countries as imports from Thailand have no discernible adverse impact and

compete under unique conditions of competition. Thai respondents note that U.S. imports from

Thailand have remained at very low levels since before imposition of the orders, never

accounting for more than 0.3 percent of U.S. consumption, even during the period when

                                                            

(...continued)

Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐

908 (Review), USITC Publication 3956, October 2007, p. 20.

15 Domestic interested party U.S. Steel’s posthearing brief, p. 10; Domestic interested party

ArcelorMittal USA’s prehearing brief, p. 5; Domestic interested party Nucor’s prehearing brief, p. 8;

Domestic interested parties SDI, Gallatin, SSAB’s prehearing brief, p. 2, and hearing transcript, p. 33

(Price).

16 Respondent interested parties Essar and JSW’s posthearing brief, pp. 7‐13. 17 Respondent interested party Shang Chen Steel’s posthearing brief, pp. 7‐11 and hearing transcript,

pp. 221‐224 (Waite).
  

IV‐10

Thailand’s largest producer was not subject to the antidumping duty order. Thai respondents

also contend that Thai producers are almost exclusively focused on the home market, Thailand

is a net importer of hot‐rolled steel, Thailand has imposed trade remedy protection against

dumped hot‐rolled steel imports in its home market, and the largest Thai producer, SSI, has

recently acquired a slab producer to enable it to supply the growing auto industry in Thailand.18

Geographical markets

As previously noted, hot‐rolled steel produced in the United States is shipped

nationwide. During January 2007‐June 2013, the top Customs districts for imports were as

follows:  

 China: Houston‐Galveston, Texas and New Orleans, Louisiana;

 India: Houston‐Galveston, Texas;

 Taiwan: Houston‐Galveston, Texas, Los Angeles, California, and U.S. Virgin Islands;  

 Thailand: Houston‐Galveston, Texas; and  

 Ukraine: Laredo, Texas.

Presence in the market

Table IV‐5 presents data on the monthly entries of U.S. imports of hot‐rolled steel, by

source, during January 2007‐June 2013. While imports from any subject source were not

present in all months of any year during January 2007‐June 2013, imports from China and

Taiwan were present in at least two months in each full year, imports from India and Thailand

were present in 2007 and 2008, imports from Ukraine in 2008 and 2012, and imports from

Indonesia were not present at any time during January 2007‐June 2013. Imports from

nonsubject sources were present in every month during January 2007‐June 2013.

Table IV-5 

Hot-rolled steel: U.S. imports, monthly entries into the United States, by sources, January 2007-

June 2013

Item 2007 2008 2009 2010 2011 2012 Jan-Jun 2013

China 9 8 5 7 7 11 5 

India 4 2 0 0 0 0 0 

Indonesia 0 0 0 0 0 0 0 

Taiwan 2 2 4 2 5 4 1 

Thailand 2 2 0 0 0 0 0 

Ukraine 0 3 0 0 0 2 0 

All others 12 12 12 12 12 12 6 

Staff adjusted 2009-June 2013 imports from India to reflect non-hot-rolled steel imports. *** which ***. 

Source: Compiled from official import statistics. 

                                                      

18 Respondent interested party SSI’s posthearing brief, pp. 2‐11 and hearing transcript, pp. 202‐206

(LaFrankie).
  

IV‐11

THE SUBJECT FOREIGN INDUSTRIES

Table IV‐6 presents capacity, production, exports, and trade remedy data, for each

subject country for 2012.

Table IV-6 

Hot-rolled steel: Comparison of capacity, production, net capacity changes, exports, net exports, 

and trade remedies, in subject countries, 2012

1

 China export data include exports of hot-rolled carbon and alloy steel (discussed further later in this report). 

Note.--Net export data include exports of carbon and alloy steel. Staff telephone interview with ***. 

Source: Published from *** and Global Trade Atlas; reported from data submitted in response to Commission 

questionnaires; and trade remedy measures from data submitted in response to Commission questionnaires and 

responses to notice of institution. 

Capacity Production Net capacity change (2009-12) 

Item Published Reported Published Reported Published Reported 

Quantity (1,000 short tons) 

China1 *** *** *** *** *** ***

India *** *** *** *** *** ***

Indonesia *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Thailand *** *** *** *** *** ***

Ukraine *** *** *** *** *** ***

 Total *** *** *** *** *** ***

Exports Net exports Trade remedy measures 

Published Reported Published (number) 

Quantity (1,000 short tons) 

China1 10,684 *** *** 5

India 1,758 *** *** 4

Indonesia 19 *** *** 1

Taiwan 3,393 *** *** 4

Thailand 27 *** *** 2

Ukraine 3,023 *** *** 2

 Total 18,904 *** ***
  

IV‐12

THE INDUSTRY IN CHINA

Overview

The following five Chinese producers of the subject merchandise provided the

Commission with information on their hot‐rolled steel operations in China in the original

investigations: Angang Group International Trade Corp. (“Angang”); Shanghai Baosteel Group

Corp. (“Shanghai Baosteel”); Benxi Iron and Steel Group Co.(“Benxi”); Pangang Group

International Economic & Trading Corp. (“Pangang”); and International Economic & Trading

Corp. Wugang Group (“Wugang”). These five firms accounted for 75.7 percent of U.S. imports

of the Chinese subject merchandise during 2000.19 Shanghai Baosteel, the largest of the

responding Chinese producers at that time, accounted for *** percent of total reported

Chinese production of hot‐rolled steel products during 2000.20

In the first reviews, the domestic interested parties indicated that there are about 35

producers of hot‐rolled steel in China, with the largest five producers (i.e., Anshan Iron and

Steel Group Corp. (“Anshan”), Baoshan Iron and Steel Co., Benxi, Tangshan Iron and Steel, and

Wuhan Iron and Steel Co. (“Wuhan”)) representing slightly more than one‐half of the total

capacity to produce hot‐rolled steel in China. Data on hot‐rolled operations were provided by

eight Chinese producers: Anshan; Baosteel Iron & Steel Co. (“Baosteel”); Benxi; Jiangsu Shagang

Group Co., Ltd. (“Jiangsu Shagang”); Maanshan Iron & Steel Co. Ltd. (“Maanshan”); Panzhihua

Iron & Steel (Group) Co. (“Panzhihua”); Taiyuan Iron & Steel (Group) Co. Ltd. (“Taiyuan”); and

Wuhan. These firms represented between one‐quarter and one‐half of total production of hot‐

rolled steel in China during 2006. The largest responding Chinese hot‐rolled steel producer,

Baosteel, alone accounted for an estimated *** percent of total production of hot‐rolled steel

in China during 2006.21

In the current reviews, domestic parties identified more than 160 Chinese

producers/exporters of hot‐rolled steel and respondent parties identified nine Chinese

producers/exporters. No Chinese producers/exporters of hot‐rolled steel provided a response

to the Commission’s questionnaire. Exports of hot‐rolled steel from China were subject to tariff

or non‐tariff barriers to trade in countries other than the United States, as presented the

following tabulation:22

                                                      

19 Hot‐Rolled Steel Products from Argentina and South Africa:  Investigation No. 701‐TA‐404 (Final)

and Investigations Nos. 731‐TA‐898 and 905 (Final), USITC Publication 3446, p. VII‐2.

20 Hot‐Rolled Steel Products from Argentina, China, India, Indonesia, Kazakhstan, Netherlands,

Romania, South Africa, Taiwan, Thailand, and Ukraine, Investigations Nos. 701‐TA‐404‐408 (Final) and

731‐TA‐898‐908 (Final), INV‐Y‐141, August 6, 2001, p. VII‐3. 21 Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐

908 (Review), USITC Publication 3956, October 2007, pp. IV‐21‐22. 22 Domestic parties’ response to the notice of institution. Information compiled from the WTO’s

semiannual “Definitive Anti Dumping Measures,” for the reporting countries noted in the tabulation and

(continued...)
  

IV‐13

Product Country 

Year 

imposed Barrier (rate) 

Hot-rolled steel in coils and 

cut-to-length, nonalloy and 

alloy steel Canada 2001 Antidumping: 77.0 percent 

Hot-rolled steel in coils, 

nonalloy steel Indonesia 2008 Antidumping: 0.0-42.58 percent 

Hot rolled steel alloyed with 

boron in coils and cut-to-length 

Thailand 

2012 Antidumping: 14.28 –19.47 percent 

Hot-rolled steel in coils and 

cut-to-length, nonalloy steel 2011 Antidumping: 30.91 percent 

Hot-rolled flat steel products 

with certain amounts of 

alloying elements 

2013 Definitive safeguard duty: 

September 15, 2013 – February 26, 2014: 

44.20 percent; 

February 27, 2014 – February 26, 2015: 

43.57 percent; 

February 27, 2015 – February 26, 2016: 

42.95 percent 

Table IV‐7 presents data on China’s capacity, production, exports, and net exports for

2009‐12 and China’s top export markets for hot‐rolled carbon and alloy steel are presented in

table IV‐8.23

                                                            

(...continued)

Canadian Border Services Agency, “Measures in Force Goods subject to anti‐dumping or countervailing

duties,” updated November 21, 2013.

23 Data compiled by *** suggest that that while hot‐rolled sheet consumption in China slightly

exceeds hot‐rolled sheet production, coiled plate consumption is far less than coiled plate production

(suggesting net exports of *** short tons in 2012). ***. Moreover, published descriptions of exports of

Chinese hot‐rolled coil (sometimes abbreviated “HRC”) include terms such as “commercial‐grade, boron‐

containing HRC,” suggesting that some volume of hot‐rolled steel exports with elevated boron levels

(possibly within “micro‐alloy” levels specified in the scope of the current reviews) might be classified for

export purposes as alloy steel product rather than carbon (or carbon‐equivalent) steel product.  See

“Chinese HRC exports slow on uncompetitive offers” in Metal Bulletin, November 26, 2012. As shown in

the table below, exports of hot‐rolled alloy steel, including boron‐containing hot‐rolled steel, increased

greater than three‐fold in 2011 compared with 2010.

Quantity (short tons)

Item 2007   2008   2009 2010 2011 2012  

Total 787,268 4,029,060 1,216,596 2,928,273 8,953,998 10,500,275

Source: Global Trade Atlas (HTS: 7225.30, 7225.40, 7225.99, 7226.91, and 7226.99).
  

IV‐14

Table IV-7 

Hot-rolled steel: Chinese capacity, production, exports, and net exports, 2009-12

 2009 2010 2011 2012 

Item Quantity (1,000 short tons) 

Capacity *** *** *** ***

Production *** *** *** ***

Exports1 4,874 11,392 9,432 10,684

Net exports *** *** *** ***

1

 China export data include exports of hot-rolled carbon and alloy steel. 

Source: *** and Global Trade Atlas. 

Table IV-8 

Hot-rolled steel: Chinese exports of hot-rolled carbon and alloy steel, by market, 2007-12 

 Quantity (short tons)

Item 2007 2008 2009 2010 2011 2012

Korea 4,562,602 5,298,601 1,870,299 3,158,272 3,461,263 3,480,943 

Vietnam 1,470,863 1,042,818 675,495 1,440,837 937,474 1,276,477 

India 1,402,061 1,021,245 610,993 2,277,388 874,723 867,240 

Thailand 196,133 281,854 105,038 158,806 322,637 760,121 

Philippines 115,492 75,186 60,928 203,291 294,709 424,318 

Singapore 328,529 172,190 50,656 134,110 383,407 415,027 

Peru 60,252 125,003 7,232 171,275 141,233 237,535 

Chile 24,010 25,970 2,113 172,467 113,633 231,160 

Spain 417,148 312,624 39,635 217,857 146,931 193,155 

United Arab 

Emirates 302,198 394,308 157,622 236,512 306,355 180,409 

Pakistan 109,947 47,352 15,301 142,712 57,486 174,017 

Taiwan 210,731 194,296 71,396 183,566 200,229 166,599 

Saudi Arabia 185,673 235,906 45,940 106,481 110,196 164,820 

Japan 271,531 262,078 68,558 222,312 201,063 161,115 

Portugal 46,589 61,593 37,744 110,310 55,993 155,388 

Mexico 10,222 40,616 166 9,380 54,961 140,646 

Italy 1,103,983 1,508,533 138,245 767,172 199,705 138,146 

Malaysia 66,555 68,517 17,461 126,710 69,930 136,660 

Indonesia 351,835 107,421 43,489 50,271 89,475 123,880 

Belgium 442,079 496,982 52,262 187,278 205,883 123,212 

All others 1,126,156 1,480,350 803,017 1,314,776 1,205,059 1,133,288 

 Total 12,804,588 13,253,442 4,873,589 11,391,783 9,432,346 10,684,157 

Table continued on next page. 

   
  

IV‐15

Table IV-8--Continued

Hot-rolled steel: Chinese exports of hot-rolled carbon and alloy steel, by market, 2007-12

Item 

Value (1,000 dollars)

2007 2008 2009 2010 2011 2012

Korea 2,189,529 4,020,612 896,037 1,710,805 2,184,990 1,897,613 

Vietnam 686,833 661,066 299,225 779,287 600,431 689,432 

India 718,121 922,163 293,720 1,211,922 569,525 481,737 

Thailand 84,280 223,033 52,686 90,921 204,659 408,308 

Philippines 55,818 59,924 27,972 106,350 187,476 237,431 

Singapore 167,639 134,322 27,180 75,431 247,685 234,263 

Peru 29,669 99,382 3,387 93,263 87,162 130,946 

Chile 12,558 22,629 1,210 100,704 74,614 125,178 

Spain 207,729 268,145 19,025 123,250 99,498 106,199 

United Arab 

Emirates 144,774 320,340 75,426 126,212 196,927 98,992 

Pakistan 55,715 40,791 8,807 77,642 38,513 96,092 

Taiwan 99,210 151,416 35,077 111,330 141,308 101,456 

Saudi Arabia 91,995 194,257 22,145 58,069 70,025 90,617 

Japan 130,851 209,676 35,519 130,041 139,799 94,915 

Portugal 23,064 53,575 16,188 63,521 37,406 82,829 

Mexico 4,942 39,798 223 5,817 37,122 78,707 

Italy 535,334 1,263,142 68,624 427,227 132,892 86,526 

Malaysia 35,215 53,383 9,473 70,059 49,334 77,491 

Indonesia 161,939 82,509 24,203 29,719 60,425 70,493 

Belgium 218,971 440,254 30,723 106,064 151,184 78,775 

All others 603,027 1,283,811 472,610 810,352 893,255 733,914 

 Total 6,257,210 10,544,226 2,419,461 6,307,986 6,204,229 6,001,917 

Korea 480 759 479 542 631 545 

Vietnam 467 634 443 541 640 540 

India 512 903 481 532 651 555 

Thailand 430 791 502 573 634 537 

Philippines 483 797 459 523 636 560 

Singapore 510 780 537 562 646 564 

Peru 492 795 468 545 617 551 

Chile 523 871 573 584 657 542 

Spain 498 858 480 566 677 550 

United Arab 

Emirates 479 812 479 534 643 549 

Pakistan 507 861 576 544 670 552 

Taiwan 471 779 491 606 706 609 

Saudi Arabia 495 823 482 545 635 550 

Japan 482 800 518 585 695 589 

Portugal 495 870 429 576 668 533 

Mexico 484 980 1,347 620 675 560 

Italy 485 837 496 557 665 626 

Malaysia 529 779 543 553 705 567 

Indonesia 460 768 557 591 675 569 

Belgium 495 886 588 566 734 639 

All others 535 867 589 616 741 648 

 Average 489 796 496 554 658 562 

Note.--Data include exports of hot-rolled carbon and alloy steel. 

Source: Global Trade Atlas (HTS 7208.10, 7208.25, 7208.26, 7208.27, 7208.36, 7208.37, 7208.38, 208.39, 7208.40, 

7208.53, 7208.54, 7208.90, 7211.14, 7211.19, 7225.30, 7225.40, 7225.99, 7226.91, and 7226.99).
  

IV‐16

THE INDUSTRY IN INDIA

Overview

Four firms responded to the Commission’s questionnaire in the original investigations:  

Ispat Industries, Ltd. (“Ispat”); Essar Steel, Ltd. (“Essar”); Steel Authority of India, Ltd. (“SAIL”);

and Tata Iron and Steel Co., Ltd. (“Tata”). The four responding firms accounted for 79.1 percent

of U.S. imports of the subject merchandise during 2000.24 In the first review, two producers in

India, JSW Steel Ltd. (“JSW”) and Tata, provided useable data, and another, Essar provided a

response but with little useable data.25 Finally, in these current reviews, two producers in India,

Essar and JSW, provided data in response to the Commissions questionnaires. Essar and JSW

estimated that they accounted for *** and *** percent, respectively, of hot‐rolled steel

production in India in 2012.26  

Exports of hot‐rolled steel from India were subject to tariff or non‐tariff barriers to trade

in countries other than the United States, as presented the following tabulation:27

   

                                                      

24 Hot‐Rolled Steel Products from Argentina and South Africa:  Investigation No. 701‐TA‐404 (Final)

and Investigations Nos. 731‐TA‐898 and 905 (Final), USITC Publication 3446, p. VII‐2.

25 Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐

908 (Review), USITC Publication 3956, October 2007, pp. IV‐31.

26 Staff compared the Indian producers that responded to the Commission’s questionnaires to those

producers identified by the steel analysts at ***. See ***. According to this comparison, the two

responding Indian producers accounted for *** percent of hot strip rolling capacity in India in 2012.

27 Domestic parties’ response to the notice of institution. Information compiled from the WTO’s

semiannual “Definitive Anti Dumping Measures,” for the reporting countries noted in the tabulation and

Canadian Border Services Agency, “Measures in Force Goods subject to anti‐dumping or countervailing

duties,” updated November 21, 2013.
  

IV‐17

Product Country Year 

imposed 

Barrier (rate) 

Hot-rolled steel in 

coils and cut-tolength, nonalloy and 

alloy Canada 2001 

Antidumping: 77.0 percent 

CVD: 3,150 rupees per metric ton 

Hot-rolled steel in 

coils, nonalloy Indonesia 2008 Antidumping: 12.95 - 56.51 percent 

Hot-rolled steel in 

coils and cut-tolength, nonalloy 

Thailand 

2003 Antidumping: 20.02 – 31.92 percent 

Hot-rolled flat steel 

products with certain 

amounts of alloying 

elements 2013 

Definitive safeguard duty: 

September 15, 2013 – February 26, 2014: 

44.20 percent; 

February 27, 2014 – February 26, 2015: 

43.57 percent; 

February 27, 2015 – February 26, 2016: 

42.95 percent 

Table IV‐9 presents data on India’s capacity, production, exports, and net exports for

2009‐12 and India’s top export markets are presented in table IV‐10.  

