U.S. International Trade Commission

Publication 4472 June 2014

Washington, DC 20436

Carbon and Certain Alloy Steel Wire Rod 

from Brazil, Indonesia, Mexico, Moldova, 

Trinidad & Tobago, and Ukraine

Investigation Nos. 701-TA-417 and 

731-TA-953, 957-959, 961, and 962 (Second Review)
U.S. International Trade Commission

COMMISSIONERS 

 

Irving A. Williamson, Chairman 

Dean A. Pinkert 

David S. Johanson 

Meredith M. Broadbent 

F. Scott Kieff 

Rhonda K. Schmidtlein

Robert B. Koopman

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Director of Operations

Mary Messer, Investigator 

Karl Tsuji, Industry Analyst 

Aimee Larsen, Economist 

David Boyland, Accountant 

Mara Alexander, Statistician 

Carolyn Holmes, Statistical Assistant 

David Fishberg, Attorney 

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

Washington, DC 20436 

www.usitc.gov

Publication 4472 June 2014

Carbon and Certain Alloy Steel Wire Rod 

from Brazil, Indonesia, Mexico, Moldova, 

Trinidad & Tobago, and Ukraine

Investigation Nos. 701-TA-417 and 

731-TA-953, 957-959, 961, and 962 (Second Review)

CONTENTS

Page

i

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

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

Separate and dissenting views of Chairman Irving A. Williamson and  

     Commissioner David S. Johanson regarding cumulation for Ukraine ................................. 51

Separate and dissenting views of Commissioner David S. Johanson ...................................... 55

Part I: Introduction and overview.......................................................................................... I‐1

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

The original investigations ........................................................................................................ I‐3

The first five‐year review .......................................................................................................... I‐4

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

Related investigations............................................................................................................... I‐9

Title VII investigations ........................................................................................................... I‐9

Safeguard investigation....................................................................................................... I‐12

Statutory criteria and organization of the report................................................................... I‐12

Statutory criteria ................................................................................................................. I‐12

Organization of report......................................................................................................... I‐14

Commerce’s reviews............................................................................................................... I‐15

Administrative reviews........................................................................................................ I‐15

Changed circumstances reviews ......................................................................................... I‐18

Scope inquiry reviews.......................................................................................................... I‐18

Anti‐circumvention Inquiry ................................................................................................. I‐18

Five‐year reviews................................................................................................................. I‐19

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

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

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

The product............................................................................................................................. I‐26

Description and applications............................................................................................... I‐26

Manufacturing processes.................................................................................................... I‐30

Domestic like product issues................................................................................................... I‐36

U.S. market participants.......................................................................................................... I‐37

U.S. producers..................................................................................................................... I‐37

U.S. importers...................................................................................................................... I‐39

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

Apparent U.S. consumption and U.S. market shares.............................................................. I‐41

Merchant market apparent U.S. consumption and U.S. market shares................................. I‐41
CONTENTS

Page

ii

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

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

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

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

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

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

U.S. demand ....................................................................................................................... II‐11

Substitutability issues............................................................................................................. II‐14

Lead times .......................................................................................................................... II‐15

Knowledge of country sources........................................................................................... II‐15

Factors affecting purchasing decisions............................................................................... II‐16

Comparisons of domestic products, subject imports, and nonsubject imports................ II‐19

Elasticity estimates................................................................................................................. II‐26

U.S. supply elasticity........................................................................................................... II‐26

U.S. demand elasticity ........................................................................................................ II‐26

Substitution elasticity ......................................................................................................... II‐26

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

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

Background.............................................................................................................................. III‐1

Changes in existing operations ............................................................................................... III‐1

Anticipated Changes in existing operations............................................................................ III‐3

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

Constraints on capacity ........................................................................................................... III‐4

Alternative products................................................................................................................ III‐5

U.S. producers’ U.S. shipments and exports........................................................................... III‐5

U.S. producers’ U.S. shipments, by application ...................................................................... III‐8

U.S. producers’ inventories..................................................................................................... III‐9

U.S. producers’ imports and purchases................................................................................ III‐10

U.S. employment, wages, and productivity .......................................................................... III‐11

Financial experience of U.S. producers................................................................................. III‐12

Background........................................................................................................................ III‐12

Operations on wire rod ..................................................................................................... III‐13

Capital expenditures and research and development expenses...................................... III‐20
CONTENTS

Page

iii

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

U.S. shipments of imports, by application ..............................................................................IV‐7

U.S. importers’ imports subsequent to December 31, 2013 ..................................................IV‐8

U.S. importers’ inventories .....................................................................................................IV‐9

Cumulation considerations .....................................................................................................IV‐9

Fungibility ............................................................................................................................ IV‐9

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

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

Subject country producers....................................................................................................IV‐11

The industry in Brazil.............................................................................................................IV‐13

Overview............................................................................................................................IV‐13

Operations on wire rod .....................................................................................................IV‐15

The industry in Indonesia......................................................................................................IV‐19

Overview............................................................................................................................IV‐19

Operations on wire rod .....................................................................................................IV‐21

The industry in Mexico..........................................................................................................IV‐24

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

Operations on wire rod .....................................................................................................IV‐27

The industry in Moldova .......................................................................................................IV‐33

Overview............................................................................................................................IV‐33

Operations on wire rod .....................................................................................................IV‐34

The industry in Trinidad & Tobago........................................................................................IV‐37

Overview............................................................................................................................IV‐37

Operations on wire rod .....................................................................................................IV‐37

The industry in Ukraine .........................................................................................................IV‐41

Overview............................................................................................................................IV‐41

Operations on wire rod .....................................................................................................IV‐43

Global market........................................................................................................................IV‐47

Production.............................................................................................................................IV‐47

Consumption .........................................................................................................................IV‐47

Prices.....................................................................................................................................IV‐49

Additional global supply and demand factors ......................................................................IV‐52
CONTENTS

Page

iv

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

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

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

Transportation costs to the U.S. market..............................................................................V‐3

U.S. inland transportation costs...........................................................................................V‐4

Pricing practices .......................................................................................................................V‐4

Pricing methods....................................................................................................................V‐4

Sales terms and discounts....................................................................................................V‐5

Price leadership ....................................................................................................................V‐5

Price data..................................................................................................................................V‐6

Price trends.........................................................................................................................V‐11

Price comparisons ..............................................................................................................V‐12

Appendixes

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

B. List of hearing witnesses (reserved) .....................................................................................  B‐1

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

D. Comments by U.S. producers, importers, purchasers, and foreign producers  

   regarding the effects of the orders and the likely effects of revocation .............................. D‐1

E. Financial results on merchant market sales as reported in the most recently completed

     preliminary‐phase investigations.........................................................................................  E‐1

F. Smaller diameter wire rod from Deacero.............................................................................  F‐1

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

be published and therefore has been deleted from this report. Such deletions are indicated by

asterisks.
UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation Nos. 701‐TA‐417 and 731‐TA‐953, 957‐959, 961, and 962 (Second Review)

CARBON AND CERTAIN ALLOY STEEL WIRE ROD FROM   

BRAZIL, INDONESIA, MEXICO, MOLDOVA, TRINIDAD AND TOBAGO, AND UKRAINE

DETERMINATIONS

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 order

on carbon and certain alloy steel wire rod (“wire rod”) from Brazil and the antidumping duty

orders on wire rod from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago 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 determines, pursuant to section

751(c) of the Tariff Act of 1930 (19 U.S.C. § 1675(c)), that revocation of the antidumping duty

order on wire rod from Ukraine 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.2

BACKGROUND

The Commission instituted these reviews on June 3, 2013 (78 FR 33103) and determined

on September 6, 2013 that it would conduct full reviews (78 FR 60316, October 1, 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 December 18, 2013 (78 FR 76653).    The hearing was held in Washington,

DC, on April 22, 2014, 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 Chairman Irving A. Williamson and Commissioner David S. Johanson dissented with respect to

subject imports from Ukraine, finding that revocation of the antidumping duty order on wire rod from

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. Commissioner David S. Johanson also dissented

with respect to subject imports from Mexico, finding that revocation of the antidumping duty order on

wire rod from Mexico 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. Commissioner Rhonda K. Schmidtlein

did not participate in these reviews.

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

order on carbon and certain alloy steel wire rod (“wire rod”) from Brazil and the antidumping

duty orders on wire rod from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago

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  We determine that revocation of the  

antidumping duty order on wire rod from Ukraine 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.2 3

I. Background

Original Investigations.  In October 2002, the Commission found that an industry in the

United States was materially injured by reason of subject imports of wire rod from Brazil,

Canada, Indonesia, Mexico, Moldova, Trinidad and Tobago, and Ukraine.

4

  Commerce issued

antidumping and countervailing duty orders covering the subject merchandise on October 29,

2002.5 6

                                                       

1 Chairman Williamson determines that revocation of the countervailing duty order on wire rod

from Brazil and the antidumping duty orders on wire rod from Brazil, Indonesia, Mexico, Moldova,

Trinidad and Tobago, 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.  Except as otherwise

noted, he joins all sections of these views except for section VIII. 2 Commissioner Johanson determines that revocation of the countervailing duty order on wire

rod from Brazil and the antidumping duty orders on wire rod from Brazil, Indonesia, Moldova, Trinidad

and Tobago, 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.  He determines that revocation of

the antidumping duty order on wire rod from Mexico 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.  

He joins sections I, II, III (A), (B), (C), IV, V, VI and VII, except as otherwise noted.

3 Commissioner Schmidtlein did not participate in these reviews. 4 Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Germany, Indonesia, Mexico,

Moldova, Trinidad and Tobago, and Ukraine, Inv. Nos. 701‐TA‐417 and 731‐TA‐953, 954, 956‐959, 961,

and 962 (Final), USITC Pub. 3546 (Oct. 2002) (“Original Determinations”).    5 67 Fed. Reg. 64871 (Oct. 29, 2002) (countervailing duty order on subject imports from Brazil),

67 Fed. Reg. 65944‐65947 (Oct. 29, 2002) (antidumping duty orders on subject imports from Brazil,

Canada, Indonesia, Mexico, Moldova, Trinidad and Tobago, and Ukraine).

6 The only litigation regarding the Commission’s original determinations concerning the subject

imports at issue in these reviews was an appeal of the affirmative determination on subject imports

from Trinidad and Tobago.  USITC Pub. 3546 at 36‐38.  The U.S. Court of International Trade (“CIT”)

affirmed this determination.  Caribbean Ispat Ltd. v. United States, 366 F. Supp. 2d 1300 (Ct. Int’l Trade

2005).  However, the United States Court of Appeals for the Federal Circuit (“Federal Circuit”) vacated

(Continued...)
4

First Reviews.  The Commission instituted its first five‐year review of the orders in

September 2007 and conducted full reviews.7  The Commission determined that revocation of

the countervailing duty order on subject imports from Brazil and the antidumping orders on

subject imports from Brazil, Indonesia, Mexico, Moldova, Trinidad and Tobago, 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.8

  Commerce issued a continuation of the

antidumping and countervailing duty orders covering the merchandise from these subject

countries on July 30, 2008.9

   

Current Reviews.  The Commission instituted these five‐year reviews on June 3, 2013.  

The Commission received a consolidated response to the notice of institution from domestic

producers Gerdau Ameristeel US Inc. (“Gerdau”), ArcelorMittal USA, LLC (“ArcelorMittal USA”),

Keystone Consolidated Industries, Inc. (“Keystone”), Charter Steel (“Charter”), and Evraz Pueblo

(“Evraz”) (collectively, “Gerdau Parties”) and Nucor Corp. (“Nucor”).  It received a response

from Deacero S.A.P.I. de C.V. , a producer and exporter of subject merchandise from Mexico,

and Deacero USA Inc. (“Deacero USA”), a U.S. importer of subject merchandise from Mexico

(collectively, “Deacero”), and a response from Ternium Mexico, S.A. de C.V. (“Ternium”), also a

producer and exporter of subject merchandise from Mexico.  On September 6, 2013, the

Commission determined that the domestic interested party group response was adequate for

all reviews and the respondent interested party group response was adequate for the review

                                                                                                                                                                              

(...Continued)

and remanded so that the Commission could (1) ascertain whether imports from subject countries other

than Trinidad and Tobago were an alternative cause of injury to the domestic industry and (2) conduct

an analysis under the decision in Bratsk Aluminum Smelter v. United States, 444 F.3d 1369 (Fed. Cir.

2006).  Caribbean Ispat Ltd. v. United States, 450 F.3d 1336 (Fed. Cir. 2006).  On first remand, the

Commission reached a negative determination applying the replacement/benefit test it perceived was

mandated by the Bratsk.  Carbon and Certain Alloy Steel Wire Rod from Trinidad and Tobago, Inv. No.

731‐TA‐961 (Final) (Remand), USITC Pub. 3903 (Jan. 2007).  The CIT affirmed.  Mittal Steel Point Lisas

Ltd. v. United States, 495 F. Supp. 2d 1374 (Ct. Int’l Trade 2007).  On appeal, the Federal Circuit again

vacated and remanded.  Mittal Steel Point Lisas Ltd. v. United States, 542 F.3d 867 (Fed. Cir. 2008).  On

second remand the Commission reached an affirmative determination.6

  The CIT affirmed.  Carbon and

Certain Alloy Steel Wire Rod from Trinidad and Tobago, Inv. No. 731‐TA‐961 (Final) (Second Remand),

USITC Pub. 4170 (June 2010).    7 72 Fed. Reg. 73880 (Dec. 28, 2007).

8 Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Indonesia, Mexico, Moldova,

Trinidad and Tobago, and Ukraine, Inv. Nos. 701‐TA‐417 and 731‐TA‐953, 954, 956‐959, 961, and 962

(Final), USITC Pub. 4014 (June 2008) (“First Review Determinations”).  The Commission found that

revocation of the antidumping duty order on subject imports from Canada 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.  Id.  Commerce subsequently revoked this order on July 30, 2008.  73 Fed. Reg. 44223

(July 30, 2008).

9 73 Fed. Reg. 44218 (July 30, 2008).
5

on the order on subject imports from Mexico and inadequate for all other reviews.10  The

Commission determined to conduct full reviews of the orders on wire rod from Brazil,

Indonesia, Moldova, Trinidad and Tobago, and Ukraine in order to promote administrative

efficiency in light of the Commission’s determination to conduct a full review of the order on

wire rod from Mexico.11

Parties to the Proceedings.  The Commission received prehearing and posthearing briefs

from each of Gerdau Parties and Nucor (collectively, “Domestic Producers”).  Representatives

of Gerdau Parties and Nucor, as well as a representative from USW Local 7898, a labor union

representing U.S. wire rod production workers, appeared at the Commission hearing.   

The Commission received several sets of briefs from parties that support revocation of

the orders.  Deacero filed prehearing and posthearing briefs.  Public Joint Stock Company Iron

and Steel Works (“Yenakiieve”), a producer of subject merchandise from  Ukraine, filed

prehearing and posthearing briefs.  The American Wire Producers Ass’n (“AWPA”), an

association of U.S. purchasers of wire rod, filed a prehearing brief.  Representatives from

Deacero and Yenakiieve, as well as representatives from the Embassy of Mexico and the

Embassy of Ukraine, appeared at the Commission hearing.   

Data Coverage.  U.S. industry data are based on questionnaire responses from ten U.S.

producers of wire rod that are believed to account for all known U.S. production of wire rod in

2013.12  The Commission received usable questionnaire data from 37 U.S. importers of wire

rod, representing virtually all U.S. imports of wire rod from Mexico in 2013 and 84.8 percent of

U.S. imports of wire rod from nonsubject countries.13  There were no reported subject imports

from Brazil, Indonesia, Moldova, Trinidad and Tobago, or Ukraine in 2013.14   One U.S. importer

of wire rod from Trinidad and Tobago provided a response to the Commission’s questionnaire

accounting for *** percent of total U.S. imports of wire rod from Trinidad and Tobago in 2008

based on official Commerce statistics.15  U.S. import data are based on questionnaire responses

for wire rod imported from Mexico and on official Commerce statistics for all other sources.  

The Commission also received foreign producers’ questionnaire responses from one producer

in Brazil estimated to account for *** percent of that country’s total wire rod production in

2013, one producer in Indonesia estimated to account for *** percent of that country’s total

wire rod production, three producers in Mexico that estimate that they account for *** of that

country’s wire rod production, the sole producer of subject merchandise in Trinidad and

Tobago, and two producers in Ukraine estimated to account for *** of that country’s wire rod

                                                      

10 Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia, Mexico, Moldova, Trinidad

and Tobago, and Ukraine: Notice of Commission Determination to Conduct Full Five‐Year Reviews, 78

Fed. Reg. 60316 (Oct. 1, 2013). 11 Confidential Report (“CR”) at I‐1‐I‐2 n.4, Public Report (“PR”) at I‐1‐I‐2n.4. 12 CR at I‐48, PR at I‐37.

13 CR at I‐52, PR at I‐40. 14 CR at I‐52, PR at I‐40.

15 CR at IV‐1 n.5, PR at IV‐1 n.5.
6

production.16  The Commission received no questionnaire response from any foreign producer

in Moldova.17   

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.”18  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.”19  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.20  

Commerce has defined the imported merchandise within the scope of the orders under

review as follows:

Certain hot‐rolled products of carbon steel and alloy steel, in coils,

of approximately round cross section, 5.00 mm or more, but less

than 19.00 mm, in solid cross‐sectional diameter.21

This definition is subject to several lengthy exclusions.  Among the items excluded from

the scope are rebar; articles made with stainless steel, tool steel, high nickel steel, ball bearing

steel, and free machining steel;22 grade 1080 tire cord quality rod;23  and grade 1080 tire bead

quality rod.24  

                                                       

16 CR at IV‐17, IV‐29, IV‐39, IV‐ 55, and IV‐66; PR at IV‐14, IV‐19, IV‐25, IV‐37, and IV‐42. 17 CR at I‐17, PR at I‐14.

18 19 U.S.C. § 1677(4)(A).

19 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).

20 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). 21 78 Fed. Reg. 63450‐51 (Oct. 24, 2013 (final results of Commerce sunset reviews). 22 As the scope definition states:   

Specifically excluded are steel products possessing the above‐noted physical characteristics and

meeting the Harmonized Tariff Schedule of the United States (“HTSUS”) definitions for (a) stainless steel;

(b) tool steel; (c) high nickel steel; (d) ball bearing steel; and (e) concrete reinforcing bars and rods.  Also

excluded are (f) free machining steel products (i.e., products that contain by weight one or more of the

(Continued...)
7

Anti‐Circumvention Inquiry. On June 8, 2011, at the request of the domestic industry,

Commerce initiated an anti‐circumvention inquiry into whether Mexican wire rod producers

Deacero and Ternium shipped wire rod to the United States with an actual diameter measuring

4.75 mm, which is less than the 5.00 mm minimum diameter specified in the scope definition,

in a manner that constituted merchandise altered in form or appearance in such minor respects

that it should be included within the scope of the order on wire rod from Mexico.25  On October

1, 2012, Commerce published its final determination of circumvention, finding that Ternium

had not shipped this type of wire rod to the United States but that Deacero’s shipments of this

type of wire rod constituted merchandise altered in form or appearance in such minor respects

that it should be included within the scope of the order.26  Deacero appealed Commerce’s

circumvention finding to the CIT, and on September 30, 2013, the CIT remanded the matter to

                                                                                                                                                                              

(...Continued)

following elements: 0.03 percent or more of lead, 0.05 percent or more of bismuth, 0.08 percent or

more of sulfur, more than 0.04 percent of phosphorus, more than 0.05 percent of selenium, or more

than 0.01 percent of tellurium).  CR at I‐29, PR at I‐23.

23 Grade 1080 tire cord quality wire rod is defined as follows:  

(i) wire rod measuring 5.0 mm or more but not more than 6.0 mm in cross‐sectional diameter;

(ii) with an average partial decarburization of no more than 70 microns in depth (maximum individual

200 microns); (iii) having no non‐deformable inclusions greater than 20 microns and no deformable

inclusions greater than 35 microns; (iv) having a carbon segregation per heat average of 3.0 or better

using European Method NFA 04‐114; (v) having a surface quality with no surface defects of a length

greater than 0.15 mm; (vi) capable of being drawn to a diameter of 0.30 mm or less with 3 or fewer

breaks per ton; and (vii) containing by weight the following elements in the proportions shown: (1) 0.78

percent or more of carbon, (2) less than 0.01 percent of aluminum, (3) 0.040 percent or less, in the

aggregate, of phosphorus and sulfur, (4) 0.006 percent or less of nitrogen, and (5) not more than 0.15

percent, in the aggregate, of copper, nickel, and chromium.  CR at I‐29, PR at I‐23.

24 Grade 1080 tire bead quality rod is defined as follows:  

(i) wire rod measuring 5.5 mm or more but not more than 7.0 mm in cross‐sectional diameter;

(ii) with an average partial decarburization of no more than 70 microns in depth (maximum individual

200 microns); (iii) having no non‐deformable inclusions greater than 20 microns and no deformable

inclusions greater than 35 microns; (iv) having a carbon segregation per heat average of 3.0 or better

using European Method NFA 04‐114; (v) having a surface quality with no surface defects of a length

greater than 0.2 mm; (vi) capable of being drawn to a diameter of 0.78 mm or larger with 0.5 or fewer

breaks per ton; and (vii) containing by weight the following elements in the proportions shown: (1) 0.78

percent or more of carbon, (2) less than 0.01 percent of soluble aluminum, (3) 0.040 percent or less, in

the aggregate, of phosphorus and sulfur, (4) 0.008 percent or less of nitrogen, and (5) either not more

than 0.15 percent, in the aggregate, of copper, nickel, and chromium (if chromium is not specified), or

not more than 0.10 percent in the aggregate of copper and nickel and a chromium content of 0.24 to

0.30 percent (if chromium is specified).  CR at I‐29‐I‐30, PR at I‐23‐I‐24.

25 Carbon and Certain Alloy Steel Wire Rod from Mexico: Initiation of Anti‐Circumvention Inquiry

of Antidumping Duty Order, 76 Fed. Reg. 33218 (June 8, 2011).

26 Carbon and Certain Alloy Steel Wire Rod from Mexico: Affirmative Final Determination of

Circumvention of the Antidumping Order, 77 Fed. Reg. 59892 (Oct. 1, 2012).
8

Commerce.27  Pursuant to the CIT’s order, on January 28, 2014, Commerce reversed its final

determination “under respectful protest” and found that Deacero’s shipments of 4.75 mm wire

rod to the United States are outside the scope of the order and thus such shipments do not

constitute a circumventing minor alteration.28  The CIT ruling on Commerce’s final remand

determination was pending at the time the record closed in these reviews.

The Original Determinations and First Five‐Year Reviews. In the original determinations,

the Commission defined the domestic like product to include grade 1080 tire cord quality wire

rod and grade 1080 tire bead quality wire rod, which Commerce had excluded from the scope.  

The Commission observed that Commerce had retained tire cord wire rod and tire bead wire

rod of both higher and lower grades in the scope and that the record did not contain

information indicating that the differences among grades of tire bead or tire cord wire rod was

significant.  Instead, it found that other domestic tire cord wire rod and tire bead wire rod

articles that corresponded directly to products within the scope closely shared physical

characteristics, uses, prices, channels of distribution, and production processes with the

excluded grade 1080 articles.29

The Commission rejected arguments asserted by respondents that tire cord quality rod,

cold heading quality (CHQ) wire rod meeting Industrial Fasteners Institute Specification IFI‐140,

and clean steel precision bar in coils (CSPBIC) should each be defined as a distinct domestic like

product.  The Commission found that, although each of these products was a high‐end product

that met exacting quality requirements, there was no clear dividing line between any one of

these products and other wire rod products.30  Instead, the Commission concluded that “the

wire rod industry is composed of so many different products, used in so many different

applications, that the only clear dividing line is between wire rod and other steel products.”31   

Accordingly, the Commission defined a single domestic like product consisting of both the wire

rod within the scope definition and the grade 1080 tire cord and grade 1080 tire bead wire rod

that Commerce had excluded from the scope.32

In the first five‐year reviews, the Commission found that there were no material

changes in pertinent product characteristics from the original investigations or any other reason

to revisit the like product definition.33  Consequently, the Commission continued to define the

                                                      

27 Deacero S.A. de C.V. v. United States, 942 F. Supp. 2d 1321, 1331‐32 (CIT 2013).  The Court

directed Commerce to reconsider its finding that 4.75 mm wire rod is circumventing the order, or if

Commerce were to again find that 4.75 mm wire rod is a circumventing minor alteration of subject

merchandise, to thoroughly explain how the record and relevant law supports that determination in

light of the fact that 4.75 mm wire rod was commercially available before the investigation and

petitioners chose to limit the scope to certain steel products of 5.00 mm or more.

28 Final Results of Redetermination Pursuant to Court Remand, Ct. No. 12‐00345 (Dep’t

Commerce Jan. 28, 2014).

29 Original Determinations, USITC Pub. 3546 at 7‐8.

30 See Original Determinations, USITC Pub. 3546 at 8‐12.

31 Original Determinations, USITC Pub. 3546 at 12.

32 Id.

33 First Review Determinations, UISTC Pub. 4014 at 8.
9

domestic like product to encompass all wire rod, including the grade 1080 tire cord and grade

1080 tire bead wire rod that Commerce had excluded from the scope.34

The Current Reviews. In these second five‐year reviews, the Commission solicited

comments from interested parties regarding the appropriate definition of the domestic like

product and domestic industry.35  Domestic interested parties agree with the Commission’s

definitions of the domestic like product from the original investigations and first reviews.36  

Both Mexican producer Deacero and Ukrainian producer Yenakiieve indicated that they do not

disagree with the Commission’s definition of the domestic like product.37   

We define the domestic like product in the same manner as in the original investigations

and first reviews.  The record contains no information suggesting that the characteristics and

uses of domestically produced wire rod have changed since the prior proceedings or that the

like product definition should be revisited.38  No party argued that the Commission should

depart from the like product definitions it adopted in the original investigations, and no party

requested that the Commission collect data concerning other possible domestic like products in

the comments on the Commission’s draft questionnaires.39  Consequently, we define the

domestic like product to encompass both wire rod within the scope definition and the grade

1080 tire cord and grade 1080 tire bead wire rod that Commerce has excluded from the scope.

   

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.”40  In defining the domestic industry, the Commission’s general practice has been

to include in the industry producers of all domestic production of the like product, whether toll‐

produced, captively consumed, or sold in the domestic merchant market.  

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

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

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

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

                                                      

34 Id.

35 CR at I‐46, PR at I‐36; see 78 Fed. Reg. 33013 (June 3, 2013) (Commission’s notice of

institution).

36 Domestic Interested Parties’ Response to Notice of Institution at 31; Gerdau Parties’

Prehearing Brief at 5.

37 Deacero’s Response to Notice of Institution at 15; Yenakiieve’s Prehearing Brief at 5.

38 See generally CR at I‐32‐I‐47, PR at I‐26‐I‐36.

39 CR at I‐47, PR at I‐36.

40 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.
10

or which are themselves importers.41  Exclusion of such a producer is within the Commission’s

discretion based upon the facts presented in each investigation.42

In the original determinations, the Commission defined the domestic industry to

encompass all domestic producers of wire rod.  The Commission found that three domestic

producers were potentially subject to exclusion pursuant to the related parties provision

because they had imported subject merchandise during the period examined.  However, it

concluded that appropriate circumstances did not exist to exclude any of these producers from

the domestic industry.43

In the first reviews, the Commission again defined the domestic industry to encompass

all domestic producers of wire rod.  The Commission found that two domestic producers,

ArcelorMittal USA and Gerdau Ameristeel, were potentially subject to exclusion because they

were affiliated with exporters or importers of subject merchandise and that one domestic

producer, ***, was potentially subject to exclusion because it imported subject merchandise

during the period of review.44  The Commission concluded, however, that appropriate

circumstances did not exist to exclude any of these producers from the domestic industry.45

In the current reviews, domestic interested parties argue that no U.S. producer should

be excluded from the domestic industry as a related party.  They observe that U.S. producers

Gerdau and ArcelorMittal USA are primarily interested in U.S. production, did not benefit from

affiliations with subject producers of wire rod, did not import subject merchandise during the

period, and do not support revocation of any orders.46  Yenakiieve also indicated that it did not

                                                      

41 See Torrington Co v. United States, 790 F. Supp. 1161, 1168 (Ct. Int’l Trade 1992), aff’d without

opinion, 991 F.2d 809 (Fed. Cir. 1993); Sandvik AB v. United States, 721 F. Supp. 1322, 1331‐32 (Ct. Int’l

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

1348, 1352 (Ct. Int’l Trade 1987).

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

circumstances exist to exclude a related party include the following:

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

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

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

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

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

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

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

43 Original Determinations, USITC Pub. 3546 at 14.  The Commission further concluded that a

fourth producer that purchased subject merchandise during the period examined was not a related

party because its purchases were insufficient to constitute direct or indirect control of an importer.  Id.    44 First Reviews, USITC Pub. 4014 at 9‐10.

45 Id.  The Commission further concluded that a fourth producer that purchased subject

merchandise during the period examined was not a related party because its purchases were insufficient

to constitute direct or indirect control of an importer.  Id. at 8‐9 n.39.

46 See Gerdau Parties Prehearing Brief at 5‐6.
11

see a basis to exclude Gerdau or ArcelorMittal USA from the domestic industry.47  No other

respondent addressed the issue.

We first identify which domestic producers are related parties.  Domestic producer

Gerdau reported that it is a wholly owned subsidiary of Gerdau SA, a wire rod producer in

Brazil.48  There were no reported imports or exports of subject merchandise from Brazil to the

United States during the period, and we therefore find that Gerdau is not a related party due to

its affiliation with Gerdau SA.   

Domestic producer Republic Steel (“Republic”) reported that it is owned by Mexican

producers Pacific Steel, Industrias ICH, and Grupo Simec.49  Proprietary data from *** provide

no indication that any of Republic’s affiliated firms in Mexico exported subject merchandise to

the United States or that there were any imports of wire rod from these firms.50  We therefore

find that Republic is not a related party due to its affiliation with the aforementioned Mexican

producers.   

Domestic producer ArcelorMittal USA reported that it is a wholly owned subsidiary of

ArcelorMittal SA (Luxembourg), which has subsidiary wire rod producers in numerous

countries, including subject countries Brazil, Mexico, Trinidad and Tobago, and Ukraine.51  

ArcelorMittal USA is a related party because a subject producer also controlled by ArcelorMittal

S.A., ArcelorMittal Point Lisas, exported subject merchandise from Trinidad and Tobago during

the period of review.52  Additionally, ArcelorMittal USA is a related party because it has

common ownership with ArcelorMittal entities *** that imported subject merchandise from

Mexico during the period of review.53    

We next consider whether appropriate circumstances exist for the exclusion of related

party producer ArcelorMittal USA.  During the period of review, ArcelorMittal USA was the ***

largest domestic wire rod producer, accounting for *** percent of domestic production.54   

ArcelorMittal USA supports continuation of all orders under review, except it takes no position

on the continuation of the order on wire rod from Trinidad and Tobago.55   In every year of the

period except for 2010, when ArcelorMittal temporarily closed down its main production

facility, the ratio of subject imports from ArcelorMittal‐affiliated firms to ArcelorMittal USA’s

                                                      

47 Yenakiieve’s Prehearing Brief at 5.

48 CR at III‐17, PR at III‐10.

49 CR/PR at Table I‐11.

50 CR at I‐50 and III‐17, PR at I‐39 and III‐10.

51 CR at III‐17, PR at III‐10.

52 CR/PR at Table IV‐24.

53 CR at III‐18, PR at III‐10; CR/PR at Table III‐9.  ArcelorMittal‐affiliated firms did not import

subject merchandise from Trinidad and Tobago during the period of review.  CR at III‐17 – III‐18, PR at III‐

10.

54 CR/PR at Table I‐11. 55 CR/PR at Table I‐11.  We also observe that ArcelorMittal Point Lisa’s 2008 exports to the

United States were *** percent of ArcelorMittal USA’s production that year.  CR/PR at Tables III‐9 and

IV‐24.
12

production was less than *** percent.56  ArcelorMittal USA’s operating margin was *** of the

period of review.57 58    

The record does not indicate that the activities of ArcelorMittal affiliates importing

subject merchandise from Mexico or exporting subject merchandise from Trinidad and Tobago

have benefitted ArcelorMittal USA.  Except during 2010, ArcelorMittal USA had substantial

domestic wire rod production operations, and ArcelorMittal principally supplied the U.S.

market with domestic production, as opposed to subject imports, during the period of review.  

Moreover, no party argues for ArcelorMittal USA’s exclusion from the domestic industry.  

Accordingly, we conclude that there are not appropriate circumstances for its exclusion from

the domestic industry.

Based on the foregoing and our like product definition, we define the domestic industry

to include all U.S. producers of wire rod, including grade 1080 tire cord and grade 1080 tire

bead wire rod.

III. Cumulation

A. Legal Standard

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.59

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

are governed by section 771(7)(G)(i) of the Tariff Act.60  The Commission may exercise its

                                                       

56 CR/PR at Table III‐9. 57 CR/PR at Table III‐13.

58 Commissioner Pinkert does not rely upon financial performance to determine whether there

are appropriate circumstances to exclude ArcelorMittal USA from the domestic industry.  In his view, the

present record is not sufficient to link the company’s financial performance with respect to U.S.

operations to any benefit it derives as a related party.

59 19 U.S.C. § 1675a(a)(7).

60 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

(Continued...)
13

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.

In the original determinations, for purposes of the determinations on subject imports

from Brazil, Canada, Indonesia, Mexico, Moldova, and Ukraine, the Commission cumulated

imports from these six subject countries and subject imports from Trinidad and Tobago.61   With

respect to fungibility, it found that domestically produced wire rod and wire rod from each of

the subject sources was generally interchangeable.  It also found that there was a reasonable

overlap in product types between the domestic like product and the subject imports and

among subject imports from each of the subject countries. The Commission found sufficient

geographic overlap, because the domestic like product and imports from all subject countries

were generally marketed throughout the United States.62  The Commission also found an

overlap of channels of distribution because both the domestic like product and the subject

imports were sold to end users.63   The domestic like product and imports from all subject

countries were present in the U.S. market throughout the period examined.  

Imports from all seven subject countries were eligible for cumulation for all

determinations in the first reviews because the CBERA exception to cumulation is only

applicable in original investigations.64  Based on the record, the Commission did not find that

subject imports from any of the subject countries were likely to have no discernible adverse

impact on the domestic industry in the event of revocation of the orders covering those

imports.  The Commission found that, during the period of review, each of the countries’

industries had exported substantial quantities of subject merchandise, most of the industries in

those countries had substantial excess capacity, and several of the industries had expanded

their capacity.65  

The Commission also found that there would likely be a reasonable overlap of

competition among subject imports from each subject country and the domestic like product,

                                                                                                                                                                              

(...Continued)

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

Int’l Trade 2008).

61 Original Determinations, USITC Pub. 3546 at 23.  For purposes of the determination on subject

imports from Trinidad and Tobago, the Commission did not cumulate subject imports from Trinidad and

Tobago with any other subject imports.  The statute precluded such cumulation in the original

investigations because Trinidad and Tobago was a beneficiary country under the Caribbean Basin

Economic Recovery Act (CBERA).  Original Determinations, USITC Pub. 3546 at 18.

62 Original Determinations, USITC Pub. 3546 at 22.

63 Original Determinations, USITC Pub. 3546 at 22.

64 First Review Determinations, USITC Pub. 4014 at 12.

65 First Review Determinations, USITC Pub. 4014 at 14.  Not all participating Commissioners

found it necessary to reach this issue with respect to every subject country.  See id. at 12 n.64

(Commissioner Pearson), at 14 n.76 (Commissioner Okun and Commissioner Pearson).
14

as well as between subject imports from each country.  With respect to fungibility, it found that

domestically produced wire rod and wire rod from each of the subject sources was at least

sometimes interchangeable.  The Commission found sufficient geographic overlap and an

overlap of channels of distribution because the domestic like product and imports from subject

sources other than Trinidad and Tobago were predominantly sold directly to end users and sold

throughout the United States.66  The Commission stated that the absence from the U.S. market

of imports from several of the subject countries during the bulk of the period of review was

influenced by the imposition of the orders and that upon revocation subject imports would

likely be simultaneously present in the market as they were during the original investigations.67

The Commission also found that there were no significant differences in the likely

conditions of competition among imports from all subject sources other than Canada.68   The

Commission stated that record information indicated that the industry in each of these

countries produces a product mix focusing heavily on low‐carbon and high‐carbon industrial

grade products, that each of the subject countries had largely similar volume trends during the

period, that the market penetration for five of the six countries increased during the original

investigations and the remaining country’s market penetration was unchanged, and that each

of the subject countries has significant quantities of unused capacity during portions of the

period of review.69  Thus, it exercised its discretion to cumulate the subject imports from all of

the subject countries, except for Canada.70

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.71  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

                                                      

66 First Review Determinations, USITC Pub. 4014 at 16.

67 First Review Determinations, USITC Pub. 4014 at 14.

68 Two Commissioners did not join this discussion and two joined it in part.  First Review

Determinations, USITC Pub. 4014 at 17 n.100 (Commissioner Lane and Commissioner Pinkert).

First Review Determinations, USITC Pub. 4014 at 19 n.111 (Commissioner Okun and Commissioner

Pearson).

69 First Review Determinations, USITC Pub. 4014 at 19.

70 First Review Determinations, USITC Pub. 4014 at 19.  The Commission determined that subject

imports from Canada were likely to compete in the U.S. market under sufficiently different conditions of

competition than imports from the other subject countries and therefore declined to exercise its

discretion to cumulate subject imports from Canada with any other subject imports.  First Review

Determinations, USITC Pub. 4014 at 18.  The Commission concluded that subject imports from Canada

had exhibited different volume trends since the imposition of the orders, different trends in capacity,

different pricing patterns, and a different product mix tending toward more specialized products.  First

Review Determinations, USITC Pub. 4014 at 18‐19. 71 19 U.S.C. § 1675a(a)(7).
15

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

industry.72  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.

Brazil.  In the original investigations, the quantity of subject imports from Brazil

increased from *** short tons in 1999 to *** short tons in 2001.73  In the first reviews, the only

subject imports from Brazil were *** short tons in 2002.74  In the current reviews, there were

no subject imports from Brazil.75   

In these reviews, the Commission received one response to its foreign producer

questionnaire from ArcelorMittal Brasil, which is estimated to account for *** percent of

Brazilian wire rod production in 2013 and is affiliated with the ArcelorMittal group.76  According

to ***, production capacity in Brazil increased from *** short tons in 2008 to *** short tons in

2009, and then remained constant until 2013.77  Capacity is projected to increase to *** short

tons in 2014 and *** short tons in 2015 as three new mills are projected to come online in

Brazil during 2014‐2015.78  *** reported production in Brazil of *** short tons in 2013, or ***

percent of published capacity.79  The percentage of subject wire rod shipments exported by the

reporting Brazilian producer ranged from *** percent in 2013 to *** percent in 2009.80  

According to Global Trade Atlas data, the United States, Argentina, and Korea were the largest

export markets for wire rod from Brazil in 2013.81

                                                      

72 SAA, H.R. Rep. No. 103‐316, vol. I at 887 (1994).

73 CR/PR at Appendix C (reproduction of Table I‐1 of the Commission Report from the first

review determinations).

74 CR/PR at Appendix C (reproduction of Table I‐1 of the Commission Report from the first

review determinations).  There were imports of grade 1080 tire cord/bead from Brazil.  CR at IV‐17, PR

at IV‐13‐IV‐14. 75 CR/PR at Table I‐1.

76 CR at IV‐17, PR at IV‐13‐IV‐14; CR/PR at Table I‐11.  The following five firms were identified by

the parties as currently operating producers of wire rod in Brazil: ArcelorMittal Brasil, Votorantim

Metals/Barra Mansa, Companhia Siderurgica Nacional, Gerdau Acos Brazil, and Villares Metals.  CR at IV‐

17, PR at IV‐13.  Gerdau Acos Brasil and ArcelorMittal Brasil together are estimated to account for ***

percent of total wire rod capacity in Brazil.  CR at IV‐17, PR at IV‐13. 77 CR/PR at Table IV‐7.  *** data for 2013 are estimates.  Reported production capacity was ***

short tons throughout the period of review.  CR/PR at Table IV‐8.  See below for discussion of the

coverage of the *** data.

78 CR/PR at Table IV‐7.  The three mills are GV do Brasil (2014), CSN (2014), and Siderurgica

Latino‐Americana S/A (Silat) (2015).

79 CR/PR at Table IV‐7; CR at IV‐19, PR at IV‐15.  Reported production was *** short tons in 2013,

or *** percent of capacity.  CR/PR at Table IV‐8.

80 CR/PR at Table IV‐8.

81 CR/PR at Table IV‐10.  The *** and Global Trade Atlas data include grade 1080 tire cord and

tire bead wire rod and 4.75 mm wire rod, which are not subject merchandise, and therefore the

(Continued...)
16

Based on the record, including information on the size of the wire rod industry in Brazil,

its substantial unused capacity, its exports, and its additional capacity coming online in the

reasonably foreseeable future, we do not find that subject imports from Brazil would likely have

no discernible adverse impact on the domestic industry if the orders were revoked.

Indonesia.  In the original investigations, the quantity of subject imports from Indonesia

increased from 69,805 short tons in 1999 to 86,940 short tons in 2000, and then declined to

60,065 short tons in 2001.82  In the first reviews, subject imports from Indonesia declined to

40,863 short tons in 2002 and were present thereafter only in 2004, when they were 29,937

short tons.83  There were no subject imports from Indonesia during the current reviews.

The Commission received one response to its questionnaires from PT Ispat Indo, which

is estimated to account for *** percent of Indonesian wire rod production in 2013.84 According

to ***, production capacity in Indonesia was *** short tons throughout the period of review

and is projected to remain constant through 2015.85  *** reported production of *** short tons

in 2013, or *** percent of published capacity.86  The percentage of subject wire rod shipments

exported by the reporting Indonesian producer ranged from *** percent in 2012 to *** percent

in 2008.87  According to Global Trade Atlas data, Australia and Bangladesh were the largest

export markets for wire rod from Indonesia in 2012.88

Based on the record, including information indicating substantial unused capacity, we

do not find that subject imports from Indonesia would likely have no discernible adverse impact

on the domestic industry if the order was revoked.

                                                                                                                                                                              

(...Continued)

capacity, production, and export data they provide overstate the quantities of subject merchandise.  Id.  

As discussed above, there were no subject imports of wire rod from the United States during the period

of review and, therefore, all exports to the United States from Brazil consisted of nonsubject

merchandise. Nevertheless, the fact that the United States was the largest export market for shipments

of nonsubect wire rod from Brazil throughout the period of review demonstrates that Brazilian

producers of wire rod remain interested in the U.S. market.  CR/PR at Table IV‐10.

82Original Determinations, USITC Pub. 3546, USITC Report at Table I‐1.

83 First Review Determinations, USITC Pub. 4014, USITC Report at Table I‐1.

84 CR at IV‐29, PR at IV‐20.  According to *** there are six firms in Indonesia that maintain wire

rod rolling capacity: Gunung Garuda (estimated *** short tons of capacity), PT Ispat Indo (estimated ***

short tons of capacity), PT Krakatau Steel (estimated *** short tons of capacity), Growth Sumatra

(estimated *** short tons of capacity), Hanil Jaya Metalworks (estimated *** short tons of capacity),

and Budidharma Jakarta (estimated *** short tons of capacity).  CR at IV‐28, PR at  IV‐19.    85 CR/PR at Table IV‐12.  *** data for 2013 are estimates.  Master Steel reports an ongoing

modernization and expansion project including a 500,000 metric ton wire rod and bar combi‐mill.  CR at

IV‐29 n.23, PR at IV‐20 n.23.  As previously stated, *** and Global Trade Atlas data include some

nonsubject wire rod and therefore may overstate capacity, production, and exports of subject

merchandise.  Reported production capacity was *** short tons throughout the period of review.  CR/PR

at Table IV‐13.

86 CR/PR at Table IV‐2; CR at IV‐30, PR at IV‐21.  Reported production was *** short tons in 2013,

or *** percent of capacity.  CR/PR at Table IV‐13.

87 CR at Table IV‐13.

88 CR/PR at Table IV‐14.  Global Trade Atlas data for Indonesia are not yet available for 2013.   
17

Mexico.  In the original investigations, the quantity of subject imports from Mexico

increased from 122,038 short tons in 1999 to 266,925 short tons in 2001.89  In the first reviews,

subject imports from Mexico declined to 123,380 short tons in 2002, declined further in 2003,

rose to 68,498 short tons in 2004, and did not exceed 11,480 short tons from 2005 to 2007.90 In

the current reviews, subject imports from Mexico increased from *** short tons in 2008 to ***

short tons in 2010, declined to *** short tons in 2011, increased to *** short tons in 2012, and

declined to *** short tons in 2013.91  During the period of review, the share of the quantity of

apparent U.S. consumption represented by subject imports from Mexico was never greater

than *** percent.92   

The Commission received responses to its questionnaires from three producers that

appear to have accounted for all or nearly all subject wire rod production in Mexico during

2013: Deacero, Ternium, and ArcelorMittal las Truchas.93  ArcelorMittal las Truchas is affiliated

with the ArcelorMittal group.94  Reported capacity in Mexico increased irregularly from 2.4

million short tons in 2008 to 2.8 million short tons in 2013.95  The reported capacity utilization

of the Mexican producers during the period of review ranged from *** percent in 2011 to ***

percent in 2013.96  The percentage of subject wire rod shipments exported by the reporting

Mexican producers ranged from *** percent in 2009 to *** percent in 2011.97  According to

Global Trade Atlas data, Colombia and Canada were the largest export markets for wire rod

from Mexico in 2013.98

                                                      

89 Original Determinations, USITC Pub. 3546, USITC Report at Table I‐1.

90 First Review Determinations, USITC Pub. 4014, USITC Report at Table I‐1.

91 CR/PR at Table C‐1. Imports from Mexican producer Deacero of nonsubject 4.75 mm wire rod

increased from *** short tons in 2008 to *** short tons in 2010, declined to *** short tons in 2011, and

then declined sharply to *** short tons in 2013.  CR/PR at Table E‐1.  Domestic interested parties argue

that the Commission should treat Deacero’s shipments of 4.75 mm wire rod to the United States as

subject imports.  See, e.g., Gerdau Parties’ Prehearing Brief at 25‐26.  We are under no obligation to

treat Deacero’s 4.75 mm shipments of wire rod to the United States as subject imports because, as

explained in section II of this opinion, 4.75 mm wire rod was not originally within the scope of these

reviews and the latest Commerce decision does not include 4.75 mm wire rod within the scope.  

Notwithstanding that it is nonsubject merchandise, Deacero’s shipments to the United States of 4.75

mm wire rod, which it acknowledges is largely substitutable for subject merchandise, shows a continued

interest in the U.S. market.  Tr. at 19 (Campbell).

92 CR/PR at Table C‐1.

93 CR at IV‐39 – IV‐40, PR at IV‐25.  The coverage ratio is a comparison of questionnaire data with

*** data.  We note there is additional production of wire rod by Talleros y Aceros and by Simec.  CR at

IV‐39 nn.32 and 33, PR at IV‐25 nn.32 and 33.

94 CR/PR at Table I‐11.

95 CR/PR at Table IV‐17.

96 CR/PR at Table IV‐17.

97 CR/PR at Table IV‐17.    98 CR/PR at Table IV‐19.  The  Global Trade Atlas data include grade 1080 tire cord and tire bead

wire rod, as well as smaller diameter wire rod produced by Deacero, which are not subject merchandise,

and therefore overstate quantities of subject merchandise from Mexico.  Id.
18

Based on the record, including information indicating increasing capacity and continued

interest in the U.S. market, we do not find that subject imports from Mexico would likely have

no discernible adverse impact on the domestic industry if the order were revoked.

Moldova.  In the original investigations, the quantity of subject imports from Moldova

increased from 190,239 short tons in 1999 to 191,074 short tons in 2000, and then declined to

187,370 short tons in 2001.99  In the first reviews, subject imports from Moldova declined to

18,826 short tons in 2002 and were not present in the U.S. market thereafter.100  In the current

reviews, there were no imports of wire rod from Moldova.

Moldova Steel Works (“MSW”), the only known producer of wire rod in Moldova, did

not respond to the Commission’s questionnaire in these reviews.  According to ***, MSW’s

capacity was *** short tons throughout the period of review, and it is projected to remain

constant through 2015.101  Domestic interested parties report that MSW exports approximately

***.102  According to Global Trade Atlas data, Romania and Poland were the largest export

markets for wire rod from Moldova in 2013.103

Based on the record, including information concerning the industry’s significant export

orientation, we do not find that subject imports from Moldova would likely have no discernible

adverse impact on the domestic industry if the order was revoked.

Trinidad and Tobago.  In the original investigations, the quantity of subject imports from

Trinidad and Tobago increased from 341,815 short tons in 1999 to 355,089 short tons in

2001.104  During the first reviews, subject imports from Trinidad and Tobago declined irregularly

from 386,419 short tons in 2002 to 95,325 short tons in 2007.105  In the current reviews, there

were subject imports of wire rod from Trinidad and Tobago of 21,794 short tons in 2008, but no

imports thereafter.106  In 2008, the share of the quantity of apparent U.S. consumption

represented by subject imports from Trinidad and Tobago was *** percent.107                 

ArcelorMittal Point Lisas, the sole producer of wire rod in Trinidad and Tobago,

responded to the Commission’s questionnaire.108  ArcelorMittal Point Lisas is affiliated with the

ArcelorMittal group.109  Its production capacity was *** short tons throughout the period of

review.110   ArcelorMittal Point Lisas’ reported capacity utilization during the period of review

                                                      

99 Original Determinations, USITC Pub. 3546, USITC Report at Table I‐1.

100 First Review Determinations, USITC Pub. 4014, USITC Report at Table I‐1.

101 CR/PR at Table IV‐21.  As previously stated, *** and Global Trade Atlas data include some

nonsubject wire rod and hence may overstate capacity, production, and exports of subject merchandise.

102 CR at IV‐52, PR at IV‐34.

103 CR/PR at Table IV‐22.    104 Original Determinations, USITC Pub. 3546, USITC Report at Table I‐1.

105 First Review Determinations, USITC Pub. 4014, USITC Report at Table I‐1.

106 CR/PR at Table C‐1.

107 CR/PR at Table C‐1.

108 CR at IV‐52, PR at IV‐34.

109 CR/PR at Table I‐11.

110 CR/PR at Table IV‐25.
19

ranged from *** percent in 2009 to *** percent in 2011, and was *** percent in 2013.111  

During each year of the period of review, ArcelorMittal Point Lisas exported at least ***

percent of its shipments.112  According to Global Trade Atlas data, El Salvador, Nicaragua,

France, and Guatemala were the largest export markets for wire rod from Trinidad and Tobago

in 2013.113

Based on the record, including information concerning the industry’s significant export

orientation and substantial excess capacity, we do not find that subject imports from Trinidad

and Tobago would likely have no discernible adverse impact on the domestic industry if the

order were revoked.

Ukraine.

114  In the original investigations, the quantity of subject imports from Ukraine

increased from 193,003 short tons in 1999 to 367,712 short tons in 2000, and then declined to

258,526 short tons in 2001.115  In the first reviews, subject imports from Ukraine declined to

11,159 short tons in 2002 and there were no additional imports from Ukraine other than 738

short tons in 2005.116  During the current reviews, there have been no subject imports of wire

rod from Ukraine.  

The Commission received responses to its questionnaires from two wire rod producers

in Ukraine: ArcelorMittal Kryvyi Rih (“ArcelorMittal KR”) and Yenakiieve.117  It is estimated that

these two firms accounted for *** subject wire rod production in Ukraine during 2013.118     

ArcelorMittal KR, the largest producer of wire rod in Ukraine during the period of

review, is the successor firm to Krivorozhstal, which accounted for *** percent of Ukrainian

production of wire rod during the original investigations and *** percent of subject exports to

the United States.119  ArcelorMittal KR is affiliated with the ArcelorMittal group.120   In the first

                                                      

111 CR/PR at Table IV‐24. 112 CR/PR at Table IV‐24.

113 CR/PR at Table IV‐19.  The Global Trade Atlas data includes grade 1080 tire cord and tire bead

wire rod, which are not subject merchandise, and data may therefore be overstated.  Id. 114 Chairman Williamson and Commissioner Johanson do not join this discussion.  See Separate

and Dissenting Views of Chairman Irving A. Williamson and Commission David J. Johanson Regarding

Cumulation for Ukraine.   115 Original Determinations, USITC Pub. 3546, USITC Report at Table I‐1.

116 First Review Determinations, USITC Pub. 4014, USITC Report at Table I‐1. 117 CR at IV‐66, PR at IV‐42.

118 CR at IV‐66‐67, PR at IV‐42.  *** reported that capacity to produce wire rod in Ukraine was

expected to increase in 2014, but the additional capacity reported by *** is for firms that are not

believed to be producers of wire rod in Ukraine (Euro Finance and Donestsk).  CR at IV‐66 n.48, PR at IV‐

42 n.48; Tr. at 160 (Dimitrova).  Domestic producers also assert that Dneprovsky Dzerzhinsky

Metallurgical Plant (“DMKD”) is currently completing reconstruction of its rolling mill, which it estimates

will result in 181,881 short tons of annual wire rod capacity.  See Gerdau Parties’ Posthearing Brief, Exh.

1, at 45‐46; Nucor’s Prehearing Brief, Exh. 14.  We observe that *** has not included this capacity in its

projections for wire rod capacity in Ukraine through 2015 and that the product mix, target markets, and

ramp up time of such a project are uncertain.    119 CR at IV‐65, PR at IV‐41.

120 CR/PR at Table I‐11.
20

review, the Commission stated the following regarding the likelihood that ArcelorMittal would

increase its exports from subject countries in a manner that would impair the operations of its

domestic production affiliates:

By contrast, Arcelor Mittal does act as a single entity in the United

States. ***.  Even assuming arguendo that Arcelor Mittal’s

corporate structure will serve to deter it from exporting large

additional quantities of subject merchandise upon revocation in

light of a desire to protect Arcelor Mittal USA, much of the unused

and additional capacity in the subject countries is attributable to

countries not controlled by Arcelor Mittal.121

During these reviews, ArcelorMittal acknowledged that the information on the record

from the first reviews accurately reflected ArcelorMittal’s current policy and reported the

following to the Commission:

ArcelorMittal employs a commercial coordination policy that

***.122

We find that ArcelorMittal’s commercial coordination policy favoring the *** make it

unlikely that ArcelorMittal KR will export more than minimal volumes of wire rod to the U.S.

market in the reasonably foreseeable future.  At the outset, we observe that in 2013

ArcelorMittal USA had significant excess capacity *** short tons to increase its U.S. production

to service any orders for ArcelorMittal‐supplied wire rod in the United States. 123  To the extent

it supplements domestic supply with imports, ArcelorMittal owns several other mills from

which wire rod can be exported to the United States that are more geographically proximate to

the United States than ArcelorMittal KR, including facilities in Canada, Mexico, Brazil, and

Trinidad and Tobago.124  In accordance with its local supply strategy, the *** of ArcelorMittal’s

U.S. imports of wire rod during the period of review were from ***, which were not subject to

                                                      

121First Review Determinations, EDIS Doc. No. 515654, at 50‐51.  Vice Chairman Aranoff and

Commissioner Pinkert found that ArcelorMittal would likely balance the interests of its various

operations, including its U.S. operations, in deciding whether to export subject merchandise to the

United States. Id.at 51 n.216. 122 TR. at 84‐85 (Cannon); CR at III‐19, PR at III‐10 (citing Gerdau Parties’ Posthearing Brief, Exh. 1

at 56‐57).

123 ArcelorMittal USA U.S. Producers’ Questionnaire Response at II‐6.   ArcelorMittal USA’s

questionnaire response reported that it ***, which would appear to indicate that it would not need

subject imports to supplement local production to supply certain types of wire rod that it did not

produce.  ArcelorMittal USA U.S. Producers’ Questionnaire Response at II‐15a (***). ***. 124 CR/PR at Table I‐11 n.2.
21

an order, and to a lesser extent from ***.125  Even in 2010, as ArcelorMittal USA experienced

the closure of its Georgetown facility and the idling of its Indiana Harbor facility, resulting in its

domestic production plummeting to *** short tons, it was primarily imports from *** that filled

the gap in its domestic production.126  Imports from ArcelorMittal affiliates in *** remained at

low levels throughout the period of review.127  In addition, there is no evidence that imports

from ArcelorMittal affiliates in *** entered the U.S. market during the period of review.128  

Given ArcelorMittal’s commercial coordination policy favoring the ***, we find it likely that the

large majority of any wire rod imports from ArcelorMittal in the foreseeable future would be

from sources proximate to the United States and initiated by ArcelorMittal USA, not initiated by

exporting ArcelorMittal entities.  

Finally, ArcelorMittal has provided the Commission with an indication of which foreign

affiliates in subject countries would consider importing wire rod into the United States should

the orders be revoked.  ArcelorMittal KR reported ***.129  This stands in sharp contrast to the

responses of ***.130

Accordingly, for purposes of our no discernible adverse impact analysis, we find that the

volume of any imports of wire rod from Ukrainian producer ArcelorMittal KR is not likely to be

above minimal levels in the reasonably foreseeable future.  

The only other significant current producer of wire rod in Ukraine, Yenakiieve, has never

exported wire rod to the U.S. market.131  In fact, according to information on the record,

Yenakiieve did not ship subject wire rod to the Western Hemisphere during the period of

review.132  Rather, Yenakiieve has shipped a majority of its production of wire rod to ***.133  

                                                      

125 CR/PR at Table III‐9 (showing that well over *** percent of ArcelorMittal’s imports during the

period were from *** and, to a lesser extent, from ***).  ArcelorMittal USA has acknowledged that ***.  

Gerdau Parties’ Posthearing Brief, Exh. 1, at 57.

126 CR/PR at Table III‐9.  We observe that ArcelorMittal USA has resumed production in all of its

U.S. facilities and in 2013 was the *** largest domestic producer of wire rod at *** short tons.

127 Imports from ArcelorMittal affiliates in *** reached their highest levels for the period at ***

short tons in ***.  ***.

128 CR/PR at TableIII‐9; ***.

129 ***.