Table IV-9 

Hot-rolled steel: Indian capacity, production, exports, and net exports, 2009-12

 2009 2010 2011 2012

Item Quantity (1,000 short tons)

Capacity *** *** *** *** 

Production *** *** *** *** 

Exports 508 1,337 2,247 1,758 

Net exports *** *** *** *** 

Source: *** and Global Trade Atlas. 
  

IV‐18

Table IV-10 

Hot-rolled steel: Indian exports, by market, 2007-12

 Quantity (short tons)

Item 2007 2008 2009 2010 2011 2012

United Arab Emirates 240,842 181,154 22,722 105,504 110,144 293,703 

Belgium 535,943 458,565 43,466 722,299 835,100 261,442 

Spain 81,587 126,898 6,813 15,969 199,578 212,509 

Saudi Arabia 47,935 48,694 7,387 21,516 47,665 140,060 

Oman 2,672 13,488 11,825 18,059 26,010 94,034 

Nepal 3,617 13,919 13,806 13,903 11,813 80,244 

Thailand 4,169 34,588 8,153 118 5,133 74,474 

Taiwan 49 20 17,609 81,437 145,898 69,073 

Italy 33,200 33,392 57,075 779 94,480 64,837 

Kenya 40,750 44,831 19,593 22,702 106,490 59,173 

Sri Lanka 9,406 5,685 6,358 12,244 16,022 40,561 

Tanzania 19,942 29,499 34,882 14,483 57,058 39,093 

Vietnam 7,617 55,116 9,597 141 51,290 35,711 

Singapore 904 25,804 8,431 8,803 175,683 34,219 

Malaysia 540 233 22 106 34 25,913 

Unidentified Country 0 12 4 17,949 11,753 25,029 

France 1,444 87 (

1

) 36 26,886 21,777 

Bangladesh 11,053 15,896 80,933 26,835 3,757 21,248 

United Kingdom 53,245 75,483 13,978 149,774 38,976 18,952 

Mozambique 463 722 17 9 9,134 18,090 

All others 360,514 156,879 145,551 104,811 274,458 128,119 

 Total 1,455,889 1,320,963 508,223 1,337,478 2,247,364 1,758,262 

Value (1,000 dollars)

United Arab Emirates 144,802 139,232 12,356 63,268 73,952 157,978 

Belgium 300,643 363,442 20,529 417,896 562,025 144,232 

Spain 45,293 99,591 3,814 9,585 119,763 113,067 

Saudi Arabia 27,700 39,981 3,179 13,423 31,151 84,526 

Oman 1,834 8,774 6,746 12,301 14,678 51,565 

Nepal 2,307 11,059 8,137 8,969 7,744 45,834 

Thailand 2,856 24,322 3,173 157 3,217 37,339 

Taiwan 43 25 8,061 44,763 84,235 35,545 

Italy 19,763 26,506 21,283 1,806 61,224 32,548 

Kenya 24,012 41,833 11,204 14,476 74,775 33,916 

Sri Lanka 5,325 3,906 3,086 7,399 9,376 22,868 

Tanzania 11,748 21,338 19,952 9,771 38,612 21,849 

Vietnam 4,935 33,768 4,072 169 29,205 19,416 

Singapore 560 26,217 3,927 4,572 108,806 19,327 

Malaysia 545 266 27 98 88 12,943 

Unidentified Country 0 16 3 11,707 8,592 9,037 

France 1,058 84 (

1

) 92 19,627 11,884 

Bangladesh 6,004 9,307 39,060 14,450 2,435 12,795 

United Kingdom 30,783 67,420 6,106 85,926 26,663 11,277 

Mozambique 477 672 5 9 5,005 8,844 

All others 246,711 117,487 78,770 64,590 186,288 95,969 

 Total 877,398 1,035,246 253,488 785,426 1,467,462 982,759 

Table continued on next page. 

 
  

IV‐19

Table IV-10 --Continued

Hot-rolled steel: Indian exports, by market, 2007-12 

Item 

Unit value (dollars per short ton)

2007 2008 2009 2010 2011 2012

United Arab Emirates 601 769 544 600 671 538 

Belgium 561 793 472 579 673 552 

Spain 555 785 560 600 600 532 

Saudi Arabia 578 821 430 624 654 603 

Oman 686 651 570 681 564 548 

Nepal 638 795 589 645 656 571 

Thailand 685 703 389 1,330 627 501 

Taiwan 895 1,281 458 550 577 515 

Italy 595 794 373 2,317 648 502 

Kenya 589 933 572 638 702 573 

Sri Lanka 566 687 485 604 585 564 

Tanzania 589 723 572 675 677 559 

Vietnam 648 613 424 1,196 569 544 

Singapore 619 1,016 466 519 619 565 

Malaysia 1,008 1,146 1,203 926 2,584 499 

Unidentified Country (

2

) 1,346 753 652 731 361 

France 733 963 (

1

) 2,518 730 546 

Bangladesh 543 585 483 538 648 602 

United Kingdom 578 893 437 574 684 595 

Mozambique 1,031 931 280 1,054 548 489 

All others 684 749 541 616 679 749 

 Average 603 784 499 587 653 559 

1

 Result not meaningful due to small quantity of exports. 

2

 Not applicable. 

Source: Global Trade Atlas (HTS 7208.10, 7208.25, 7208.26, 7208.27, 7208.36, 7208.37, 7208.38, 208.39, 7208.40, 

7208.53, 7208.54, 7208.90, 7211.14, and 7211.19). 

Operations on hot‐rolled steel

Table IV‐11 presents data on Essar and JSW’s hot‐rolled steel operations in India during

2007‐12, January‐June 2012, and January‐June 2013.28 The combined hot‐rolled steel capacity

increased between 2007 and 2012, and was higher in January‐June 2013 compared to January‐

June 2012. ***. In December 2010 JSW increased its stake in Ispat to become the largest

shareholder and in June 2013 Ispat was merged with JSW.29 This merger included ***.

The *** of shipments of hot‐rolled steel of Indian producers were to ***. Essar reported

that ***, while JSW stated that ***.

                                                      

28 JSW only provided value for total exports, so Staff estimated value of exports to individual markets

based on this and the share of these markets for total exports.

29 “Merger catapults JSW Steel to top league in Indian steel sector,” JSW press release, January 9,

2012, found at http://www.jswispat.in/pdf/PressRelease.pdf and “JSW steel completes merger of JSW

Ispat,”The Economic Times, found at http://articles.economictimes.indiatimes.com/2013‐06‐

03/news/39714934_1_jsw‐ispat‐steel‐jsw‐building‐systems‐jsw‐ispat.
  

IV‐20

Table IV-11 

Hot-rolled steel: Indian producers’ capacity, production, shipments, and inventories, 2007-12, 

January-June 2012, and January-June 2013 

* * * * * * * 

Alternative and downstream products

As shown in table IV‐12, both Indian producers ***. These firms ***. While the capacity

utilization for hot‐rolled steel ranged from a low of *** percent in interim 2013 to a high of ***

percent in 2009, the capacity utilization of downstream products was lower in 2008 and 2009,

but was generally higher in periods after 2009 ***.

Table IV-12 

Hot-rolled steel: Indian producers’ capacity, production, and capacity utilization for alternative 

and downstream products, 2007-12, January-June 2012, and January-June 2013

* * * * * * * 

THE INDUSTRY IN INDONESIA

Overview

The Commission identified one Indonesian producer of hot‐rolled steel, PT Krakatau

Steel (“Krakatau”) in the original investigations, and in the first five‐year reviews the

Commission issued questionnaires to two possible producers in Indonesia, PT Gunung Raja

Paksi and Krakatau, neither of which responded.30 In the current reviews, the Commission

issued questionnaires to these firms, neither of which responded.  

The larger of these two firms, Krakatau, reportedly has a hot‐rolled steel production

capacity of 2.6 million short tons (2.4 million metric tons) and a cold‐rolled steel mill with a

capacity of 937,000 short tons (850,000 metric tons).31 In 2012, Krakatau produced 2.02 million

short tons (1.83 million metric tons) of hot‐rolled steel and 590,838 short tons (536,000 metric

tons) of cold‐rolled steel, an increase from 2011 of 4.3 percent and 29.4 percent, respectively.32

Krakatau reported that in 2012 it had 41 percent market share for hot‐rolled steel in

Indonesia.33 Krakatau also has a joint venture with Posco (Korea), PT. Krakatau Posco, with the

first stage of production of 3.0 million metric tons of plate and slab steel scheduled for

                                                      

30 Hot‐Rolled Steel Products from Argentina and South Africa:  Investigation No. 701‐TA‐404 (Final)

and Investigations Nos. 731‐TA‐898 and 905 (Final), USITC Publication 3446, VII‐5 and Hot‐Rolled Steel

Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South Africa, Taiwan, Thailand,

and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐908 (Review), USITC

Publication 3956, October 2007, p. IV‐34.

31 “About Us, Production Facilities,” found at http://www.krakatausteel.com/?page=content&cid=47.   32 PT Krakatau Steel, Annual report 2012, p. 51.

33 PT Krakatau Steel, Annual report 2012, p. 68.
  

IV‐21

completion in late 2013.34 The second phase of this project, which is scheduled to commence in

2015, will include the production of hot‐rolled steel.35 The other known hot‐rolled steel

producer in Indonesia, PT Gunung Raja Paksi, which is part of the Gunung Steel Group

(Indonesia), has a hot‐rolled steel capacity of 265,000 short tons (240,000 metric tons).36  

Exports of hot‐rolled steel from Indonesia were subject to tariff or non‐tariff barriers to

trade in countries other than the United States, as presented the following tabulation:37

Product Country Year imposed Barrier (rate) 

Hot-rolled in coils and 

cut-to-length, nonalloy Thailand 2003 Antidumping: 24.48 percent 

Table IV‐13 presents data on Indonesia’s capacity, production, exports, and net exports

for 2009‐12 and Indonesia’s top export markets are presented in table IV‐14.  

Table IV-13 

Hot-rolled steel: Indonesian capacity, production, exports, and net exports, 2009-12

2009 2010 2011 2012 

Item Quantity (1,000 short tons) 

Capacity *** *** *** *** 

Production *** *** *** *** 

Exports 111 20 32 19 

Net exports *** *** *** *** 

Source: *** and Global Trade Atlas. 

                                                      

34 PT Krakatau Steel, Annual report 2012, p. 67, and “Indonesia Integrated Steelworks manufactures

first coke,” Posco press release, October 18, 2013, found at

http://www.posco.com/homepage/docs/eng2/jsp/prcenter/news/s91c1010025v.jsp?mode=view&idx=

2224.   35 “Krakatau Posco’s $3b mills to begin operations in December,” Jakarta Post, June 12, 2013, found

at http://www.thejakartapost.com/news/2013/06/12/krakatau‐posco‐s‐3b‐mills‐begin‐operations‐

december.html, and “Company,” PT Krakatau Postco website, found at

http://www.krakatauposco.co.id/company/our_company.   36 “Coil service center,” Gunung Steel Group website, found at

http://www.grdsteel.com/index.php?option=com_content&view=article&id=64&Itemid=101.   37 Domestic parties’ response to the notice of institution. Information compiled from the WTO’s

semiannual “Definitive Anti Dumping Measures,” for Thailand.
  

IV‐22

Table IV-14 

Hot-rolled steel: Indonesian exports, by market, 2007-12

 Quantity (short tons)

Item 2007 2008 2009 2010 2011 2012

Malaysia 18,374 12,541 7,194 15,282 21,609 11,572 

Vietnam 7,792 31,591 9,608 0 2,212 4,926 

Australia 30,489 10,582 7,453 981 2,986 1,895 

Singapore 77,384 69,840 57,442 2,744 4,428 432 

United Arab Emirates 405 7,092 5,456 129 278 154 

Japan 16,475 19,279 (

1

) (1) 64 52 

Nigeria 0 0 26 0 0 23 

Philippines 17 2,815 (

1

) (1) 42 3 

Korea South 2 6,736 311 (1) (1) 2 

China 0 960 0 1 (

1

) 2 

Thailand 3,635 24,101 8,217 118 36 2 

Hong Kong 0 0 (1) 12 2 (1) 

Germany 4,450 16,512 0 0 (

1

) (1) 

Taiwan 228 0 0 0 0 (1) 

Senegal 0 0 0 0 0 (1) 

Solomon Islands 0 0 0 0 25 0 

Sri Lanka 422 109 713 420 169 0 

Tonga 0 0 0 (

1

) 0 0 

United Kingdom 1,285 355 (1) 0 (

1

) 0 

Kuwait 0 621 0 0 0 0 

All others 166,498 69,586 14,284 (1) 645 0 

 Total 327,456 272,720 110,703 19,690 32,498 19,065 

Value (1,000 dollars)

Malaysia 9,869 10,118 3,530 9,290 15,773 6,607 

Vietnam 5,262 23,804 4,615 0 984 3,622 

Australia 16,441 7,987 4,135 697 2,205 1,372 

Singapore 52,796 65,861 28,361 1,352 2,598 548 

United Arab Emirates 392 7,962 2,694 321 752 423 

Japan 9,877 14,921 (

1

) (1) 291 472 

Nigeria 0 0 51 0 0 47 

Philippines 16 3,050 (

1

) (1) 530 149 

Korea South 10 7,464 217 (1) (1) 36 

China 0 963 0 2 (

1

) 10 

Thailand 2,353 24,742 4,098 118 353 190 

Hong Kong 0 0 (1) 2,074 2,958 (1) 

Germany 3,087 13,278 0 0 (

1

) (1) 

Taiwan 68 0 0 0 0 (1) 

Senegal 0 0 0 0 0 (1) 

Solomon Islands 0 0 0 0 29 0 

Sri Lanka 296 87 327 213 120 0 

Tonga 0 0 0 (

1

) 0 0 

United Kingdom 595 406 (1) 0 (

1

) 0 

Kuwait 0 743 0 0 0 0 

All others 96,937 64,030 7,895 (1) 448 0 

 Total 197,999 245,416 55,937 14,113 27,071 14,044 

Table continued on next page. 

 
  

IV‐23

Table IV-14 --Continued

Hot-rolled steel: Indonesian exports, by market, 2007-12 

Item 

Unit value (dollars per short ton)

2007 2008 2009 2010 2011 2012

Malaysia 537 807 491 608 730 571 

Vietnam 675 753 480 (

2

) 445 735 

Australia 539 755 555 710 738 724 

Singapore 682 943 494 493 587 1,269 

United Arab Emirates 968 1,123 494 2,486 2,708 2,742 

Japan 600 774 (

1

) (1) 4,554 9,110 

Nigeria (2) (2) 1,943 (2) (2) 2,009 

Philippines 953 1,083 (

1

) (1) 12,653 (1) 

Korea South 4,411 1,108 698 (1) (1) (1) 

China (2) 1,003 (2) 1,559 (1) 4,548 

Thailand 647 1,027 499 1,000 9,691 (

1

) 

Hong Kong (

2

) (2) (1) (1) (1) (1) 

Germany 694 804 (

2

) (2) (1) (1) 

Taiwan 300 (

2

) (2) (2) (2) (1) 

Senegal (2) (2) (2) (2) (2) (1) 

Solomon Islands (

2

) (2) (2) (2) 1,138 (2) 

Sri Lanka 701 802 459 508 712 (2) 

Tonga (2) (2) (2) (1) (2) (2) 

United Kingdom 463 1,144 (1) (2) (1) (2) 

Kuwait (2) 1,198 (2) (2) (2) (2) 

All others 582 920 553 (1) 695 (2) 

 Average 605 900 505 717 833 737 

1

 Results not meaningful due to the small quantity of exports. 2

 Not applicable 

Source: Global Trade Atlas (HTS 7208.10, 7208.25, 7208.26, 7208.27, 7208.36, 7208.37, 7208.38, 208.39, 7208.40, 

7208.53, 7208.54, 7208.90, 7211.14, and 7211.19). 
  

IV‐24

THE INDUSTRY IN TAIWAN

Overview

During the Commission’s original investigations, the hot‐rolled steel industry in Taiwan

included two known firms, China Steel Corp. (“China Steel”) and Yieh Loong Enterprise Co., Ltd.

(“Yieh Loong”).38 The exports to the United States of these two firms combined represented

*** percent of total U.S. imports of the subject merchandise from Taiwan during 1998‐2000.

China Steel was the larger of the two firms, accounting for *** percent of reported production

in Taiwan during 2000.39  

In the first five‐year reviews, the Commission issued and received responses to the

Commission’s questionnaires by three producers in Taiwan, China Steel, Chung Hung Steel

Corp. (“Chung Hung”) (formerly Yieh Loong) and Shang Shing Industrial Co., Ltd. (“Shang Shing”)

(formerly An Feng Steel Co., Ltd.). These three firms accounted for all production of hot‐rolled

steel in Taiwan.40 China Steel accounted for *** percent of Taiwan production during 2006,

Chung Hung accounted for *** percent, and Shang Shing accounted for *** percent.41  

In the current five‐year reviews, four firms (China Steel, Chung Hung, Dragon Steel Corp.

(“Dragon Steel”), and Shang Chen) provided data on their hot‐rolled steel operations in Taiwan.

These firms are believed to account for virtually all of current hot‐rolled steel production in

Taiwan. 42 Exports of hot‐rolled steel from Taiwan were subject to tariff or non‐tariff barriers to

trade in countries other than the United States, as presented the following tabulation:43

                                                      

38 Hot‐Rolled Steel Products from Argentina and South Africa:  Investigation No. 701‐TA‐404 (Final)

and Investigations Nos. 731‐TA‐898 and 905 (Final), USITC Publication 3446, p. VII‐8.

39 Hot‐Rolled Steel Products from Argentina, China, India, Indonesia, Kazakhstan, Netherlands,

Romania, South Africa, Taiwan, Thailand, and Ukraine, Investigations Nos. 701‐TA‐404‐408 (Final) and

731‐TA‐898‐908 (Final), INV‐Y‐141, August 6, 2001, p. VII‐18.