130 ***; ***; ***.

131  Yenakiieve’s Final Comments at 10. Yenakiieve is a member of the Metinvest Group of

Ukrainian steel companies, and Yenakiieve is the only Metinvest company that produces subject wire

rod.  CR at IV‐73, PR at IV‐44.

132 Yenakiieve’s Posthearing Brief at 3; ***.  Yenakiieve reported that it ships wire rod exclusively

to its home market and regional export markets, and it did not ***.  Id.

133 ***.  Yenakiieve has already committed approximately *** of its capacity to home market

and European Union purchasers in 2014 and 2015.  Yenakiieve’s Posthearing Brief at Exh. 1.  The record

also shows that exports of wire rod from China have not had a material impact on Yenakiieve’s

shipments to its home market and most important regional markets.  There have been no shipments of

Chinese wire rod in Ukraine during the period of review, and exports of wire rod from China to the

European Union have been almost nonexistent since 2009 due to the European Union’s antidumping

duty order on wire rod from China.  Although imports from China to the Middle East have increased,

(Continued...)
22

Yenakiieve provided credible data indicating that these established home and regional export

markets and an established customer base offer more attractive transportation and logistical

costs than shipments to the United States.134   

Yenakiieve’s production capacity has remained unchanged since 2011 at *** short

tons.135  Since 2011, Yenakiieve’s capacity utilization has been at least *** percent and was ***

percent in 2013.136  Theoretically, even if Yenakiieve were able to operate at 100 percent

capacity utilization, its excess capacity of *** short tons equates to only *** percent of

apparent U.S. consumption.137  A representative from Yenakiieve testified that if the order on

Ukraine was revoked, at most the company would ship 3,000 to 5,000 tons of wire rod per

quarter, or roughly 12,000 to 20,000 tons per year.138  In 2013, this amount equated to only ***

percent of apparent U.S. consumption.139  Based on the record, we find that even the maximum

likely volume of subject imports from Yenakiieve would likely have no discernible adverse

impact on the domestic industry within a reasonably foreseeable time if the order is revoked.  

Based on the record, including the largest Ukrainian producer’s affiliation with the

ArcelorMittal group and the other significant Ukrainian producer’s limited excess capacity and

lack of exports of subject merchandise to the Western Hemisphere during the period of review,

we find that subject imports from Ukraine would likely have no discernible adverse impact on

the domestic industry if the order was revoked.140

                                                                                                                                                                              

(...Continued)

Yenakiieve has been able to retain its market share in the Middle East because China cannot satisfy its

customers’ demands for shorter lead times.  Gerdau Parties’ Prehearing Brief at Exh. 4, Tr. at 100

(Rosenthal); Tr. at 199 (Dimitrova).

134 Yenakiieve’s Posthearing Brief at 11‐12.  Domestic producers argued that U.S. prices were

$*** Ukrainian export AUVs in 2013, and therefore the United States represents an attractive market

for Ukrainian producers of wire rod.  See, e.g., Nucor’s Posthearing Brief at 13.  Even if we were to

assume that Yenakiieve’s lack of a history exporting subject wire rod to the United States and its

consequent lack of customer relationships and familiarity with Ukrainian product in the United States

would not serve as impediments to Ukrainian exports of wire rod to the United States, Yenakiieve

provided a declaration documenting its likely costs of shipments to the United States totaling $*** per

ton.  Yenakiieve’s Posthearing Brief at Exh. 3 (Declaration of ***).   Although domestic producers dispute

these estimates establishing that transportation and logistical costs associated with shipments to the

United States would negate any alleged price advantages for Ukrainian exports, we find the declarations

and other supporting evidence placed on the record by Yenakiieve to be credible.

135 ***.   136 ***.   137 *** & CR/PR at Table C‐1.

138 Tr. at 192 (Dimitrova).

139 CR/PR at Table C‐1.

140 We have considered any combined impact of likely volumes from ArcelorMittal KR and

Yenakiieve and do not find that they rise to the level of having a likely discernible adverse impact on the

domestic industry.
23

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.141  Only a “reasonable overlap” of competition is required.142  In five‐year reviews, the

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.143

Fungibility.  Wire rod sold in the United States is categorized by quality according to end

use, with 11 major types of wire rod identified by the Iron and Steel Society.144  The

Commission requested market participants to classify their shipments into seven different

categories.  Industrial quality wire rod currently accounts for the majority of wire rod consumed

in the United States.145

In their questionnaire responses, market participants generally reported that wire rod

from different sources was interchangeable.  A majority of U.S. producers said wire rod from

different sources was always interchangeable in every comparison between the domestic like

product and subject imports and between subject imports from different sources.146  A majority

of importers reported that wire rod was at least frequently interchangeable in all comparisons

between the domestic like product and the subject imports and among subject imports from

different sources.147  A majority of purchasers said that wire rod was at least frequently

                                                      

141 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

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).

142 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).

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

2002). 144 CR at I‐33, PR at I‐26; CR/PR at Table I‐10.

145 CR at I‐33, PR at I‐26.

146 CR/PR at Table II‐9. 147 CR/PR at Table II‐9.
24

interchangeable in all but one comparison between the domestic like product and the subject

imports.148  A majority of purchasers stated that wire rod was at least sometimes

interchangeable in comparisons between subject imports from different sources.149

Purchasers were also asked to compare products from different sources with respect to

a number of factors.  In comparisons between the domestic like product and imports from the

subject countries, the majority of purchasers found the domestic like product to be either

superior or comparable.150  There were limited purchaser comparisons concerning product

factors between subject imports from different sources, but purchasers generally considered

the products to be comparable in most aspects.151

The Commission also sought product mix data from the domestic and subject industries,

requesting breakouts of shipments in seven different product categories.  The domestic

industry shipped products in each of the categories, with the two largest being low and

medium‐low carbon industrial and standard quality (49.1 percent of 2013 shipments) and high

and medium‐high carbon industrial and standard quality (27.9 percent of 2013 shipments).152

For each subject country that reported data, the vast majority of imports or shipments during

the period of review were in these two categories.153

Geographic Overlap.  Five of ten responding U.S. producers and one of four responding

importers from Mexico reported selling nationwide.154  The sole responding importer from

Trinidad and Tobago reported that it only sold to U.S. markets *** states.155  All geographic

markets in the contiguous 48 states are served by domestic producers and importers of subject

merchandise from Mexico.156

Channels of Distribution.  The overwhelming majority of domestically produced wire rod

is sold directly to end users.157  All wire rod imported from Trinidad and Tobago during the

                                                      

148 CR/PR at Table II‐9.  In one exception, two purchasers reported that the domestic like

product and subject imports from Moldova were “always” interchangeable and three purchasers

reported that they were “sometimes” interchangeable.  Id.

149 CR/PR at Table II‐9.

150 CR/PR at Table II‐8.  Pluralities of majorities of purchasers found that domestic like product

was superior to subject imports from Brazil in delivery terms, delivery time, and U.S. transportation

costs, superior to subject imports from Indonesia in all factors, superior to subject imports from Mexico

in delivery time, superior to subject imports from Moldova in availability, delivery time, extension of

credit, and quality exceeds industry standards, and superior to subject imports from Trinidad and

Tobago in delivery time, minimum quantity requirements, and technical support/service.

151 CR/PR at Table II‐8

152 CR/PR at Table III‐7.

153 CR/PR at Tables IV‐3, IV‐11, IV‐15, IV‐20, IV‐27, and IV‐32.  For each of these countries, the

majority of shipments were in the low carbon industrial category.

154 CR at II‐3, PR at II‐2.

155 CR at II‐3, PR at II‐2.

156 CR/PR at Table II‐2.

157 CR/PR at Table II‐1.
25

period of review was also sold directly to end users.158  Wire rod from Mexico was sold

exclusively to end users in 2008 and 2009, was sold mainly to distributors in 2010 and 2011,

and was split almost evenly between the two channels in 2012 and 2013.159

Simultaneous Presence in Market.  There were no U.S. imports of subject wire rod from

Brazil, Indonesia, Moldova, or Ukraine during the period of review.  According to official import

statistics, subject wire rod was imported from Trinidad and Tobago during four months of 2008

and from Mexico during nine months of that year.160  Subject imports from Mexico entered the

U.S. market during at least nine months of every year from 2009 to 2013.161

Analysis.  Market participants overwhelmingly find wire rod from different sources to be

at least sometimes interchangeable.  The large majority of shipments of the domestic like

product and imports from subject sources are in industrial quality grades.  Both these factors

support a finding of fungibility.   

The domestic like product and subject imports from Mexico were both predominantly

sold directly to end users and sold throughout the United States during the period of review.  

While imports from several of the subject countries were absent from the U.S. market during

the bulk of the period of review, this was likely due to the imposition of the orders.  We find

that upon revocation, subject imports would likely be simultaneously present in the market as

they were during the original investigations and the first year of the first reviews and would

likely be sold in overlapping channels of distribution and geographic markets.

No party argued that a reasonable overlap of competition is not likely.  In view of this

and the foregoing considerations, we conclude that there would likely be a reasonable overlap

of competition between the domestic like product and subject imports from all five countries,

and among imports from the different subject countries, should the orders be revoked.162

                                                      

158 CR/PR at Table II‐1.

159 CR/PR at Table II‐1.

160 CR at IV‐13, PR at IV‐10.

161 CR at IV‐13, PR at IV‐10.

162 Chairman Williamson considered subject imports from all six countries at issue in his analysis

of reasonable overlap of competition.   
26

D. Likely Conditions of Competition163 164

We do not find significant differences in likely conditions of competition among subject

imports from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago.  The record in these

reviews continues to indicate a lack of significant distinctions in conditions of competition

among these subject countries insofar as they might impact competition in the U.S. market.  

Each subject country continues to focus primarily on low‐carbon and high‐carbon industrial

grade wire rod.165  The market penetration of four of the five subject countries increased during

the original period of investigation, and the remaining country’s market penetration was

unchanged.166  Under the discipline of the orders, imports from each of these subject countries

have been considerably below pre‐order levels.167  Moreover, imports from each of the subject

countries predominantly undersold the domestic like product in the original investigations and

the first reviews, except for subject imports from Mexico, which undersold the domestic like

product in 26 of 54 possible comparisons in the first reviews.168  In these reviews, subject

imports from Mexico, the only subject imports for which the Commission received pricing

product data, undersold the domestic like product in 30 of 37 instances.169  Finally, each of the

subject industries continued to have significant quantities of unused capacity during portions of

the period of review.170   

We considered Deacero’s arguments that the Commission should exercise its discretion

not to cumulate subject imports from Mexico, but found them unpersuasive in light of the

considerations discussed above.  We do not find that Deacero’s sales of nonsubject 4.75 mm

wire rod differentiate Mexico from the other subject countries.  Deacero itself acknowledges

that 4.75 mm wire rod is “substitutable” with subject 5.5 mm wire rod, a product that all U.S.

                                                      

163 Chairman Williamson joins the discussion, but also finds no significant differences in likely

conditions of competition that would warrant not cumulating Ukraine with the other subject countries.  

As discussed in his dissenting views, he does not find that ArcelorMittal’s corporate policy would

prevent substantial imports of steel wire rod from ArcelorMittal KR.  Once that issue has been disposed

of, Ukraine does not present differences with the other subject countries substantial enough to warrant

not exercising his discretion to cumulate all subject countries.

164 Commissioner Johanson does not join this section.  As detailed in his dissenting views, he

does not exercise his discretion to cumulate subject imports from Mexico with those of the other five

countries, based primarily on his finding that the industry in Mexico is characterized by a unique

combination of high capacity utilization and low export orientation, and so are likely to compete in the

U.S. market under different conditions of competition.

165 CR/PR at Tables IV‐27, IV‐11, IV‐15, and IV‐20.  No producer or exporter of subject

merchandise from Moldova participated in these reviews, and information available does not indicate

that MSW has changed its focus from this type of wire rod since the first reviews.  First Review

Determinations, USITC Pub. 4014, at 19.

166 First Review Determinations, USITC Pub. 4014, at 19.

167 CR/PR at Tables I‐1 and C‐1.

168 CR at V‐18, nn.15 and 16, PR at V‐12 ‐ V‐13 nn.15 and 16

169 CR/PR at V‐8.

170 CR/PR at Tables IV‐7, IV‐12, IV‐17, and IV‐24; CR at IV‐52, PR at IV‐34.   
27

producers and other subject producers sell.171  Also, Deacero’s production of 4.75 mm wire rod,

which peaked in 2010 at *** short tons and averaged approximately *** short tons during the

period of review, represents only a small fraction of the Mexican industry’s  total production

capacity of *** short tons in 2013 and its actual production of subject merchandise of *** short

tons in that year.172  The pricing data also show that Deacero’s smaller diameter wire rod

undersold the domestic like product in *** instances.173  Deacero’s witnesses testified that it

undersold the domestic industry’s 5.5 mm wire rod to provide a price incentive on substitutable

4.75 mm wire rod products in order to gain sales and market share in the United States and

that it would also ship subject wire rod to the United States if the order was revoked.174  

Moreover, the fact that Deacero shipped nonsubject wire rod to the United States during the

period of review does not distinguish it from producers in Brazil who also shipped large

volumes of nonsubject wire rod to the United States during this period.175   

E. Conclusion176

We find that the no discernible adverse impact exception to cumulation applies to

subject imports from Ukraine and therefore do not cumulate such imports with subject imports

from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago.177  We further find that the

no discernible adverse impact exception to cumulation does not apply with respect to subject

imports from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago and that there

would likely be a reasonable overlap of competition between imports from those countries and

the domestic like product as well as among subject imports from each of these countries.  We

also determine that subject imports from Brazil, Indonesia, Mexico, Moldova, and Trinidad and

Tobago would be likely to compete under similar conditions of competition.  Accordingly, for

the reasons discussed above, we exercise our discretion to cumulate subject imports from

Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago.

                                                      

171 Tr. at 20 (Campbell).     172 Deacero’s Foreign Producer Questionnaire Response at II‐12; CR/PR at Table IV‐18.

173 CR at F‐4, PR at F‐3.    174 Tr. at 181‐82 (D. Gutierrez, Campbell); Tr. at 210 (Campbell).    175 CR/PR at Table IV‐10.  Moreover, we do not find that Mexico’s geographic proximity to the

United States by itself presents a significant difference in likely conditions of competition.    176 Chairman Williamson joins the discussion below, except he includes Ukraine as well, and

cumulates all six countries.    177 For the reasons discussed above and in the Separate and Dissenting Views of Commissioner

David S. Johanson, Commissioner Johanson exercises his discretion to cumulate subject imports from

Brazil, Indonesia, Moldova, Trinidad and Tobago, and Ukraine.  He determines that subject imports from

Mexico are likely to compete in the U.S. market under different conditions of competition from subject

imports of the other five countries, and so does not exercise his discretion to cumulate subject imports

from Mexico.   
28

IV. 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.”178  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.”179  Thus, the likelihood

standard is prospective in nature.180  The CIT 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.181  

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.”182  According to the SAA, a “‘reasonably foreseeable time’ will vary from case‐to‐case,

but normally will exceed the ‘imminent’ timeframe applicable in a threat of injury analysis in

original investigations.”183

                                                       

178 19 U.S.C. § 1675a(a).

179 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.

180 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.

181 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’”).

182 19 U.S.C. § 1675a(a)(5).

183 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

(Continued...)
29

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.”184  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).185  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.186

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.187  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.188

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

United States at prices that otherwise would have a significant depressing or suppressing effect

on the price of the domestic like product.189

                                                                                                                                                                              

(...Continued)

only manifest themselves in the longer term, such as planned investment and the shifting of production

facilities.”  Id. 184 19 U.S.C. § 1675a(a)(1).

185 19 U.S.C. § 1675a(a)(1). No duty absorption findings have been made for any of the subject

countries.  CR at I‐19 n. 19; PR at I‐15 n. 19.

186 19 U.S.C. § 1675a(a)(5).  Although the Commission must consider all factors, no one factor is

necessarily dispositive.  SAA at 886.

187 19 U.S.C. § 1675a(a)(2).

188 19 U.S.C. § 1675a(a)(2)(A‐D).

189 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.
30

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.190  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.191

V. Findings from the Original Investigations and Prior Reviews

A. Conditions of Competition

Original Investigations.  In the original determinations, the Commission characterized

wire rod as an intermediate product used to make a variety of products.  It found that there

was a continuum of wire rod products.192  Apparent U.S. consumption of wire rod, measured by

quantity, declined from 1999 to 2001.  Purchasers asserted that a reason for the decline in

demand was increased imports of downstream products incorporating wire rod.193  At the time

of the original determinations, the domestic industry consisted of 12 producers.  The producers

were dispersed geographically, and most individual producers produced a variety of products.  

Five domestic producers experienced bankruptcies or partial to full shutdowns of their wire rod

operations late in the period of investigation.194

The Commission noted that most purchasers reported that subject imports from most

sources and the domestic like product were used in the same applications.  Purchasers

identified quality, price, and availability, in that order, as the most important factors in selecting

a supplier.195  The share of the U.S. market held by nonsubject imports was relatively stable

from 1999 to 2001.  Wire rod imports from all countries except Canada and Mexico were

                                                       

190 19 U.S.C. § 1675a(a)(4).

191 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.

192 Original Determinations, USITC Pub. 3546 at 23.

193 Original Determinations, USITC Pub. 3546 at 24.

194 Original Determinations, USITC Pub. 3546 at 24.

195 Original Determinations, USITC Pub. 3546 at 25.
31

subject to a tariff rate quota that the President imposed affective March 1, 2000 as a safeguard

measure under section 203(a)(3) of the Trade Act of 1974.196

First Reviews.  In the first reviews apparent U.S. consumption of wire rod, measured by

quantity, was lower at the end of the period than at its inception, but fluctuated on an annual

basis.197  Market participants cited several different reasons for decreases in U.S. demand,

including declines in construction activity, a weakened U.S. automotive market, and increases in

imports of finished downstream wire products.198  During that review period, several U.S. firms

declared bankruptcy or closed operations, while others reorganized or merged.199  Several U.S.

producers expanded or made improvements to their production operations, and as a result,

domestic capacity was greater at the end of the reviews than during the original

investigations.200  Two significant domestic wire rod producers, ArcelorMittal USA and Gerdau

Ameristeel, were affiliated with producers of subject merchandise.201

The Commission noted that most market participants reported that subject imports

from most sources and the domestic like product were highly substitutable, particularly for

industrial grades.202  Low carbon industrial quality wire rod constituted the majority of

shipments by the domestic industry and from all subject countries except for Canada.203  The

share of the U.S. market held by nonsubject imports dropped sharply in 2007 due to a change in

Chinese export tax policies affecting wire rod.204  Throughout the period, subject imports

supplied smaller quantities of wire rod to the U.S. market than did either the domestic industry

or nonsubject sources, and Canada continued to be the largest supplier of subject imports.205

B. Volume of Subject Imports  

Original Investigations.  In the original investigations, the Commission found that

cumulated subject import volume and market penetration rose during the period of

investigation.  The volume of subject imports increased from 2000 to 2001 despite a

simultaneous decline in apparent U.S. consumption.  The Commission further found that the

increase in market share by cumulated subject imports came at the expense of the domestic

industry.  Accordingly, the Commission found the volume of cumulated subject imports, and

the increase in that volume, to be significant both in absolute terms and relative to production

and consumption in the United States.206  With respect to Trinidad and Tobago, the Commission

                                                      

196 Original Determinations, USITC Pub. 3546 at 25‐26.

197 First Review Determinations, USITC Pub. 4014 at 25.

198 Id.

199 Id. at 26.

200 Id.

201 Id.

202 Id. at 27.

203 Id.

204 Id.

205 Id.

206 Original Determinations, USITC Pub. 3546 at 27‐28.   
32

observed that that country was the second or third largest source of subject imports

throughout the period of investigation.  It indicated that the volume and market penetration of

subject imports from Trinidad and Tobago increased during the period of investigation and that

these subject imports were concentrated in low carbon industrial quality products, which was a

very price sensitive market.  The Commission found that, in light of the price‐sensitive market,

the volume of subject imports from Trinidad and Tobago was significant.207

First Reviews. In the first review determinations, the Commission found that the orders

had a substantial restraining effect on imports from the subject countries as the quantity of

subject imports and their share of apparent U.S. consumption fell sharply after the imposition

of the orders.208  The Commission further found that the industries in the subject countries

were substantial and that there was considerable unused capacity.209  It found that the United

States was the world’s largest single market for wire rod in 2006, that the cumulated subject

countries exported substantial quantities of wire rod during the period of review, and that the

United States had been among the highest‐priced markets during most of the review period.210  

Accordingly, the Commission determined that producers in the subject countries would be

likely to direct substantial quantities of unused and new capacity to the U.S. market if the

orders were revoked.211   

In doing so, the Commission rejected respondents’ argument that the United States was

an unattractive market because prices were lower than in other markets, finding that significant

excess capacity allowed subject producers to supply the U.S. market without diverting exports

from any other markets and that no respondent had argued that a subject producer could not

profitably sell subject merchandise in the United States upon revocation.212  The Commission

likewise rejected respondents’ arguments that Gerdau and ArcelorMittal would not likely

increase exports in a manner that would impair the operations of their domestic production

affiliates.  Specifically, the Commission found that, given that Gerdau did not act as a single

entity, the record did not support respondents’ assertions that its affiliation with a U.S.

producer would materially restrain its exports to the United States.  While the Commission

found that ArcelorMittal did act as a single entity in the United States, it found that, even

assuming that ArcelorMittal’s corporate structure would deter it from exporting large

quantities of subject merchandise upon revocation, much of the unused and additional capacity

in the subject countries was attributable to companies not controlled by ArcelorMittal.213

                                                      

207 Original Determinations, USITC Pub. 3546 at 36‐37.    208 First Review Determinations, USITC Pub. 4014 at 28.

209 First Review Determinations, USITC Pub. 4014 at 29‐30.

210 First Review Determinations, USITC Pub. 4014 at 31. 211 First Review Determinations, USITC Pub. 4014 at 30‐31. 212 First Review Determinations, USITC Pub. 4014 at 31.

213 First Review Determinations, USITC Pub. 4014 at 31‐32.
33

C. Price Effects

Original Investigations.  In the original investigations, the Commission found significant

underselling of the domestic like product by cumulated subject imports.  Cumulated subject

imports undersold the domestic like product in approximately two‐thirds of all comparisons,

and the Commission highlighted the consistently high underselling margins of subject imports

from Brazil, Moldova, and Ukraine.  The Commission further concluded that the subject imports

suppressed prices to a significant degree, as the domestic industry could not raise prices to

cover increased costs.214  With respect to Trinidad and Tobago, the Commission emphasized the

nature of the price competition and found that both the domestic like product and subject

imports from Trinidad and Tobago were concentrated in the price‐sensitive low carbon

industrial quality category.215  The Commission found significant underselling, with subject

imports from Trinidad and Tobago underselling the domestic like product in 70.8 percent of

quarterly comparisons.  It further found that subject imports from Trinidad and Tobago had

significant price‐suppressing effects, for reasons paralleling those presented in the cumulated

analysis.216

First Reviews. In the first review determinations, the Commission found that price

played an important role in purchasing decisions and that the industrial grades of wire rod, in

which both the domestic like product and cumulated subject imports tended to be

concentrated and considered good substitutes, were highly price sensitive.217  The Commission

found that, upon revocation, the quantities of additional cumulated subject imports would

likely exceed greatly any amount needed to rectify short supply conditions and, therefore,

importers would need to sell on the basis of price.  In light of the likely volume of cumulated

subject imports and their historic pattern of underselling, the Commission concluded that

significant underselling was likely upon revocation.  It further found that cumulated subject

imports would also likely have significant price‐suppressing or ‐depressing effects.  The

Commission observed that raw material costs and the ratio of cost of goods sold to net sales

increased during the review period and that significant quantities of low‐priced subject imports

would likely exacerbate the domestic industry’s inability to raise prices commensurately with

increases in costs.  Thus, the Commission concluded that cumulated subject imports were likely

to have significant price effects.218

D. Impact

Original Investigations.  In the original investigations, the Commission found that the

domestic industry lost market share as the volume of cumulated subject imports increased.  

                                                      

214 Original Determinations, USITC Pub. 3546 at 29‐30.

215 Original Determinations, USITC Pub. 3546 at 37.    216 Original Determinations, USITC Pub. 3546 at 37‐38.

217 First Review Determinations, USITC Pub. 4014 at 33.  Price was characterized as a “very

important” purchasing factor by 38 out of 41 purchasers.  Id. at Table II‐4.

218 First Review Determinations, USITC Pub. 4014 at 33‐34.
34

Indicators such as production, domestic shipments, and capacity utilization declined from 1999

to 2000 and fell more sharply from 2000 to 2001.  The Commission emphasized the domestic

industry’s increasing operating losses and noted declines in employment‐related indicators.  

The Commission determined that, while other factors contributed to the domestic industry’s

financial problems, cumulated subject imports played a significant role in the adverse market

conditions facing the domestic industry, including the loss of sales and market share to lower‐

priced subject imports.  It consequently concluded that cumulated subject imports had a

significant impact on the domestic industry.219  The discussion regarding the impact of subject

imports from Trinidad and Tobago referenced the discussion of cumulated subject imports.220

First Reviews. In the first reviews, the Commission found that the domestic industry’s

capacity had increased irregularly over the period of review, observing that one producer began

production operations, another restarted production in a previously closed facility, and two

domestic producers anticipated further increasing their capacities in 2008 or 2009.221  The

Commission observed that the domestic industry’s production fluctuated within a narrow range

during the period of review and that capacity utilization declined because capacity increased

more rapidly than production.222  The domestic industry’s U.S. shipments and employment

levels fluctuated during the period of review while inventories declined.223  In contrast to the

original investigations, the domestic industry generally operated profitably during the period of

review, although operating performance fluctuated considerably on an annual basis.224  The

Commission attributed these improvements to the orders.225  The Commission found that, if

the antidumping and countervailing duty orders were revoked, a significant volume of

additional cumulated subject imports would likely enter the U.S. market and undersell the

domestic like product, having significant price‐suppressing or ‐depressing effects.226  The

Commission determined that the additional imports would likely be significantly greater than

needed to rectify any existing supply shortages in the U.S. market and that, given that demand

was at its lowest level of the period of review in 2007 and was reportedly expected to decline

further, additional imports would not be absorbed by increasing demand.227  Accordingly, the

Commission concluded that revocation of the antidumping and countervailing duty orders

would likely have a significant adverse impact on the domestic industry’s output, sales, market

share, employment, profits, and return on investment.228   

                                                      

219 Original Determinations, USITC Pub. 3546 at 31‐33.    220 Original Determinations, USITC Pub. 3546 at 38.    221 First Review Determinations, USITC Pub. 4014 at 35. 222 First Review Determinations, USITC Pub. 4014 at 35.  Capacity utilization was at a period high

of 84.6 percent in 2002 and reached a period low of 69.4 percent in 2005 before increasing to 74.9

percent in 2007.  Id.    223 First Review Determinations, USITC Pub. 4014 at 35.

224 First Review Determinations, USITC Pub. 4014 at 35.

225 First Review Determinations, USITC Pub. 4014 at 36.

226 First Review Determinations, USITC Pub. 4014 at 36.

227 First Review Determinations, USITC Pub. 4014 at 36.

228 First Review Determinations, USITC Pub. 4014 at 36.
35

VI. 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.”229  The following conditions of competition inform our determinations.

A. Demand Conditions

Wire rod continues to be used as an intermediate product.  Most wire rod is sold, or

internally transferred, to wire drawers that produce a wide variety of wire products.230  

Consequently, demand for wire rod depends on demand for these many downstream

products.231  Wire rod is used primarily in the construction, automotive, energy, and agriculture

industries.232   

Apparent U.S. consumption of wire rod fluctuated during the period of review.  

Apparent U.S. consumption in 2013 was *** percent below the pre‐recession levels of 2008.233  

During the general economic recession, apparent U.S. consumption fell from *** short tons in

2008 to *** short tons in 2009, before increasing in 2010 and 2011 to *** short tons and ***

short tons, respectively.234  Apparent U.S. consumption increased to *** short tons in 2012

before declining slightly to 5.30 million short tons in 2013.235   

The majority of market participants noted the negative effect of the 2009 recession,

with some indicating that, despite some recovery, demand, particularly in the construction

market, had not returned to the pre‐recession levels.236  A plurality of firms indicated that

demand is expected to increase over the next two years, with a majority reporting that they

anticipate demand to increase slowly, particularly in the automotive and construction

markets.237  The majority of market participants that responded to the Commission’s

questionnaires reported that worldwide demand has fluctuated or decreased since 2008 but

anticipate that it will increase or remain unchanged in the future.238  The majority of foreign

                                                       

229 19 U.S.C. § 1675a(a)(4).

230 CR/PR at II‐1.

231 CR at II‐18 – II‐19, PR at II‐11.  Reported end uses include fasteners, wire garment hangers,

wire mesh, nails, concrete reinforcing mesh, baling wire, industrial wire, tire cord/bead, shelving wire,

sod staples, suspension springs, and PC strand.  Id.    232 CR/PR at II‐1.

233 CR/PR at Table C‐1.    234 CR/PR at Table C‐1.    235 CR/PR at Table C‐1.    236 CR at II‐20, PR at II‐12.    237 CR at II‐21, PR at II‐13.    238 CR/PR at Tables II‐3 and IV‐35
36

producers indicated that demand in their home markets fell during the recession but has

generally recovered and is expected to increase.239   

B. Supply Conditions   

Throughout the period of review, the domestic industry was the largest supplier of wire

rod to the U.S. market.  The domestic industry’s share of the U.S. market fluctuated during the

period of review, ending the period at its lowest level; it was *** percent in 2008, *** percent

in 2009, *** percent in 2010, *** percent in 2011, *** percent in 2012, and 67.9 percent in

2013.240  There are ten U.S. producers of wire rod, with seven of these firms internally

transferring some of their wire rod production for the manufacture of downstream products.241  

The domestic industry’s capacity to produce wire rod fell from 2008 to 2010, increased in 2011,

and subsequently fell to a level in 2013 that was 8.5 percent lower than what was reported for

2008. 242  Several U.S. producers reported that they are not operating at full capacity due to

market conditions and that import competition limits their ability to produce more wire rod.243   

Nonsubject countries are the next largest suppliers to the U.S. wire rod market after the

domestic industry.  Their share of apparent U.S. consumption declined from 2008 to 2009 but

fluctuated upward from 2009 to 2013, for an overall increase of *** percentage points from

2008 to 2013.244  The leading nonsubject source of wire rod imports was China, which

accounted for 36.4 percent of total imports in 2013; these imports are subject to ongoing

antidumping and countervailing duty investigations.245  Other leading nonsubject sources of

wire rod imports include Canada and Japan, which accounted for 28.3 and 15.1 percent,

respectively, of total imports in 2013.246

Under the discipline of the orders, subject imports were largely absent from the U.S.

market during the period of review.  There were no reported U.S. imports of subject wire rod

                                                      

239 CR at IV‐80, PR at IV‐47.    240 CR/PR at Table C‐1.    241 CR at III‐13, PR at III‐7.    242 CR/PR at Table III‐4.  Nucor opened a new wire rod mill at its Darlington, South Carolina

facility in October 2013 and reopened a previously idled facility at Kingman, Arizona.  Id.  ArcelorMittal’s

Georgetown, South Carolina facility, Evraz Pueblo’s Pueblo, Colorado facility, and Keystone’s Peoria,

Illinois facility underwent production curtailments and resumptions.  CR/PR at III‐1.  Gerdau idled the

rolling mill at its Perth Amboy, New Jersey facility in ***, and it remains idled.  Id.  Gerdau also invested

in melting and rolling capacity expansions at its Jacksonville, Florida facility during 2008‐2010.  Id.

243 CR at III‐9, PR at III‐4.    244 CR at IV‐7, PR at IV‐7; CR/PR at Table C‐1.  Nonsubject imports’ share of apparent U.S.

consumption was *** percent in 2008, *** percent in 2009, *** percent in 2010, *** percent in 2011,

*** percent in 2012, and 31.9 percent in 2013.  CR/PR at Table C‐1.    245 CR/PR at Table IV‐1; CR at IV‐7, PR at IV‐5.  See Carbon and Certain Alloy Steel Wire Rod from

China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248 (Preliminary), USITC Publication 4458 (March 2014).  The

Commission made affirmative preliminary determinations on March 20, 2014.  79 Fed. Reg. 16373 (Mar.

25 2014).

246 CR/PR at Table IV‐2; CR at IV‐7, PR at IV‐5.   
37

from Brazil, Indonesia, Moldova, and Ukraine, and subject imports from Trinidad and Tobago

ceased after 2008.247  Mexico was the largest supplier of subject imports and the only subject

country from which wire rod was imported during each year of the review period.248  Subject

imports’ share of the U.S. market fluctuated but remained low throughout the period of

review.249

C. Substitutability  

Wire rod sold in the United States is categorized by quality according to end use, with 11

major types of wire rod identified by the Iron and Steel Society.250  The Commission requested

market participants to classify their shipments into seven different categories.  The domestic

industry produces wire rod in each of the seven categories.  The three largest categories for the

domestic industry are low/medium‐low carbon industrial/standard quality (accounting for 49.1

percent of U.S. producers’ U.S. shipments in 2013) followed by high/medium‐high carbon

industrial/standard quality (accounting for 27.9 percent of shipments), and cold heading quality

(“CHQ”) (accounting for *** percent of shipments).251  Subject imports from Mexico were

reported as being only low/medium‐low carbon industrial/standard quality (accounting for ***

percent of U.S. importers’ shipments of subject imports in 2013) and high/medium‐high carbon

industrial/standard quality (accounting for *** percent of shipments).252  Nonsubject imports

were reported in all seven categories; the three largest categories for nonsubject imports were

low/medium‐low carbon industrial/standard quality (accounting for 34.2 percent of U.S.

importers’ shipments of nonsubject imports in 2013), followed by CHQ (accounting for 25.5

percent of shipments) and high/medium‐high carbon industrial/standard quality (accounting

for 18.8 percent of shipments).253  Therefore, there is substantial overlap between the

categories of wire rod supplied by the domestic industry, subject imports, and nonsubject

imports.   

Domestically produced wire rod and subject imports of the same type, particularly in the

same industrial quality grades, tend to be highly substitutable.254  For specialty grades, however,

not all sources can produce each product, and there may be differences in wire rod with the

same specifications that may limit the degree of substitution.255   

                                                      

247 CR at IV‐3, PR at IV‐2; CR/PR at Table IV‐1.    248 CR at IV‐3 – IV‐4, PR at IV‐2; CR/PR at Table IV‐1.    249 CR/PR at Table C‐1.  Subject imports’ share of apparent U.S. consumption was *** percent in

2008, *** percent in 2009, *** percent in 2010, *** percent in 2011, *** percent in 2012, and 0.2

percent in 2013.  Id.    250 CR at I‐33, PR at I‐26.

251 CR/PR at Table III‐7.

252 CR/PR at Table IV‐3.    253 CR/PR at Table IV‐3.    254 CR at II‐23, PR at II‐14.

255 CR at II‐23 – II‐24, PR at II‐14 – II‐15.
38

D. Other Conditions  

The principal inputs used in the U.S. production of wire rod are steel billets (produced

from steel scrap), natural gas, and electricity.256  The billets sourced from the United States are

produced using minimill technology that melts ferrous scrap and other raw materials in an

electric arc furnace.257  The price of steel scrap fluctuated between January 2008 and December

2013, peaking during the last week of July 2008, falling to a period low in the second week of

November 2008, increasing irregularly from the end of 2008 through 2010, and then continuing

to fluctuate, decreasing slightly from the first week of January 2011 through the last week of

December 2013.258  U.S. natural gas prices peaked in mid‐2008 and fell steeply until October

2009 when prices began to rise; prices then decreased irregularly between January 2010 and

May 2012 before increasing irregularly through December 2013.259  Electricity prices fluctuated

seasonally but with no significant net changes.260   

During the period of review, a significant share of domestic production was captively

consumed.  The domestic industry internally consumed or transferred to related firms more

than *** short tons of wire rod in 2013.261  Internal consumption and transfers to related firms

accounted for *** percent of the domestic industry’s total shipments in 2008, *** percent in

2009, *** percent in 2010, *** percent in 2011, *** percent in 2012, and *** percent in

2013.262  The *** of such shipments were transferred to related firms, reportedly at market

prices.263  Commercial (merchant market) shipments accounted for virtually all of the balance of

the domestic industry’s shipments.264

Most U.S. producers and importers set prices on a transaction‐by‐transaction basis.265  

However, firms also reported using contracts, set price lists, and other methods, including

indexing prices to scrap and other raw material costs as well as market conditions.266   

                                                      

256 CR/PR at V‐1.    257 CR at I‐40, PR at I‐31.

258 CR/PR at V‐1 and Figure V‐1.

259 CR at V‐2  – V‐3, PR at V‐2; CR/PR at Figure V‐2.

260 CR at V‐3, CR/PR at Figure V‐2.

261 Calculated from CR/PR at Table III‐11.  We observe that, although several firms reported

internal transfers, a single firm, ***, accounted for the vast majority of the domestic industry’s internal

transfers.  CR/PR at Table III‐13.    262 CR/PR at Table III‐6.

263 CR/PR at Table III‐6; CR at III‐13 n.10, PR at III‐7 n.10.

264 CR/PR at Table III‐6.    265 CR at V‐5, PR at V‐4; CR/PR at Table V‐1.    266 CR at V‐5, PR at V‐4; CR/PR at Table V‐1.   
39

VII. Revocation of the Antidumping and Countervailing Duty Orders on

Subject Imports from Brazil, Indonesia, Mexico, Moldova, and Trinidad

and Tobago Is Likely to Lead to the Continuation or Recurrence of

Material Injury to the Domestic Industry within a Reasonably Foreseeable

Time267 268

A. Likely Volume of Subject Imports

As discussed above, under the discipline of the orders, there were very limited volumes

of subject imports during the period of review.  Cumulated subject imports were *** short tons

in 2008, *** short tons in 2009, *** short tons in 2010, *** short tons in 2011, *** short tons

in 2012, and 10,333 short tons in 2013.269  Their share of apparent U.S. consumption was ***

percent in 2008, *** percent in 2009, *** percent in 2010, *** percent in 2011, *** percent in

2012, and 0.2 percent in 2013.270 271 272

Production capacity in the cumulated subject countries is substantial.  The reported

aggregate capacity of producers in Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago

                                                       

267 As discussed earlier and in his dissenting views regarding Ukraine, Chairman Williamson

cumulates all subject countries.  His analysis for the six cumulated countries does not differ in any

material respect from the majority’s analysis, which he joins subject to the footnotes below.

268 As discussed earlier and in his Separate and Dissenting Views regarding Mexico,

Commissioner Johanson exercises his discretion to cumulate subject imports from Brazil, Indonesia,

Moldova, Trinidad and Tobago, and Ukraine, but does not exercise his discretion to cumulate subject

imports from Mexico.

269 CR/PR at Table IV‐1.  As discussed above, subject imports from Trinidad and Tobago were

present in the U.S. market only in 2008; imports of wire rod from Mexico were the only subject imports

present in the U.S. market in each year of the period of review.  Id.

270 CR/PR at Table C‐1.

271 Chairman Williamson has cumulated subject imports from all six subject countries.  His

inclusion of subject imports from Ukraine does not change the data above concerning subject import

volumes during the period of review.  He joins generally the discussion below, and his addition of

Ukraine in his cumulated analysis does not result in any material differences between his analysis and

the majority’s.  However, his additional consideration of Ukraine’s capacity (reported at *** short tons

in 2013), excess capacity (reported at *** short tons in 2013), and export orientation (*** percent of

total shipments were exported in 2013) further supports his ultimate conclusion that cumulated subject

import volumes will likely be significant if the orders were revoked.  See CR/PR at Table IV‐29.

272 Commissioner Johanson has cumulated subject imports from Brazil, Indonesia, Moldova,

Trinidad and Tobago, and Ukraine.  There were similarly very limited volumes of these cumulated

subject imports during the period of review.  CR/PR at Table IV‐1.  He finds that subject imports for the

five countries he has cumulated will likely be equally as significant as the countries that the majority has

cumulated because the aggregate capacity in 2013 (*** short tons) was even higher, as was the

aggregate excess capacity in 2013 (*** short tons).
40

was *** short tons in 2013.273  Thus, the total reported capacity of producers in cumulated

subject countries exceeds the 5.3 million short tons of apparent U.S. consumption in 2013.274  

There is also considerable unused capacity in the cumulated subject countries.  The reported

aggregate excess capacity was *** short tons in 2013.275  Moreover, production capacity is

expected to increase in the reasonably foreseeable future.276   

We find that producers in the subject countries would likely direct significant quantities

of wire rod to the U.S. market should the pertinent orders be revoked.  Throughout the period

of review, the United States continued to be one of the largest markets for wire rod imports.277  

The cumulated subject countries, in the aggregate, exported substantial quantities of wire rod

during the period of review.278  In addition, the record in these reviews indicates that the United

States has been among the highest priced markets for wire rod during most of the period of

                                                      

273 CR/PR at Table IV‐6.  The “reported” capacity data for Moldova are data published by ***

because the sole producer of wire rod in Moldova did not respond to the Commission’s questionnaire in

these reviews.  Id. at note 1.  If we were to rely upon data published by *** and GTIS/GTA for capacity

data for the industries in all cumulated subject countries, aggregate capacity would be substantially

higher than reported by responding producers in Brazil, Indonesia, Mexico, and Trinidad and Tobago.  

Published data indicate capacity was *** short tons in 2013.  Id.  “Published” capacity data for Trinidad

and Tobago are the data reported by the Trinidadian producer in questionnaire responses because data

from industry monitoring sources were not available.  Id. at note 2.

274 CR/PR at Table C‐1.

275 CR/PR at Table IV‐6.  As noted above, the “reported” capacity data for Moldova are data

published by ***.  Id. at note 1.  If we were to rely upon data published by *** and GTIS/GTA for

capacity and production data for the industries in all cumulated subject countries, aggregate unused

capacity would be substantially higher than reported.  Published data indicate unused capacity was ***

short tons in 2013.  Id.  As noted above, published capacity data for Trinidad and Tobago are the data

reported by the Trinidadian producer in questionnaire responses.  Id. at note 2.

276 Specifically, according to ***, three new mills are forecast to come online in Brazil during

2014‐15, with an estimated combined capacity of approximately *** short tons in 2014 and *** short

tons in 2015.  CR at IV‐18 – IV‐19, PR at IV‐14.  In addition, ***.  CR at IV‐23 – IV‐24, PR at IV‐16.  

Respondent Deacero contends that wire rod capacity in Mexico will decrease as a result of plans to

convert capacity in one of its mills from wire rod to special bar quality.  Deacero’s Posthearing Brief at 7

(citing Tr. at 140 (Gutierrez)), Exhibit 23 & Responses to Commission’s Questions at 27 (citing Tr. at 227

(Gutierrez)).  Deacero, however, has not asserted that this purported conversion will occur in the near

future, but rather, its representative testified that any such conversion would be gradual and done

slowly.  Tr. at 228 (Gutierrez).  Accordingly, we rely upon the capacity data reported by Mexican

producers in questionnaire responses.  Commissioner Johanson does not join the preceding two

sentences.

277 CR/PR at Table IV‐40.    278 CR/PR at Tables IV‐8, IV‐10, IV‐13, IV‐14, IV‐17, IV‐19, IV‐22, IV‐24 and IV‐26.  The data in

these tables may include some wire products that are not subject merchandise.  CR/PR at Tables IV‐10

note, IV‐14 note, IV‐19 note, IV‐22 note and IV‐26 note.
41

review.279  Moreover, we observe that subject producers continue to demonstrate interest in

the U.S. market, as is evidenced by their exports of out‐of‐scope wire rod products.280 281 282  This

                                                      

279 CR/PR at Figure IV‐2 and Table IV‐38.  Country‐specific monthly transaction prices for wire

rod indicate that Chinese market prices were consistently below U.S. prices.  CR/PR at Table IV‐38; CR at

IV‐91, PR at IV‐51.  Korean wire rod market prices were generally below U.S. prices, with notable

exceptions in 2010, 2012, 2013, and 2014.  Id.  Japanese market prices were generally higher than U.S.

market prices in 2009 through the first half of 2012 but consistently lower in 2008 and the latter half of

2012 through the first three months of 2014.  Id.  Similarly, Canadian market prices were generally

higher than U.S. prices in 2009 through the first half of 2013 but generally lower in 2008 and the latter

half of 2013 through the first three months of 2014.  CR/PR at Table IV‐38.  European market prices

were higher than U.S. prices for most of 2008 but then consistently lower than U.S. prices from the

latter part of 2008 through the first three months of 2014.  CR/PR at Figure IV‐2 and Table IV‐38.  

Although we recognize that these data may not be as precise as pricing data based on specific pricing

product definitions, CR at IV‐84, PR at IV‐50, we nonetheless find the data to be demonstrative of the

likely attractiveness of the U.S. wire rod market in the reasonably foreseeable future.    280 In particular, the U.S. market continued to be the largest export market for nonsubject wire

rod imports from Brazil during the period of review.  CR/PR at Table IV‐10.  Similarly, subject imports as

well as nonsubject wire rod imports from Mexico were present in the U.S. market throughout the period

of review, and Deacero itself stated that imports from Mexico maintained a continued “substantial

presence” during the review period.  CR/PR at Tables IV‐17, IV‐19, C‐1 and Appendix F; Deacero’s

Posthearing Brief at 5.  Accordingly, notwithstanding Deacero’s assertion that wire rod prices in third

countries are higher than U.S. prices, Deacero’s Posthearing Brief at 8‐9 and Prehearing Brief at 23‐26,

we find that the persistent presence of wire rod imports from Mexico during the review period

demonstrates that the U.S. market continues to be viewed by Mexican producers as an attractive

market.  Moreover, as discussed above in section III.D., Deacero acknowledged that the 4.75 mm wire

rod that it shipped during the review period is “substitutable” with subject 5.5 mm wire rod, and

Deacero undersold domestically produced 5.5 mm wire rod by providing a price incentive on its 4.75

mm wire rod to gain sales and market share in the United States.  Tr. at 181‐82 (D. Gutierrez, Campbell).  

Additionally, Deacero indicated that it might also ship subject wire rod to the United States if the order

were revoked.  Tr. at 210 (Campbell).

281 Respondents argue that Gerdau and ArcelorMittal are unlikely to increase exports from

subject countries in a manner that would impair the operations of their domestic production affiliates.  

AWPA Prehearing Brief at 8‐13.  In the first reviews, we found that Gerdau did not act as a single entity,

and there is nothing in the record of these second reviews that calls that conclusion into question.  

Accordingly, there are no material disincentives to Gerdau affiliates to import wire rod to the United

States.  With respect to ArcelorMittal, the record in these reviews continues to indicate that

ArcelorMittal coordinates its global operations.  Gerdau Parties’ Posthearing Brief, Responses to

Commission’s Questions at 54‐55.  However, the record also continues to indicate that substantial

portions of the foreign industries are controlled by firms that are not affiliated with ArcelorMittal.  As

discussed above, ArcelorMittal Brasil was estimated to account for less than *** of Brazilian wire rod

production in 2013.  CR at IV‐17, PR at IV‐13.  Moreover, as discussed above, the majority of new wire

rod capacity that is expected to be added in 2014 and 2015 in Brazil is attributable to firms unrelated to

ArcelorMittal.  CR at IV‐18 – IV‐19 and CR at IV‐23 – IV‐24, PR at IV‐14 and IV‐16.  With respect to the

wire rod industry in Mexico, we observe that Deacero was estimated to account for *** percent of

(Continued...)
42

participation in the U.S. market also indicates that the subject producers have ready access to

U.S. distribution networks.   

Given the cumulated subject producers’ excess capacity, likely capacity increases, and

overall export orientation, and the size and relative attractiveness of the U.S. market, we

conclude cumulated subject import volumes will likely be significant, both in absolute terms

and relative to U.S. consumption, upon revocation.283

                                                                                                                                                                              

(...Continued)

production in 2013.  CR at IV‐40, PR at IV‐25.  Although ArcelorMittal Point Lisas is the sole producer of

wire rod in Trinidad and Tobago, the sole producer of wire rod in Moldova is not affiliated with

ArcelorMittal.  In addition, although the AWPA asserts that the Commission should consider PT Ispat

Indo to be affiliated with ArcelorMittal, Gerdau Parties dispute this assertion and challenged it in the

first review.  Gerdau Parties’ Posthearing Brief, Responses to Commission’s Questions at 56; First Review

Determinations, USITC Report, at IV‐36 n.19.  In any event, we observe that *** estimated PT Ispat Indo

to account for only *** percent of total rolling wire rod capacity in Indonesia in 2013.  CR at IV‐29, PR at

IV‐20.  PT Ispat Indo itself estimated that it accounted for only *** percent of wire rod production in

Indonesia in 2013.  PT Ispat Indo Foreign Producer Questionnaire Response.  Accordingly, the record

indicates that substantial portions of the industries in each of the cumulated subject countries other

than Trinidad and Tobago are controlled by companies that are not affiliated with ArcelorMittal.  

Furthermore, we observe that ***.  CR at Appendix D‐24, PR at Appendix D‐3.  Thus, to the extent that

ArcelorMittal may import to the United States if the orders were revoked, it would likely rely on sources

more proximate to the United States, including the subject countries of Mexico and Trinidad and

Tobago.  This is consistent with ArcelorMittal’s pattern during the period of review, including in 2010

when it experienced closure and idling of U.S. production facilities, to ***.  CR/PR at Table III‐9.

282 Chairman Williamson and Commissioner Johanson join the prior footnote’s discussion only in

part.  In particular, they join its discussion of Gerdau, and its discussion that substantial portions of

several foreign industries are controlled by firms not affiliated with ArcelorMittal.  However, as

discussed in their dissenting views on Ukraine, they do not join any suggestion that ArcelorMittal’s

corporate policies would prevent imports into the United States from ArcelorMittal affiliates, and do not

join the conclusion that any such imports would be most likely from sources more proximate to the

United States.   283 We have also considered several other statutory factors in our analysis of likely subject

import volume.  Reported end‐of‐period inventories of subject merchandise for 2013 maintained in

Brazil, Indonesia, Mexico, and Trinidad and Tobago were *** short tons.  CR/PR at Tables IV‐9, IV‐13, IV‐

17 and IV‐24.  U.S. inventories of subject merchandise were present in the United States only during

2008 and 2011.  CR at IV‐11, PR at IV‐9.  In ***, U.S. importers’ inventories of subject imports from

Trinidad and Tobago were *** short tons; in ***, U.S. importers’ inventories of subject imports from

Mexico were *** short tons.  CR/PR at Table IV‐5.   

The record indicates that there are existing or potential barriers to exports of wire rod

applicable to wire rod from Indonesia.  Specifically, the record indicates that Malaysia imposed an

antidumping duty order against imports of wire rod from Indonesia in 2013 and that Australia initiated

an investigation into alleged dumping of rod in coils from Indonesia, Taiwan, and Turkey in 2014.  CR at

IV‐15, PR at IV‐12.  Additionally, Colombia is currently conducting a global safeguard investigation on

wire rod, as well as rebar and wire round.  Id.  Chairman Williamson and Commissioner Johanson note

that Mexico imposed an antidumping duty order on wire rod imports from Ukraine in 2000.  

(Continued...)
43

B. Likely Price Effects  

The record in these reviews indicates that subject imports and domestically produced

wire rod of the same type are highly substitutable284 and that price is a very important factor in

purchasing decisions.285  Moreover, as discussed above, both the domestic like product and

subject imports tend to be concentrated in industrial quality grades.  Thus, for purchasers of

industrial quality grades of wire rod, pricing is particularly important in purchasing

decisions.286 287  

The Commission collected quarterly pricing data on four wire rod products – two

industrial quality products, a mesh quality product, and a product for spring applications.288  

Nine U.S. producers and two importers of wire rod from Mexico provided usable pricing data

for sales of the requested products, although not all firms reported pricing for all products for

all quarters.289  Pricing data reported by these firms accounted for approximately 31.0 percent

of U.S. producers’ shipments of wire rod and *** percent of U.S. shipments of subject imports

from Mexico during the period of review.290  The pricing data show that cumulated subject

imports undersold the domestic like product in 30 out of 37 instances, with margins of

underselling ranging from *** to *** percent.291   

                                                                                                                                                                              

(...Continued)

Some producers in the cumulated subject countries produce other products in the same

facilities where they produce wire rod.  Specifically, ArcelorMittal Brasil and all three responding

Mexican producers reported producing *** using shared equipment and machinery.  CR at IV‐22 and IV‐

44; PR at IV‐16 and IV‐29; CR/PR at Tables IV‐9 and IV‐18.  ArcelorMittal Point Lisas reported ***.  CR at

IV‐59, PR at IV‐38; CR/PR at Table IV‐25.    284 CR at II‐23, PR at II‐14.

285 The most often cited top three factors firms consider in their purchasing decisions for wire

rod were quality (33 firms), price (30 firms), and availability (16), with 14 firms citing quality as the most

important factor and 12 firms citing price as the most important factor.  CR at II‐25 – II‐26, PR at II‐16;

CR/PR at Table II‐5.  In addition, 36 responding purchasers rated price as a “very important” purchasing

factor.  CR at II‐27 – II‐28, PR at II‐17; CR/PR at Table II‐6.    286 Chairman Williamson has cumulated subject imports from all six subject countries.  He joins

generally the discussion below, and his addition of Ukraine in his cumulated analysis does not result in

any material differences between his analysis and the majority’s.    287 Commissioner Johanson has cumulated subject imports from Brazil, Indonesia, Moldova,

Trinidad and Tobago, and Ukraine.  He observes that there are no pricing data for the period of review

concerning the subject imports he has cumulated.  He finds that these cumulated subject imports will

likely have significant adverse price effects because they undersold the domestic like product in 117 of

146 available quarterly comparisons in the original investigations and in 25 of 31 available quarterly

comparisons in the first reviews.

288 CR at V‐8, PR at V‐6.

289 CR at V‐8, PR at V‐6.

290 CR at V‐8, PR at V‐6.    291 CR at V‐18, PR at V‐12; CR/PR at Tables V‐3 – V‐6.
44

Given the predominant underselling during both this period of review and the first

reviews and the significant underselling in the original investigations,292 as well as our findings

that subject imports would likely increase upon revocation, we find that significant underselling

would likely recur if the antidumping and countervailing duty orders were revoked.  Because of

the importance of price in purchasing decisions, this underselling in turn would likely cause the

domestic industry to consider either reducing its prices or foregoing price increases to maintain

market share, as was the case in the original investigations.  We therefore conclude that the

likely significant volume of cumulated subject imports of wire rod would likely undersell the

domestic like product to a significant degree to gain market share and would also likely have

significant price‐depressing or ‐suppressing effects.   

C. Likely Impact  

Over the period of review, most trade indicators declined as a result of the recession in

2009, subsequently increased through 2011 but then declined in 2012 and 2013.  The domestic

industry’s capacity decreased from 5.55 million short tons in 2008 to 5.30 million short tons in

2009 and 4.97 million short tons in 2010 before increasing to 5.17 million short tons in 2011

and subsequently falling to 5.13 million short tons in 2012 and 5.10 million short tons in

2013.293  Production quantity similarly decreased from 4.06 million short tons in 2008 to 2.84

million short tons in 2009 before increasing to 3.38 million short tons in 2010 and 5.17 million

short tons in 2011 and subsequently decreasing to 5.13 million short tons in 2012 and 5.07

million short tons in 2013.294  Capacity utilization fluctuated during the review period but

declined overall; it was 73.1 percent in 2008, 53.6 percent in 2009, 68.2 percent in 2010, 75.5

percent in 2011, 75.6 percent in 2012, and 72.0 percent in 2013.295

The domestic industry’s U.S. shipments, both on a total basis and on a commercial

(merchant market) basis, showed patterns similar to those for production.  Total U.S. shipments

were 4.1 million short tons in 2008, 2.83 million short tons in 2009, 3.34 million short tons in

2010, 3.88 million short tons in 2011, 5.13 million short tons in 2012, and 5.07 million short

                                                      

292 Cumulated subject imports from Brazil, Indonesia, Mexico, Moldova, and Trinidad and

Tobago undersold the domestic like product in 133 of 170 available comparisons in the original

investigations and in 45 out of 79 available comparisons in the first reviews.  CR at V‐18 nn.15 and 16, PR

at V‐12 nn.15 and 16.  Chairman Williamson and Commissioner Johanson note that subject imports from

Ukraine undersold the domestic like product in *** available comparisons in the original investigations

and in *** available comparisons in the first review.  Id.

293 CR/PR at Tables III‐5 and C‐1.  Gerdau Parties contend that the capacity utilization rate is

understated because the figures do not account for all capacity reported by domestic producers in

questionnaire responses.  Gerdau Parties’ Prehearing Brief at 91‐92.  Specifically, the capacity data do

not include any capacity at Gerdau’s Perth Amboy, New Jersey facility because that facility has been

idled since the second half of 2009.  CR at III‐8, PR at III‐4; CR/PR at Table III‐5 note.

294 CR/PR at Tables III‐5 and C‐1.

295 CR/PR at Tables III‐5 and C‐1.
45

tons in 2013.296  Commercial shipments were 2.95 million short tons in 2008, 2.03 million short

tons in 2009, 2.41 million short tons in 2010, 2.94 million short tons in 2011, 2.82 million short

tons in 2012, and 1.86 million short tons in 2013.297  Inventories relative to U.S. shipments

increased from 5.7 percent in 2008 to 6.8 percent in 2009 before declining to 5.8 percent in

2010 and 4.9 percent in 2011; they subsequently increased to 6.1 percent in 2012 and 7.4

percent in 2013.298  As discussed above, although the domestic industry accounted for the

majority of apparent U.S. consumption, its market share fluctuated and declined from 2008 to

2013, ending the review period at its lowest level.299   

The number of production and related workers employed by the domestic industry and

total hours worked fluctuated but declined overall during the review period.300  Wages paid and

hourly wages also fluctuated during the period of review but were highest in 2012 before

declining in 2013.301  The industry’s productivity also fluctuated but was highest in 2011 and

2013.302

The financial performance of the domestic industry showed some recovery from the

recession but subsequently displayed declines from 2011 to 2013.  The domestic industry’s

total net sales values declined from $3.6 million in 2008 to $1.7 million in 2009 before

increasing to $2.3 million in 2010 and $3.1 million in 2011 and then declining to $2.9 million in

2012 and $2.6 million in 2013.303  The domestic industry’s ratio of COGS to net sales increased

from 87.9 percent in 2008 to 98.4 percent in 2009, then decreased to 91.6 percent in 2010 and

90.0 percent in 2011 before increasing to 91.7 percent in 2012 and 92.4 percent in 2013.304  As a

result, while the domestic industry recovered somewhat from the recession and was profitable

                                                      

296 CR/PR at Tables III‐6 and C‐1.

297 CR/PR at Table III‐6.  As discussed above, although there was substantial captive consumption

during the period of review, the majority of domestic shipments were in the merchant market.  The

percentage of commercial shipments ranged from 70.8 percent of total U.S. shipments to 75.3 percent

on an annual basis during the review period.  Id.    298 CR/PR at Tables III‐8 and C‐1.