40 Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐

908 (Review), USITC Publication 3956, October 2007, p. IV‐50. 41 Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐

908 (Review), INV‐EE‐136, September 21, 2007, p. IV‐98.

42 Staff compared the Taiwan producers that responded to the Commission’s questionnaires to those

producers identified by the steel analysts at ***. See ***. According to this comparison, the four

responding Taiwan producers accounted for *** percent of hot strip rolling capacity in Taiwan in 2012.

43 Domestic parties’ response to the notice of institution. Information compiled from the WTO’s

semiannual “Definitive Anti Dumping Measures,”for the reporting countries noted in the tabulation and

Canadian Border Services Agency, “Measures in Force Goods subject to anti‐dumping or countervailing

duties,” updated November 21, 2013.
  

IV‐25

Product Country Year imposed Barrier (rate) 

Hot-rolled in coils and cut-tolength, nonalloy Australia 2012 Antidumping: 2.6- 8.2 percent 

Hot-rolled in coils and cut-tolength, nonalloy and alloy Canada 2001 Antidumping: 77.0 percent 

Hot-rolled in coils, nonalloy 

Indonesia 2008 

Antidumping: 0 - 37.02 

percent 

Hot-rolled in coils and cut-tolength, nonalloy Thailand 2003 Antidumping: 3.45 - 25.15 

percent 

Table IV‐15 presents data on Taiwan’s capacity, production, exports, and net exports for

2009‐12 and Taiwan’s top export markets are presented in table IV‐16.  

Table IV-15 

Hot-rolled steel: Taiwan capacity, production, exports, and net exports, 2009-12

2009 2010 2011 2012 

Item Quantity (1,000 short tons) 

Capacity *** *** *** *** 

Production *** *** *** *** 

Exports 2,933 2,600 3,174 3,393

Net exports *** *** *** *** 

Source: *** and Global Trade Atlas. 
  

IV‐26

Table IV-16 

Hot-rolled steel: Taiwan exports, by market, 2007-12

 Quantity (short tons)

Item 2007 2008 2009 2010 2011 2012

Japan 641,137 570,095 391,805 512,663 620,261 617,023 

Vietnam 361,618 417,001 519,253 396,797 510,031 525,377 

Malaysia 428,598 366,177 348,408 471,093 418,156 445,478 

Korea South 246,173 278,086 616,898 434,605 565,311 426,746 

Indonesia 167,391 146,425 99,117 116,866 175,760 254,487 

Thailand 19,662 14,004 20,663 19,132 71,972 198,464 

China 331,206 213,309 571,338 228,624 225,836 155,784 

Philippines 185,083 116,974 79,509 86,952 141,705 149,420 

Australia 28,374 32,235 29,278 68,933 87,644 99,846 

Hong Kong 94,078 93,370 56,287 59,817 121,882 82,426 

Saudi Arabia 23,101 15,742 6,908 8,346 21,975 59,278 

Bangladesh 52,553 67,491 33,815 39,262 37,798 57,377 

Singapore 17,953 17,829 39,920 53,123 44,586 56,399 

India 27,825 1,615 66,891 49,382 36,659 51,809 

United Arab Emirates 9,043 17,902 31,365 1,008 0 44,312 

Mexico 7 1,186 5,353 23,112 25,913 34,037 

Djibouti 0 6 0 10 0 30,723 

Kenya 0 105 0 0 104 20,320 

Pakistan 2,468 3,276 2,274 4,709 11,810 18,070 

Spain 830 7,615 0 5,276 26,228 14,672 

All others 98,884 71,717 14,253 20,186 30,407 51,329 

 Total 2,735,986 2,452,159 2,933,333 2,599,895 3,174,039 3,393,377 

Value (1,000 dollars)

Japan 284,066 378,611 240,604 318,878 441,704 361,986 

Vietnam 178,771 264,528 205,370 216,718 317,040 291,463 

Malaysia 203,614 248,158 160,308 270,023 268,464 261,545 

Korea South 120,757 189,190 252,125 241,083 358,922 242,981 

Indonesia 85,586 104,949 51,639 74,845 120,082 155,963 

Thailand 13,043 11,542 9,895 12,980 47,614 115,340 

China 177,504 150,690 245,371 141,863 158,865 106,136 

Philippines 94,481 85,410 35,309 48,539 88,852 85,758 

Australia 14,314 23,257 14,417 40,096 58,317 63,583 

Hong Kong 48,227 65,980 26,473 36,732 81,857 50,709 

Saudi Arabia 11,441 11,901 3,396 4,417 13,305 34,741 

Bangladesh 26,528 45,184 16,720 22,192 22,826 33,317 

Singapore 9,485 11,261 19,148 30,241 30,107 35,399 

India 13,014 1,204 23,741 25,107 21,426 28,511 

United Arab Emirates 4,970 13,554 11,836 629 0 23,154 

Mexico 16 913 3,071 13,635 18,001 23,528 

Djibouti 0 4 0 7 0 16,947 

Kenya 0 71 0 0 76 10,354 

Pakistan 961 2,597 1,231 3,411 8,034 9,828 

Spain 470 6,246 0 2,701 16,666 8,184 

All others 51,841 52,123 8,029 11,842 21,570 33,356 

 Total 1,339,089 1,667,374 1,328,683 1,515,936 2,093,726 1,992,783 

Table continued on next page. 

 
  

IV‐27

Table IV-16--Continued 

Hot-rolled steel: Taiwan exports, by market, 2007-12 

Item 

Unit value (dollars per short ton)

2007 2008 2009 2010 2011 2012

Japan 443 664 614 622 712 587 

Vietnam 494 634 396 546 622 555 

Malaysia 475 678 460 573 642 587 

Korea South 491 680 409 555 635 569 

Indonesia 511 717 521 640 683 613 

Thailand 663 824 479 678 662 581 

China 536 706 429 621 703 681 

Philippines 510 730 444 558 627 574 

Australia 504 721 492 582 665 637 

Hong Kong 513 707 470 614 672 615 

Saudi Arabia 495 756 492 529 605 586 

Bangladesh 505 669 494 565 604 581 

Singapore 528 632 480 569 675 628 

India 468 746 355 508 584 550 

United Arab Emirates 550 757 377 624 (1) 523 

Mexico 2,353 769 574 590 695 691 

Djibouti (1) 801 (1) 690 (1) 552 

Kenya (1) 680 (1) (1) 734 510 

Pakistan 390 793 541 724 680 544 

Spain 566 820 (

1

) 512 635 558 

All others 524 727 563 587 709 650 

 Average 489 680 453 583 660 587 

1

 Not applicable. 

Source: Global Trade Atlas (HTS 7208.10, 7208.25, 7208.26, 7208.27, 7208.36, 7208.37, 7208.38, 208.39, 7208.40, 

7208.53, 7208.54, 7208.90, 7211.14, and 7211.19). 
  

IV‐28

Operations on hot‐rolled steel

Data provided by China Steel,44 Chung Hung, Dragon Steel,45 and Shang Chen concerning

their operations in Taiwan during 2007‐12, January‐June 2012, and January‐June 2013 are

presented in table IV‐17. These firms are believed to account for virtually all of current hot‐

rolled steel production in Taiwan.46  

The combined hot‐rolled steel capacity in Taiwan increased in 2009‐11 due to ***.

Capacity in interim 2013, during which ***, was higher compared with interim 2012.47

Aggregate production declined from 2007 to its lowest level in 2009, then increased to its

highest level in 2011, and then declined again, ending *** percent higher in 2012 than in 2007.

Aggregate capacity utilization ranged from a high of *** in 2007 to a low of *** in January‐June

2013.48 ***, reported at least *** of their shipments for internal consumption. ***. Unlike

internal consumption, which as a share of total shipments fluctuated during 2007‐12,

commercial home market shipments declined during 2007‐12, while total exports share (largely

to Asia) increased over the same period.  

                                                      

44 China Steel reported ***. Email from ***, November 15, 2013.

The hot‐rolled steel capacity, 7.7 million short tons, published on the firm’s website, is *** to the

***, while the *** is *** to other published sources (***).  

The reported design capacity and effective capacity are shown in the table below.

 Calendar years January-June 

Item 2007 2008 2009 2010 2011 2012 2012 2013 

 Quantity (short tons) 

Design 

capacity *** *** *** *** *** *** *** ***

Effective 

capacity *** *** *** *** *** *** *** ***

45 Dragon Steel, a wholly owned subsidiary of China Steel, noted that *** Email from ***, September

3, 2013, and “Dragon Steel –Milestones,” found at www.dragonsteel.com.tw/en/company.aspx

46 China Steel estimated that it accounted for *** percent of hot‐rolled steel production in Taiwan,

Chung Hung estimated it accounted for *** percent, Dragon Steel estimated it accounted for ***

percent, and Shang Chen estimated it accounted for *** percent. 47 ***.

48 ***, which reported production greater than capacity in ***, reported that reported capacity is

based on design or nameplate capacity, which is based on a certain product/specification mix. The

actual production can be higher than design capacity if the relevant product specifications take less time

to produce than the mix assumed for the design capacity. Email from ***, September 3, 2013.
  

IV‐29

Table IV-17 

Hot-rolled steel: Taiwan capacity, production, shipments, and inventories, 2007-12, January-June 

2012, and January-June 2013

* * * * * * * 

Alternative and downstream products

Table IV‐18 presents data on alternative and downstream products. One producer, ***,

produced nonsubject products on the hot‐strip/steckel mill, and all responding producers

produced downstream products. *** reported that its can switch to ***.49

Table IV-18 

Hot-rolled steel: Taiwan producers’ capacity, production, and capacity utilization for alternative 

and downstream products, 2007-12, January-June 2012, and January-June 2013 

* * * * * * * 

THE INDUSTRY IN THAILAND

Overview

The Commission received information from three Thai firms (i.e., Nakornthai Strip Mill

Public Co. Ltd. (“Nakornthai”), Sahaviriya Steel Industries Public Co. Ltd. (“Sahaviriya” or “SSI”),

and Siam Strip Mill Public Co. Ltd. (“Siam”)) on their operations concerning the subject

merchandise during the original investigations.50 Exports of the subject merchandise to the U.S.

market by these three firms accounted for *** percent of total U.S. imports of subject

merchandise from Thailand during 1998‐2000.51  

The three Thai producers participating in the first five‐year reviews (G Steel Public Co.

Ltd. (“G Steel”) (successor firm to Siam),52 Nakornthai, and Sahaviriya) indicated that they

accounted for all production of the subject merchandise in Thailand. During 2006, G Steel

                                                      

49 *** reported outsourcing coated steel and steel plate, and so has not been included in the table.

50 Hot‐Rolled Steel Products from Argentina and South Africa:  Investigation No. 701‐TA‐404 (Final)

and Investigations Nos. 731‐TA‐898 and 905 (Final), USITC Publication 3446, p. VII‐8.

51 Hot‐Rolled Steel Products from Argentina, China, India, Indonesia, Kazakhstan, Netherlands,

Romania, South Africa, Taiwan, Thailand, and Ukraine: Investigations Nos. 701‐TA‐404‐408 (Final) and

731‐TA‐898‐908 (Final), INV‐Y‐141, August 6, 2001, p. VII‐20.

52 In 2001, at the time of the financial crisis in Thailand, Siam filed for bankruptcy and undertook a

debt restructuring program. By 2003, Siam emerged from bankruptcy and began operations under its

new name, G Steel.
  

IV‐30

accounted for *** percent of hot‐rolled steel production in Thailand, Nakornthai accounted for

*** percent, and Sahaviriya accounted for *** percent.53  

In these current reviews, the one responding Thai producer, Sahaviriya, indicated in its

response to the Commission’s notice of institution that it accounts for all current (i.e. as of the

filing) production of the subject merchandise in Thailand,54 and estimated that it accounted for

*** percent of hot‐rolled steel production in Thailand in 2012. 55

In 2008, Nakornthai changed its name to G J Steel Public Company (“G J Steel”) under a

restructuring plan, with G Steel holding 49.67 percent56 In March 2011, ArcelorMittal signed an

agreement to acquire a 40‐percent stake in G Steel,57 but in December 2011 withdrew from the

agreement.58 G Steel and G J Steel ceased production in August 5, 2012 for “annual

maintenance due to the selling price of hot‐rolled coil is lower than its production costs.”59 On

March 20, 2013 G J Steel announced that it had restarted its mill operations, while G Steel

remained closed.60 61  

Exports of hot‐rolled steel from Thailand were subject to tariff or non‐tariff barriers to

trade in countries other than the United States, as presented the following tabulation:62

   

                                                      

53 Hot‐Rolled Steel Products From Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐902 and 904‐

908 (Review), INV‐EE‐136, September 21, 2007, p. IV‐108.

54 Sahaviriya response to notice of institution, p. 2. 55 Staff compared the Thailand producers that responded to the Commission’s questionnaires to

those producers identified by the steel analysts at ***. See ***. According to this comparison, the

responding Thailand producer accounted for *** percent of hot strip rolling capacity in Thailand in 2012.

56 G J Steel 2009 annual report, p. 8. 57 “ArcelorMittal to invest in a leading Thai steel producer G Steel Public Company Limited ("G

Steel"),” ArcelorMittal press release, March 2, 2011, found at http://corporate.arcelormittal.com/news‐

and‐media/press‐releases/2011/mar/02‐03‐2011. 58 “ArcelorMittal scraps deal to buy stake in Thai G Steel,” Reuters, December 21, 2011, found at

http://www.reuters.com/article/2011/12/21/gsteel‐arcelormittal‐idUSL3E7NL0HI20111221. 59 “G Steel Public Company Limited and its Subsidiaries, Interim financial statements for the three‐

month period ended 31 March 2013,” p. 14, and “Explanation of operational results for the year 2012,”

G J Steel, March 4, 2013, found at http://www.gjsteel.co.th/download/FS%20Q4‐

2012/Explanation%20of%20operational%20results%20for%20the%20year%202012_EN.pdf.

60 “Notification of restarting operation,” G J Steel, March 20, 2013, found at

http://www.gjsteel.co.th/download/GJS30_RestartOperation_EN.pdf, and “G Steel Public Company

Limited and its Subsidiaries, Interim financial statements for the three‐month period ended 31 March

2013,” p. 14,

61 SSI reported that GJ Steel is currently operating at less than 50 percent capacity and that it might

achieve 50 percent by end of 2013. Hearing transcript, p. 231 (LaFrankie) and SSI’s posthearing brief,

exh. 1, p. 19.

62 Domestic parties’ response to the notice of institution. Information compiled from the WTO’s

semiannual “Definitive Anti Dumping Measures,” for Thailand.
  

IV‐31

Product Country Year imposed Barrier (rate) 

Hot-rolled in coils, nonalloy Indonesia 2008 

Antidumping: 7.52 - 27.44 

percent 

Table IV‐19 presents data on Thailand’s capacity, production, exports, and net exports

for 2009‐12 and Thailand’s top export markets are presented in table IV‐20.  

Table IV-19 

Hot-rolled steel: Thai capacity, production, exports, and net exports, 2009-12

2009 2010 2011 2012 

Item Quantity (1,000 short tons) 

Capacity *** *** *** ***

Production *** *** *** ***

Exports 333 192 36 27

Net exports *** *** *** ***

Source: *** and Global Trade Atlas. 
  

IV‐32

Table IV-20 

Hot-rolled steel: Thai exports, by market, 2007-12

 Quantity (short tons)

Item 2007 2008 2009 2010 2011 2012

Saudi Arabia 70,347 160,478 84,583 106,772 12,220 9,091 

Laos 3,982 4,332 6,726 6,752 2,542 7,899 

Malaysia 734 357 3,854 10,672 9,713 5,121 

Myanmar 13,089 12,984 16,593 19,730 6,413 3,299 

Cambodia 522 128 64 311 56 960 

Vietnam 146,654 138,890 99,343 32,283 4,056 112 

China 19 281 52,301 291 31 89 

Pakistan 1,294 41 24 22 82 78 

Papua New Guinea 0 (1) 0 6 15 39 

Japan 15 384 21 84 114 28 

Singapore 3,474 16,823 429 499 455 20 

Philippines 9,807 14,505 10 8 29 17 

Indonesia 97,562 84,576 32,102 226 443 17 

Australia 1,831 2,875 97 9 (

1

) 3 

Taiwan (1) 3,496 28 42 10 3 

India 340,698 81,329 10 24 13 3 

Argentina 0 0 0 0 0 3 

Madagascar 0 0 0 0 11 2 

Sri Lanka (

1

) (1) 0 0 (

1

) (1) 

Norway 0 0 0 0 0 (1) 

All others 226,943 96,937 36,696 13,952 30 (1) 

 Total 916,973 618,417 332,879 191,682 36,235 26,785 

Value (1,000 dollars)

Saudi Arabia 38,348 140,822 45,815 67,819 9,028 5,430 

Laos 2,644 3,656 3,761 4,585 2,055 5,904 

Malaysia 358 295 1,881 6,502 6,490 3,387 

Myanmar 7,739 8,753 8,393 12,144 4,833 2,335 

Cambodia 318 113 45 242 47 778 

Vietnam 77,909 73,617 42,023 16,882 2,648 117 

China 16 304 20,595 203 44 104 

Pakistan 710 47 14 21 83 95 

Papua New Guinea 0 (1) 0 4 24 90 

Japan 36 475 27 141 189 66 

Singapore 2,047 12,018 278 291 666 6 

Philippines 5,236 8,678 12 13 30 16 

Indonesia 56,048 56,569 16,536 238 458 39 

Australia 1,050 1,624 53 12 (

1

) 6 

Taiwan (1) 2,080 18 24 17 5 

India 186,304 57,356 16 48 22 5 

Argentina 0 0 0 0 0 7 

Madagascar 0 0 0 0 254 55 

Sri Lanka (

1

) (1) 0 0 (

1

) (1) 

Norway 0 0 0 0 0 (1) 

All others 132,286 80,751 22,549 8,756 48 (1) 

 Total 511,053 447,162 162,017 117,924 26,945 18,460 

Table continued on next page. 