299 CR/PR at Table C‐1.    300 CR/PR at Tables III‐10 and C‐1.  The number of production related workers was 2,339 in 2008,

2,083 in 2009, 2,173 in 2010, 2,239 in 2011, 2,269 in 2012, and 2,192 in 2013.  Hours worked were 4.7

million in 2008, 3.8 million in 2009, 4.2 million in 2010, 4.6 million in 2011, 4.6 million in 2012, and 4.3

million in 2013.  Id.

301 CR/PR at Tables III‐10 and C‐1.  Unit labor costs also fluctuated from year to year but

increased slightly from 2008 to 2013.  Id.

302 CR/PR at Tables III‐10 and C‐1.    303 CR/PR at Tables III‐11 and C‐1.  The domestic industry’s net commercial sales values similarly

declined from $2.6 million in 2008 to $1.2 million in 2009, then increased to $1.7 million in 2010 and

$2.4 million in 2011 before declining to $2.2 million in 2012 and $1.9 million in 2013.  CR/PR at Table III‐

11.    304 CR/PR at Tables III‐11 and C‐1.   
46

in every year except for 2009, its operating income did not return to pre‐recession levels.305  

The domestic industry’s ratio of operating income to net sales fell from 9.8 percent in 2008 to

negative 2.6 percent in 2009, then rose to 4.3 percent in 2010 and 7.2 percent in 2011 before

falling to 5.2 percent in 2012 and 4.2 percent in 2013.306  The industry’s capital expenditures

decreased from 2008 to 2009 but subsequently increased steadily from 2009 to 2013.307  

Research and development expenses, which were much lower than capital expenditures,

fluctuated from year to year and were higher in 2012 and 2013 than in 2008.308

Although we acknowledge that most performance indicators declined in 2012 and 2013

after showing some recovery from the recession, we find that the domestic industry is not

currently in a vulnerable condition.  Nonetheless, as discussed above, should the orders under

review be revoked, we have found that the volume of subject imports would likely increase to a

significant level.309 310  We have further found that this additional volume of subject imports

would likely be priced in a manner that would undersell the domestic like product.  

Consequently, the domestic industry would need to respond either by forgoing sales and ceding

market share or by lowering or restraining prices.  Under either circumstance, the domestic

industry’s revenues and financial performance would likely decline, resulting in declines in the

domestic industry’s production, shipments, market share, and employment.  Moreover, as

discussed above, although a significant share of U.S. wire rod production is internally

transferred, the substantial majority of domestic shipments are in the merchant market.  

Therefore, we find the existence of captive consumption does not insulate the domestic

industry from competition.   

We have also considered the role of nonsubject imports in the U.S. market.  Nonsubject

imports’ share of the U.S. wire rod market fluctuated throughout the period of review and

increased overall.311 312  As discussed above, the leading nonsubject source of wire rod imports

was China, and those imports are currently subject to ongoing antidumping and countervailing

duty investigations.  The continued presence of nonsubject imports in the U.S. market, as was

the case in the original investigations and first reviews, would not preclude subject imports

                                                      

305 CR/PR at Tables III‐13 and C‐1.  The domestic industry’s operating income was $347.1 million

in 2008, negative $42.9 million in 2009, $98.8 million in 2010, $218.0 million in 2011, $148.4 million in

2012, and $107.7 million in 2013.  Id.   306 CR/PR at Tables III‐13 and C‐1.    307 CR/PR at Tables III‐14 and C‐1.    308 CR/PR at Table III‐14.  Four U.S. producers reported research and development expenses.  Id.

309 Chairman Williamson has cumulated subject imports from all six subject countries.  He finds

the discussion below is equally applicable to the subject imports he has cumulated.

310 Commissioner Johanson joins the conclusions in this paragraph with respect to the subject

imports from Brazil, Indonesia, Moldova, Trinidad and Tobago, and Ukraine that he has cumulated.

311 CR/PR at Table C‐1.

312 Commissioner Johanson has also considered the subject imports from Mexico that he has not

cumulated.  As detailed in his Separate and Dissenting Views, he determines that subject imports from

Mexico are not likely to lead to a continuation or recurrence of material injury were the order on Mexico

to be revoked.   
47

from taking market share from the domestic industry, the largest supplier of wire rod to the

U.S. market, or forcing the domestic industry to its lower prices to compete.   

Accordingly, in light of the likely significant volumes and likely adverse price effects, we

find that revocation of the antidumping and countervailing duty orders would likely have a

significant adverse impact on the domestic industry.

VIII. Revocation of the Antidumping Order on Subject Imports from Ukraine Is

Not Likely to Lead to the Continuation or Recurrence of Material Injury to

the Domestic Industry within a Reasonably Foreseeable Time313

A. Likely Subject Import Volume

For purposes of our analysis of likely subject import volume, we incorporate by

reference our discussion of subject imports from Ukraine in section III.B. above.  In that

discussion, we found that it was unlikely that the largest producer of subject wire rod in

Ukraine, ArcelorMittal KR, would ship more than minimal volumes of wire rod to the United

States due to its affiliation with the ArcelorMittal Group and lack of geographic proximity to the

U.S. market.  We further found that the only other significant current subject producer in

Ukraine, Yenakiieve, had not shipped wire rod to the Western Hemisphere during the period of

review and was unlikely to direct more than a modest portion of its limited excess capacity to

the United States.  Accordingly, we conclude that the likely volume of subject wire rod imports

from Ukraine would not be significant, in absolute terms or relative to production or

consumption in the United States, within a reasonably foreseeable time in the event of

revocation.

B. Likely Price Effects

During the original investigations, subject imports from Ukraine undersold the domestic

like product in 21 of 22 quarterly price comparisons, with an average underselling margin of

*** percent.314  In the first reviews, subject imports from Ukraine undersold the domestic like

product in all six quarterly price comparisons, with an average margin of underselling of ***

percent.315  There were no price comparisons in the current reviews.

We find that pricing data for Ukraine from the original investigations, and the first year

of the first review, are not indicative of likely pricing patterns upon revocation of the order.316  

The composition of the industry in Ukraine has changed dramatically since the original

                                                       

313 Chairman Williamson and Commissioner Johanson do not join this section of the opinion.  See

Separate and Dissenting Views of Chairman Irving A. Williamson and Commission David J. Johanson

Regarding Cumulation for Ukraine.   314 CR at V‐18 n.11, PR at V‐4 n.11

315 CR at V‐18 n.11, PR at V‐4 n.11.

316 First Review Determinations, USITC Report, at Table V‐2.
48

investigation, as the mills that have since become ArcelorMittal KR and Yenakiieve were then

under different management.317  Moreover, as discussed above, due to ArcelorMittal KR’s

affiliation with the ArcelorMittal Group and Yenakiieve’s limited excess capacity and lack of

interest or experience in supplying wire rod to markets in the Western Hemisphere, subject

imports from Ukraine are not likely to be at significant volumes upon revocation.  

Consequently, subject producers in Ukraine are not likely to have any incentive to price

aggressively to gain U.S. market share.  We find that any modest volumes of imports that may

be expected to enter the U.S. market from Ukraine upon revocation of the order would be too

small to have a material influence on pricing for the entire U.S. market.  Given the likely small

volume of subject imports from Ukraine in the event of revocation, we find that revocation of

the antidumping duty order on subject imports of wire rod from Ukraine would not be likely to

lead to significant underselling or significant price depression or suppression within a

reasonably foreseeable time.

C. Likely Impact  

We incorporate by reference the discussion in section VII.C. above concerning the

domestic industry’s performance during the period of review, as well as our finding that the

domestic industry is not in a vulnerable condition.  Given that we find it likely that there would

not be a significant volume of subject imports from Ukraine and there would not be likely

significant price effects from these imports, we find that revocation of the antidumping and

countervailing duty orders on subject imports from Ukraine is not likely to lead to a significant

impact on the domestic industry within a reasonably foreseeable time.

Thus, we conclude that revocation of the antidumping duty order on subject imports

from Ukraine would not be likely to lead to continuation or recurrence of material injury to the

domestic industry within a reasonably foreseeable time.

IX. Conclusion

For the foregoing reasons, we determine that revocation of the countervailing duty

order on carbon and certain alloy steel wire rod from Brazil and the antidumping duty orders on

wire rod from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago, would be likely to

lead to continuation or recurrence of material injury to an industry in the United States within a

reasonably foreseeable time.318  We determine that revocation of the antidumping duty order

                                                       

317 CR at IV‐65 – IV‐66, PR at IV‐41 – IV‐42; Yenakiieve’s Prehearing Brief at 15‐16.  We observe

that this is the first time that the Commission has had a chance to consider fully these changes in the

industry in Ukraine as no Ukrainian producer participated in the first reviews through filing briefs or

providing testimony at the hearing.

318 Commissioner Johanson determines that revocation of the countervailing duty order on wire

rod wire rod from Brazil and the antidumping duty orders on wire rod from Brazil, Indonesia, Moldova,  

Trinidad and Tobago, 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.  He determines that

(Continued...)
49

on wire rod from Ukraine 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.319

                                                                                                                                                                              

(...Continued)

revocation of the antidumping duty order on wire rod from Mexico 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.

319 Chairman Williamson determines that revocation of the countervailing duty order on wire

rod wire rod from Brazil and the antidumping duty orders on wire rod from Brazil, Indonesia, Mexico,

Moldova, Trinidad and Tobago, 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.

51

SEPARATE AND DISSENTING VIEWS OF CHAIRMAN IRVING A. WILLIAMSON AND

COMMISSIONER DAVID S. JOHANSON REGARDING CUMULATION FOR UKRAINE

Based on the record in these reviews, we do not find that subject imports of steel wire

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

the order on such imports were revoked.

In the original investigations, subject imports from Ukraine increased from 193,003

short tons in 1999 to 367,712 short tons in 2000, then declined to 258,526 short tons in 2001,

for an overall increase of 33.9 percent from 1999 to 2001.  Their share of apparent U.S.

consumption was *** percent in 1999, *** percent in 2000, and *** percent in 2001.1

  Subject

imports from Ukraine undersold domestic product in 21 of 22 available comparisons.2  In the

first five‐year review, with the order in place, subject imports from Ukraine were absent from

the U.S. market except in 2002 (11,159 short tons) and 2005 (738 short tons).3  Subject imports

undersold domestic product in all 6 comparisons.4

  There were no subject imports from Ukraine

during the current period of review.5

Two producers of subject product in Ukraine – ArcelorMittal Kryvyi Rih (“ArcelorMittal

KR”) and Yenakiieve Iron and Steel Works (“Yenakiieve”) – responded to the Commission’s

foreign producer questionnaire in these reviews.  While *** presents data that cover other

producers, the two responding producers accounted for *** percent of the total wire rod

rolling capacity and *** percent of wire rod production in Ukraine during 2013 as reported by

***.6  We consider the two responding producers to account for at least the vast majority of

the current industry in Ukraine.

The larger of the two responding producers, ArcelorMittal KR, is part of the

ArcelorMittal group.  Yenakiieve argues that, based on ArcelorMittal’s regional supply policy,

this producer is unlikely to export meaningful volumes of steel wire rod to the United States.  In

particular, Yenakiieve argues that ArcelorMittal’s corporate policy is to serve local markets with

local production, and that decisions concerning imports are ***.7

We conclude that ArcelorMittal’s corporate policy is not likely to prevent ArcelorMittal

KR from exporting substantial volumes of steel wire rod to the United States in the event of

revocation.   First, the corporate policy clearly permits imports from other ArcelorMittal mills

                                                      

1 Original Determinations, USITC Pub. 3546, USITC Report at Table I‐1 (reproduced in CR/PR appendix

C).  Over the three full years of the original period of investigation, the total volume of subject imports

from Ukraine were the second highest of the six countries remaining in these reviews, following only

subject imports from Trinidad & Tobago.  Id. 2 CR at V‐18 n.15, PR at V‐12 n.15.

3 First Review Determinations, USITC Pub. 4014, USITC Report at Table I‐1. 4 CR at V‐18 n.16, PR at V‐12 n.16. 5 CR/PR at Table C‐1.

6 CR at IV‐67 n. 51; PR at IV‐42 n.51. 7 See, e.g., Yenakiieve’s Prehearing Brief at 5‐6 and 34.
52

depending on market opportunities.  ArcelorMittal reports that it “employs a commercial

coordination policy that ***” and that “***.”8

  Indeed, in the first five‐year review of these

orders, despite similar affiliations, the Commission cumulated all subject countries except

Canada, and the decision on Canada was not based on ArcelorMittal affiliations.9

  Second, over

the POR, there have indeed been imports of wire rod into the United States from ArcelorMittal

companies, including from ***.10   While ArcelorMittal may have some preference for sourcing

U.S. imports from its Western Hemisphere affiliates, we do not find this would prevent imports

from other affiliates, such as ArcelorMittal KR, in light of the continuing antidumping duty

orders on Mexico and Trinidad and Tobago as well as imports from other affiliates over the

period of review.   Third, ArcelorMittal KR has *** – in 2013, its capacity utilization rate was ***

percent, and its ***.11  Given this level of ***, and the high fixed cost nature of steel wire rod

production,12 we find that ArcelorMittal would have a strong incentive to produce additional

wire rod in Ukraine and export to the United States if the order were revoked.  Fourth,

ArcelorMIttal USA is a *** producer.  In 2013, it accounted for only *** percent of domestic

capacity, and only *** percent of domestic production.  ArcelorMittal USA itself was a ***

importer of steel wire rod over the POR, and these imports *** over the POR.13  In 2013, its

total imports of steel wire rod totaled *** short tons, equivalent to *** percent of its domestic

production.14

Based on these facts, we find that, upon revocation, it is likely that there would be U.S.

imports of steel wire rod from ArcelorMittal KR.  The volume of such imports are of course

uncertain, but given the *** at ArcelorMittal KR, such import volumes would likely be at least

large enough to have a discernible adverse impact on the domestic industry, even without

consideration of the other Ukrainian producer, Yenakiieve.

Having rejected the argument related to ArcelorMittal, we consider the Ukrainian

industry as a whole.  Questionnaire data indicate that the industry has *** and growing excess

capacity.  Capacity utilization in Ukraine declined steadily from *** percent in 2010 to ***

percent in 2011, *** percent in 2012, and *** percent in 2013.15  Absolute excess capacity has

***, reaching *** tons in 2013; this is equivalent to nearly *** of apparent U.S. consumption in

that year.16  We also note that there is some evidence on the record that additional capacity

will come online in 2014 at the Dneprovsky (Dzerzhinsky) Metallurgical Plant.17  

                                                      

8 CR at III‐19, PR at III‐10.

9 First Review Determinations, USITC Pub. 4014 at 12‐19.

10 CR/PR at Table I‐12. 11 Foreign Producer Questionnaire Response of ArcelorMittal KR at II‐5a. 12 See CR at III‐40 n.42, III‐42 n.46, and III‐43 n.49; PR at III‐18 n.42, III‐19 n.46, and III‐19 n.49.

13 CR/PR at Table III‐9. 14 CR/PR at Table III‐9.

15 CR/PR at Table IV‐29.

16 CR/PR at Tables IV‐29 and C‐1. 17 See, e.g., Nucor’s Prehearing Brief at 32 and n.177; Gerdau Parties’ Posthearing Brief at Ex. 1 p. 2.
53

The industry in Ukraine is also *** export‐oriented.  Exports accounted for *** percent

of total shipments throughout the POR;18 the share was *** percent in 2013.19  We also note

that in each year of the POR, Ukraine was the world’s third‐ or fourth‐largest exporter of wire

rod products; none of the other subject countries were in the top ten.20  Yenakiieve argues that

its exports are concentrated in nearby markets, and that it is not likely to export outside those

markets.  As discussed above, we are considering the Ukrainian industry as a whole.  For that

industry, exports have been to many countries, and the industry has demonstrated an ability to

quickly shift shipments among export markets.21  While some of Ukraine’s largest export

markets are currently in Europe, the Middle East, and western Asia, it also has significant

exports to Nigeria and Senegal.22  There is also some evidence that Ukraine has reduced its

exports to Russia.23  At the Commission’s hearing, the witness from Ukraine stated that the

current political situation in Ukraine was not affecting exports of steel products from that

country’s ports.24  Moreover, while the Ukrainian industry may not be currently exporting steel

wire rod to the Western Hemisphere, it has previously done so, as demonstrated by the trade

remedy in place in Mexico, which was imposed in 2000 and has been continued.25

In sum, we find that, upon revocation, there will likely be substantial imports of steel

wire rod from ArcelorMittal KR, notwithstanding ArcelorMittal’s corporate policies, and that

imports of steel wire rod from Ukraine overall are not likely to have no discernible adverse

impact on the domestic industry.  We also determine, as discussed in our footnotes to the

majority opinion, to exercise our discretion to cumulate Ukraine with the other subject

countries we each are cumulating.

                                                      

18 The record from the original investigations and the first review show that the Ukrainian industry

was equally export oriented during those earlier periods.  Original Determinations, USITC Pub. 3546,

USITC Report at Table VII‐8; First Review Determinations, USITC Pub. 4014, USITC Report at Table IV‐35.

19 CR/PR at Table IV‐29.

20 CR/PR at Table IV‐41. 21 CR/PR at Table IV‐31. 22 Id. 23 Nucor Prehearing Brief at Ex. 1 p. 6 and Ex. 18; Yenakiieve Prehearing Brief at Ex. 16.

24 Tr. at 199 (Dimitrova).

25 CR at IV‐15; PR at IV‐12; Gerdau Parties’ Prehearing Brief at 75 and Ex. 14.

55

SEPARATE AND DISSENTING VIEWS OF  

COMMISSIONER DAVID S. JOHANSON

I. INTRODUCTION

Based on the record in these five‐year reviews, I concur with my colleagues in

determining that material injury is likely to continue or recur within a reasonably foreseeable

time if the countervailing duty order on subject imports of carbon and certain alloy steel wire

rod (“wire rod”) from Brazil and the antidumping duty orders on subject imports of wire rod

from Brazil, Indonesia, Moldova, and Trinidad and Tobago are revoked.1 I write separately from

my colleagues, however, as I find that material injury is not likely to continue or recur within a

reasonably foreseeable time if the antidumping duty order on subject imports of wire rod from

Mexico is revoked.  I join the discussion of the Commission majority regarding background

(Section I), domestic like product and domestic industry (Section II), cumulation (only Sections

III(A)–(C)), legal standards (Section IV), findings from the original investigations and prior

reviews (Section V), conditions of competition in the U.S. market (Section VI), and the finding

that revocation of the orders with respect to Brazil, Indonesia, Moldova, and Trinidad and

Tobago is likely to lead to a continuation or recurrence of material injury (Section VII), with

exceptions as noted.  I write separately to discuss my analysis of the statutory factors regarding

imports from Mexico.

II. CUMULATION

A. Likelihood of No Discernible Adverse Impact

I concur with my colleagues (Section III(B) of majority views) in not finding that subject

imports of wire rod from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago would

likely have no discernible adverse impact on the domestic industry if those orders were

revoked.  However, as detailed in our joint dissenting views, Chairman Williamson and I differ

from the majority because we do not find that subject imports from Ukraine would likely have

no discernible adverse impact on the domestic industry if that order were revoked.

B. Likelihood of a Reasonable Overlap of Competition

I concur with my colleagues (Section III(C) of majority views) in concluding that there

would likely be a reasonable overlap of competition between the domestic like product and

subject imports from all six countries.

   

                                                             1 I also find that material injury is likely to continue or recur within a reasonably foreseeable

time if the antidumping duty order on wire rod from Ukraine were revoked.  For my views on subject

imports from Ukraine, see Separate and Dissenting Views of Chairman Irving A. Williamson and

Commissioner David S. Johanson Regarding Cumulation for Ukraine.
56

C. Likely Conditions of Competition

I write separately because, based on the evidence, I exercise my discretion to cumulate

subject imports from five countries—Brazil, Indonesia, Moldova, Trinidad and Tobago, and

Ukraine—but I do not exercise my discretion to cumulate subject imports from Mexico.

I base my cumulation decision primarily on my analysis of the likely volume of subject

imports that might come from each the six countries in the event of revocation.  I find that, of

the foreign industries producing wire rod in these six countries, the industry in Mexico is unique

in that it alone combines both the highest average capacity utilization and lowest average

export orientation over the period of these second reviews.  I consider this important as both

characteristics make the Mexican industry less likely to export to the U.S. market in the event of

revocation.2

Over the period of these second reviews, capacity utilization by the Mexican industry

was consistently high and ranged from 85.0 percent in 2013 to 98.1 percent in 2011, and

averaged 92.0 percent over 2008‐2013.3  Over the period of these reviews, excess capacity in

Mexico ranged from 49,752 short tons in 2011 to 412,708 short tons in 2013, and averaged

201,726 short tons.4

  Total exports of wire rod from Mexico, as a share of total shipments, were

consistently low and ranged from 9.4 percent in 2009 to 16.6 percent in 2011, and averaged

*** percent over 2008‐2013.5

  Further, I find that these characteristics of the Mexican industry

have been consistent over the periods of the original investigations,6 the first reviews,7 and

                                                             2 As will be detailed in Section III(A) of these Separate and Dissenting Views, the combination of

the two characteristics leads me to conclude that a significant increase in subject imports from Mexico is

not likely if the antidumping order on Mexico were revoked.

3 CR/PR at Table IV‐17 (average calculated by summing total production and dividing by total

capacity over the full six‐year period).  I choose to use data from Table IV‐17 because Commission staff

considers data reported by *** and GTA to be “overstated” as it contains non‐scope products.  CR at IV‐

40 n.34 and IV‐47; PR at IV‐26 n.34 and IV‐30. 4 CR/PR at Table IV‐17.  Since the recession year of 2009, production capacity in Mexico has

increased steadily, and while production also increased steadily through 2012, production declined by

8.6 percent in 2013, leading to higher excess capacity.  Id.  As I discuss below in Section III(A), this

decline in production was primarily related to temporary political conditions that are expected to

resolve themselves this year. 5 CR/PR at Table IV‐17 (average calculated by summing total exports and dividing by total

shipments over the full six‐year period).  Mexico does not appear on the list of the “top 10” exporters of

wire rod in the world and total exports reported by Mexico were significantly lower than the volume of

exports of the country ranked as the number 10 exporter, Italy.  Compare CR/PR at Table IV‐41 with

CR/PR at Table IV‐17.   6 Over the period of the original investigations, available questionnaire responses covering an

estimated *** percent of Mexican production (and *** percent of exports to the U.S. market) showed

the Mexican industry ranging from *** percent capacity utilization in interim 2002 to *** percent in

1999, and averaging *** percent utilization over the period Jan. 1999 to Mar. 2002.  Total exports of

wire rod from Mexico ranged from *** percent of total shipments in 2000 to *** percent in interim

2002, and averaged *** percent over the period Jan. 1999 to Mar. 2002.  2002 Staff Report at Table VII‐

5.
57

these second reviews (suggesting that such characteristics are not simply a manifestation of the

presence of these U.S. trade remedies).8

   

Finally, I find that changes in the structure of the Mexican industry producing wire rod

since the period of the original investigation have reinforced its tendencies toward high

capacity utilization and low export orientation.  Deacero, which was not mentioned as a

member of the Mexican wire rod industry in the original investigations, became *** producer

in the Mexican industry during the period of the first reviews, accounting for *** Mexican

production.9

  Deacero’s core business is “downstream wire products” (e.g. chain link fence,

barbed wire, staples, and nails)10 and Deacero’s primary reason for producing wire rod is for

internal consumption, which accounts for “over 70 percent” of its wire rod production.11  

Likewise, at the end of the period of the first review, Sicartsa, the *** exporter to the U.S.

market during the period of the original investigations, was acquired by ArcelorMittal and has

reduced its presence in the U.S. market to *** of U.S. consumption; 12 ArcelorMittal Las Truchas

forecasts that, even in the event of revocation, it would ***.13  

In contrast, I find that the other five countries involved in these reviews can be

characterized has having either low capacity utilization, or—in the case of Moldova, Trinidad

and Tobago, and Ukraine—both low capacity utilization and high export orientation.  These

characteristics make it likely that they would use their excess capacity, in the event of

revocation of the orders, to supply the U.S. market with significant volumes of subject imports.  

Over the period of these reviews, data contained in the Commission’s staff report show that

capacity utilization for the industries producing wire rod in:

 Brazil ranged from *** percent in 2009 to *** percent in 2010, and averaged ***

percent over 2009‐2013;14

 Indonesia ranged from *** percent in 2009 to *** percent in 2011, and averaged ***

percent over 2009‐2013;15

 Moldova was reportedly *** percent in 2012;16

                                                                                                                                                                                                7 Over the period of the first reviews, available questionnaire responses covering an estimated

*** percent of Mexican production showed the Mexican industry ranging from *** percent capacity

utilization in 2006 to *** percent in 2004, and averaging *** percent over 2002‐2007. Total exports of

wire rod from Mexico ranged from *** percent of total shipments in 2006 to *** percent in 2002, and

averaged *** percent over the period 2002‐2007. 2008 Staff Report at Table IV‐25.

8 Separate and Dissenting Views of Chairman Daniel R. Pearson, First Reviews, USITC Pub. 4014,

at 49‐50.

9 2008 Staff Report at IV‐69.  In 2013, Deacero accounted for *** percent of total wire rod

production in Mexico.  CR at IV‐40; PR at IV‐25.

10 Tr. at 141‐42 (D. Gutierrez). 11 Tr. at 140 (S. Gutierrez); Deacero’s prehearing brief at 7‐8 and 26‐27. 12 Tr. at 152 (Campbell); Deacero’s prehearing brief at 5‐6; Deacero’s posthearing brief at 10.  

ArcelorMittal Las Truchas argues that its subject imports over this period of review have been only ***

ArcelorMittal’s U.S. production.  Id.

13 Deacero’s prehearing brief at 6; Deacero’s posthearing brief at 10. 14 CR/PR at Table IV‐7.

15 CR/PR at Table IV‐12.
58

 Trinidad and Tobago ranged from *** percent in 2009 to *** percent in 2011, and

averaged *** percent over 2008‐2013;17

 Ukraine ranged from *** percent in 2009 to *** percent in 2010, and averaged ***

percent over 2009‐2013.18

So while none of the other five countries had an average capacity utilization over the

period of these second reviews that exceeded *** percent, Mexico’s average capacity

utilization over this period was *** percent.  In every year of the period of these reviews,

Mexico’s capacity utilization was the highest of the six countries.

Available data on export orientation are less comparable due to the overinclusiveness of

some export data (also, the denominator is “shipments” for Mexico and Trinidad and Tobago,

but “production” for the other countries), but the data show that export orientation for the

industries producing wire rod in:

 Brazil ranged from *** percent in 2013 to *** percent in 2009, and averaged ***

percent over 2009‐2013;19

 Indonesia ranged from *** percent in 2013 to *** percent in 2009, and averaged ***

percent over 2009‐2012;20

 Moldova was *** percent in 2013;21

 Trinidad and Tobago ranged from *** percent in 2008 to *** percent in  2011, and

averaged *** percent over 2008‐2013;22

 Ukraine ranged from *** percent in 2013 to *** percent in 2012, and averaged ***

percent over 2009‐2013.23

While Mexico may not have had the lowest degree of export orientation among the six

subject countries throughout the period of these reviews (as it had in 2009 and 2010), it was

always among the lowest three countries (Brazil and Indonesia sometimes having a lower

degree of export orientation) and its average over the period of these second reviews was the

lowest (at *** percent), again, to the extent that the data are comparable.

I do not place heavy emphasis on Deacero’s shipments of out‐of‐scope 4.75 mm wire

rod to the U.S. market and do not view the mere presence of Mexican production of the smaller

diameter wire rod as a likely distinguishing condition of competition.24  The peak year of

                                                                                                                                                                                                16 CR/PR at Table IV‐21; CR at IV‐52; PR at IV‐34. 17 CR/PR at Table IV‐24.

18 CR/PR at Table IV‐29.

19 CR/PR at Table IV‐6.  Combining production data from Table IV‐7 with (over‐inclusive) export

data from Table IV‐10.

20 CR/PR at Table IV‐6.  Combining production data from Table IV‐12 with (over‐inclusive) export

data from Table IV‐14. 21 CR/PR at Table IV‐6. 22 CR/PR at Table IV‐24.

23 CR/PR at Table IV‐6.  Combining production data from Table IV‐28 with (over‐inclusive) export

data from Table IV‐31.

24 Cf. Deacero’s prehearing brief at 8‐14.
59

imports of this smaller diameter wire rod was 2010, the last full year prior to the initiation of a

circumvention inquiry by Commerce.25  In 2010, Deacero states that it believed that it was

unrestrained by the antidumping order for that product and had not yet learned of the

circumvention inquiry.26  U.S. imports of the small diameter wire rod from Mexico in 2010 were

*** short tons,27 which was *** than subject import volume from Mexico in *** of the period

of the original investigations; the peak volume of imports of the smaller diameter wire rod from

Mexico in 2010 was also *** than the subject import volumes in each year of the period of the

original investigation for three of the other five countries being reviewed here (Moldova,

Trinidad and Tobago, and Ukraine).28  As a rough measure, the volume of non‐subject 4.75 mm

imports from Mexico would have accounted for *** percent of U.S. consumption in 2010.  

While the Mexican industry did avail itself of the opportunity to export to the U.S. market

outside the discipline of these orders, even in 2010, it did not export a volume of wire rod

inconsistent with the limited excess capacity possessed in the Mexican industry (recall from

above that Mexican excess capacity averaged just over *** short tons over the period of these

reviews); also, even if this quantity of out‐of‐scope exports had been considered in‐scope, it

would not have significantly increased the Mexican industry’s level of export orientation.29

Therefore, I determine that, based on the existence of unique conditions of competition

inherent in the Mexican industry, subject imports from Mexico would be likely to compete

under different conditions of competition than the subject imports from the other five subject

countries.  Accordingly, for the reasons discussed above, I do not exercise my discretion to

cumulate subject imports from Mexico and I consider them separately from all other subject

imports.

III. REVOCATION OF THE ANTIDUMPING DUTY ORDER ON SUBJECT IMPORTS FROM

MEXICO IS NOT LIKELY TO LEAD TO A CONTINUATION OR RECURRENCE OF MATERIAL

INJURY TO THE DOMESTIC INDUSTRY WITHIN A REASONABLY FORESEEABLE TIME

A. Likely Volume of Subject Imports from Mexico

During the period of the original investigations, the volume of subject imports from

Mexico increased by 118.7 percent, increasing steadily from 122,038 short tons in 1999 to

266,925 short tons in 2001.  Over the three full years of the period of the original investigations,

subject import volume from Mexico increased the fastest of the six countries under review

here, but the aggregate volume of subject imports from Mexico during 1999‐2001 was the ***

                                                             25 CR/PR at Table F‐1; CR at I‐23; PR at I‐18.

26 Deacero’s prehearing brief at 3 and 22.

27 CR/PR at Table F‐1.

28 CR/PR at App. C:  Reproduction of Table I‐1 from First Review.  ***.  Id. 29 Instead of the ratio of exports to shipments being 12.8 percent, the ratio would have been

*** percent.  CR/PR at Tables IV‐17 and F‐4.
60

largest (behind ***).  The U.S. market share held by subject imports from Mexico increased

steadily from *** percent in 1999 to *** percent in 2001.30

After imposition of the antidumping duty order against Mexico in 2002, subject imports

from Mexico fell irregularly to 11,480 short tons in 2005, and have exceeded that level ***

since that year (reaching ***).  After falling to a U.S. market share of 0.2 percent in 2005,

subject imports from Mexico have never exceeded the *** percent level, which they reached in

***.31

As discussed above in the section on cumulation, my primary reason for not cumulating

subject imports from Mexico is that the Mexican industry producing wire rod is unique in that it

had, over the period of these second reviews, both the highest average capacity utilization and

the lowest average export orientation.  Mexico has both low levels of excess capacity with

which to increase production of wire rod, and a low propensity to export its production of this

product.  Both of these characteristics make it unlikely that there will be significant increases in

subject imports from Mexico within the reasonably foreseeable future were the antidumping

duty order on Mexico to be revoked.

I also find, as discussed above in the cumulation section, that these characteristics have

distinguished the Mexican industry producing wire rod even during the period of the original

investigations and the period of the first review.  Changes in the structure of the Mexican

industry since 2002 have acted to further reinforce the high rate of capacity utilization and low

export orientation.  First, Deacero, which sees itself as primarily a wire products operation that

produces its wire rod primarily for internal consumption, became the dominant Mexican

producer of wire rod.32  Second, the *** exporter of Mexican wire rod during the original

investigations was acquired by ArcelorMittal in 2007 and has since exported *** of wire rod to

the United States.33

As an illustration of how these characteristics affect Mexican exports of wire rod, I note

that the growth rate in the Mexican economy slowed from about 4 percent in 2011 and 2012 to

1.1 percent in 2013.34  This led to declines in Mexican production, internal

consumption/transfers, and home market shipments.  Yet total exports ***, increasing by ***

                                                             30 2002 Staff Report at Table I‐1.

31 CR/PR at App. C:  Reproduction of Table I‐1 from First Review.  Over the period of these

reviews, more than *** percent of the in‐scope subject imports from Mexico shown in Table IV‐17 were

sourced from ***.  *** foreign producer questionnaire response, at 10.

32 Deacero “did not supply wire rod to the U.S. before 2008.”  Tr. at 144 (D. Gutierrez).

33 Deacero prehearing brief at 5‐6; Tr. at 152 (Campbell).  I am not arguing that the ArcelorMittal

affiliation will, by itself, act to inhibit likely volumes of subject imports from Mexico, but rather that over

the six years of this review period, ArcelorMittal Las Truchas’ capacity utilization has never been lower

than *** percent (in ***) and was higher than *** percent in four of the six years.  ArcelorMittal Las

Truchas’ foreign producer questionnaire response at 10.  Such ***, rather than global corporate

strategy, motivates my finding that the Mexican industry is not likely to increase exports significantly to

the U.S. market in the event of revocation.   34 Deacero prehearing brief at 24 and Exhibit 14.  This slowdown was blamed, to a large extent,

on the change in presidential administrations in Mexico, which occurred in July 2013, and the impact

this had on government spending.  Therefore, this slowdown appears to be a transitory event, with

more normal rates of growth returning this year.
61

short tons (an increase of *** percent).35  Instead of responding to the domestic slowdown by

*** exports to maintain capacity utilization, the Mexican industry decreased production,

leading to a decline in capacity utilization.36   

Although the Mexican wire rod industry is not export oriented, the primary export

markets for Mexican wire rod have been primarily to Central and South America.37  Mexican

producers view these exports as commercial commitments that are strengthened by the

presence of free trade agreements between Mexico and many of these countries in the

Americas;38 such trade preferences also act to give Mexican exports of wire rod an advantage

over of Chinese exports of wire rod to those markets.39  In the case of the 2013 Colombian

safeguard case on wire rod and rebar,40 Mexican exports of wire rod have been assigned a

tariff‐rate quota, a privilege that the Chinese were not accorded,41 and Deacero argues that it

will be able to continue shipping “the same quantities as before the safeguard investigation was

initiated.”42  The Mexican interested parties argue that this is the case as 80 percent of the tariff

rate quota volumes will be assigned to “historical importers.”43

Hence I conclude that, in the event that the order on subject imports of wire rod from

Mexico were revoked, the likely volume of such imports would not be significant.

B. Likely Price Effects of Subject Imports from Mexico

During the period of the original investigations, Mexico does not appear to have been

the most likely to undersell among the six countries the Commission is now reviewing.  Pricing

product data for subject imports from Mexico showed 37 quarters of underselling and 9

quarters of overselling (80.4 percent of comparisons).  Of the six countries involved in these

second reviews, this was the second lowest percentage of underselling, following only Trinidad

                                                             35 CR/PR at Table IV‐17.  Mexican production declined by 8.6 percent between 2012 and 2013.

36 While the likelihood and timing of any capacity decreases by individual Mexican producers

were strenuously argued by both parties in these reviews, I note that Deacero argued that “there will be

no capacity expansions in Mexico within the reasonably foreseeable future.”  Deacero’s responses to

Commissioners’ questions at 29.

37 CR/PR at Tables IV‐17 and IV‐19; Deacero’s prehearing brief at 27.

38 Mexico has free trade agreements with Central America (Costa Rica, El Salvador, Guatemala,

Honduras, and Nicaragua), Peru, Bolivia, Uruguay, Chile, and Colombia; a framework agreement with

Mercosur; and partial preference arrangements with Argentina, Brazil, Paraguay, Panama, and Ecuador.  

Deacero’s posthearing brief at Exhibit 11 (list from the Organization of American States).

39 Tr. at 143 (D. Gutierrez); 193 (S. Gutierrez); and 195, 197‐98 (E. Gutierrez); Deacero’s

posthearing brief at 9; Deacero’s responses to Commissioners’ questions at 9‐10.

40 CR at IV‐15, PR at IV‐12. 41 Tr. at 197 (E. Gutierrez).

42 Tr. at 155 (Campbell).

43 Deacero’s prehearing brief at 28‐29; Tr. at 143‐44 (D. Gutierrez); Deacero’s posthearing brief

at 9 & Exhibit 12 (showing that the expected Colombian tariff‐rate quota exceeds Mexican exports to

Colombia in 2011 and 2012, but not 2013).
62

and Tobago, which had underselling in 69.2 percent of comparisons.44  Mexico also had the

second‐lowest average margin of underselling in the original investigations (again, second only

to Trinidad and Tobago).45  Only 4 of 25 lost sales allegations from the original investigations

involved subject imports from Mexico; of the two purchasers that responded to these

allegations, only one partially agreed with the allegation.46  No lost revenue allegations involved

subject imports from Mexico.47

In the first review, there were many fewer comparisons, but Brazil undersold the U.S.

product in all 3 of its comparison, Indonesia undersold in all 3 of its comparisons, Moldova

undersold in all 5 of its comparisons, and Ukraine undersold in all 6 of its comparisons.   

Trinidad and Tobago undersold the U.S. product in 8 of 14 quarterly comparisons (57.1 percent

of comparisons) and Mexico undersold the U.S. product in 26 of 54 quarterly comparisons (48.1

percent of comparisons).48  Granted, these pricing comparisons were conducted under the

discipline of U.S. trade remedies, but the data show that Mexico, when compared to the other

five subject countries, had less adverse results in the pricing product comparisons.49

Likewise in these second reviews, there were few pricing comparisons and these

comparisons only involved subject imports from Mexico, which undersold the U.S. product in

30 of 37 quarterly comparisons (81.1 percent of comparisons).  The average margin of

underselling in the 30 comparisons was 9.6 percent and the average margin of overselling in the

7 comparisons was 1.8 percent.50  In an attempt to explain the continued underselling by

subject imports from Mexico, Mexican interested parties argued that several purchasers’

                                                             44 2002 Staff Report at Table V‐10; CR at V‐18 n.15.  For pricing product 1, in *** possible

quarters of comparison from the original investigations, prices of subject imports from Mexico were

higher than any other of the five countries under review in these second reviews.  (This product

accounted for *** of the 9 instances of Mexican overselling.)  2002 Staff Report at Table V‐3.  For pricing

product 2, in *** possible quarters of comparison, prices of subject imports from Mexico were higher

than any other of the five countries under review in these reviews.  (This product accounted for *** of

the 9 instances of Mexican overselling.)  2002 Staff Report at Table V‐4.  For pricing product 5, in ***

possible quarters of comparison, prices of subject imports from Mexico were higher than any other of

the five countries under review in these reviews.  (This product accounted for *** of the 9 instances of

Mexican overselling.)  2002 Staff Report at Table V‐7.  This pattern of relative pricing among the six

subject countries is bolstered by data on AUVs, which shows that in all three full years of the period of

the original investigations, Mexican AUVs were the second highest (following Trinidad and Tobago) and

in the interim 2002 period, Mexican AUVs were the highest.  CR/PR at App. C:  Reproduction of Table I‐1

from First Review.

45 Both using an arithmetic average and a weighted average.  2008 Staff Report at Table V‐10.

46 2002 Staff Report at Table V‐11. 47 2002 Staff Report at Table V‐12.

48 2008 Staff Report at Table V‐9; CR at V‐18 n.16.

49 2008 Staff Report at Table V‐9.  In four of the six years of the period covered by the first

review, Mexico had a weighted average that showed overall overselling.  Trinidad and Tobago had one

year that showed overall overselling and the weighted averages for the other four countries showed

only underselling.  Id. 50 CR/PR at Table V‐8.
63

questionnaire responses reflected a preference for domestic product and a stated willingness

to pay higher prices for it.51

Domestic interested parties point to the pricing of the 4.75 mm out‐of‐scope product

sold by Deacero in 2009‐2011 as evidence of Mexican pricing behavior for the in‐scope product

if the order on Mexico were to be revoked.52  For me to consider the pricing of this out‐of‐scope

product as relevant to behavior of subject imports post‐revocation, I would need to be able to

conclude that the small diameter wire rod that would enter the U.S. market will instead enter

the U.S. market as subject imports (at least 5.5 mm in diameter) in the reasonably foreseeable

future.  The statement by Deacero’s counsel that allegedly confirms Deacero’s intentions is

tentatively couched in the form of a double negative:  Deacero is “not representing today that

they won’t ship any 5.5 but the focus is instead going to be 4.75 and we would say all right we

heard 4.75 would be most of their imports.”53  I note that there were some exports of 5.5 mm

wire rod to the U.S. market by Deacero in 2011‐2013,54 but such imports were only *** percent

of the total subject imports from Mexico shown in Table IV‐17 of the confidential staff report

over the six‐year period of these reviews.55

Given that a significant volume of subject imports from Mexico is not likely to occur

upon revocation and given the mixed record of underselling by subject imports from Mexico

(especially when compared with the other five subject countries), I do not find a likelihood of

significant adverse price effects from subject imports from Mexico in the event of revocation of

the order.  I therefore conclude that, if the order on wire rod imports from Mexico were

revoked, the volumes of subject imports from Mexico would not be likely to undersell

significantly the domestic product or gain market share, nor would such imports be likely to

have significant price depressing or suppressing effects.

C. Likely Impact of Subject Imports from Mexico

Because Mexico was cumulated with other subject countries in both the original

investigations and the first sunset review, the Commission has not had the occasion to weigh

the individual contribution of Mexico to the likelihood of a continuation or recurrence of

material injury in the event of revocation of this order.56  While I do not place heavy emphasis

on the imports of 4.75 mm wire rod from Mexico, I would note that it does not appear that,

                                                             51 Deacero responses to Commissioners’ questions at Commissioner Question #2 (pages 6‐7); Tr.

at 224‐25 (Campbell).

52 Gerdau Parties’ responses to Commissioners’ questions at 13‐22.

53 Tr. at 210 (Campbell).   54 Deacero prehearing brief at 7 n.18. 55 ArcelorMittal Las Truchas’ foreign producer questionnaire response at 10.

56 In the first review, Chairman Pearson did decumulate Mexico and found that if the order on

subject imports from Mexico were revoked, such imports would not be likely to have a significant

adverse impact on the domestic industry.  Separate and Dissenting Views of Chairman Daniel R. Pearson,

First Reviews, USITC Pub. 4014, at 52.
64

even in 2010—the peak year of imports of the smaller diameter wire rod—there was any

adverse impact on the domestic industry.57

In light of my finding that revocation of the antidumping duty order on subject imports

from Mexico would not be likely to lead to a significant increase in the volume of subject

imports that would undersell the domestic like product and significantly depress or suppress

U.S. producers’ prices, I find that, if the order on imports from Mexico were revoked, such

imports would not be likely to have a significant adverse impact on the production, shipments,

sales, market share, and revenues of the domestic industry.  Accordingly, I conclude that, if the

order on imports from Mexico were revoked, subject imports from Mexico would not be likely

to have a significant adverse impact on the domestic industry within a reasonably foreseeable

time.

IV. CONCLUSION

For the foregoing reasons, I determine that revocation of the antidumping duty order on

wire rod from Mexico would not be likely to lead to continuation or recurrence of material

injury to the domestic industry within a reasonably foreseeable time.

                                                             57 Between 2009 and 2010 (the peak year of imports of the small diameter wire rod), the

financial indicators of the domestic industry generally improved.  Operating income jumped from

negative 2.6 percent to 4.3 percent.  The COGS‐to‐net‐sales ratio also improved, falling by 6.8

percentage points from 98.4 percent in 2009 to 91.6 percent in 2010.
I‐1

PART I: INTRODUCTION AND OVERVIEW

BACKGROUND

On June 3, 2013, 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 order on

carbon and certain alloy steel wire rod (“wire rod”) from Brazil and the antidumping duty

orders on wire rod from Brazil, Indonesia, Mexico, Moldova, Trinidad & Tobago, and Ukraine

would likely lead to the continuation or recurrence of material injury to a domestic industry.2 3

On September 6, 2013, the Commission determined that it would conduct full reviews pursuant

to section 751(c)(5) of the Act. 4  

                                                            

1 19 U.S.C. 1675(c). 2 Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia, Mexico, Moldova, Trinidad and  

Tobago, and Ukraine: Institution of five‐year reviews, 78 FR 33103, June 3, 2013. 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, 78 FR 33063, June 3, 2013. 4 Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia, Mexico, Moldova, Trinidad and

Tobago, and Ukraine: Notice of Commission Determination To Conduct Full Five‐Year Reviews, 78 FR

60316, October 1, 2013. The Commission received a joint response to the notice of institution from six

U.S. producers of wire rod (ArcelorMittal USA LLC (“ArcelorMittal USA”), Cascade Steel Rolling Mills Inc.

(“Cascade”), Evraz Rocky Mountain Steel (currently known as “Evraz Pueblo”), Gerdau Ameristeel US Inc.

(“Gerdau”), Keystone Consolidated Industries, Inc. (“Keystone”), and Nucor Corp. (“Nucor”)); one U.S.

importer of subject merchandise from Mexico (Deacero USA, Inc. (“Deacero USA”)); and two producers

and exporters of the subject merchandise in Mexico (Deacero S.A. de C.V. (“Deacero”) and Ternium

Mexico, S.A. de C.V. (“Ternium Mexico”)). The Commission found that the domestic interested party

group response and the respondent interested party group response with respect to Mexico were

adequate and determined to conduct a full review of the order on wire rod from Mexico. The

Commission also found that the respondent interested party group response with regard to the reviews

concerning subject imports from Brazil, Indonesia, Moldova, Trinidad & Tobago, and Ukraine to be

inadequate because it did not receive a response from any respondent interested parties with respect to

those orders. Notwithstanding the inadequate respondent interested party group responses, the

Commission determined to conduct full reviews of the orders on wire rod from Brazil, Indonesia,

Moldova, Trinidad & Tobago, and Ukraine in order to promote administrative efficiency in light of the

Commission’s determination to conduct a full review of the order on wire rod from Mexico.
I‐2

The following tabulation presents information relating to the background and schedule of this

proceeding:5

  

Effective date Action

October 22, 2002

Commerce’s countervailing duty order on wire rod from Brazil and Canada

(67 FR 64871)  

October 29, 2002

Commerce’s antidumping duty orders on wire rod from Brazil, Canada,

Indonesia, Mexico, Moldova, Trinidad & Tobago, and Ukraine (66 FR 65945)

July 30, 2008

Commerce’s first continuation of countervailing duty order on wire rod from

Brazil and antidumping duty orders on wire rod from Brazil, Indonesia,

Mexico, Moldova, Trinidad & Tobago, and Ukraine (73 FR 44218)

June 3, 2013 Commission’s institution of five‐year reviews (78 FR 33103)

June 3, 2013 Commerce’s initiation of five‐year reviews (78 FR 33063)

October 1, 2013 Commission’s determinations to conduct full five‐year reviews (78 FR 60316)

October 2, 2013

Commerce’s final results of expedited five‐year review of the countervailing

duty order on wire rod from Brazil (78 FR 60850)

October 24, 2013

Commerce’s final results of expedited five‐year reviews of the antidumping

duty orders on wire rod from Brazil, Indonesia, Mexico, Moldova, Trinidad &

Tobago, and Ukraine (78 FR 63450)

December 11, 2013 Commission’s scheduling of the reviews (78 FR 76653, December 18, 2013)

April 22, 2014 Commission’s hearing

May 30, 2014 Commission’s vote

June 16, 2014 Commission’s determinations and views

                                                            

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. Witnesses that appeared at the Commission’s hearing are

presented in Appendix B.
I‐3

THE ORIGINAL INVESTIGATIONS

The original investigations resulted from petitions filed by counsel on behalf of Co‐Steel

Raritan, Inc., Perth Amboy, New Jersey; GS Industries, Inc., Charlotte, North Carolina; Keystone

Consolidated Industries, Inc., Dallas, Texas; and North Star Steel Texas, Inc., Edina, Minnesota,

on August 31, 2001, alleging that an industry in the United States is materially injured and

threatened with material injury by reason of subsidized imports of wire rod from Brazil, Canada,

Germany, Trinidad & Tobago, and Turkey and less‐than‐fair‐value (“LTFV”) imports of wire rod

from Brazil, Canada, Egypt, Germany, Indonesia, Mexico, Moldova, South Africa, Trinidad &

Tobago, Ukraine, and Venezuela. In October 2002, the Commission determined that a domestic

industry was materially injured by reason of subsidized imports of wire rod from Brazil and

Canada and by reason of LTFV imports of wire rod from Brazil, Canada, Indonesia, Mexico,

Moldova, Trinidad & Tobago, and Ukraine.6 The U.S. Department of Commerce published

countervailing duty orders on subject imports from Brazil and Canada on October 22, 2002.7

Commerce published antidumping duty orders on subject imports from Brazil, Canada,

Indonesia, Mexico, Moldova, Trinidad & Tobago, and Ukraine on October 29, 2002.8 Effective

                                                            

6 Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Germany, Indonesia, Mexico,

Moldova, Trinidad and Tobago, and Ukraine, Inv. Nos. 701‐TA‐417‐421, 731‐TA‐953, 954, 956‐959, 961,

and 962 (Final), USITC Publication 3546, October 2002 (“Original Determination”). Subsequent to

Commerce’s final negative countervailing duty determinations with respect to Trinidad & Tobago and

Turkey, the Commission terminated the countervailing duty investigations concerning those countries.

67 FR 62075, October 3, 2002. The investigations concerning subject imports from Egypt, South Africa,

and Venezuela were terminated after the Commission found in its preliminary determination that

imports from those three subject countries were negligible. Carbon and Certain Alloy Steel Wire Rod

from Brazil, Canada, Egypt, Germany, Indonesia, Mexico, Moldova, South Africa, Trinidad and Tobago,

Turkey, Ukraine, and Venezuela, Inv. Nos. 701‐TA‐417‐421,731‐TA‐953‐963 (Preliminary), USITC

Publication 3456, October 2001. The antidumping and countervailing duty investigations concerning

subject imports from Germany were terminated after the Commission found in its final determination

that imports from Germany were negligible. Carbon and Certain Alloy Steel Wire Rod from Brazil,

Canada, Germany, Indonesia, Mexico, Moldova, Trinidad and Tobago, Turkey, and Ukraine, Inv. Nos.

701‐TA‐417‐421 and 731‐TA‐953, 954, 956‐959, 961, and 962 (Final), USITC Publication 3546, October

2002. 7 Notice of Countervailing Duty Orders: Carbon and Certain Alloy Steel Wire Rod from Brazil and  

Canada, 67 FR 64871, October 22, 2002.

8 Notice of Amended Final Determination of Sales at Less Than Fair Value and Antidumping Duty

Order: Carbon and Certain Alloy Steel Wire Rod from Canada, 67 FR 65944, October 29, 2002; Notice of

Antidumping Duty Orders: Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia,  Mexico,

Moldova, Trinidad and Tobago, and Ukraine, 67 FR 65945, October 29, 2002.
I‐4

January 23, 2004, Commerce revoked the countervailing duty order on subject imports from

Canada.9

The only litigation concerning the Commission’s determinations on subject imports at

issue in these reviews was an appeal of the Commission’s affirmative determination on subject

imports from Trinidad & Tobago.10 The Court of International Trade (“CIT”) affirmed that

determination. However, the Federal Circuit vacated and remanded so that: (1) the Commission

could ascertain whether imports from subject countries other than Trinidad & Tobago were an

alternative cause of injury to the domestic industry and (2) to conduct the analysis required by

the decision in Bratsk Aluminum Smelter v. United States, 444 F.3d 1369 (Fed. Cir. 2006). On

first remand, the Commission reached a negative determination applying the

replacement/benefit test it perceived was mandated by the Federal Circuit.11 The CIT affirmed.

On appeal, the Federal Circuit again vacated and remanded. On second remand, the

Commission reached an affirmative determination.12 The CIT affirmed. There were no further

proceedings.

THE FIRST FIVE‐YEAR REVIEWS

The Commission instituted its first five‐year reviews of the countervailing duty order on

wire rod from Brazil and the antidumping duty orders on wire rod from Brazil, Canada,

Indonesia, Mexico, Moldova, Trinidad & Tobago, and Ukraine on September 4, 2007.13 ln June

2008, the Commission completed its full first five‐year reviews of the subject orders and

determined that revocation of the countervailing duty order on subject imports from Brazil and

antidumping orders on subject imports from Brazil, Indonesia, Mexico, Moldova, Trinidad &

                                                            

9 Carbon and Certain Alloy Steel Wire Rod from Canada: Final Results of Countervailing Duty Changed

Circumstances Review and Revocation of Countervailing Duty Order, in Whole, 69 FR 3330, January 23,

2004.

10 Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Egypt, Germany, Indonesia, Mexico,

Moldova, South Africa, Trinidad and Tobago, Turkey, Ukraine, and Venezuela, Inv. Nos. 701‐TA‐417‐

421,731‐TA‐953‐963 (Preliminary), USITC Publication 3456 (October 2001), pp. 36‐38. 11 Carbon and Certain Alloy Steel Wire Rod from Trinidad and Tobago, lnv. No. 731‐TA‐961 (Final)

(Remand), USITC Publication 3903, January 2007. 12 Carbon and Certain Alloy Steel Wire Rod from Trinidad and Tobago, lnv. No. 731‐TA‐961 (Final)

(Second Remand), USITC Publication 4170, June 2010. Commissioners Okun, Pearson, and Pinkert

dissented.

13 Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Indonesia, Mexico, Moldova,  Trinidad

and Tobago, and Ukraine, 72 FR 50696, September 4, 2007.
I‐5

Tobago, 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.14  

Following affirmative determinations in the first five‐year reviews by Commerce and the

Commission,15 Commerce issued a continuation of the countervailing duty order on wire rod

from Brazil and the antidumping duty orders on wire rod from Brazil, Indonesia, Mexico,

Moldova, Trinidad & Tobago, and Ukraine, effective July 30, 2008.16 The Commission’s

determinations in the first five‐year reviews were not appealed.  

SUMMARY DATA

Table I‐1 presents a summary of data for the final years of the original investigations

(2001) and the first five‐year reviews (2007), and a summary of data collected in the current full

second five‐year reviews (2008‐13). A summary of data from the original investigations and

first‐five year reviews is presented separately in appendix C.

                                                            

14 Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Indonesia, Mexico, Moldova, Trinidad

and Tobago, and Ukraine, Inv. Nos. 701‐TA‐417 and 731‐TA‐953, 954, 957‐959, 961, and 962 (Review),

USITC Publication 4014, June 2008. The Commission determined that subject imports from Canada

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. Commissioner Okun dissented from the determination

concerning subject imports from Trinidad & Tobago. Commissioner Pearson dissented from the

determinations concerning subject imports from Mexico and Trinidad & Tobago. Commissioners Lane

and Pinkert dissented from the determination concerning subject imports from Canada.

15 Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Indonesia, Mexico, Moldova,  Trinidad

and Tobago, and Ukraine, 73 FR 41116, July 17, 2008; Carbon and Certain Alloy Steel Wire Rod from

Brazil: Final Results of Expedited Five–Year Sunset Review of the Countervailing Duty Order , 73, FR 1323,

January 8, 2008; Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Indonesia, Mexico,

Moldova, Trinidad and Tobago, and Ukraine: Final Results of the Expedited Sunset Reviews of the

Antidumping Duty Orders, 73 FR 1321, January 8, 2008.   16 Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia, Mexico, Moldova, Trinidad and

Tobago, and Ukraine: Continuation of Antidumping and Countervailing Duty Orders, 73 FR 44218, July

30, 2008.
I‐6

Table I-1 

Wire rod: Comparative data from the original investigations, first five-year reviews, and second five-year reviews, 2001,

2007, and 2008-13 

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton) 

Item 

Original 

invs. 