 
  

IV‐33

Table IV-20--Continued

Hot-rolled steel: Thai exports, by market, 2007-12 

Item 

Unit value (dollars per short ton)

2007 2008 2009 2010 2011 2012

Saudi Arabia 545 878 542 635 739 597 

Laos 664 844 559 679 808 747 

Malaysia 487 826 488 609 668 661 

Myanmar 591 674 506 616 754 708 

Cambodia 608 883 697 779 840 810 

Vietnam 531 530 423 523 653 1,040 

China 829 1,081 394 698 1,430 1,169 

Pakistan 549 1,148 590 947 1,018 1,212 

Papua New Guinea (

2

) (1) (2) 678 1,558 2,330 

Japan 2,332 1,237 1,275 1,678 1,663 2,390 

Singapore 589 714 649 583 1,462 281 

Philippines 534 598 1,254 1,673 1,054 956 

Indonesia 574 669 515 1,054 1,035 2,370 

Australia 574 565 545 1,405 (

1

) 1,748 

Taiwan (1) 595 635 576 1,694 1,445 

India 547 705 1,630 1,960 1,689 1,663 

Argentina (2) (2) (2) (2) (2) 2,267 

Madagascar (2) (2) (2) (2) (1) (1) 

Sri Lanka (

1

) (1) (2) (2) (1) (1) 

Norway (2) (2) (2) (2) (2) (1) 

All others 583 833 614 628 1,629 (1) 

 Average 557 723 487 615 744 689 

1

 Results not meaningful due to the small quantity of exports. 2

 Not applicable. 

Source: Global Trade Atlas (HTS 7208.10, 7208.25, 7208.26, 7208.27, 7208.36, 7208.37, 7208.38, 208.39, 7208.40, 

7208.53, 7208.54, 7208.90, 7211.14, and 7211.19). 

Operations on hot‐rolled steel

Table IV‐21 presents data for Sahaviriya’s hot‐rolled steel operations in Thailand during

2007‐12, January‐June 2012, and January‐June 2013. The vast majority of Sahaviriya’s

shipments were ***.63 The firm ***.  

Production capacity for Sahaviriya varied over 2007‐12, January‐June 2012, and January‐

June 2013, as it was based on planned and actual product mix and downtime.64 Capacity

utilization varied from a low of *** percent in 2007 to a high of *** percent in 2009. The firm

projects to increase both capacity and production of hot‐rolled steel in 2014‐15 due to a more

stable supply of slab from its recently acquired affiliated supplier, and less downtime. In March

2011, Sahaviriya acquired the UK slab facility, Teesside Cast Products (now known as Sahaviriya

Steel Industries UK).65 Production at this facility started in April 2012,66 with Sahaviriya receiving

                                                      

63 Email from ***, August 27, 2013.

64 G Steel and GJ Steel have an estimated 2012 capacity of ***.

65 Sahaviriya Steel Industries (United Kingdom) website, found at http://www.ssi‐

steel.co.uk/index.php.  
  

IV‐34

the first slab shipment in ***. ***. Prior to this, Sahaviriya imported slab from various sources,

with varying quality. Sahaviriya noted that ***.

Table IV-21 

Hot-rolled steel: Thai producer Sahaviriya’s capacity, production, shipments, and inventories, 

2007-12, January-June 2012, and January-June 2013

* * * * * * * 

Alternative and downstream products

Sahaviriya ***.

THE INDUSTRY IN UKRAINE

Overview

Two of the four firms identified in the original petition provided a questionnaire

response in the Commission’s original investigations, Ilyich Iron and Steel Works (“Ilyich”) and

Zaporizhstal Iron & Steel Works (“Zaporizhstal”).67 Exports of the subject merchandise to the

U.S. market by these two firms accounted for *** percent of total U.S. imports of subject

merchandise from Ukraine during 2000. Zaporizhstal was the larger of the two producing firms

in Ukraine at that time.68 In the first five‐year reviews and the current reviews the Commission

issued questionnaires to these two same firms, neither of which responded to either requests.

Exports of hot‐rolled steel from Ukraine were subject to tariff or non‐tariff barriers to

trade in countries other than the United States, as presented the following tabulation:69

Product Country Year imposed Barrier (rate) 

Hot-rolled in coils and cut-tolength, nonalloy and alloy Canada 2001 Antidumping: 77.0 percent 

Hot-rolled in coils and cut-tolength, nonalloy Thailand 2003 Antidumping: 30.45 - 67.69 

percent 

                                                            

(...continued)

66 “SSI begins to reap benefits of strategic UK acquisition,” Bangkok Post, November 23, 2012, found

at http://ssi‐steel.com/en/investor‐relations/newsroom/newsroom‐clippings.php. 67 Hot‐Rolled Steel Products from Argentina and South Africa:  Investigation No. 701‐TA‐404 (Final)

and Investigations Nos. 731‐TA‐898 and 905 (Final), USITC Publication 3446, p. VII‐9.

68 Hot‐Rolled Steel Products from Argentina, China, India, Indonesia, Kazakhstan, Netherlands,

Romania, South Africa, Taiwan, Thailand, and Ukraine, Investigations Nos. 701‐TA‐404‐408 (Final) and

731‐TA‐898‐908 (Final), INV‐Y‐141, August 6, 2001, p. VII‐23.

69 Domestic parties’ response to the notice of institution. Information compiled from the WTO’s

semiannual “Definitive Anti Dumping Measures,”for the reporting countries noted in the tabulation and

Canadian Border Services Agency, “Measures in Force Goods subject to anti‐dumping or countervailing

duties,” updated November 21, 2013.
  

IV‐35

Zaporizhstal has hot‐roll steel production capacity of 4.1 million short tons (3.7 million

metric tons).70 Table IV‐22 presents data on Ukraine’s capacity, production, exports, and net

exports for 2009‐12 and Ukraine’s top export markets are presented in table IV‐23.  

Table IV-22 

Hot-rolled steel: Ukrainian capacity, production, exports, and net exports, 2009-12

2009 2010 2011 2012 

Item Quantity (1,000 short tons) 

Capacity *** *** *** ***

Production *** *** *** ***

Exports 3,031 3,448 3,541 3,023

Net exports *** *** *** ***

Source: *** and Global Trade Atlas. 

                                                      

70 “Production structure,” Zaporizhstal website, found at

http://www.zaporizhstal.com/en/about/production/  
  

IV‐36

Table IV-23 

Hot-rolled steel: Ukrainian exports, by market, 2007-12

 Quantity (short tons)

Item 2007 2008 2009 2010 2011 2012

Turkey 1,629,713 1,506,900 640,725 809,245 728,395 638,265 

Russia 450,825 272,349 206,796 280,510 427,585 419,966 

Poland 150,148 117,443 160,009 324,762 387,774 354,854 

Bulgaria 30,851 76,448 14,663 64,500 187,473 216,305 

Greece 4,210 16,238 40,842 115,697 170,561 158,538 

Lebanon 96,095 99,441 178,806 240,980 150,651 123,971 

Belarus 175,056 126,266 79,529 120,219 99,450 112,314 

Pakistan 89,524 44,631 230,302 130,139 17,124 101,251 

Italy 0 0 134,495 196,337 238,548 78,655 

Nigeria 61,431 48,183 58,657 44,745 40,199 69,319 

Iraq 2,294 0 3,689 4,963 32,480 66,651 

Jordan 66,843 25,782 85,017 217,389 61,468 61,662 

Slovakia 43,907 46,131 13,400 30,731 42,339 61,226 

Israel 180,750 105,064 105,870 78,178 100,885 60,676 

India 57,476 22,058 97,507 34,577 168,655 59,257 

United Arab Emirates 195,923 124,680 89,513 102,321 73,687 57,850 

Romania 2,780 5,356 8,764 23,051 42,739 53,712 

Syria 310,566 254,890 225,247 175,508 179,077 53,125 

Bosnia & Herzegovina 70,636 80,549 68 8,811 42,636 43,126 

Egypt 4,085 8,235 26,745 68,553 40,684 39,506 

All others 500,046 636,997 630,566 377,035 308,912 192,583 

 Total 4,123,161 3,617,642 3,031,213 3,448,251 3,541,322 3,022,813 

Value (1,000 dollars)

Turkey 688,752 979,284 247,474 387,979 413,057 318,588 

Russia 191,433 182,078 77,262 135,699 253,114 219,988 

Poland 72,407 74,842 64,110 170,875 237,356 187,994 

Bulgaria 14,074 52,712 5,831 33,222 108,245 105,798 

Greece 2,026 8,044 15,470 55,840 96,052 78,219 

Lebanon 41,392 57,065 60,473 108,334 85,072 60,822 

Belarus 82,312 90,005 31,274 62,251 60,553 59,601 

Pakistan 36,527 25,777 75,523 59,798 8,880 52,142 

Italy 0 0 48,124 96,847 134,827 39,829 

Nigeria 26,765 27,132 20,720 22,141 23,718 34,939 

Iraq 923 0 1,267 2,612 19,294 30,991 

Jordan 29,415 14,958 28,575 100,685 32,533 29,807 

Slovakia 22,480 31,595 5,414 16,521 25,645 32,061 

Israel 75,641 65,619 37,071 36,764 59,852 30,514 

India 22,202 11,241 30,259 14,888 95,663 28,800 

United Arab Emirates 84,795 71,967 33,290 50,630 42,075 30,287 

Romania 1,256 3,759 3,567 11,917 25,490 26,669 

Syria 130,277 136,632 76,196 82,482 96,176 26,072 

Bosnia & Herzegovina 31,217 63,479 26 4,678 25,097 21,107 

Egypt 1,856 6,574 12,975 32,548 23,911 19,318 

All others 222,724 408,479 211,554 183,969 180,758 100,403 

 Total 1,778,473 2,311,243 1,086,454 1,670,682 2,047,368 1,533,951 

Table continued on next page. 
  

IV‐37

Table IV-23--Continued

Hot-rolled steel: Ukrainian exports, by market, 2007-12 

Item 

Unit value (dollars per short ton)

2007 2008 2009 2010 2011 2012

Turkey 423 650 386 479 567 499 

Russia 425 669 374 484 592 524 

Poland 482 637 401 526 612 530 

Bulgaria 456 690 398 515 577 489 

Greece 481 495 379 483 563 493 

Lebanon 431 574 338 450 565 491 

Belarus 470 713 393 518 609 531 

Pakistan 408 578 328 459 519 515 

Italy (1) (1) 358 493 565 506 

Nigeria 436 563 353 495 590 504 

Iraq 402 (

1

) 343 526 594 465 

Jordan 440 580 336 463 529 483 

Slovakia 512 685 404 538 606 524 

Israel 418 625 350 470 593 503 

India 386 510 310 431 567 486 

United Arab Emirates 433 577 372 495 571 524 

Romania 452 702 407 517 596 497 

Syria 419 536 338 470 537 491 

Bosnia & Herzegovina 442 788 378 531 589 489 

Egypt 454 798 485 475 588 489 

All others 445 641 335 488 585 521 

 Average 431 639 358 485 578 507 

1

 Not applicable. 

Source: Global Trade Atlas (HTS 7208.10, 7208.25, 7208.26, 7208.27, 7208.36, 7208.37, 7208.38, 208.39, 7208.40, 

7208.53, 7208.54, 7208.90, 7211.14, and 7211.19). 
  

IV‐38

GLOBAL MARKET

Production

Production increased globally during 2009‐10 by *** percent (*** tons) as the world

was recovering from the global financial crisis (table IV‐24).71 During 2009‐13 global production

increased by *** percent (*** tons). All regions increased production during 2009‐10. However,

production in Europe declined steadily during 2011‐13 by *** percent (*** tons) as end‐user

demand remained weak in this region. Most of the global production increase during 2009‐13

was accounted for by China which produced *** tons more in 2013 than in 2009.  

Table IV-24 

Hot-rolled steel: Global and regional production, 2009-13 

* * * * * * * 

All regions are forecasted to increase production during 2014‐18 (table IV‐25) with

global production expected to increase *** percent (*** tons) with China accounting for ***

percent of the increase (*** tons).  

Table IV-25 

Hot-rolled steel: Forecasted global and regional production, 2014–18 

* * * * * * * 

Consumption

Global consumption increased during 2009‐13 by *** percent (*** tons) as shown in

table IV‐26.72 China alone accounts for about half of the increase (*** tons) but its consumption

increase was less than its production increase (*** tons) during this period. Each year during

the same period, the CIS consistently produced about *** tons a year more than it consumed.

All of the major consuming regions increased consumption relatively steadily during this period

with the exception of Europe whose consumption steadily decreased during 2011‐13 as weak

demand persists in that region. Consumption is predicted to rise steadily both globally and for

all regions during 2014‐17 (table IV‐27).  

Table IV-26 

Hot-rolled steel: Global and regional consumption, 2009 - 2013

* * * * * * * 

                                                      

71 Data for 2007‐08 are not available from ***.

72 Data for 2007‐08 are not available from ***.
  

IV‐39

Table IV-27 

Hot-rolled steel: Forecasted global and regional consumption, 2014 – 2017 

* * * * * * * 

Prices

Published price data are available from several reputable sources. These data, however,

are collected based on different product categories, timing, and commercial considerations,

and so may not be directly comparable with each other. Moreover, such data are distinct from

the pricing data presented in Part V of this report, which are collected directly from U.S.

producers and U.S. importers according to precise product definitions. Average world prices, as

compiled by Management Engineering & Production Services (“MEPS”), are presented in figure

IV‐1.

Figure IV-1 

Average world price for hot-rolled steel, January 2007-July 2013 

Source: Compiled from data published by MEPS, found at 

http://www.meps.co.uk/World%20Carbon%20Price.htm
  

IV‐40

Globally country‐specific and regional transaction prices have generally declined since

2011, and most markets expect prices to continue their decline in the near future (tables IV‐28

and IV‐29).73 In North America, ***. Europe is experiencing ***. In China, ***. In Japan, ***.74

Table IV-28 

Hot-rolled steel: Spot prices for hot-rolled steel, by selected country or region, and by month, 

January 2007- September 2013 

* * * * * * * 

Table IV-29 

Hot-rolled steel: Spot prices for hot-rolled steel, by selected country or region, and by month, 

January 2007- September 2013

* * * * * * * 

Additional global supply and demand factors

Production capacity during 2009‐13 was relatively stable except in Asia. Of the global

capacity increase of *** tons during this period, China accounted for *** and the rest of Asia

accounted for *** (table IV‐30). Little capacity growth is predicted globally and for most regions

during 2014‐17 (table IV‐31). The Middle East will be the only region expected to substantially

increase capacity and the increase will occur during 2015‐17, (*** tons and *** percent).  

Table IV-30 

Hot-rolled steel: Global and regional production capacity, 2009-13

* * * * * * * 

Table IV-31 

Hot-rolled steel: Forecasted global and regional production capacity, 2014-17

* * * * * * * 

Most responding U.S. producers (8 of 11),75 importers (13 of 24), and purchasers (17 of

33) reported that demand outside the U.S. market has fluctuated since January 2007 (table IV‐

32). At least one firm in each respondent group reported that demand outside the United

States had increased, decreased, and not changed. Purchasers cited the improving economy as

the main actor driving increased demand. The only producer reporting increased demand

explained that growth in Asia was greater than the declines elsewhere. The sole importer

reporting an increase in demand outside the United States reported growth in Mexico. Two

foreign producers reported increasing demand and two reported fluctuating demand, while

                                                      

73 Price data were compiled from ***. 74 Information in this section was compiled from ***. 75 One producer reported both that demand had fluctuated and demand had decreased.
  

IV‐41

one reported decreasing demand. Foreign producers reported the same trends for their home

markets. Firms reporting declining demand outside the U.S. market reported that it was caused

by economic conditions/the recession or, specifically, economic conditions in Europe, as well as

an oversupplied market for hot‐rolled steel.

Table IV-32 

Hot-rolled steel: U.S. producer, importer, and purchaser responses regarding demand since 2007 

and anticipated demand through 2014 for hot-rolled steel outside the United States 

Item 

Number of firms reporting 

Increase No Change Decrease Fluctuate

Demand since 2007: 

 U.S. producers 2 1 1 8 

 Importers 3 4 4 13 

 Foreign producers 2 0 1 2 

 Purchasers 5 4 7 17 

Anticipated demand through 2014: 

 U.S. producers 5 2 0 4 

 Importers 8 6 1 10 

Foreign producers 5 0 0 0 

 Purchasers 9 4 2 14 

Source: Compiled from data submitted in response to Commission questionnaires. 

Producers, importers, foreign producers, and purchasers are more optimistic about

future demand outside the United States. More producers, importers, and purchasers

anticipate increased demand through 2014 than reported increased demand since 2007.

Demand is expected to improve with the economy and improvements in specific countries

(particularly developing countries). Firms predicting decreased demand expect substitution of

lightweight materials for fuel economy, a lack of improvements in the EU economy, and

continued oversupply.

World demand for hot‐rolled steel decreased during the 2007‐08 global financial crisis

but began to recover thereafter. During the crisis, demand in important end‐use markets for

hot‐rolled steel, such as automotive and appliances, decreased sharply. Since 2009, global

demand increased (table IV‐26).

***.76 ***.77  ***.78 ***.79  ***.80 ***.81  

With respect to trade, annual exports of hot‐rolled steel are compiled for reporting

countries in the Global Trade Atlas. As shown in table IV‐33, between 2007 and 2012,

worldwide exports decreased by 18 percent (13 million short tons). Top exporters include

                                                      

76 ***. 77 ***. 78 ***.

79 ***.

80 ***.

81 ***.
  

IV‐42

Japan, Korea, and Russia. With respect to imports, top import markets include Korea, United

States, Italy, and Germany (table IV‐34).

Table IV-33 

Hot-rolled steel: Reported worldwide exports, by market, 2007-12 

Reporting country 2007 2008 2009 2010 2011 2012

Quantity (short tons)

United States 1,969,565 2,376,774 1,680,025 2,179,324 1,989,353 1,851,003 

Top exporters: 

Japan 7,803,994 7,801,616 8,011,273 10,177,278 9,699,231 11,378,300 

South Korea 3,657,987 4,123,424 4,703,354 5,261,738 6,917,554 6,690,971 

Russia 5,321,169 4,552,387 6,644,445 6,296,760 6,035,349 5,068,207 

Germany 3,733,691 3,761,272 2,545,257 3,037,055 3,096,813 4,071,703 

Taiwan 2,735,986 2,452,159 2,933,333 2,599,895 3,174,039 3,393,377 

Belgium 5,878,878 5,853,378 2,896,670 3,550,210 3,713,738 3,037,941 

Ukraine 4,123,161 3,617,642 3,031,212 3,448,251 3,541,322 3,022,813 

France 2,784,436 2,040,155 1,118,894 1,382,820 1,454,050 2,726,100 

Netherlands 2,602,530 2,335,653 1,778,631 1,991,300 2,454,218 2,350,350 

Italy 2,549,836 2,275,284 1,643,709 2,015,790 2,211,509 2,210,284 

All other 31,605,415 27,398,513 19,473,821 27,066,393 20,496,075 15,530,154 

 Total 74,766,648 68,588,256 56,460,626 69,006,814 64,783,250 61,331,203 

Value (1,000 dollars)

United States 1,207,962 1,841,632 990,308 1,489,125 1,539,899 1,380,573 

Top exporters: 

Japan 3,870,664 5,515,047 3,884,391 6,063,537 6,632,360 6,898,331 

South Korea 1,953,028 3,040,742 2,427,072 3,222,643 4,729,562 4,095,808 

Russia 2,665,060 3,093,107 2,510,653 3,000,753 3,567,021 2,642,595 

Germany 2,504,058 2,905,337 1,667,227 1,914,825 2,421,227 2,777,930 

Taiwan 1,339,089 1,667,374 1,328,683 1,515,936 2,093,726 1,992,783 

Belgium 3,723,963 4,470,969 1,882,441 2,210,745 2,848,612 2,010,382 

Ukraine 1,778,473 2,311,243 1,086,454 1,670,682 2,047,368 1,533,951 

France 1,449,773 1,549,779 802,410 920,895 1,113,743 1,744,084 

Netherlands 1,559,076 1,832,592 937,365 1,175,733 1,718,990 1,432,539 

Italy 1,483,796 1,719,205 888,238 1,150,608 1,587,583 1,399,305 

All other 16,767,756 21,331,836 9,354,937 15,529,097 14,087,457 9,732,317 

 Total 40,302,699 51,278,864 27,760,180 39,864,578 44,387,548 37,640,599 

Unit value (per short ton)

United States 613 775 589 683 774 746 

Top exporters: 

Japan 496 707 485 596 684 606 

South Korea 534 737 516 612 684 612 

Russia 501 679 378 477 591 521 

Germany 671 772 655 630 782 682 

Taiwan 489 680 453 583 660 587 

Belgium 633 764 650 623 767 662 

Ukraine 431 639 358 485 578 507 

France 521 760 717 666 766 640 

Netherlands 599 785 527 590 700 610 

Italy 582 756 540 571 718 633 

All other 531 779 480 574 687 627 

 Average 539 748 492 578 685 614 

Source: Global Trade Atlas (HTS 7208.10, 7208.25, 7208.26, 7208.27, 7208.36, 7208.37, 7208.38, 208.39, 7208.40, 

7208.53, 7208.54, 7208.90, 7211.14, and 7211.19). 
  

IV‐43

Table IV-33 

Hot-rolled steel: Reported worldwide imports, by market, 2007-12 

Reporting country 2007 2008 2009 2010 2011 2012

Quantity (short tons)

United States 3,389,559 3,646,224 2,294,693 3,114,532 3,578,210 3,871,992 

Top importers: 

South Korea 8,359,167 8,478,830 6,508,045 8,051,880 5,937,138 5,463,537 

Italy 5,226,824 5,581,083 3,337,426 4,359,232 4,919,987 3,342,920 

Germany 4,655,090 4,222,540 2,771,005 3,317,613 3,519,450 3,083,249 

Turkey 5,156,250 4,837,254 3,353,328 3,601,119 3,170,103 2,963,505 

Thailand 2,601,222 2,815,142 1,567,375 2,444,535 2,424,332 2,820,879 

France 4,130,658 3,826,728 2,092,085 2,788,119 2,833,106 2,473,135 

India 3,552,320 2,711,124 3,598,608 3,719,834 2,403,262 2,236,600 

Belgium 4,039,279 2,920,914 949,747 1,866,966 2,312,211 1,939,847 

Japan 1,906,514 1,809,762 1,134,016 1,730,871 1,960,296 1,918,678 

Spain 3,195,675 2,326,308 1,283,139 1,991,233 2,044,361 1,908,505 

All other 21,388,923 25,263,029 21,463,257 28,025,598 27,085,495 25,488,954 

 Total 67,601,482 68,438,939 50,352,724 65,011,533 62,187,952 57,511,799 

Value (1,000 dollars)

United States 1,746,417 2,789,142 1,171,874 1,834,395 2,500,544 2,511,681 

Top importers: 

South Korea 4,181,419 6,490,105 3,258,015 4,845,109 4,132,710 3,361,591 

Italy 2,987,234 4,236,775 1,733,182 2,469,592 3,305,026 1,977,371 

Germany 3,114,965 3,450,788 1,769,538 2,171,177 2,802,666 2,140,215 

Turkey 2,753,236 3,748,568 1,647,287 2,008,582 2,121,982 1,729,993 

Thailand 1,474,122 2,104,480 907,484 1,613,904 1,849,314 2,048,629 

France 2,596,789 2,853,998 1,390,209 1,792,488 2,216,268 1,682,853 

India 2,172,318 2,405,736 1,935,377 2,298,833 1,589,236 1,372,475 

Belgium 2,259,897 2,322,819 556,483 963,055 1,465,831 1,045,828 

Japan 896,174 1,281,340 689,765 1,131,898 1,480,593 1,217,488 

Spain 1,900,883 1,801,033 739,922 1,223,157 1,561,433 1,215,452 

All other 12,980,577 19,101,078 11,589,565 17,518,902 19,691,319 16,721,977 

 Total 39,064,030 52,585,862 27,388,698 39,871,091 44,716,922 37,025,553 

Unit value (per short ton)

United States 515 765 511 589 699 649 

Top importers: 

South Korea 500 765 501 602 696 615 

Italy 572 759 519 567 672 592 

Germany 669 817 639 654 796 694 

Turkey 534 775 491 558 669 584 

Thailand 567 748 579 660 763 726 

France 629 746 665 643 782 680 

India 612 887 538 618 661 614 

Belgium 559 795 586 516 634 539 

Japan 470 708 608 654 755 635 

Spain 595 774 577 614 764 637 

All other 607 756 540 625 727 656 

 Average 578 768 544 613 719 644 

Source: Global Trade Atlas (HTS 7208.10, 7208.25, 7208.26, 7208.27, 7208.36, 7208.37, 7208.38, 208.39, 7208.40, 

7208.53, 7208.54, 7208.90, 7211.14, and 7211.19). 

V‐1

PART V: PRICING DATA

FACTORS AFFECTING PRICES

Hot‐rolled steel prices reflect the quality, material properties, and intended end use of

the steel.  Important pricing factors include the carbon content of the hot‐rolled steel and its

levels of alloy elements; the metallurgical properties of the hot‐rolled steel, such as the purity

and grain structure of the steel; and surface and edge qualities.  These elements typically are

measured in terms of AISI and SAE grades, which generally rate the steel’s chemistry, and ASTM

specifications, which rate the steel for mechanical and physical properties.  Prices also include

additional processing such as pickling and oiling, temper rolling, edge trimming, cutting to size

and weight, and packaging.  Finally, prices can vary depending on the nature of the purchase

agreement, including the quantity purchased; whether the agreement is a spot sale or a longer

term contract; and, at times, surcharges for raw materials, transportation, fuel, and/or energy.

Raw material costs

Raw material cost share

As noted in Part I of this report, there are different processes used to manufacture hot‐

rolled steel.  These were described as the integrated and non‐integrated steelmaking processes.

Nine of 13 responding U.S. producers specifically noted that scrap, iron (either pig iron, iron

pellets, direct reduced iron, or iron ore), and alloys were the primary raw materials used in the

production of hot‐rolled steel.  Coke was identified by four producers and coal by three.  

Additionally, four non‐integrated producers identified purchased steel slabs for re‐rolling as

their primary raw material for hot‐rolled steel.  

Raw materials, as a share of cost of goods sold for domestic producers of hot‐rolled

steel, increased irregularly from 61.2 percent in 2007 to 70.0 percent in 2011 before decreasing

slightly to 69.4 percent in 2012.  The ratio was 68.3 percent in January‐June 2013, compared

with 71.0 percent in January‐June 2012.  

Scrap and iron

Since January 2007, the price of heavy melt scrap steel has varied between a high of

$513 per short ton in May 2008 to a low of $92 per short ton in November 2008 (see figure V‐

1).  In general, prices of scrap steel rose from 2007 to early 2008 and spiked in spring and

summer 2008, then decreased by more than 80 percent in the remainder of 2008.  Since that

time, prices of scrap steel increased until the start of 2011, remained around $400 per short ton

into early 2012 and have been declining slightly since that time.  Prices of hot‐rolled steel sheet
V‐2

have generally followed scrap price movements1 with the exception of 2011, during which time

prices for hot‐rolled steel increased and then decreased while scrap prices remained relatively

steady.   

Figure V-1 

Hot-rolled steel: Steel sheet and heavy melt scrap prices, monthly, January 2007-September 2013 

Source: American Metal Market. 

Integrated producers typically use iron ore instead of scrap to produce hot‐rolled steel.  

Certain of the larger integrated producers own iron mining operations, and therefore use an

internal price for iron ore.  The price of iron ore increased from $54.10 per short ton in 2007 to

$84.15 in 2009 and $90.22 in 2011.  It is estimated to be $91.63 in 2012.2  

Metallurgical coke

Coke combined with iron ore pellets is used to charge the blast furnaces.  Several

integrated steel producers manufacture their own coke from coal stocks, and even sell coke to

other steel companies, while others import coke.  As seen in figure V‐2, Customs import unit

values of coke were rising in 2007 and increased greatly in 2008.  After September 2008, unit

values decreased precipitously and were at early 2008 levels until early 2010.  Since then, unit

values increased until mid‐2011, but have been generally declining since that time.  Domestic

prices of coke compiled by the Department of Energy were slightly higher than import unit

                                                       

1 The correlation coefficients between these two data series, with scrap prices lagged one month, is

0.763.  This indicates that current scrap prices may provide an indication of the direction hot‐rolled steel

prices will move in the following month. 2 Iron Ore, United States Geological Survey, Mineral Commodity Summaries, January 2011 and

January 2013.  Prices are based on estimates from reported values of ore at mines.
V‐3

values but tended to move in similar directions:  $311 per short ton in 2009, $203 in 2010, $432

in 2011, and $396 in 2012.3

Figure V-2 

Coke: Unit values of imports of coke for blast furnaces (on Customs value basis), monthly, 

January 2007-September 2013 

Source: USITC Dataweb, HTS subheading 2704.00.00. 

Anticipated raw material costs

Nine of 12 responding producers indicated that they believe that raw material prices will

continue to be volatile.  Producer *** stated that a new direct‐reduced iron (“DRI”) facility due

to open soon in the United States may have an impact on iron ore prices.4

  Producer ***

anticipates no significant changes in the second half of 2013 for coke or iron ore, but a ***

percent decrease in the price of iron ore in 2014 and no change again in 2015.  With respect to

coke, it anticipates a *** percent increase in 2014 and a *** percent increase in 2015.  

Producer *** expects no significant changes.  Nine of 11 responding importers also expect

continued fluctuations, whereas the other two anticipate declining raw material costs.  Foreign

producers *** anticipated fluctuating raw iron prices (decreasing in the second half of 2013 due

to increased mining of inputs and continuing to decrease by a further 10 percent in 2014, but

then increasing by 3 percent in 2015), whereas *** anticipates increased raw material costs.

                                                       

3 U.S. Department of Energy Quarterly Coal Report, various issues. 4 Nucor’s 2.5 million tons‐per‐year DRI facility on the Mississippi River in Louisiana was expected to

begin production by the end of September 2013.  “Planned expansions at Nucor push ahead,” American

Metal Market, July 19, 2013.  However, one of its storage domes collapsed in late September, pushing

back its opening until the end of 2013.  “Storage Dome Collapse At Nucor Steel Louisiana,” found at

http://www.nucor.com/investor/news/releases/?rid=1859123, retrieved November 19, 2013.
V‐4

Raw material purchase basis

U.S. producers purchase raw materials according to a wide variety of schedules – from

spot market purchases to contracts ranging from one month to five years.  Long‐term raw

material contracts may include quarterly and/or annual price and volume adjustments.  Four of

12 responding producers have changed their raw material purchasing frequency since 2007:  

*** have begun using or have increased the use of contracts for pig iron; *** is purchasing raw

materials using shorter contracts that have variable prices instead of their previous annual

contracts; and *** has pricing that now changes on a quarterly basis rather than an annual

basis.     

A majority of producers, importers, and foreign producers stated that raw material

prices affect the price of hot‐rolled steel.  Some firms noted concurrent price changes or the

inclusion of price mechanisms (e.g., surcharges or price increase pass‐throughs) in their

contracts.  One producer and one importer noted that hot‐rolled steel prices only change if the

raw material price change is large enough.  In contrast, five producers and three importers

stated that hot‐rolled steel prices are affected by demand‐side market considerations or are

not affected by raw material pricing changes.

Raw material surcharges

Six responding producers reported that they had included surcharges in their sales

contracts for hot‐rolled steel to cover changes in the prices of raw materials at some point since

2007, while only one importer had done so.  Most of these surcharges occurred in 2007 and

2008, but have since been integrated into the negotiated price of hot‐rolled steel.  Fifteen of 24

responding purchasers reported paying raw material/scrap surcharges on their purchases of

hot‐rolled steel since 2007, although surcharges were not applied uniformly through June 2013.  

Some indicated that the surcharges have been integrated into pricing, while others indicated

that certain suppliers are still using raw material surcharges (e.g., Evraz, Nucor, and SSAB as

noted by ***, and “generally all US producers” as reported by ***).     

Energy costs

In addition to raw material costs, energy costs are an important factor in hot‐rolled steel

production, especially for mills using electric arc furnaces.  Available data indicate that annual

average industrial prices of electricity (per kilowatt‐hour) generally increased from 6.1 cents in

January 2007 to 6.5 cents in January 2013, and from 6.7 cents to 7.2 cents between July 2007

and July 2013 (figure V‐3).  Natural gas prices (per thousand cubic feet) spiked during mid‐2008

but then declined irregularly through early 2012.  Since then, natural gas prices have been

increasing and are predicted to continue to climb through 2014.  The price for electricity is not

forecasted to vary appreciably from 2012‐13 levels in 2013‐14.  

   
V‐5

Figure V-3 

Industrial natural gas and electricity prices, monthly January 2007-September 2013 and October 

2013-December 2014 (forecast) 

Source: Energy Information Administration, http://www.eia.gov/forecasts/steo/tables/?tableNumber=8#, retrieved 

November 6, 2013. 

Transportation costs to the United States

Overseas transportation costs have declined overall since 2007.  One index to which

parties referred in this proceeding, and often used as a point of reference for overseas shipping

costs, is the Baltic Dry Index.5

  After rising from slightly more than 4,000 at the beginning of

2007 to its peak of more than 11,500 in the first half 2008, the index had fallen to under 1,000

through most of 2013.  Recently, it increased briefly over 2,000, but had declined to around

1,500 in mid‐November 2013. Domestic interested parties submitted that ocean freight for hot‐

rolled steel is currently inexpensive relative to earlier in the review period.6

   

Domestic interested parties reported that transportation costs from subject countries

such as Taiwan or India are approximately the same whether the hot‐rolled steel is shipped to

                                                       

5 The Baltic Dry Index is “a shipping and trade index created by the London‐based Baltic Exchange

that measures changes in the cost to transport raw materials such as metals, grains and fossil fuels by

sea.  The Baltic Exchange directly contacts shipping brokers to assess price levels for a given route,

product to transport and time to delivery (speed).  The Baltic Dry Index is a composite of three sub‐

indexes that measure different sizes of dry bulk carriers (merchant ships) ‐ Capesize, Supramax and

Panamax.  Multiple geographic routes are evaluated for each index to give depth to the index's

composite measurement.  It is also known as the ‘Dry Bulk Index’.”  Found at

http://www.investopedia.com/terms/b/baltic_dry_index.asp, retrieved November 26, 2013.    6 Baltic Dry Index, found at http://www.findata.co.nz/markets/index/bdi/chart.htm, retrieved

November 20, 2013 and domestic interested party Nucor’s posthearing brief, exh. 1, pp. 60‐61.
V‐6

various third country markets or the United States.7  Respondent interested parties disagreed

with this characterization, noting that shipping to the United States is more expensive than

shipping to markets in third countries.8

U.S. inland transportation costs

Thirteen U.S. producers provided usable U.S. transportation cost data.  Transportation

costs in 2012 averaged 5 percent and ranged from 2 to 8 percent of the total delivered cost of

their U.S. shipments.  U.S.‐produced hot‐rolled steel is shipped a variety of distances, though a

large majority in 2012 was shipped less than 100 miles (40.0 percent) or between 101 and

1,000 miles (54.5 percent). Eleven producers reported arranging transportation for purchasers,

whereas four reported that purchasers arrange it themselves.9 The only importer to report

usable U.S. transportation costs indicated that such costs averaged *** percent of total

delivered costs for subject imports.  

Five of 12 responding producers and 3 of 30 responding importers reported using

transportation or fuel surcharges at some point since 2007.  Nineteen of 24 responding

purchasers noted paying fuel surcharges at some time since 2007 on the hot‐rolled steel that

they bought.  Department of Energy diesel indices were most frequently noted as the basis for

these surcharges.   

PRICING PRACTICES

Pricing methods

Pricing basis

The majority of hot‐rolled steel is sold on a spot basis. Thirteen U.S. producers reported

that they set prices for hot‐rolled steel on a transaction‐by‐transaction basis, 11 reported

selling via contracts, and two reported using price lists (table V‐1). Twenty‐four of 25

responding importers also reported setting prices on a transaction‐by‐transaction basis.

                                                      

7 Hearing transcript, p. 74 (Scherrbaum) and domestic interested party Nucor’s posthearing brief,

exh. 1, pp. 60‐64.