 First 

reviews Second reviews 

2001 2007 2008 2009 2010 2011 2012 2013

 Quantity (short tons) 

U.S. consumption *** 5,858,981 *** *** *** *** *** 5,300,149

 Share of quantity (percent) 

Share of U.S. 

consumption: 

 U.S. producers' share *** 69.6 *** *** *** *** *** 67.9

 U.S. importers' share: 

 Brazil *** 0.0 0.0 0.0 0.0 0.0 0.0 0.0

 Canada *** *** (

1

) (1) (1) (1) (1) (1) 

 Indonesia *** 0.0 0.0 0.0 0.0 0.0 0.0 0.0

 Mexico *** 0.1 *** *** *** *** *** 0.2

 Moldova *** 0.0 0.0 0.0 0.0 0.0 0.0 0.0

 Trinidad & Tobago *** 1.6 *** 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

 Subtotal, subject 

 sources *** *** *** *** *** *** *** 0.2

 Grade 1080 tire 

 cord/bead from 

 subject sources (2

) *** *** *** *** *** *** 1.8

 All other sources3 *** *** *** *** *** *** *** 30.1

 Subtotal, nonsubject *** *** *** *** *** *** *** 31.9

 Total imports *** 30.4 *** *** *** *** *** 32.1

 Value (1,000 dollars) 

U.S. consumption *** 3,403,602 *** *** *** *** *** 3,756,412

 Share of value (percent) 

Share of U.S. 

consumption: 

 U.S. producers' share *** 68.8 *** *** *** *** *** 67.3

 U.S. importers' share: 

 Brazil *** 0.0 0.0 0.0 0.0 0.0 0.0 0.0

 Canada *** *** (

1

) (1) (1) (1) (1) (1) 

 Indonesia *** 0.0 0.0 0.0 0.0 0.0 0.0 0.0

 Mexico *** 0.1 *** *** *** *** *** 0.2

 Moldova *** 0.0 0.0 0.0 0.0 0.0 0.0 0.0

 Trinidad & Tobago *** 1.4 *** 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

 Subtotal, subject 

 Sources *** *** *** *** *** *** *** 0.2

 Grade 1080 tire 

 cord/bead from 

 subject sources (2

) *** *** *** *** *** *** 1.7

 All other sources3 *** *** *** *** *** *** *** 30.8

 Subtotal, nonsubject *** *** *** *** *** *** *** 32.5

 Total imports *** 31.2 *** *** *** *** *** 32.7

Continued on the following page. 
I‐7

Table I-1--Continued

Wire rod: Comparative data from the original investigations, first five-year reviews, and second five-year reviews, 2001,

2007, and 2008-13 

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton) 

Item 

Original 

invs. 

 First 

reviews Second reviews 

2001 2007 2008 2009 2010 2011 2012 2013

U.S. imports from-- 

Brazil 

 Quantity *** 0 0 0 0 0 0 0

 Value *** 0 0 0 0 0 0 0

 Unit value *** (4

) (

4

) (4) (4) (4) (4) (

4

) 

Canada 

 Quantity *** (1

) (1) (1) (1) (1) (1) 

 Value *** (1) (1) (1) (1) (1) (1) 

 Unit value *** (1) (1) (1) (1) (1) (1) 

Indonesia 

 Quantity *** 0 0 0 0 0 0 0

 Value *** 0 0 0 0 0 0 0

 Unit value *** (4

) (

4

) (4) (4) (4) (4) (

4

) 

Mexico 

 Quantity *** 8,244 *** *** *** *** *** 10,333

 Value *** 4,263 *** *** *** *** *** 6,128

 Unit value *** $517 *** *** *** *** *** $593

Moldova 

 Quantity *** 0 0 0 0 0 0 0

 Value *** 0 0 0 0 0 0 0

 Unit value *** (4

) (

4

) (4) (4) (4) (4) (

4

) 

Trinidad & Tobago 

 Quantity *** 95,325 21,794 0 0 0 0 0

 Value *** 46,228 14,298 0 0 0 0 0

 Unit value *** $485 $656 (4

) (4) (4) (4) (

4

) 

Ukraine 

 Quantity *** 0 0 0 0 0 0 0

 Value *** 0 0 0 0 0 0 0

 Unit value *** (4) (4) (4) (4) (4) (4) (4) 

Subtotal, subject 

 Quantity *** *** *** *** *** *** *** 10,333

 Value *** *** *** *** *** *** *** 6,128

 Unit value *** *** *** *** *** *** *** $593

1080 tire cord/bead from 

subject sources: 

 Quantity (2

) *** 139,459 71,759 129,184 116,513 102,517 96,639

 Value (2) *** 126,654 50,808 91,621 103,073 84,521 64,506

 Unit value (2) *** $908 $708 $709 $885 $824 $667

Other nonsubject:3

 Quantity *** *** 1,536,768 777,083 1,284,771 1,059,512 1,391,895 1,593,718

 Value *** *** 1,360,431 550,614 988,457 992,791 1,159,903 1,156,290

 Unit value *** *** $885 $709 $769 $937 $833 $726

Subtotal, nonsubject 

 Quantity *** *** 1,676,227 848,842 1,413,955 1,176,024 1,494,413 1,690,357

 Value *** *** 1,487,085 601,423 1,080,078 1,095,863 1,244,424 1,220,797

 Unit value *** *** $887 $709 $764 $932 $833 $722

All countries: 

 Quantity *** 1,782,699 *** *** *** *** *** 1,700,690

 Value *** 1,063,201 *** *** *** *** *** 1,226,925

 Unit value *** $596 *** *** *** *** *** $721

Continued on the following page. 
I‐8

Table I-1--Continued

Wire rod: Comparative data from the original investigations, first five-year reviews, and second five-year reviews, 2001,

2007, and 2008-13 

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton) 

Item 

Original 

invs. 

 First 

reviews Second reviews 

 2001 2007 2008 2009 2010 2011 2012 2013

U.S. industry: 

Capacity (quantity) *** 5,429,678 5,546,751 5,295,752 4,965,095 5,173,168 5,131,954 5,073,815

Production (quantity) *** 4,067,549 4,055,641 2,837,165 3,384,322 3,907,416 3,879,060 3,655,088

Capacity utilization 

(percent) *** 74.9 73.1 53.6 68.2 75.5 75.6 72.0

U.S. shipments: 

 Quantity *** 4,076,282 4,050,961 2,833,426 3,340,954 3,876,145 3,809,728 3,599,459

 Value *** 2,340,401 3,485,005 1,651,451 2,246,759 3,012,054 2,826,974 2,529,487

 Unit value *** $574 $860 $583 $672 $777 $742 $703

Export shipments: 

 Quantity *** *** 39,707 39,301 42,049 34,687 26,748 24,319

 Value *** *** 31,925 22,886 26,912 28,888 31,597 22,566

 Unit value *** *** $804 $582 $640 $833 $1,181 $928

Ending inventory *** 152,512 231,279 195,717 196,677 193,261 235,848 266,868

Inventories/total 

shipments *** *** 5.7 6.8 5.8 4.9 6.1 7.4

Production workers *** 2,397 2,339 2,083 2,173 2,239 2,269 2,192

Hours worked (1,000) *** 5,174 4,741 3,825 4,220 4,552 4,587 4,258

Wages paid ($1,000) *** 161,821 170,467 128,170 145,939 166,385 174,648 156,838

Hourly wages *** $31.28 $35.96 $33.51 $34.58 $36.55 $38.07 $36.83

Productivity (short tons 

per 1,000 hours) *** 786.0 855.4 741.7 802.0 858.4 845.7 858.4

Unit labor costs *** $39.78 $42.03 $45.18 $43.12 $42.58 $45.02 $42.91

Financial data: 

 Net sales: 

 Quantity *** 4,087,541 4,126,388 2,881,432 3,384,018 3,920,918 3,836,475 3,623,777

 Value *** 2,347,208 3,547,031 1,679,395 2,274,325 3,048,561 2,858,572 2,552,054

 Unit value *** $574 $860 $583 $672 $778 $745 $704

 Cost of goods sold *** 2,219,518 3,116,677 1,652,958 2,083,987 2,743,826 2,622,588 2,358,335

 Gross profit (loss) *** 127,690 430,354 26,437 190,338 304,735 235,984 193,719

 Operating income 

 (loss) *** 74,869 347,095 (42,915) 98,754 218,013 148,351 107,694

 Unit COGS *** $543 $755 $574 $616 $700 $684 $651

 Unit operating income *** $18 $84 $(15) $29 $56 $39 $30

 COGS/sales (percent) *** 94.6 87.9 98.4 91.6 90.0 91.7 92.4

 Operating income 

 (loss)/sales (percent) *** 3.2 9.8 (2.6) 4.3 7.2 5.2 4.2 1

 As Canada is no longer subject to an antidumping duty order, data for Canada are not presented separately from the "all 

other sources" line for the 2008-13 annual periods. 

2

 Data on 1080 tire cord/tire bead wire rod were not reported separately in the original investigations. 3

 Data on U.S. imports from the Canadian exporter Stelco, which had in previous proceedings been reported separately from 

the "all other sources" line have been combined into the "all other sources" line. The data presented are overstated by imports

of wire rod of less than 5mm in diameter imported from Canada. ***. 4

 Undefined. 

Source: Compiled from official Commerce statistics and data submitted in response to Commission questionnaires; 

Investigation Nos. 701-TA-417 and 731-TA-953, 954, 957-959, 961, and 962 (Review): Carbon and Certain Alloy Steel 

Wire Rod from Brazil, Canada, Indonesia, Mexico, Moldova, Trinidad and Tobago, and Ukraine--Staff Report, INV-FF058, May 15, 2008, table I-1. 
I‐9

As the data presented in table I‐1 show, apparent U.S. consumption of wire rod totaled

approximately 5.3 million short tons ($3.8 billion) in 2013. U.S. producers’ U.S. shipments of

wire rod totaled 3.6 million short tons ($2.5 billion) in 2013, and accounted for 67.9 percent of

the quantity of apparent U.S. consumption. There were no reported U.S. imports from five of

the six countries subject to these reviews during 2013. U.S. imports from Mexico (i.e., the only

subject country reporting subject imports during 2013) totaled 10,333 short tons ($6.1 million)

in 2013 and accounted for 0.2 percent of the quantity of apparent U.S. consumption, whereas

total nonsubject U.S. imports (primarily wire rod from China, Canada, and Japan) totaled 1.7

million short tons ($1.2 billion) in 2013 and accounted for 31.9 percent of the quantity of

apparent U.S. consumption. The quantity of apparent U.S. consumption has decreased

irregularly since 2001, while U. S. producers’ share of consumption has fluctuated upward,

reaching its highest levels in 2009 and 2011 before falling to 67.9 percent in 2013. Since the

original investigations and the first five‐year reviews, the share of subject imports declined

overall, while the share of nonsubject imports generally increased, led by increases in imports

from China in recent years.  

The three leading sources of subject imports in 2001 and 2007 were, in descending

order of magnitude, Canada (no longer subject), Trinidad & Tobago, and Mexico. As previously

indicated, the only source of subject imports in 2013 was Mexico. U.S. imports of wire rod from

Brazil, Moldova, and Ukraine largely ceased following the imposition of duties in 2002, while

U.S. imports of wire rod from Indonesia, the smallest supplier during the original investigations,

ceased after 2005. The U.S. imports of wire rod from Trinidad & Tobago ceased after 2008.

The U.S. producers’ reported capacity was lower in 2007 than reported in 2001, while

production and capacity utilization fluctuated to a level in 2007 that was higher than reported

in 2001. U.S. producers’ reported capacity increased from 2007 to 2008 but generally fell

threafter, whereas production and capacity utilization fluctuated from 2007 to 2012 with the

lowest levels reported during 2009‐10. The quantity of U.S. producers’ U.S. shipments

fluctuated upward from the original investigations (2001) to the first reviews (2007), but

fluctuated downward thereafter. The level of employment remained relatively flat from the end

of the original investigations through 2007, but declined overall from 2007 to 2013.  

RELATED INVESTIGATIONS

Title VII investigations

The Commission has conducted a number of previous import relief investigations on

wire rod products or similar merchandise. Table 1‐2 presents data on previous and related title

VII investigations.
I‐10

Table I-2 

Wire rod: Previous and related title VII investigations 

Original investigation First review Second review

Date Current status 1 Number Country Outcome Date1 Outcome Date1 Outcome

1982 731-TA-88 Venezuela Negative - - - - - 

1982 731-TA-113 Brazil Affirmative - - - - ITA revoked 9/20/85 

1982 731-TA-114 Trinidad & Tobago Affirmative - - - - ITA revoked 12/14/87 

1982 701-TA-148 Brazil Affirmative2 - - - - Investigation terminated 8/21/85

1982 701-TA-149 Belgium Affirmative2 - - - - Petition withdrawn11/9/82 

1982 701-TA-150 France Affirmative2 - - - - Petition withdrawn 11/9/82 

1983 701-TA-209 Spain Affirmative - - - - ITA revoked 9/11/85 

1983 731-TA-157 Argentina Affirmative 1998 Negative - - - 

1983 731-TA-158 Mexico Negative2 - - - - - 

1983 731-TA-159 Poland Negative - - - - - 

1983 731-TA-160 Spain Affirmative - - - - ITA revoked 9/16/85 

1984 731-TA-205 E. Germany Affirmative2 - - - - Petition withdrawn 8/1/85 

1985 701-TA-243 Portugal Negative2 - - - - - 

1985 701-TA-244 Venezuela Affirmative2 - - - - Petition withdrawn 7/24/85 

1985 731-TA-256 Poland Affirmative2 - - - - Petition withdrawn 9/10/85 

1985 731-TA-257 Portugal Affirmative2 - - - - Petition withdrawn 11/20/85 

1985 731-TA-258 Venezuela Affirmative2 - - - - Petition withdrawn 8/30/85 

1992 701-TA-314 Brazil Affirmative 1999 - - - ITA revoked 11/15/99 

1992 701-TA-315 France Affirmative 1999 - - - ITA revoked 11/15/99 

1992 701-TA-316 Germany Affirmative 1999 - - - ITA revoked 11/15/99 

1992 701-TA-317 United Kingdom Affirmative 1999 - - - ITA revoked 11/15/99 

1992 731-TA-552 Brazil Affirmative 1999 - - - ITA revoked 11/15/99 

1992 731-TA-553 France Affirmative 1999 - - - ITA revoked 11/15/99 

1992 731-TA-554 Germany Affirmative 1999 - - - ITA revoked 11/15/99 

1992 731-TA-555 United Kingdom Affirmative 1999 - - - ITA revoked 11/15/99 

1992 731-TA-572 Brazil Negative - - - - - 

1993 731-TA-646 Brazil Negative - - - - - 

Table continued on next page. 
I‐11

Table I-2--Continued 

Wire rod: Previous and related title VII investigations 

Original investigation First review Second review 

Date Current status 1 Number Country Outcome Date1 Outcome Date1 Outcome 

1993 731-TA-647 Canada Affirmative2 - - - - Petition withdrawn 4/18/94

1993 731-TA-648 Japan Negative - - - - - 

1993 731-TA-649 Trinidad & Tobago Negative2 - - - - - 

1994 701-TA-359 Germany Negative2 - - - - - 

1994 731-TA-686 Belgium Affirmative2 - - - - Petition withdrawn 7/7/94 

1994 731-TA-687 Germany Negative2 - - - - - 

1997 701-TA-368 Canada Negative - - - - - 

1997 701-TA-369 Germany Negligible3 - - - - - 

1997 701-TA-370 Trinidad & Tobago Negative - - - - - 

1997 701-TA-371 Venezuela Negative - - - - - 

1997 731-TA-763 Canada Negative - - - - - 

1997 731-TA-764 Germany Negative - - - - - 

1997 731-TA-765 Trinidad & Tobago Negative - - - - - 

1997 731-TA-766 Venezuela Negative - - - - - 

2001 701-TA-417 Brazil Affirmative 2007 Affirmative 2013 - Current review 

2001 701-TA-418 Canada Affirmative - - - - ITA revoked 1/23/04 

2001 701-TA-419 Germany Negative - - - - - 

2001 701-TA-420 Trinidad & Tobago Negative4 - - - - - 

2001 701-TA-421 Turkey Negative4 - - - - - 

2001 731-TA-953 Brazil Affirmative 2007 Affirmative 2013 - Current review 

2001 731-TA-954 Canada Affirmative 2007 Negative - - - 

2001 731-TA-955 Egypt Negligible3 - - - - - 

2001 731-TA-956 Germany Negligible3 - - - - - 

2001 731-TA-957 Indonesia Affirmative 2007 Affirmative 2013 - Current review 

2001 731-TA-958 Mexico Affirmative 2007 Affirmative 2013 - Current review 

2001 731-TA-959 Moldova Affirmative 2007 Affirmative 2013 - Current review 

2001 731-TA-960 South Africa Negligible3 - - - - - 

2001 731-TA-961 Trinidad & Tobago Affirmative 2007 Affirmative 2013 - Current review 

2001 731-TA-962 Ukraine Affirmative 2007 Affirmative 2013 - Current review 

2001 731-TA-963 Venezuela Negligible3 - - - - - 

2005 731-TA-1099 China Negative2 - - - - - 

2005 731-TA-1100 Germany Negative2 - - - - - 

2005 731-TA-1101 Turkey Negative2 - - - - - 

2014 701-TA-512 China Affirmative2 - - - - Final determination 

pending 

2014 731-TA-1248 China Affirmative2 - - - - Final determination 

pending 1 “Date” refers to the year in which the investigation or review was instituted by the Commission. 2

 Preliminary determination. 

3

 The Commission found subject imports to be negligible, and its investigation was thereby terminated. 4

 The Department of Commerce made a negative determination. 

Source: Various Commission publications. 
I‐12

Safeguard investigation

In 1999, the Commission conducted a safeguard investigation under section 202 of the

Trade Act of 1974 to determine whether steel wire rod was being imported into the United

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

thereof, to the domestic industry producing an article like or directly competitive with the

imported article. The Commission was equally divided in its injury determination.17 The

President considered the determination of the Commissioners voting in the affirmative and

issued Proclamation 7273 imposing relief in the form of a Tariff Rate Quota (“TRQ”) on imports

of steel wire rod for a period of three years and one day, effective March 1, 2000.

Imports of subject products in excess of the quarterly or the annual quota amounts

were assessed duties in addition to the column‐1 general rates of duty in the amounts of 10

percent ad valorem in the first year of relief (in‐quota quantity of 1,580,000 short tons); 7.5

percent ad valorem in the second year of relief (in‐quota quantity of 1,611,600 short tons); and

5 percent ad valorem in the third year of relief (in‐quota quantity of 1,643,832 short tons). The

President subsequently issued Proclamation 7505 effective November 24, 2001, modifying the

TRQ, by providing that the in‐quota quantity of the TRQ be allocated among these four supplier

country groupings: European Community; Commonwealth of Independent States; Trinidad and

Tobago; and all other countries.18

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.

                                                            

17 Pursuant to section 311(a) of the North American Free Trade Agreement (“NAFTA”)

Implementation Act, the Commission made negative findings with respect to imports of wire rod from

Canada and Mexico.

18 Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Indonesia, Mexico, Moldova, Trinidad

and Tobago, and Ukraine, Investigation Nos. 701‐TA‐417 and 731‐TA‐953, 954, 957‐959, 961, and 962

(Review), USITC Publication 4014, June 2008, pp. I‐11‐I‐12.
I‐13

The Commission shall consider the likely volume, price effect, and impact 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  
I‐14

(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–

(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 report

Information obtained during the course of the reviews that relates to the statutory

criteria is presented throughout this report. A summary of trade and financial data for wire rod

as collected in the reviews is presented in appendix C. U.S. industry data are based on the

questionnaire responses of ten U.S. producers of wire rod that are believed to have accounted

for all domestic production of wire rod in 2013. U.S. import data and related information are

based on Commerce’s official import statistics and the questionnaire responses of 37 U.S.

importers of wire rod. The U.S. producers and importers and their shares of U.S. production and

U.S. imports, respectively, are presented later in Part I of this report (see “U.S. Market

Participants”). Foreign industry data and related information are based on the questionnaire

responses of one producer in Brazil, one producer in Indonesia, three producers in Mexico, one

producer in Trinidad & Tobago, and two producers in Ukraine. Coverage information on the

eight responding producers in the subject countries are presented in country‐specific sections

in Part IV of this report. The producer of wire rod in Moldova did not provide a response to the

Commission’s questionnaire. Therefore, the foreign industry data and related information for
I‐15

the wire rod industry in Moldova are based on publicly available industry information and ***.

Responses by U.S. producers, importers, purchasers, and foreign producers of wire rod 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 financial data for 2011‐13, excluding internal consumption and transfers to

related parties. Appendix F presents data and other information with respect to wire rod in

diameters less than 5.0 mm.

COMMERCE’S REVIEWS

Administrative reviews19

Commerce has completed one or more administrative reviews of the outstanding

antidumping duty orders on wire rod from Brazil, Canada, Indonesia, Mexico, and Trinidad &

Tobago. Commerce has completed no administrative reviews of the outstanding antidumping

duty orders on wire rod from Moldova and Ukraine, nor of the countervailing duty order on

wire rod from Brazil.20  

Brazil

Commerce completed one antidumping duty administrative review with regard to the

antidumping duty order on imports of wire rod from Brazil prior to the first five‐year review.  

The results of the administrative review are shown in table I‐3. Commerce has not conducted

any administrative reviews since it issued its final results of the first expedited five‐year review.

Table I-3 

Wire rod: Administrative review of the antidumping duty order for Brazil 

Date results published Period of review Producer or exporter Margin (percent) 

May 17, 2005 (70 FR 28271) 4/10/2002 - 9/30/2003 

Belgo Mineira1 98.69

All others 74.35

1

 ArcelorMittal Brasil is the successor to Belgo Mineira.

Source: Cited Federal Register notice. 

                                                            

19 No duty absorption findings have been made for any of the subject countries. Issues and Decision

Memorandum for the Final Results of Expedited Second Sunset Reviews of the Antidumping Duty Orders

on Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia, Mexico, Moldova, Trinidad and

Tobago, and Ukraine, October 17, 2013, p. 5.

20 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‐16

Indonesia

Commerce completed one antidumping duty administrative review with regard to

subject imports of wire rod from Indonesia prior to the first five‐year review. The results of the

administrative review are shown in table I‐4. Commerce has not conducted any administrative

reviews since it issued its final results of the first expedited five‐year review.

Table I-4 

Wire rod: Administrative review of the antidumping duty order for Indonesia 

Date results published Period of review Producer or exporter Margin (percent)

October 19, 2005 (70 FR 60787) 10/1/2003 - 9/30/2004

P.T. Ispat Indo 0.381

All others 4.06

1 De minimis margin (i.e., margin is less than 0.5 percent), therefore no cash deposit was required to be 

paid to Customs. 

Source: Cited Federal Register notice. 

Mexico

Commerce completed five antidumping duty administrative reviews with regard to

subject imports of wire rod from Mexico. The results of the administrative reviews are shown in

table I‐5.

Table I-5 

Wire rod: Administrative reviews of the antidumping duty order for Mexico 

Date results published Period of review Producer or exporter 

Margin 

(percent) 

May 16, 2005 (70 FR 25809) 4/10/2002 - 9/30/2003 

Hylsa 5.45

Sicartsa 1.06

All others 20.11

May 15, 2006 (71 FR 27989) 10/1/2003 - 9/30/2004 

Hylsa 1.81

Sicartsa 1.26

All others 20.11

March 13, 2008 (73 FR 13532) 10/1/2005 - 9/30/2006 Hylsa 17.94

March 7, 2012 (77 FR 13545) 10/01/2009 - 9/30/2010 Arcelor Mittal Las Truchas1 5.59

May 14, 2013 (78 FR 28190) 10/01/2010 - 9/30/2011 Deacero 12.08

1 Arcelor Mittal Las Truchas is the successor-in-interest to Sicartsa (76 FR 45509, July 29, 2011). 

Source: Cited Federal Register notices. 
I‐17

Trinidad & Tobago

Commerce completed six antidumping duty administrative reviews with regard to

subject imports of wire rod from Trinidad & Tobago. The results of the administrative reviews

are shown in table I‐6.  

Table I-6 

Wire rod: Administrative reviews of the antidumping duty order for Trinidad & Tobago 

Date results published Period of review Producer or exporter 

Margin 

(percent) 

March 15, 2005 (70 FR 12648) 4/10/2002 - 9/30/2003 

CIL 3.61

All others 11.40

November 16, 2005 (70 FR 69512) 10/1/2003 - 9/30/2004 

CIL 4.13

All others 11.40

March 6, 2007 (72 FR 9922) 10/1/2004 - 9/30/2005 

Mittal Steel Point Lisas 0.061

All others 11.40

November 7, 2007 (72 FR 62824) 1011/2005 - 9/30/2006 

Mittal Steel Point Lisas 0.401

All others 11.40

March 12, 2009 (74 FR 10722) 10/01/2006 - 9/30/2007 Arcelor Mittal Point Lisas2 1.56

February 25, 2010 (75 FR 8650) 10/01/2007 - 9/30/2008 Arcelor Mittal Point Lisas2 23.95

1 De minimis margin (i.e., margin is less than 0.5 percent), therefore no cash deposit was required to be 

paid to Customs. 

2 ArcelorMittal Point Lisas Limited is the successor–in–interest to Mittal Steel Point Lisas (73 FR 30052, 

May 23, 2008). 

Source: Cited Federal Register notices. 
I‐18

Changed circumstances reviews

Commerce completed four changed circumstances reviews with regard to imports of

wire rod subject to these second five‐year reviews. The results of the changed circumstances

reviews are shown in table I‐7.  

Table I-7 

Wire rod: Changed circumstances reviews 

Publication date 

(FR cite) Requestor Final result 

November 12, 2003 

(68 FR 64079) Petitioners 

Commerce initiated a changed circumstances review to clarify the 

technical descriptions of certain grade 1080 tire cord/bead quality 

wire rod that were originally excluded from the scope of the 

countervailing duty order. In its final results, Commerce amended 

the technical description so that certain grade 1080 tire cord/bead 

quality steel wire rod “having no non-deformable inclusions greater 

than 20 microns and no deformable inclusions greater than 35 

microns” rather than just those “having no inclusions greater than 

20 microns” were revoked from the countervailing duty order, 

effective July 24, 2003. 

May 23, 2008 

(73 FR 30052) 

ArcelorMittal 

Point Lisas 

Commerce determined that ArcelorMittal Point Lisas is the 

successor-in-interest to Mittal Steel Point Lisas Ltd. 

May 13, 2009 

(74 FR 22514) 

Ternium 

Mexico 

Commerce determined that Ternium Mexico is the successor-ininterest to Hylsa. 

July 29, 2011 

(76 FR 45509) 

ArcelorMittal 

Las Truchas 

Commerce determined that ArcelorMittal Las Truchas is the 

successor-in-interest to Sicartsa. 

Source: Cited Federal Register notices. 

Scope inquiry reviews

On May 11, 2004, Commerce initiated a scope inquiry to clarify the exclusion for grade

1080 tire cord quality wire rod and tire bead quality wire rod from the antidumping and  

countervailing duty orders on wire rod from Brazil. On May 9, 2005, Commerce issued a final

scope ruling and determined that for grade 1080 tire cord quality wire rod and tire bead quality

wire rod, the phrase, “having no inclusions greater than 20 microns” means no inclusions

greater than 20 microns in any direction.21

Anti‐circumvention inquiry

On June 8, 2011, at the request of the domestic industry, Commerce initiated a

circumvention inquiry into whether Mexican wire rod producers Deacero and Ternium Mexico

shipped wire rod with an actual diameter measuring 4.75 mm to 5.00 mm in a manner that

                                                            

21 Notice of Scope Rulings, 70 FR 55110 (September 20, 2005).
I‐19

constituted merchandise altered in form or appearance in such minor respects that it should be

included within the scope.22 On October 1, 2012, Commerce published its final determination of

circumvention, finding that (1) Ternium was not covered by the affirmative anti‐circumvention

inquiry because it had not shipped wire rod with diameters of 4.75 to 5.0 mm to the United

States; and (2) shipments of wire rod with an actual diameter of 4.75 mm to 5.00 mm by

Deacero constituted merchandise altered in form or appearance in such minor respects that it

should be included within the scope of the order on wire rod from Mexico.23 Deacero appealed

Commerce’s final circumvention finding to the CIT and a remand order was issued on

September 30, 2013.24 Pursuant to the direction from the CIT, Commerce reversed its final

determination “under respectful protest” and found on final remand that wire rod with an

actual diameter of 4.75 mm to 5.00 mm shipped to the United States by Deacero is outside the

scope of the order and, thus, such shipments do not constitute a circumventing minor

alteration.25 The CIT ruling on Commerce’s final remand determination is pending.

Certain data and other information concerning the Mexican production, U.S. imports,

and U.S. purchases of the imported smaller diameter wire rod (4.75 mm to 5.0 mm) produced

by Deacero in Mexico were requested in these reviews. As noted above, such information

provided in response to questionnaires transmitted to U.S. importers, purchasers, and foreign

producer Deacero is presented separately in appendix F.

Five‐year reviews

Countervailing duty order concerning Brazil

Commerce has issued the final results of its expedited second five‐year review of the

countervailing duty order concerning Brazil.26 Table I‐8 presents information with respect to the

countervailable subsidies found by Commerce in the original investigation and subsequent five‐

year reviews.   

                                                            

22 Carbon and Certain Alloy Steel Wire Rod from Mexico: Initiation of Anti‐Circumvention Inquiry of

Antidumping Duty Order, 76 FR 33218, June 8, 2011.

23 Carbon and Certain Alloy Steel Wire Rod from Mexico: Affirmative Final Determination of

Circumvention of the Antidumping Order, 77 FR 59892, October 1, 2012.   24 Deacero S.A. de C.V. and Deacero USA Inc. v. United States and Arcelormittal USA LLC, Gerdau

Ameristeel U.S. Inc., Evraz Rocky Mountain Steel, and Nucor Corporation, Court No. 12‐00345; Slip Op.

13‐126 (CIT 2013) (“Deacero Remand”).

25 Final Results of Redetermination Pursuant to Court Remand (Deacero Remand), Office of

Enforcement & Compliance, International Trade Administration, January 28, 2014.