8 Hearing transcript, p. 244 (Fan‐Chiang), respondent interested party Shang Chen’s posthearing

brief, exh. 1, p. 1, and respondent interested party Essar’s posthearing brief, exh. 3, p. 3.

9 Some producers reported that their firm and the purchaser arranged transportation.
V‐7

Table V-1 

Hot-rolled steel: U.S. producers’ and importers’ reported price setting methods, by number of 

responding firms1

Method U.S. producers Importers 

Transaction-by-transaction 13 24 

Contract 11 7 

Set price list 2 1 

Other 3 3 1

 The sum of responses may not add up to the total number of responding firms as each firm was instructed to check 

all applicable price setting methods employed.

Source: Compiled from data submitted in response to Commission questionnaires. 

Domestic sales are largely divided between short‐term contract sales and spot sales

(table V‐2). The majority of U.S. producers’ 2012 hot‐rolled steel sales were via spot sales, and

nearly all of the remainder was sold via short‐term contracts.  Importers of subject hot‐rolled

steel10 sold exclusively on a spot basis in 2012.

Table V-2 

Hot-rolled steel: U.S. producers’ and importers’ reported use of contracts and spot sales, by type 

of sale, 2012 

Type of sale U.S. producers Importers 

Long-term contracts 1.9 0.0 

Short-term contracts 41.6 0.0 

Spot sales 56.4 100.0 

Source: Compiled from data submitted in response to Commission questionnaires. 

Contract terms

Twelve U.S. producers reported that the duration of short‐term contracts ranged

between 1 and 12 months (averaging 8 months). Terms also varied: two responding producers’

short‐term contracts fixed price only, whereas six fixed price and quantity and five fixed

quantity only. Two producers reported that prices typically are renegotiable whereas nine

reported that they are not. Eleven producers’ contracts typically did not contain meet‐or‐

release clauses, whereas one did.11

Although no importers reported any 2012 shipments of subject imports pursuant to

contracts, two importers noted terms regarding their typical short‐term sales contracts.  ***

typically fix both price and quantity, price cannot be renegotiated, and the company does not

include meet‐or‐release provisions.  *** only noted that its short‐term contracts include meet‐

or‐release provisions.    

                                                      

10 These firms reported importing hot‐rolled steel from ***. 11 Not all producers which indicated that they used short‐term contracts responded to all portions of

this question.
V‐8

Sales terms and discounts

All 13 responding producers12 but only 3 of 9 responding importers reported that the

majority of their sales were on an f.o.b. basis. The remaining six importers reported that most

of their sales were on a delivered basis.  

Both U.S. producers and U.S. importers typically sell hot‐rolled steel on a net 30

payment basis. Nearly half (6 of 13) of responding producers do not offer discounts to

purchasers of hot‐rolled steel except for early payment discounts, whereas four offer quantity

or annual volume discounts.  Discounts may be included in the sales negotiations.  Two

producers indicated that discounts may be granted in competitive situations.  The industry

standard payment terms producers offered are 1⁄2 percent 10/net 30 days. Twenty‐three of 25

responding importers offer no discounts.  

PRICE DATA

The Commission requested U.S. producers and U.S. importers of hot‐rolled steel to

provide quarterly data for the total quantity and value of hot‐rolled steel that was shipped to

unrelated customers in the U.S. market. Quarterly data were requested for the period January

2007–June 2013. The products for which pricing data were requested are as follows:

Product 1.–Hot‐rolled carbon steel plate in coils, as‐rolled (unprocessed), not pickled or temper‐

rolled, not high strength, produced to AISI‐1006‐1025 grade (including, but not limited to, ASTM

A36), 0.187" through 0.625" in nominal or actual thickness, 40" through 72" in width.

Product 2.–Hot‐rolled carbon sheet in coils, commercial quality, SAE 1006‐1015 or ASTM A1011

equivalent, not high‐strength, not pickled and oiled, not temper‐rolled, 0.090" through 0.171" in

nominal or actual thickness, 40" to 72" in width.

Product 3.–Hot‐rolled carbon steel sheet in coils, commercial quality SAE 1006‐1015 or ASTM

A1011 equivalent, pickled and oiled, temper‐rolled, not high strength, 0.090" through 0.171" in

nominal or actual thickness, 40" to 72" in width.

Product 4.–Hot‐rolled carbon steel plate in coils, as‐rolled (unprocessed), not pickled or temper‐

rolled, in high strength low alloy qualities according to SAE J 1392, ASTM A‐572/656/1011,

0.187" through 0.625" in nominal or actual thickness 40" through 72" in width.

Thirteen U.S. producers and three importers provided usable price data for sales of the

four products, although not all firms reported prices for all products and all quarters.13

Reported pricing products represented 35.3 percent of U.S. open market (i.e., non‐captive)

shipments of U.S.‐produced products. Among subject imports, they represent *** percent of

imported product from India and *** percent from Thailand.  No pricing data were received for

                                                      

12 Two producers additionally noted that they also sell on a delivered basis.

13 Data suspected of being in error are not included.  Despite persistent attempts to allow *** to

correct its highly erroneous data for ***, it was unable to correct the errors.   As a result, data from this

producer in this year are ***.  ***.
V‐9

sales of imports from China, Indonesia, Taiwan, or Ukraine.  Price data are presented in tables

V‐3 to V‐5 and figures V‐4 to V‐7. All data are reported in short tons and dollars per short ton.

Table V-3 

Hot-rolled steel: Weighted-average f.o.b. prices and quantities of domestic and imported product 

1,1

 and margins of underselling/(overselling), by quarter, January 2007-June 2013 

Period 

United States India Thailand 

Price 

(per short 

ton) 

Quantity 

(short 

tons) 

Price

(per 

short 

ton) 

Quantity 

(short 

tons) 

Margin 

(percent) 

Price 

(per short 

ton) 

Quantity 

(short 

tons) 

Margin 

(percent) 

2007: 

Jan.-Mar. $520 730,017 $*** *** *** $*** *** ***

Apr.-June 569 773,448 -- 0 -- -- 0 --

July-Sept. 548 776,730 -- 0 -- -- 0 --

Oct.-Dec. 532 790,281 *** *** *** -- 0 --

2008: 

Jan.-Mar. 588 951,066 -- 0 -- -- 0 --

Apr.-June 804 1,073,614 -- 0 -- -- 0 --

July-Sept. 978 917,832 -- 0 -- -- 0 --

Oct.-Dec. 741 371,050 -- 0 -- -- 0 --

2009: 

Jan.-Mar. 527 360,521 -- 0 -- -- 0 --

Apr.-June 403 400,392 -- 0 -- -- 0 --

July-Sept. 445 701,439 -- 0 -- -- 0 --

Oct.-Dec. 497 651,687 -- 0 -- -- 0 --

2010: 

Jan.-Mar. 543 819,317 -- 0 -- -- 0 --

Apr.-June 639 736,659 -- 0 -- -- 0 --

July-Sept. 584 621,078 -- 0 -- -- 0 --

Oct.-Dec. 547 614,844 -- 0 -- -- 0 --

2011: 

Jan.-Mar. 669 600,217 -- 0 -- -- 0 --

Apr.-June 788 573,621 -- 0 -- -- 0 --

July-Sept. 677 687,438 -- 0 -- -- 0 --

Oct.-Dec. 640 695,868 -- 0 -- -- 0 --

2012: 

Jan.-Mar. 666 721,691 -- 0 -- -- 0 --

Apr.-June 664 569,383 -- 0 -- -- 0 --

July-Sept. 614 481,872 -- 0 -- -- 0 --

Oct.-Dec. 589 476,975 -- 0 -- -- 0 --

2013: 

Jan.-Mar. 599 532,893 -- 0 -- -- 0 --

Apr.-June 575 548,470 -- 0 -- -- 0 --

1

 Product 1: Hot-rolled carbon steel plate in coils, as-rolled (unprocessed), not pickled or temper-rolled, not high 

strength, produced to AISI-1006-1025 grade (including, but not limited to, ASTM A36), 0.187" through 0.625" in 

nominal or actual thickness, 40" through 72" in width. 

Source: Compiled from data submitted in response to Commission questionnaires.
V‐10

Table V-4 

Hot-rolled steel: Weighted-average f.o.b. prices and quantities of domestic and imported product 

2,1

 and margins of underselling/(overselling), by quarter, January 2007-June 2013 

Period 

United States India 

Price 

(per short ton) 

Quantity

(short tons) 

Price

(per short ton) 

Quantity 

(short tons) 

Margin

(percent) 

2007: 

Jan.-Mar. $500 554,298 -- 0 --

Apr.-June 556 697,842 -- 0 --

July-Sept. 548 652,982 -- 0 --

Oct.-Dec. 521 612,441 $*** *** ***

2008: 

Jan.-Mar. 582 662,212 -- 0 --

Apr.-June 777 717,958 -- 0 --

July-Sept. 947 539,742 -- 0 --

Oct.-Dec. 650 250,563 -- 0 --

2009: 

Jan.-Mar. 503 249,101 -- 0 --

Apr.-June 414 306,820 -- 0 --

July-Sept. 441 521,534 -- 0 --

Oct.-Dec. 493 497,931 -- 0 --

2010: 

Jan.-Mar. 539 601,770 -- 0 --

Apr.-June 628 576,451 -- 0 --

July-Sept. 571 497,654 -- 0 --

Oct.-Dec. 536 578,279 -- 0 --

2011: 

Jan.-Mar. 646 671,600 -- 0 --

Apr.-June 750 591,021 -- 0 --

July-Sept. 664 624,363 -- 0 --

Oct.-Dec. 622 648,956 -- 0 --

2012: 

Jan.-Mar. 654 611,070 -- 0 --

Apr.-June 646 587,693 -- 0 --

July-Sept. 597 577,316 -- 0 --

Oct.-Dec. 575 582,203 -- 0 --

2013: 

Jan.-Mar. 583 577,300 -- 0 --

Apr.-June 564 561,793 -- 0 -- 1

 Product 2: Hot-rolled carbon sheet in coils, commercial quality, SAE 1006-1015 or ASTM A1011 equivalent, not 

high-strength, not pickled and oiled, not temper-rolled, 0.090" through 0.171" in nominal or actual thickness, 40" to 

72" in width.

Source: Compiled from data submitted in response to Commission questionnaires.
V‐11

Table V-5 

Hot-rolled steel: Weighted-average f.o.b. prices and quantities of domestic products 3 and 4,1

 and 

margins of underselling/(overselling), by quarter, January 2007-June 2013 

Period 

United States product 3 United States product 4 

Price 

(per short ton) 

Quantity

(short tons) 

Price

(per short ton) 

Quantity

(short tons) 

2007: 

Jan.-Mar. $581 223,833 $569 416,845

Apr.-June 630 227,465 621 442,034

July-Sept. 578 264,711 617 437,414

Oct.-Dec. 580 228,537 601 443,060

2008: 

Jan.-Mar. 626 300,256 605 498,787

Apr.-June 836 255,430 805 533,910

July-Sept. 1,029 197,832 1,020 521,430

Oct.-Dec. 790 126,208 830 305,063

2009: 

Jan.-Mar. 579 110,682 739 223,440

Apr.-June 468 115,225 541 137,710

July-Sept. 498 173,781 629 289,606

Oct.-Dec. 549 172,259 742 387,346

2010: 

Jan.-Mar. 592 228,466 603 349,133

Apr.-June 692 187,105 678 348,728

July-Sept. 659 199,747 660 352,256

Oct.-Dec. 607 175,243 603 324,706

2011: 

Jan.-Mar. 694 299,514 694 374,932

Apr.-June 827 238,664 828 417,833

July-Sept. 738 267,613 736 404,546

Oct.-Dec. 678 246,162 685 383,506

2012: 

Jan.-Mar. 704 323,515 720 463,487

Apr.-June 716 263,479 710 400,614

July-Sept. 657 269,469 641 331,250

Oct.-Dec. 631 261,608 635 338,330

2013: 

Jan.-Mar. 638 300,666 634 353,109

Apr.-June 624 251,387 610 327,886 1

 Product 3: Hot-rolled carbon steel sheet in coils, commercial quality SAE 1006-1015 or ASTM A1011 equivalent, 

pickled and oiled, temper-rolled, not high strength, 0.090" through 0.171" in nominal or actual thickness, 40" to 72" in 

width. 

Product 4: Hot-rolled carbon steel plate in coils, as-rolled (unprocessed), not pickled or temper-rolled, in high strength 

low alloy qualities according to SAE J 1392, ASTM A-572/656/1011, 0.187" through 0.625" in nominal or actual 

thickness 40" through 72" in width. 

Source: Compiled from data submitted in response to Commission questionnaires.
V‐12

Figure V-4 

Hot-rolled steel: Weighted-average f.o.b. prices and quantities of domestic and imported product 

1, by quarter, January 2007-June 2013 

*            *            *            *           *            *            *

Figure V-5 

Hot-rolled steel: Weighted-average f.o.b. prices and quantities of domestic and imported product 

2, by quarter, January 2007-June 2013 

*            *            *            *           *            *            *

 
V‐13

Figure V-6 

Hot-rolled steel: Weighted-average f.o.b. prices and quantities of domestic product 3, by quarter, 

January 2007-June 2013 

Product 3.-- Hot-rolled carbon steel sheet in coils, commercial quality SAE 1006-1015 or ASTM A1011 equivalent, 

pickled and oiled, temper-rolled, not high strength, 0.090" through 0.171" in nominal or actual thickness, 40" to 72" in 

width. 

 
V‐14

Figure V-7 

Hot-rolled steel: Weighted-average f.o.b. prices and quantities of domestic product 4, by quarter, 

January 2007-June 2013 

Product 4.-- Hot-rolled carbon steel plate in coils, as-rolled (unprocessed), not pickled or temper-rolled, in high 

strength low alloy qualities according to SAE J 1392, ASTM A-572/656/1011, 0.187" through 0.625" in nominal or 

actual thickness 40" through 72" in width. 

Source: Table V-5. 
V‐15

Price trends

In general, prices peaked in mid‐2008, but decreased sharply between the third quarter

of 2008 and the second quarter of 2009.  Prices then increased until the second quarter of

2011,14 and have declined irregularly since that time.  As shown in figure V‐8, prices for all four

domestic pricing products were very similar.15  Changes in the pricing of product 3 mirrored

those for products 1 and 2, although the price of product 3 was always slightly higher than the

price of products 1 and 2.  Product 4, the only high‐strength low‐alloy pricing product, moved in

line with the other three products and was nearly equivalent to prices of product 3, except

during 2009.

Table V‐6 summarizes the price trends by country and by product. Despite a general

decline during the two most recent years, prices are higher in the most recent quarter (the

second quarter of 2013) for all four products than they were in the first quarter of 2007.  

Differences between the first quarter of data and the last quarter of data ranged between 7.3

and 12.8 percent.  Since price data for hot‐rolled steel imported from subject countries were

reported only for 2007, price trends were not available.   

 

                                                      

14 Prices declined for two quarters in the second half of 2010.

15 Correlation coefficients among the prices of products 1, 2, and 3 ranged between 0.986 and 0.995,

signifying nearly complete correlation.  When comparing prices of products 1, 2, and 3 with those of

product 4, correlation coefficients were also very high, ranging between 0.845 and 0.875.  

These prices also correlate well with American Metal Markets hot‐rolled sheet (Midwest) pricing

series, even though the collected price data are national and the AMM series is regional.  The

correlation coefficients for products 1‐3 ranged between 0.910 and 0.931.  For product 4, the

correlation coefficient was somewhat lower (0.774).
V‐16

Figure V-8 

Hot-rolled steel: Weighted-average f.o.b. prices and quantities of domestic products 1-4, by 

quarter, January 2007-June 2013 

Product 1.-- Hot-rolled carbon steel plate in coils, as-rolled (unprocessed), not pickled or temper-rolled, not high 

strength, produced to AISI-1006-1025 grade (including, but not limited to, ASTM A36), 0.187" through 0.625" in 

nominal or actual thickness, 40" through 72" in width. 

Product 2.-- Hot-rolled carbon sheet in coils, commercial quality, SAE 1006-1015 or ASTM A1011 equivalent, not 

high-strength, not pickled and oiled, not temper-rolled, 0.090" through 0.171" in nominal or actual thickness, 40" to 

72" in width. 

Product 3.-- Hot-rolled carbon steel sheet in coils, commercial quality SAE 1006-1015 or ASTM A1011 equivalent, 

pickled and oiled, temper-rolled, not high strength, 0.090" through 0.171" in nominal or actual thickness, 40" to 72" in 

width. 

Product 4.-- Hot-rolled carbon steel plate in coils, as-rolled (unprocessed), not pickled or temper-rolled, in high 

strength low alloy qualities according to SAE J 1392, ASTM A-572/656/1011, 0.187" through 0.625" in nominal or 

actual thickness 40" through 72" in width. 

Source: Tables V-3 - V-5. 

   
V‐17

Table V-6 

Hot-rolled steel: Summary of weighted-average f.o.b. prices for products 1 through 4 from the 

United States and subject countries 

Item 

Number of 

quarters 

Low price 

(per short ton) 

High price 

(per short ton) 

Change in 

price1

 (percent) 

Product 1 

United States 26 $403 $978 10.7 

India 2 *** *** -- 

Thailand 1 *** *** -- 

Product 2 

United States 26 414 947 12.8 

India 1 *** *** -- 

Product 3 

United States 26 468 1,029 7.3 

Product 4 

United States 26 541 1,020 7.3 1

 Percentage change is based on unrounded data. Changes are not reported for products for which data were not 

available in both the first and last year of the period. 

Source: Compiled from data submitted in response to Commission questionnaires. 

Price comparisons

As shown in table V‐7, prices for hot‐rolled steel imported from India and Thailand were

above prices for U.S.‐produced product in four comparisons; margins of overselling ranged

from *** to *** percent.

Table V-7 

Hot-rolled steel: Instances of underselling/overselling and the range and average margin by 

country, January 2007-June 2013 

Product 

and 

Country 

Number of 

quarters of 

underselling 

Number of 

quarters of 

(overselling) 

Margins of underselling Margins of (overselling) 

Average 

(percent) 

Range (percent) 

Average 

(percent) 

Range (percent) 

Min Max Min Max

India 

1 0 2 -- -- -- *** *** *** 

2 0 1 -- -- -- *** *** *** 

Thailand 

1 0 1 -- -- -- *** *** *** 

Source: Compiled from data submitted in response to Commission questionnaires. 

In the original investigations, there were 301 possible price comparisons between U.S.‐

produced hot‐rolled steel and imported hot‐rolled steel from China, India, Indonesia, Taiwan,

Thailand, and Ukraine.   
V‐18

 For China, there were 35 instances of underselling and 23 instances of

overselling, with average margins of underselling ranging from *** percent and

average margins of overselling ranging from *** percent.   

 For India, there were 29 instances of underselling, with average margins ranging

from *** percent and 9 instances of overselling, with average margins of ranging

from *** percent.   

 For Indonesia, there were 20 instances of underselling and 2 instances of

overselling, with average margins of underselling ranging from *** percent and

average margins of overselling of *** percent.  

 For Taiwan, there were 15 instances of underselling with average margins of

underselling ranging from *** percent and 22 instances of overselling with

average margins ranging from *** percent.  

 For Thailand, there were 12 instances of underselling, with average margins of

underselling ranging from *** percent and 6 instances of overselling with

average margins of overselling ranging from *** percent.

 For Ukraine, there were 28 instances of underselling and no instances of

overselling, with average margins of underselling ranging from *** percent.16

In the first reviews, there were 37 possible price comparisons between U.S.‐produced

hot‐rolled steel and imports from five of the subject countries. No data were available for

imports from Ukraine.  

 For China, there were 6 instances of underselling and 4 instances of overselling,

with average margins of underselling ranging from 2.1 to 45.4 percent and

average margins of overselling ranging from (15.3) to (29.8) percent.   

 For India, there were 7 instances of underselling, with average margins ranging

from 1.4 to 27.3 percent, and 2 instances of overselling, with average margins of

*** and *** percent.   

 For Indonesia, there were 2 instances of underselling and 6 instances of

overselling, with average margins of underselling of *** percent and average

margins of overselling ranging from (29.1) to (74.7) percent.  

 For Taiwan, there were no instances of underselling and 5 instances of

overselling with average margins ranging from (42.2) to (59.8) percent.

 For Thailand, there were 2 instances of underselling, average margins of

underselling ranging from *** percent compared with 3 instances of overselling

with average margins of overselling ranging from (11.4) to (28.2) percent.17

                                                      

16 Hot‐Rolled Steel Products from Argentina, China, India, Indonesia, Kazakhstan, Netherlands,

Romania, South Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐

898‐908 (Final), USITC Confidential Staff Report, Memorandum No. INV‐Y‐141, August 2001. 17 Hot‐Rolled Steel Products from Argentina, China, India, Indonesia, Kazakhstan, Romania, South

Africa, Taiwan, Thailand, and Ukraine, Investigation Nos. 701‐TA‐404‐408 and 731‐TA‐898‐903 and 905‐

908 (Review), USITC Confidential Staff Report, Memorandum No. INV‐EE‐136, September 2007.
  

A‐1

APPENDIX A

FEDERAL REGISTER NOTICES  

A‐3

The Commission makes available notices relevant to its investigations and reviews on its

website, www.usitc.gov. In addition, the following tabulation presents, in chronological order,

Federal Register notices issued by the Commission and Commerce during the current

proceeding.  

Citation Title Link

77 FR 66439

November 5, 2012.

Initiation of Five‐Year (“Sunset”)

Review

http://www.gpo.gov/fdsys/pkg/FR‐

2012‐11‐05/pdf/2012‐26960.pdf

77 FR 66078

November 1, 2012

Hot‐Rolled Steel Products From

China, India, Indonesia, Taiwan,

Thailand, and Ukraine;

Institution of Five‐Year Reviews

Concerning the Countervailing

Duty Orders on Hot‐Rolled Steel

Products From India, Indonesia,

and Thailand and Antidumping

Duty Orders on Hot‐Rolled Steel

Products From China, India,

Indonesia, Taiwan, Thailand,

and Ukraine

http://www.gpo.gov/fdsys/pkg/FR‐

2012‐11‐01/pdf/2012‐26803.pdf  

78 FR 11901

February 20, 2013

Hot‐Rolled Steel Products From

China, India, Indonesia, Taiwan,

Thailand, and Ukraine; Notice of

Commission Determination To

Conduct Full Five‐year Reviews

http://www.gpo.gov/fdsys/pkg/FR‐

2013‐02‐20/pdf/2013‐03798.pdf  

78 FR 24435

April 25, 2013

Hot‐Rolled Steel Products From

China, India, Indonesia, Taiwan,

Thailand, and Ukraine

http://www.gpo.gov/fdsys/pkg/FR‐

2013‐04‐25/pdf/2013‐09780.pdf  

Continued on next page.

 
A‐4

Citation Title Link

78 FR 15703

March 12, 2013

Certain Hot‐Rolled Carbon Steel

Flat Products From India,

Indonesia, the People's Republic

of China, Taiwan, Thailand, and

Ukraine; Final Results of the

Expedited Second Sunset

Reviews of the Antidumping

Duty Orders

http://www.gpo.gov/fdsys/pkg/FR‐

2013‐03‐12/pdf/2013‐05647.pdf  

78 FR 16252

March 14, 2013

Certain Hot‐Rolled Carbon Steel

Flat Products From India,

Indonesia, and Thailand: Final

Results of Expedited Sunset

Reviews

http://www.gpo.gov/fdsys/pkg/FR‐

2013‐03‐14/pdf/2013‐05932.pdf  

78 FR 64008

October 25, 2013

Hot‐Rolled Steel Products From

China, India, Indonesia, Taiwan,

Thailand, and Ukraine; Revised

Schedule for the Subject Five

Year Reviews

http://www.gpo.gov/fdsys/pkg/FR‐

2013‐10‐25/pdf/2013‐25129.pdf 

Note.–The press release announcing the Commission’s determinations concerning adequacy

and the conduct of a full or expedited review can be found at

http://www.usitc.gov/press_room/news_release/2013/er0204ll1.htm.  A summary of the

Commission’s votes concerning adequacy and the conduct of a full or expedited review and the

Commission’s explanation of its determinations can be found at can be found at

http://pubapps2.usitc.gov/sunset/caseProf/show/10201

http://pubapps2.usitc.gov/sunset/caseProf/show/10202.

http://pubapps2.usitc.gov/sunset/caseProf/show/10203;

http://pubapps2.usitc.gov/sunset/caseProf/show/10204;

http://pubapps2.usitc.gov/sunset/caseProf/show/10205;

http://pubapps2.usitc.gov/sunset/caseProf/show/10206;

http://pubapps2.usitc.gov/sunset/caseProf/show/10207;

http://pubapps2.usitc.gov/sunset/caseProf/show/10208;

http://pubapps2.usitc.gov/sunset/caseProf/show/10209.
B-1 

APPENDIX B

HEARING WITNESSES

B‐3

CALENDAR OF PUBLIC HEARING

Those listed below appeared as witnesses at the United States International Trade

Commission’s hearing:

    Subject:    Hot‐Rolled Steel Products from China, India, Indonesia,

Taiwan, Thailand, and Ukraine

    Inv. Nos.:    701‐TA‐405, 406, and 408 and 731‐TA‐899‐901 and 906‐

908 (Second Review)

    Date and Time: October 31, 2013 ‐ 9:30 a.m.

Sessions were held in connection with these reviews in the Main Hearing Room (room

101), 500 E Street, S.W., Washington, DC.

CONGRESSIONAL APPEARANCES:

The Honorable Joe Donnelly, United States Senator, Indiana

The Honorable Peter J. Visclosky, U.S. Representative, 1st District, Indiana

The Honorable Todd Rokita, U.S. Representative, 4th District, Indiana

EMBASSY WITNESS:

Royal Thai Embassy

Washington, DC

Perapat Uthaisri, Minister‐Counselor (Commercial)

OPENING REMARKS:

In Support of Continuation (Alan H. Price, Wiley Rein LLP)

In Opposition to Continuation (Frederick P. Waite, Vorys, Sater,

Seymour and Pease LLP)
B‐4

In Support of the Continuation of

    Antidumping and Countervailing Duty Orders:

Schagrin Associates   

Washington, DC

on behalf of

Gallatin Steel

SSAB Enterprises LLC

Steel Dynamics, Inc.

    Glenn Gilmore, Trade Supervisor, SSAB Enterprises LLC

    Mark Millett, President and Chief Executive Officer, Steel

    Dynamics, Inc.

    Thomas Scruggs, Commercial Manager, Flat Rolled Division,  

Steel Dynamics, Inc.

      Roger B. Schagrin    ) – OF COUNSEL

Wiley Rein LLP

Washington, DC

on behalf of

Nucor Corporation

    John J. Ferriola, President and Chief Executive Officer,

    Nucor Corporation  

    Rick Blume, General Manager, Commercial Steelmaking

    Group, Nucor Corporation

      Alan H. Price     )

      Timothy C. Brightbill    ) – OF COUNSEL

      Maureen E. Thorson )
B‐5

In Support of the Continuation of   

    Antidumping and Countervailing Duty Orders (continued):   

Kelley Drye Warren LLP   

Washington, DC

on behalf of

ArcelorMittal USA LLC (“AMUSA”)

    Daniel Mull, Executive Vice President for Sales and

    Marketing, AMUSA

    Buster Yonych, Director, Hot‐Rolled Products Sales

    and Marketing, AMUSA

    David McCall, District 1 Director, United Steel, Paper  

and Forestry, Rubber, Manufacturing, Energy,  

Allied Industrial and Service Workers  

International Union (USW)

Gina Beck, Economist, Georgetown Economic Services

      Paul C. Rosenthal    )

      Kathleen W. Cannnon ) – OF COUNSEL

      R. Alan Luberda    )  

   

Skadden, Arps, Slate, Meagher & Flom LLP   

Washington, DC

on behalf of

United States Steel Corporation

    Mario Longhi, President and Chief Executive Officer, United

    States Steel Corporation

    Joseph R. Scherrbaum, Jr., Vice President ‐ Sales, United

    States Steel Corporation

Robert Y. Kopf, General Manager, North American Flat‐ 

    Rolled Marketing, United States Steel Corporation

      Robert E. Lighthizer    )

      James C. Hecht    ) – OF COUNSEL

      Stephen P. Vaughn    )  
B‐6

In Opposition to the Continuation of

    Antidumping and Countervailing Duty Orders:

Hughes Hubbard & Reed LLP                      

Washington, DC

on behalf of

Sahaviriya Steel Industries Public Company Limited

      Robert L. LaFrankie    ) – OF COUNSEL

          

Vorys, Sater, Seymour and Pease LLP                      

Washington, DC

on behalf of

Shang Chen Steel Co., Ltd. (“Shang Chen Steel”)

    Dr. Kenneth Button, Senior Vice President, Economic

    Consulting Services LLC

      Frederick P. Waite    ) – OF COUNSEL

            

Dentons US LLP                      

Washington, DC

on behalf of

Essar Steel India Limited

      Mark P. Lunn     ) – OF COUNSEL
B‐7

In Opposition to the Continuation of   

    Antidumping and Countervailing Duty Orders (continued):

NON PARTY WITNESS:

Wu & Partners

Taipei, Taiwan

on behalf of

China Steel Corporation

Chung Hung Steel Corporation

Dragon Steel Corporation

    C.K. (Chin Kang) Fan Chiang, Manager, Sales Section‐4,

    Marketing Department, China Steel Corporation, Taiwan  

    Chien‐Chung Chu, Administrator, Foreign Marketing Research

    Section, Marketing Administration Department, China Steel  

Corporation

      LunFan Lin    ) – OF COUNSEL

REBUTTAL/CLOSING REMARKS:

      

Petitioners (Paul C. Rosenthal, Kelley Drye Warren LLP)

Respondents (Mark P. Lunn, Dentons US LLP)

  

C‐1

APPENDIX C

SUMMARY DATA

Table C-1

Jan-Jun

2007 2008 2009 2010 2011 2012 2012 2013 2007-12 2007-08 2008-09 2009-10 2010-11 2011-12 2012-13

U.S. consumption quantity:

Amount............................................................ 62,549,603 57,229,936 37,966,100 53,075,072 56,543,057 59,970,608 30,935,988 29,899,722 (4.1) (8.5) (33.7) 39.8 6.5 6.1 (3.3)

Producers' share (1)........................................ 94.6 93.7 94.0 94.3 93.7 93.6 93.7 94.3 (1.0) (1.0) 0.3 0.3 (0.5) (0.1) 0.6

Importers' share (1):

China............................................................ 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) (0.0) 0.0 (0.0) 0.0 (0.0)

India.............................................................. 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) (0.0) (0.0) 0.0 0.0 0.0 0.0

Indonesia...................................................... 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Taiwan.......................................................... 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) (0.0) 0.0 (0.0) (0.0)

Thailand........................................................ 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) 0.0 (0.0) 0.0 0.0 0.0 0.0

Ukraine......................................................... 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) 0.0 0.0 0.0 0.0

 Subject sources......................................... 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) (0.0) (0.0) 0.0 0.0 0.0 (0.0)

All others sources.......................................... 5.3 6.3 6.0 5.7 6.3 6.3 6.3 5.6 1.0 1.0 (0.3) (0.3) 0.5 0.1 (0.6)

Total imports........................................... 5.4 6.3 6.0 5.7 6.3 6.4 6.3 5.7 1.0 1.0 (0.3) (0.3) 0.5 0.1 (0.6)

U.S. consumption value:

Amount............................................................ 34,326,741 44,098,077 20,040,932 32,069,775 40,042,464 39,881,974 21,594,198 18,636,829 16.2 28.5 (54.6) 60.0 24.9 (0.4) (13.7)

Producers' share (1)........................................ 94.7 93.5 93.9 94.2 93.6 93.5 93.6 93.8 (1.2) (1.2) 0.5 0.2 (0.6) (0.1) 0.2

Importers' share (1):

China............................................................ 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) 0.0 0.0 (0.0) 0.0 (0.0)

India.............................................................. 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) (0.0) (0.0) 0.0 0.0 0.0 0.0

Indonesia...................................................... 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Taiwan.......................................................... 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) (0.0) 0.0 (0.0) (0.0)

Thailand........................................................ 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) 0.0 (0.0) 0.0 0.0 0.0 0.0

Ukraine......................................................... 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) 0.0 0.0 0.0 0.0

 Subject sources......................................... 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 (0.0) (0.0) (0.0) 0.0 0.0 0.0 (0.0)

All others sources.......................................... 5.3 6.5 6.1 5.8 6.4 6.5 6.4 6.1 1.2 1.2 (0.5) (0.2) 0.6 0.1 (0.2)

Total imports........................................... 5.3 6.5 6.1 5.8 6.4 6.5 6.4 6.2 1.2 1.2 (0.5) (0.2) 0.6 0.1 (0.2)

U.S. imports of from: cde fgh i j

China:

IMP St Quantity......................................................... 1,093 247 159 1,631 541 2,419 1,763 1,481 3 121.3 (77.4) (35.8) 927.8 (66.8) 347.0 (16.0)

IMP St Value............................................................. 732 222 172 1,469 649 3,027 2,040 1,683 13 313.2 (69.7) (22.3) 752.5 (55.8) 366.2 (17.5)

Unit value...................................................... $670 $897 $1,085 $900 $1,200 $1,251 $1,157 $1,136 86.7 33.9 21.0 (17.1) 33.3 4.3 (1.8)

India:

IMP St Quantity......................................................... 17,665 185 000000 4 (100.0) (99.0) (100.0) (2) (2) (2) (2)

IMP St Value............................................................. 10,464 291 000000 14 (100.0) (97.2) (100.0) (2) (2) (2) (2)

Unit value...................................................... $592 $1,571 $0 $0 $0 $0 $0 $0 (100.0) 165.2 (100.0) (2) (2) (2) (2)

Indonesia:

IMP St Quantity......................................................... 00000000 5 (2) (2) (2) (2) (2) (2) (2)

IMP St Value............................................................. 00000000 15 (2) (2) (2) (2) (2) (2) (2)

Unit value...................................................... $0 $0 $0 $0 $0 $0 $0 $0 (2) (2) (2) (2) (2) (2) (2)

Taiwan:

IMP St Quantity......................................................... 241 655 95 45 2,483 560 492 26 6 132.5 172.1 (85.5) (52.6) 5,413.2 (77.5) (94.7)

IMP St Value............................................................. 142 484 101 39 1,976 414 358 19 16 191.3 240.8 (79.1) (61.0) 4,903.8 (79.1) (94.7)

Unit value...................................................... $590 $739 $1,065 $877 $796 $739 $728 $726 25.2 25.2 44.2 (17.7) (9.2) (7.2) (0.3)

Thailand:

IMP St Quantity......................................................... 2,171 5,632 000000 7 (100.0) 159.5 (100.0) (2) (2) (2) (2)

IMP St Value............................................................. 1,075 4,685 000000 17 (100.0) 335.9 (100.0) (2) (2) (2) (2)

Unit value...................................................... $495 $832 $0 $0 $0 $0 $0 $0 (100.0) 68.0 (100.0) (2) (2) (2) (2)

Ukraine:

IMP St Quantity......................................................... 0 19 0 0 0 806 0 0 8 (2) (2) (100.0) (2) (2) (2) (2)

IMP St Value............................................................. 0 44 0 0 0 624 0 0 18 (2) (2) (100.0) (2) (2) (2) (2)

Unit value...................................................... $0 $2,316 $0 $0 $0 $774 $0 $0 (2) (2) (100.0) (2) (2) (2) (2)

Subtotal, Subject

IMP St Quantity......................................................... 21,169 6,739 254 1,676 3,024 3,784 2,256 1,507 9 (82.1) (68.2) (96.2) 560.7 80.4 25.2 (33.2)

IMP St Value............................................................. 12,413 5,726 274 1,508 2,625 4,064 2,398 1,702 19 (67.3) (53.9) (95.2) 451.5 74.1 54.8 (29.0)

Unit value...................................................... $586 $850 $1,078 $900 $868 $1,074 $1,063 $1,129 83.1 44.9 26.9 (16.5) (3.5) 23.7 6.2

All other sources:

IMP St Quantity......................................................... 3,327,507 3,618,209 2,273,854 3,035,620 3,535,471 3,806,535 1,947,026 1,688,597 10 14.4 8.7 (37.2) 33.5 16.5 7.7 (13.3)

IMP St Value............................................................. 1,819,256 2,880,457 1,215,906 1,867,911 2,578,646 2,598,160 1,372,570 1,145,933 20 42.8 58.3 (57.8) 53.6 38.0 0.8 (16.5)

Unit value...................................................... $547 $796 $535 $615 $729 $683 $705 $679 24.8 45.6 (32.8) 15.1 18.5 (6.4) (3.7)

Total imports:

IMP St Quantity......................................................... 3,348,676 3,624,948 2,274,108 3,037,296 3,538,495 3,810,320 1,949,281 1,690,104 11 13.8 8.3 (37.3) 33.6 16.5 7.7 (13.3)

IMP St Value............................................................. 1,831,669 2,886,183 1,216,179 1,869,419 2,581,271 2,602,224 1,374,968 1,147,635 21 42.1 57.6 (57.9) 53.7 38.1 0.8 (16.5)

Unit value...................................................... $547 $796 $535 $615 $729 $683 $705 $679 24.9 45.6 (32.8) 15.1 18.5 (6.4) (3.7)

U.S. producers':

100 Average capacity quantity................................ 80,382,246 72,818,689 70,408,591 70,418,659 72,451,936 74,840,642 37,030,805 37,518,879 293 (6.9) (9.4) (3.3) 0.0 2.9 3.3 1.3

Production quantity.......................................... 60,698,008 54,012,619 37,219,428 51,664,655 54,213,932 57,000,441 29,394,056 28,554,588 295 (6.1) (11.0) (31.1) 38.8 4.9 5.1 (2.9)

Capacity utilization (1)...................................... 75.5 74.2 52.9 73.4 74.8 76.2 79.4 76.1 312 0.7 (1.3) (21.3) 20.5 1.5 1.3 (3.3)

U.S. shipments:

Quantity......................................................... 59,200,927 53,604,988 35,691,992 50,037,776 53,004,562 56,160,288 28,986,707 28,209,618 322 (5.1) (9.5) (33.4) 40.2 5.9 6.0 (2.7)

Value............................................................. 32,495,072 41,211,894 18,824,753 30,200,356 37,461,193 37,279,750 20,219,230 17,489,194 323 14.7 26.8 (54.3) 60.4 24.0 (0.5) (13.5)

Unit value...................................................... $549 $769 $527 $604 $707 $664 $698 $620 324 20.9 40.1 (31.4) 14.4 17.1 (6.1) (11.1)

Export shipments:

Quantity......................................................... 1,456,322 1,249,300 1,101,366 1,522,803 1,054,556 822,525 391,614 430,255 302 (43.5) (14.2) (11.8) 38.3 (30.7) (22.0) 9.9

Value............................................................. 792,319 1,050,565 551,028 926,180 794,300 587,861 295,512 278,856 303 (25.8) 32.6 (47.5) 68.1 (14.2) (26.0) (5.6)

Unit value...................................................... $544 $841 $500 $608 $753 $715 $755 $648 320 31.4 54.6 (40.5) 21.6 23.8 (5.1) (14.1)

Ending inventory quantity................................. 1,785,483 943,817 1,369,887 1,473,964 1,627,207 1,644,836 1,642,943 1,558,942 304 (7.9) (47.1) 45.1 7.6 10.4 1.1 (5.1)

Inventories/total shipments (1)......................... 2.9 1.7 3.7 2.9 3.0 2.9 2.8 2.7 341 (0.1) (1.2) 2.0 (0.9) 0.2 (0.1) (0.1)

Production workers.......................................... 22,372 21,844 18,453 19,179 20,146 20,650 20,469 20,839 308 (7.7) (2.4) (15.5) 3.9 5.0 2.5 1.8

Hours worked (1,000s).................................... 47,316 45,956 34,894 42,020 42,435 43,840 21,432 22,648 309 (7.3) (2.9) (24.1) 20.4 1.0 3.3 5.7

Wages paid ($1,000)....................................... 1,559,477 1,606,431 1,147,072 1,427,443 1,500,221 1,582,994 797,637 783,567 310 1.5 3.0 (28.6) 24.4 5.1 5.5 (1.8)

Productivity (short tons per 1,000 hours).......... 1,283 1,175 1,067 1,230 1,278 1,300 1,372 1,261 345 1.4 (8.4) (9.2) 15.3 3.9 1.8 (8.1)

Unit labor costs................................................ $25.69 $29.74 $30.82 $27.63 $27.67 $27.77 $27.14 $27.44 347 8.1 15.8 3.6 (10.4) 0.2 0.4 1.1

Net sales:

Quantity......................................................... 60,527,590 55,270,071 36,703,429 51,427,741 53,739,873 56,359,493 29,271,009 28,479,002 585 (6.9) (8.7) (33.6) 40.1 4.5 4.9 (2.7)

Value............................................................. 33,293,098 42,058,970 19,683,182 31,093,634 38,038,929 37,637,053 20,490,507 17,723,398 589 13.0 26.3 (53.2) 58.0 22.3 (1.1) (13.5)

Unit value...................................................... $550 $761 $536 $605 $708 $668 $700 $622 21.4 38.3 (29.5) 12.7 17.1 (5.7) (11.1)

Cost of goods sold (COGS)............................. 29,566,504 35,663,364 20,821,586 29,225,992 33,992,832 34,244,450 18,088,380 16,329,999 593 15.8 20.6 (41.6) 40.4 16.3 0.7 (9.7)

Gross profit or (loss)........................................ 3,726,594 6,395,606 (1,138,404) 1,867,642 4,046,097 3,392,603 2,402,127 1,393,399 594 (9.0) 71.6 (

2

) (2) 116.6 (16.2) (42.0)

SG&A expenses.............................................. 874,510 878,826 644,733 717,369 909,680 1,009,994 490,201 452,258 597 15.5 0.5 (26.6) 11.3 26.8 11.0 (7.7)

Operating income or (loss)............................... 2,852,084 5,516,780 (1,783,137) 1,150,273 3,136,417 2,382,609 1,911,926 941,141 598 (16.5) 93.4 (

2

) (2) 172.7 (24.0) (50.8)

Capital expenditures........................................ 1,718,461 1,554,619 871,549 1,170,595 1,418,839 990,601 525,984 275,808 903 (42.4) (9.5) (43.9) 34.3 21.2 (30.2) (47.6)

Unit COGS....................................................... $488 $645 $567 $568 $633 $608 $618 $573 24.4 32.1 (12.1) 0.2 11.3 (3.9) (7.2)

Unit SG&A expenses....................................... $14 $16 $18 $14 $17 $18 $17 $16 24.0 10.1 10.5 (20.6) 21.4 5.9 (5.2)

Unit operating income or (loss)........................ $47 $100 ($49) $22 $58 $42 $65 $33 (10.3) 111.8 (

2

) (2) 160.9 (27.6) (49.4)

COGS/sales (1)............................................... 88.8 84.8 105.8 94.0 89.4 91.0 88.3 92.1 2.2 (4.0) 21.0 (11.8) (4.6) 1.6 3.9

Operating income or (loss)/sales (1)................ 8.6 13.1 (9.1) 3.7 8.2 6.3 9.3 5.3 (2.2) 4.6 (22.2) 12.8 4.5 (1.9) (4.0)

(1) Report data are in percent and period changes are in percentage points.

(2) Undefined. 

C-3

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)

Calendar year January to June

Report data

Calendar year

Period changes

Source : Compiled from data submitted in response to Commission questionnaires and from adjusted official Commerce statistics.

Hot-rolled steel: Summary data concerning the U.S. market, 2007-12, January to June 2012, and January to June 2013

  

D‐1

APPENDIX D

RESPONSES OF U.S. PRODUCERS, U.S. IMPORTERS, U.S. PURCHASERS, AND

FOREIGN PRODUCERS CONCERNING SIGNIFICANCE OF THE AD/CVD ORDERS

AND THE LIKELY AFFECTS OF REVOCATION

D‐3

This section is confidential in its entirety

* * * * * * * 

E‐1

APPENDIX E

HOT‐ROLLED STEEL: RESULTS OF OPERATIONS OF U.S. PRODUCERS

(VALUATION OF INTERNAL CONSUMPTION AND TRANSFERS TO RELATED

FIRMS BASED ON COST PLUS DOWNSTREAM PROFIT)

E‐3

This appendix presents the U.S. steel industry’s financial results on hot‐rolled steel using

a second valuation methodology for internal consumption and transfers to related firms from

that presented in Part III of the report, which reflected constructed fair market value. Here, the

value of hot‐rolled steel that is consumed internally or transferred to related firms reflects the

underlying cost of the hot‐rolled steel plus an amount of the gross profit of downstream

products as allocated based on relative cost (“cost plus allocated gross profit of downstream

products”).1

The data are presented in table E‐1 and the variance analysis is presented in table E‐2.

Differences in operating income or (loss) as compared with the data presented in table III‐11

are due to the differing unit values used for internal consumption and transfers. Operating

income based on constructed fair market value exceeded operating income based on cost plus

downstream profit value in four of the six yearly periods (2007, 2008, 2011, and 2012) and both

interim periods, with differences ranging from $735.1 million (25.8 percent) in 2007 to $2.0

billion (36.1 percent) in 2008. Operating income based on cost plus downstream profit

exceeded operating income based on fair market value in 2009 ($121.2 million or 6.8 percent)

and 2010 (the operating loss was less by 2.4 percent or $27.4 million).

 1 The Commission’s questionnaire instructed firms to construct a value for their internal

consumption and transfers based upon the ratio of the cost of producing hot‐rolled steel to the cost of

producing the downstream product times the unit gross profit margin of the downstream product. Total

COGS is approximately the same in dollars and unit values as depicted in table III‐10, presented earlier.

Although not all firms allocated the same SG&A expenses to their operations on hot‐rolled steel based

on cost plus downstream profit, staff does not believe the differences are meaningful.  
E‐4

Table E-1 

Hot-rolled steel: Results of operations of U.S. producers (valuation of consumption and transfers to related 

firms based on cost plus downstream profit), fiscal years 2007-12, January-June 2012, and January-June 

2013

Fiscal year January-June 

Item 2007 2008 2009 2010 2011 2012 2012 2013 

Quantity (short tons) 

Commercial sales 24,965,498 22,668,149 14,158,533 21,056,849 22,793,026 23,755,568 12,392,886 12,175,796 

Internal consumption 33,488,847 30,748,010 21,558,968 28,761,445 29,375,124 31,121,549 16,092,079 15,560,396 

Related co. transfers 2,073,245 1,853,912 985,928 1,609,447 1,571,723 1,482,376 786,044 742,810 

 Total net sales 60,527,590 55,270,071 36,703,429 51,427,741 53,739,873 56,359,493 29,271,009 28,479,002 

Value ($1,000) 

Trade sales 13,777,075 17,332,445 7,809,854 12,685,975 16,217,989 15,990,303 8,686,215 7,577,540 

Internal consumption 17,565,212 21,240,684 11,429,215 17,455,129 19,503,321 19,797,441 10,597,249 9,497,168 

Related co. transfers 1,215,752 1,496,476 565,312 980,102 1,132,070 1,006,612 558,053 461,396 

 Total net sales 32,558,039 40,069,605 19,804,381 31,121,206 36,853,380 36,794,356 19,841,517 17,536,104 

Cost of goods sold: 

 Raw materials 18,097,033 23,631,867 13,196,600 19,567,115 23,811,902 23,779,815 12,881,167 11,186,616 

 Direct labor 2,365,989 2,344,705 1,862,478 2,250,701 2,411,575 2,623,781 1,337,118 1,273,895 

 Other factory costs 9,103,481 9,686,793 5,762,508 7,408,369 7,769,355 7,840,854 3,914,266 3,902,368 

 Total COGS 29,566,503 35,663,365 20,821,586 29,226,185 33,992,832 34,244,450 18,132,551 16,362,879 

Gross profit 2,991,536 4,406,240 (1,017,205) 1,895,021 2,860,548 2,549,906 1,708,966 1,173,225 

SG&A expenses 874,510 878,636 644,733 717,369 909,683 1,009,994 490,742 452,317 

Operating income or 

(loss) 2,117,026 3,527,604 (1,661,938) 1,177,652 1,950,865 1,539,912 1,218,224 720,908 

Other income items (1,181,395) (1,649,321) (1,055,012) (828,103) (886,090) (1,036,876) (250,887) (309,400)

Net income or (loss) 935,631 1,878,283 (2,716,950) 349,549 1,064,775 503,036 967,337 411,508 

Depreciation/amortization 893,781 875,110 955,270 1,015,028 888,116 694,366 447,018 457,857 

Cash flow 1,829,412 2,753,393 (1,761,680) 1,364,577 1,952,891 1,197,402 1,414,355 869,365 

Ratio to net sales (percent) 

Cost of goods sold: 

 Raw materials 55.6 59.0 66.6 62.9 64.6 64.6 64.9 63.8 

 Direct labor 7.3 5.9 9.4 7.2 6.5 7.1 6.7 7.3 

 Other factory costs 28.0 24.2 29.1 23.8 21.1 21.3 19.7 22.3 

 Total COGS 90.8 89.0 105.1 93.9 92.2 93.1 91.4 93.3 

Gross profit 9.2 11.0 (5.1) 6.1 7.8 6.9 8.6 6.7 

SG&A expenses 2.7 2.2 3.3 2.3 2.5 2.7 2.5 2.6 

Operating income or 

(loss) 6.5 8.8 (8.4) 3.8 5.3 4.2 6.1 4.1 

Net income or (loss) 2.9 4.7 (13.7) 1.1 2.9 1.4 4.9 2.3 

Table continued on next page. 
E‐5

Table E-1 

Hot-rolled steel: Results of operations of U.S. producers (valuation of consumption and transfers 

to related firms based on cost plus downstream profit), fiscal years 2007-12, January-June 2012, 

and January-June 2013 

 Fiscal year January-June 

Item 2007 2008 2009 2010 2011 2012 2012 2013 

Average unit value (dollars per short ton) 

Trade sales 552 765 552 602 712 673 701 622 

Internal consumption 525 691 530 607 664 636 659 610 

Related co. transfers 586 807 573 609 720 679 710 621 

 Total net sales 538 725 540 605 686 653 678 616 

Cost of goods sold: 

 Raw materials 299 428 360 380 443 422 440 393 

 Direct labor 39 42 51 44 45 47 46 45 

 Other factory costs 150 175 157 144 145 139 134 137 

 Total COGS 488 645 567 568 633 608 619 575 

Gross profit 49 80 (28) 37 53 45 58 41 

SG&A expenses 14 16 18 14 17 18 17 16 

Operating income or (loss) 35 64 (45) 23 36 27 42 25 

Number of firms reporting: 

Operating losses 3 *** 11 3 3 *** *** ***

Data 14 14 14 13 14 14 14 14

Note.--*** 

Source: Compiled from data submitted in response to Commission questionnaires. 
E‐6

Table E-2 

Hot-rolled steel: Variance analysis on the financial results operations of U.S. producers (valuation 

of internal consumption and transfers to related firms based on cost plus downstream profit ), 

fiscal years 2007-12, January-June 2012, and January-June 2013 

Between fiscal years Jan.-June 

Item 2007-12 2007-08 2008-09 2009-10 2010-11 2011-12 2012-13 

 Value ($1,000) 

 Trade sales: 

 Price variance 2,880,921 4,823,150 (3,015,997) 1,071,006 2,486,031 (912,566) (956,516)

 Volume variance (667,693) (1,267,780) (6,506,594) 3,805,115 1,045,983 684,880 (152,159)

 Trade sales 2,213,228 3,555,370 (9,522,591) 4,876,121 3,532,014 (227,686) (1,108,675)

 Internal consumption: 

 Price variance 3,473,899 5,113,067 (3,463,691) 2,207,612 1,675,754 (865,401) (749,947)

 Volume variance (1,241,670) (1,437,595) (6,347,778) 3,818,302 372,438 1,159,521 (350,134)

 Internal consumption 2,232,229 3,675,472 (9,811,469) 6,025,914 2,048,192 294,120 (1,100,081)

 Transfers: 

 Price variance 137,346 409,341 (230,528) 57,276 174,941 (61,104) (65,963)

 Volume variance (346,486) (128,617) (700,636) 357,514 (22,973) (64,354) (30,694)

 Transfer variance (209,140) 280,724 (931,164) 414,790 151,968 (125,458) (96,657)

 Total net sales: 

 Price variance 6,478,353 10,339,607 (6,804,810) 3,371,903 4,333,000 (1,855,490) (1,768,547)

 Volume variance (2,242,036) (2,828,041) (13,460,414) 7,944,922 1,399,174 1,796,466 (536,866)

 Total net sales 4,236,317 7,511,566 (20,265,224) 11,316,825 5,732,174 (59,024) (2,305,413)

Cost of sales: 

 Cost variance (6,713,978) (8,665,054) 2,861,535 (51,605) (3,452,671) 1,405,407 1,279,046 

 Volume variance 2,036,031 2,568,192 11,980,244 (8,352,994) (1,313,976) (1,657,025) 490,626 

 Total cost variance (4,677,947) (6,096,862) 14,841,779 (8,404,599) (4,766,647) (251,618) 1,769,672 

Gross profit variance (441,630) 1,414,704 (5,423,445) 2,912,226 965,527 (310,642) (535,741)

SG&A expenses: 

 Expense variance (195,705) (80,087) (61,253) 186,011 (160,062) (55,967) 25,147 

 Volume variance 60,221 75,961 295,156 (258,647) (32,252) (44,344) 13,278 

 Total SG&A variance (135,484) (4,126) 233,903 (72,636) (192,314) (100,311) 38,425 

Operating income variance (577,114) 1,410,578 (5,189,542) 2,839,590 773,213 (410,953) (497,316)

Summarized as: 

 Price variance 6,478,353 10,339,607 (6,804,810) 3,371,903 4,333,000 (1,855,490) (1,768,547)

 Net cost/expense 

variance (6,909,683) (8,745,141) 2,800,282 134,407 (3,612,733) 1,349,439 1,304,193 

 Net volume variance (145,784) (183,888) (1,185,013) (666,720) 52,946 95,097 (32,962)

Note.--Unfavorable variances are shown in parentheses; all others are favorable. The data are comparable to changes 

in operating income as presented in table E-1. 

Source: Compiled from data submitted in response to Commission questionnaires.