26 Carbon and Certain Alloy Steel Wire Rod from Brazil: Final Results of the Expedited Second Sunset

Review of the Countervailing Duty Order, 78 FR 60850, October 2, 2013; and Issues and Decision

Memorandum for the Final Results of the Expedited Sunset Review of the Countervailing Duty Order on

Carbon and Certain Alloy Steel Wire Rod from Brazil, September 25, 2013.
I‐20

Table I-8 

Wire rod: Commerce’s original and first and second five-year countervailable subsidy margins for 

producers/exporters in Brazil 

Producer/exporter 

Original margin 

(percent) 

First five-year review 

margin (percent) 

Second five-year 

review margin 

(percent) 

Belgo Mineira1 6.74 6.74 6.74

Gerdau SA 2.76 2.76 2.31

All others 5.64 5.64 4.53

1

 ArcelorMittal Brasil is the successor to Belgo Mineira. 

Source: Countervailing duty order, 67 FR 64871, October 22, 2002; final results of first expedited sunset 

review, 73 FR 1323, January 8, 2008; final results of second expedited sunset review, 78 FR 60850, 

October 2, 2013. 

The following seven programs were found by Commerce to confer countervailable

subsidies in the original investigation:  

1. Financing for the Acquisition or Lease of Machinery and Equipment through the

Special Agency for Industrial Financing;

2. Programa de Financiamento as Exportações;

3. Tax Incentives Provided by the Amazon Region Development Authority (“SUDAM”)

and the Northeast Region Development Authority (“SUDENE”);

4. Debt Forgiveness/Equity Infusions Provided to Usina Siderurgica da Bahia S.A.

(previously 1988 Equity Infusions/Debt Forgiveness Provided to Usina Siderurgica da

Bahia S.A.) (specific to Gerdau S.A. (Gerdau));

5. National Bank for Economic and Social Development Financing for the Acquisition of

Dedini Siderurgica de Piracicaba (specific to Companhia Siderugica Belgo‐Mineira

(Belgo Mineira));

6. National Bank for Economic and Social Development Financing for the Acquisition of

Mendes Junior Siderurgica S.A. (specific to Belgo Mineira); and

7. “Presumed” Tax Credit for the Program of Social Integration and the Social

Contributions of Billings on Inputs Used in Exports.

In the second five‐year review of the countervailing duty order concerning Brazil,

Commerce found that these countervailable programs continue to exist and be used by

Brazilian producers and exporters of wire rod and that a countervailable subsidy is likely to

continue or recur if the order is revoked. Although it did not remove the “Debt

Forgiveness/Equity Infusions Provided to Usina Siderurgica da Bahia S.A.” program, Commerce

recalculated the rate for Gerdau and “All others” to remove the ad valorem subsidy rate of 0.45

percent attributed to Gerdau under this program because the benefits received by Gerdau in
I‐21

1986, 1987, and 1989 were fully allocated over the average useful life of the subject

merchandise (i.e., 15 years).27  

Commerce also found that three of the seven programs fall under Article 3.1 of the

SCM Agreement,28 which states that the following subsidies shall be prohibited: (a) subsidies

contingent, in law or in fact, whether solely or as one of several other conditions, upon export

performance; and (b) subsidies contingent, whether solely or as one of several other

conditions, upon the use of domestic over imported goods.

  

1. Programa de Financiamento as Exportações

2. “Presumed” Tax Credit for the Program of Social Integration and the Social

Contributions of Billings on Inputs Used in Exports

3. Financing for the Acquisition or Lease of Machinery and Equipment through the

Special Agency for Industrial Financing

Commerce found that the remaining four programs do not fall within the meaning of

Article 3.1 of the SCM Agreement, but could be subsidies described in Article 6.1 of the SCM

Agreement if the amount of the subsidy exceeds five percent, as measured in accordance with

Annex IV of the SCM Agreement. They also could fall within the meaning of Article 6.1 if they

constitute debt forgiveness, grants to cover debt repayment, or are subsidies to cover

operating losses sustained by an industry or enterprise. However, Commerce found that there

was insufficient information on the record of the second five‐year review in order to make such

a determination.

                                                            

27 Commerce noted that although the benefits Gerdau received under “Debt Forgiveness/Equity

Infusions Provided to Usina Siderurgica da Bahia S.A.” were non‐recurring in nature and were fully

allocated over the average useful life of the subject merchandise, the non‐recurring subsidy program

was not removed because there is no information on the record that it was terminated. Issues and

Decision Memorandum for the Final Results of the Expedited Sunset Review of the Countervailing Duty

Order on Carbon and Certain Alloy Steel Wire Rod from Brazil, September 25, 2013.

28 Consistent with section 752(a)(6) of the Act, Commerce provided information concerning the

nature of the subsidy and whether it is a subsidy described in Article 3 or Article 6.1 of the 1994 World

Trade Organization Agreement on Subsidies and Countervailing Measures (“SCM Agreement”). It noted,

however, that Article 6.1 of the SCM Agreement expired effective January 1, 2000. Issues and Decision

Memorandum for the Final Results of the Expedited Sunset Review of the Countervailing Duty Order on

Carbon and Certain Alloy Steel Wire Rod from Brazil, September 25, 2013.
I‐22

Antidumping duty orders

Commerce has issued the final results of its expedited second five‐year reviews of the

antidumping duty orders concerning Brazil, Indonesia, Mexico, Moldova, Trinidad & Tobago,

and Ukraine.29 Table I‐9 presents information with respect to the dumping margins.  

  

Table I-9 

Wire rod: Commerce’s original and first and second five-year dumping margins for 

producers/exporters, by subject country 

Producer/exporter 

Original margin 

(percent) 

First five-year 

review margin 

(percent) 

Second fiveyear review 

margin 

(percent) 

Brazil

Belgo Mineira/Arcelor Mittal Brasil 94.73 94.73 94.73

All others 74.35 74.45 74.45

Indonesia

PT Ispat Indo 4.06 4.06 4.05

All others 4.06 4.06 4.05

Mexico

Sicartsa/ArcelorMittal Las Truchas 20.11 20.11 20.11

All others 20.11 20.11 20.11

Moldova

Moldova-wide rate 369.10 369.10 369.10

Trinidad & Tobago

Caribbean Ispat/ArcelorMittal Point Lisas 11.40 11.40 11.40

All others 11.40 11.40 11.40

Ukraine

Krivorozhstal 116.37 116.37 116.37

All others 116.37 116.37 116.37

Source: Antidumping duty order, 67 FR 34899, May 16, 2002; final results of expedited sunset review, 73 

FR 1321, January 8, 2008; final results of second expedited sunset review, 78 FR 63450, October 24, 

2013. 

                                                            

29 Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia, Mexico, Moldova, Trinidad and

Tobago, and Ukraine: Final Results of the Expedited Second Sunset Reviews of the Antidumping Duty

Orders, 78 FR 63450, October 24, 2013.
I‐23

THE SUBJECT MERCHANDISE

Commerce’s scope

The scope of these reviews as defined by Commerce in its expedited second five‐year

review determinations is as follows:

The merchandise subject to these orders is certain hot‐rolled

products of carbon steel and alloy steel, in coils, of approximately round

cross section, 5.00 mm or more, but less than 19.00 mm, in solid cross‐

sectional diameter.  

Specifically excluded are steel products possessing the above‐

noted physical characteristics and meeting the Harmonized Tariff

Schedule of the United States (“HTSUS”) definitions for (a) stainless steel;

(b) tool steel; c) high nickel steel; (d) ball bearing steel; and (e) concrete

reinforcing bars and rods.

Also excluded are (f) free machining steel products (i.e., products

that contain by weight one or more of the following elements: 0.03

percent or more of lead, 0.05 percent or more of bismuth, 0.08 percent

or more of sulfur, more than 0.04 percent of phosphorus, more than 0.05

percent of selenium, or more than 0.01 percent of tellurium). Also

excluded from the scope are 1080 grade tire cord quality wire rod and

1080 grade tire bead quality wire rod. This grade 1080 tire cord quality

rod is defined as: (i) grade 1080 tire cord quality wire rod measuring 5.0

mm or more but not more than 6.0 mm in cross‐sectional diameter; (ii)

with an average partial decarburization of no more than 70 microns in

depth (maximum individual 200 microns); (iii) having no non‐deformable

inclusions greater than 20 microns and no deformable inclusions greater

than 35 microns; (iv) having a carbon segregation per heat average of 3.0

or better using European Method NFA 04‐114; (v) having a surface quality

with no surface defects of a length greater than 0.15 mm; (vi) capable of

being drawn to a diameter of 0.30 mm or less with 3 or fewer breaks per

ton, and (vii) containing by weight the following elements in the

proportions shown: (1) 0.78 percent or more of carbon, (2) less than 0.01

percent of aluminum, (3) 0.040 percent or less, in the aggregate, of

phosphorus and sulfur, (4) 0.006 percent or less of nitrogen, and (5) not

more than 0.15 percent, in the aggregate, of copper, nickel and

chromium.  

This grade 1080 tire bead quality rod is defined as: (i) grade 1080

tire bead quality wire rod measuring 5.5 mm or more but not more than

7.0 mm in cross‐sectional diameter; (ii) with an average partial

decarburization of no more than 70 microns in depth (maximum

individual 200 microns); (iii) having no non‐deformable inclusions greater
I‐24

than 20 microns and no deformable inclusions greater than 35 microns; (iv)

having a carbon segregation per heat average of 3.0 or better using European

Method NFA 04‐114; (v) having a surface quality with no surface defects of a

length greater than 0.2 mm; (vi) capable of being drawn to a diameter of 0.78

mm or larger with 0.5 or fewer breaks per ton; and (vii) containing by weight the

following elements in the proportions shown: (1) 0.78 percent or more of

carbon, (2) less than 0.01 percent of soluble aluminum, (3) 0.040 percent or less,

in the aggregate, of phosphorus and sulfur, (4) 0.008  percent or less of nitrogen,

and (5) either not more than 0.15 percent, in the aggregate, of  copper, nickel

and chromium (if chromium is not specified), or not more than 0.10 percent in  

the aggregate of copper and nickel and a chromium content of 0.24 to 0.30

percent (if chromium is specified).

For purposes of the grade 1080 tire cord quality wire rod and the grade

1080 tire bead quality wire rod, an inclusion will be considered to be deformable

if its ratio of length (measured along the axis ‐ that is, the direction of rolling ‐ of

the rod) over thickness (measured on the same inclusion in a direction

perpendicular to the axis of the rod) is equal to or greater than three. The size of

an inclusion for purposes of the 20 microns and 35 microns limitations is the

measurement of the largest dimension observed on a longitudinal section

measured in a direction perpendicular to the axis of the rod. This measurement

methodology applies only to inclusions on certain grade 1080 tire cord quality

wire rod and certain grade 1080 tire bead quality wire rod that are entered, or

withdrawn from warehouse, for consumption on or after July 24, 2003.

The designation of the products as “tire cord quality” or “tire bead

quality” indicates the acceptability of the product for use in the production of

tire cord, tire bead, or wire for use in other rubber reinforcement applications

such as hose wire. These quality designations are presumed to indicate that

these products are being used in tire cord, tire bead, and other rubber

reinforcement applications, and such merchandise intended for the tire cord, tire

bead, or other rubber reinforcement applications is not included in the scope.

However, should the petitioners or other interested parties provide a reasonable

basis to believe or suspect that there exists a pattern of importation of such

products for other than those applications, end‐use certification for all products

meeting the physical description of subject merchandise that are not specifically

excluded are included in this scope.30

                                                            

30 For additional information regarding Deacero’s exports of wire rod, see the “Anti‐circumvention

inquiry” section of this chapter.
I‐25

Tariff treatment

Wire rod is imported under the following statistical reporting numbers of the

Harmonized Tariff Schedule of the United States (“HTSUS” or “HTS”):  7213.91.3011,

7213.91.3015, 7213.91.3020 (added on July 1, 2008), 7213.91.3092 (discontinued on July 1,

2008), 7213.91.3093 (added on July 1, 2008),31 7213.91.4500, 7213.91.6000, 7213.99.0030,

7213.99.0090, 7227.20.0000 (discontinued on July 1, 2008),  7227.20.0030 (added on July 1,

2008), 7227.20.0080 (added on July 1, 2008),32 7227.90.6010, 7227.90.6020 (added on July 1,

2008), 7227.90.6030 (added on January 1, 2014), 7227.90.6035 (added on January 1, 2014),

7227.90.6080 (discontinued on July 1, 2008),33 and 7227.90.6085 (added on July 1, 2008, and

discontinued on January 1, 2014).34 At the time of the original investigations general U.S. tariffs

on wire rod, applicable to U.S. imports that are products of the subject countries and reported

under these provisions, ranged from 0.8 to 0.9 percent ad valorem for nonalloy steel and were

1.8 percent ad valorem for alloy steel.  By January 1, 2004, these tariffs had been eliminated,

resulting in a general duty rate of “Free.”

                                                            

     31 HTS 7213.91.3092 was replaced with two new breakouts, specifically 7213.91.3020 (covering

welding‐quality, nonalloy wire rod, with a circular diameter of less than 14 mm, not tempered, not

treated and not partly manufactured) and 7213.91.3093 (covering  other than of welding quality,

nonalloy wire rod with a circular diameter of less than 14 mm, not tempered, not treated and not partly

manufactured). HTSUS 2008 ‐ Supplement 1, “Change Record,” July 1, 2008, p. 11; HTSUS 2008 ‐ 

Supplement 1, “Chapter 72 Iron and Steel,” July 1, 2008, p. XV 72‐18; and HTSUS 2008 – Revision 2,

“Chapter 72 Iron and Steel,” April 16, 2008, p. XV 72‐18.

     32 HTS 7227.20.0000 was replaced with two new breakouts, specifically 7227.20.0030 (covering

welding‐quality, silico‐manganese alloy wire rod) and 7227.20.0080 (covering other than of welding

quality, silico‐manganese alloy wire rod). HTSUS 2008 ‐ Supplement 1, “Change Record,” July 1, 2008, p.

11; HTSUS 2008 ‐ Supplement 1, “Chapter 72 Iron and Steel,” July 1, 2008, p. XV 72‐36; and HTSUS 2008

– Revision 2, “Chapter 72 Iron and Steel,” April 16, 2008, p. XV 72‐36.

     33 HTS 7227.90.6080 was replaced with two new breakouts, specifically 7227.90.6020 (covering

welding‐quality, other alloy wire rod) and 7227.90.6085 (covering other than of welding quality, other

alloy wire rod). HTSUS 2008 ‐ Supplement 1, “Change Record,” July 1, 2008, p. 11; HTSUS 2008 ‐ 

Supplement 1, “Chapter 72 Iron and Steel,” July 1, 2008, p. XV 72‐36; and HTSUS 2008 – Revision 2,

“Chapter 72 Iron and Steel,” April 16, 2008, p. XV 72‐36.

     34 HTS 7227.90.6085 was replaced with four new breakouts, including  7227.90.6030 (covering other

alloy wire rod with a circular diameter of less than 14 mm) and 7227.90.6035 (covering other alloy wire

rod with a circular diameter of 14 mm or more but less than 19 mm).  The other two new breakouts,

7227.90.6040 (other alloy bars and rods with a circular diameter of 19 mm or more) and 7227.90.6090

(cross‐section shapes other than circular), are considered bar and rod products outside the scope of

these investigations.  HTSUS 2014 ‐ Basic, “Change Record,” January 1, 2014, pp. 6‐7; and HTSUS 2014 ‐ 

Basic, “Iron and Steel,” January 1, 2014, p. XV 72‐36.
I‐26

THE PRODUCT

Description and applications35

Wire rod is a hot‐rolled intermediate steel product of circular or approximately circular

cross section that typically is produced in nominal fractional diameters up to 47/64 inch (18.7

mm) and sold in irregularly wound coils, primarily for subsequent drawing and finishing by wire

drawers.36  Wire rod is essentially used only to manufacture wire, which is either fabricated into

downstream wire products or incorporated into finished products.37 Wire rod sold in the United

States is categorized by “quality” according to end use. End‐use categories are broad

descriptions with overlapping metallurgical qualities, chemistries,38 and physical

characteristics.39   

Table I‐10 presents quality and commodity descriptions for 11 major types of wire rod,

as indicated by the Iron and Steel Society. Industrial quality wire rod currently accounts for the

majority of wire rod consumed in the United States. It is primarily intended for drawing into

industrial (or standard) quality wire that, in turn, is used to manufacture such products as nails,

reinforcing wire mesh and chain link fence. Most of the industrial quality wire rod is produced

and sold in the smallest cross‐sectional diameter that is hot rolled in substantial commercial

quantities (7/32 inch or 5.5 mm). Industrial quality wire rod generally is manufactured from

low‐ or medium‐low‐carbon steel.40 Other relatively large‐volume qualities of wire rod

consumed in the United States include high‐ and medium‐high carbon and cold‐heading quality.

                                                            

     35 Carbon and Certain Alloy Steel Wire Rod from China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248

(Preliminary), USITC Publication 4458, March 2014, pp. I‐10 – I‐12; Carbon and Certain Alloy Steel Wire

Rod from Brazil, Canada, Indonesia, Mexico, Moldova, Trinidad and Tobago, and Ukraine, Inv. Nos. 701‐

TA‐417 and 731‐TA‐953, 954, 957‐959, 961, and 962 (Review), USITC Publication 4014, June 2008, pp. I‐

22 – I‐24; and Carbon and Certain Alloy Steel Wire Rod from China, Germany, and Turkey, Inv. Nos. 731‐

TA‐1099‐1101 (Preliminary), USITC Publication 3832, January 2006, pp. I‐6 – I‐7.

     36 Wire drawers (also referred to as redrawers) manufacture wire and wire products and may be

either independent or afflilated with wire rod producers.

     37 Carbon and Certain Alloy Steel Wire Rod from China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248

(Preliminary), USITC Publication 4458, March 2014, p. I‐11.

     38 Steel chemistries are designated as “grades” of standardized composition ranges for carbon,

nonferrous metals, and nonmetallic elements.  See e.g., table 2‐1, Standard Steels for Wire Rods and

Wire Nonresulfurized Carbon Steels, Manganese Maximum Not Exceeding 1.00 Percent.  Iron and Steel

Society, Steel Products Manual:  Carbon Steel Wire and Rods, August 1993, p. 6.

        Wire rod of AISI/SAE grade 1080 steel contains 0.75‐0.88 percent carbon, 0.60‐0.90 manganese, a

maximum of 0.040 percent phosphorous, and 0.050 percent sulfur.  Ibid.

     39 Steel ductility, hardness, and tensile strength are positively correlated with carbon content.  

Alloying elements can be added at the steel melting stage of the manufacturing process to impart

various characteristics to the wire rod.

     40 Iron and Steel Society, Steel Products Manual:  Carbon Steel Wire and Rods, August 1993, p. 36.
I‐27

High‐ and medium‐high carbon wire rod are intended for drawing into wire for such products as

strand, upholstery spring, mechanical spring, rope, screens, and pre‐stressed concrete wire.41   

Table I-10 

Wire rod: Quality, end uses, and important characteristics

Quality End uses Important characteristics

Chain quality Electric welded chain 

Butt-welding properties and uniform internal 

soundness 

Cold-finishing quality Cold-drawn bars Surface quality 

Cold-heading quality 

Cold-heading, cold-forging, coldextrusion products Internal soundness, good surface quality, may 

require thermal treatments 

Concrete 

reinforcement 

Nondeformed rods for reinforcing 

concrete (plain round or smooth 

surface rounds) 

Chemical composition important only insofar as 

it affects mechanical property 

Fine wire 

Insect screen, weaving wire, florist 

wire 

Rods must be suitable for drawing into wire 

sizes as small as 0.035 inch (0.889 mm) 

without intermediate annealing; internal quality 

important 

High carbon and 

medium-high carbon 

Strand and rope, tire bead, 

upholstery spring, mechanical spring, 

screens, aluminum conductors steel 

reinforced core, pre-stressed 

concrete strand; pipe wrap wire is a 

subset 

Requires thermal treatment prior to drawing; 

however, it is not intended to be used for music 

wire or valve spring wire 

Industrial (standard) 

quality 

Nails, coat hangers, mesh for 

concrete reinforcement, fencing 

Can only be drawn a limited number of times 

before requiring thermal treatment 

Music spring wire 

Springs subject to high stress; valve 

springs are a subset 

Restrictive requirements for chemistry, 

cleanliness, segregation, decarburization, 

surface imperfections 

Scrapless nut 

Fasteners produced by cold heading, 

cold expanding, cold punching, 

thread tapping Internal soundness, good surface quality 

Tire cord 

Tread reinforcement in pneumatic 

tires 

Restrictive requirements for cleanliness, 

segregation, decarburization, chemistry, 

surface imperfections 

Welding quality 

Wire for gas welding, electric arc 

welding, submerged arc welding, 

metal inert gas welding Restrictive requirements for uniform chemistry 

Source: Iron and Steel Society, Steel Products Manual: Carbon Steel Wire and Rods, August 1993, pp. 35-37.

                                                            

     41 The end uses of very high quality wire rod are those where manufacturing process involve large

amounts of cold deformation of the steel such as in recessed quality cold heading; those that are safety

critical, such as automotive wheel bolts and tire reinforcing wire; those that have very demanding

consistency requirements or unusual steel chemistry requirements, such as certain welding grades; and

other applications that put unusual and demanding requirements on the steel.
I‐28

According to witnesses for domestic producers, there are no specific types of wire rod

within the scope of these investigations that the domestic industry cannot supply.42 Moreover,

a witness further testified that the domestic industry supplies the full range of wire rods

purchased in the U.S. market.43 Counsel for domestic producers testified that wire rod below

5.5 mm in diameter was not commercially available at the time of the original investigations

(August 31, 2001), as no firm in the United States, Mexico, or any other subject country

produced and sold such smaller diameter wire rod in the U.S. market.44 Witnesses for Evraz

Pueblo, Gerdau, and Nucor testified that their firms do not produce smaller diameter (4.75 mm)

wire rod in the United States.45 Counsel for Deacero observed that Charter Steel produced wire

rod of diameters as small as 4.0 mm, prior to the issuance of antidumping orders.46 However,

Charter Steel no longer produces this product,47 having ***.48 According to domestic‐industry

witnesses, customers did not request 4.75 mm diameter wire rod,49 as smaller diameter wire

rod was not necessary to manufacture their downstream products.50 Moreover, Evraz Pueblo,

Gerdau, and Nucor declined to pursue production of smaller diameter wire rod, concluding that

the product price required to justify the capital investment and production costs was too high

for the anticipated market conditions.51  

Mexican producer Deacero described its U.S. shipments as predominantly of smaller

diameter, 4.75 mm wire rod.52 According to Deacero witnesses, the firm did not supply wire rod

to the U.S. market prior to 2008, when U.S. customers inquired about 4.75 mm wire rod,53 a

size not otherwise available from domestic producers during the period of review.54 Previously,

                                                            

     42 Hearing transcript, pp. 118 (Goettl), 118 (Strinaman), and 119 (Ashby).

     43 Hearing transcript, p. 46 (Ashby).

     44 Hearing transcript, p. 71 (Luberda).

     45 Hearing transcript, pp. 74 (Ashby), 74 (Kerkvliet), and 89 (Nystrom).

     46 Deacero’s prehearing brief, p. 10; and exhibit 5,  Certain Steel Wire Rod from Brazil and Japan, Inv.

Nos. 701‐TA‐646 and 648 (Final), USITC Publication 2761, March 1994, p. II‐22; and Charter Steel,

“History.”

     47 Charter Steel currently produces wire rod in diameters ranging from 5.5 mm to 40 mm. Charter

Steel, “Products & Capabilities, Bar & Rod Rolling,” http://www.chartersteel.com/products/rolling.php.

     48 The representative of Charter Steel ***, e‐mail correspondence with Commission staff, May 1, 2,

and 6, 2014.

     49 Hearing transcript, pp. 74 (Ashby), 74 (Kerkvliet), and 75 and 89 (Nystrom).

     50 Hearing transcript, p. 89 (Goettl).

     51 Hearing transcript, pp. 74 (Ashby), 74 (Kerkvliet) and 89 (Goettl), and 75 (Nystrom).

     52 During the review period, nearly *** percent of U.S. wire‐rod imports from Mexico were of 4.75

mm diameter wire rod. Deacero’s prehearing brief, p. 8.

     53 Hearing transcript, pp. 144 (D. Gutierrez) and 179 (S. Gutierrez).

     54 Deacero’s prehearing brief, pp. 8‐9; and hearing transcript, p. 20 (Campbell).
I‐29

the smallest diameter wire rod produced by Deacero was 5.5 mm in diameter.55 Considering the

potential demand as justification for the investment, after more than a year in development,

Deacero began production of 4.75 mm wire rod at its Celaya mill.56 Deacero began selling its

4.75 mm diameter wire rod into the U.S. market beginning in October 2008.57  

A witness for G3 Steel Group LLC (“G3 Steel”), a U.S. distributor that began selling

Deacero’s 4.75 mm wire rod in 2009 and continued to do so until 2012, testified that some

customers requested this smaller diameter wire rod because they previously purchased it from

Ivaco of Canada.58 Ivaco Rolling Mills (Ivaco) produces wire rod at its rolling mill in L'Orignal,

Ontario, with annual wire rod production capacity of 850,000 tons. Ivaco currently hot‐rolls

wire rods in diameters ranging from 4.75 mm to 25.5 mm,59 of various carbon and alloy steel

grades, with more than 80 pecent of its output being produced for high‐carbon, cold‐heading,

and welding quality applications.60 In contrast, Deacero reportedly produces predominantly low

to medium‐low carbon industrial‐quality wire rod.61  

Deacero attributed continued growth in its sales of 4.75 mm diameter wire rod in the

U.S. market to advantages identified by its customers for using 4.75 mm over 5.5 mm wire rod

(the most common diameter sold in the United States).62 Deacero and its customers highlighted

cost savings63 as well as the ability to manufacture new64 and improved wire products.65  

                                                            

     55 Hearing transcript, p. 144 (D. Gutierrez).

     56 Hearing transcript, pp. 144 (D. Gutierrez) and 184 (E. Gutierrez). Celaya is located in the

southeastern portion of the north‐central Mexican state of Guanajuato.

     57 Deacero’s prehearing brief, p. 9.

     58 Hearing transcript, pp. 145‐146 (Heileg).

     59 Ivaco requires a minimum order size of 750 metric tons (827 short tons) for its 4.75 mm wire rod,

but only 600 metric tons (661 short tons) for ordering all other diameters. Ivaco, “Rolling Schedule, May

1, 2014,” http://www.ivacorm.com/RollingSchedule.  

     60 See: Ivaco, “Products,” http://www.ivacorm.com/Products.  

     61 Deacero’s posthearing brief, “Responses to Commissioner questions,” p. 5.

     62 Hearing transcript, pp.  144‐145 (D. Gutierrez); Deacero’s prehearing brief, pp. 10‐12; and exhibit 7,

“Purchaser declarations.” For further details, see also, Deacero’s posthearing brief, exhibit 5, “Purchaser

statements regarding 4.75 mm wire rod and summary sheet.”

     63 A witness for Cavert Wire Co.  (Cavert) claimed that drawing 4.75 mm wire rod required only three

dies as opposed to the four dies required for drawing 5.5 mm wire rod to produce steel wire; using one

less die reduced its production costs by 25 percent (i.e., for electricity, cooling  lubricants, and

replacement dies),  and speeded‐up production and increased productivity. Further, 5.5 mm wire rod

was previously reduced in the first draft (draw) down to a diameter of about 0.187 inch (4.75 mm), so

starting with 4.75 mm wire rod already achieves the initial 0.187‐inch diameter even before beginning

the drawing process. Hearing transcript, pp. 149‐150 (Spittler); Deacero’s prehearing brief, pp. 10‐11;

and Deacero’s posthearing brief, pp. 13‐14.

Further, a witness for G3 Steel testified that wire drawers can draw‐down 4.75 mm wire rod

directly to finer diameter wire without having to anneal (heat treat) the wire to restore ductility by

relieving accumulated work hardening and brittleness, as less drawing is required. In contrast, 5.5 mm

(continued...)
I‐30

Domestic producers66 and respondent Deacero67 generally agree that 4.75 mm wire rod

is a substitute for 5.5 mm wire rod, the most common diameter sold in the United States.

However, witnesses for domestic producers testified there are no downstream applications

that require use of 4.75 mm wire rod.68 Witnesses and counsel for domestic producers describe

cost savings as “minimal” from drawing smaller diameter 4.75 mm wire rod,69  and one

witnesses characterized the users of this lower diameter wire rod as benefitting much more

from lower rod prices than lower costs of wire production.70  

Manufacturing processes71

The manufacturing process for wire rod consists of several stages:  (1) melting and

refining to set the steel’s chemical and metallurgical properties; (2) casting the steel into a

semifinished shape (billet); (3) hot‐rolling the billet into rod on a multistand, high‐speed rolling

mill; and (4) coiling and controlled cooling of the wire rod as it passes along a Stelmor deck, a

                                                            

(...continued)

wire rod requires annealing to achieve some finer diameter wires, which raises production costs through

longer production times and additional natural‐gas consumption. Wire annealing also requires wire

drawers to either operate and maintain their own annealing equipment or outsource the annealing

process to other firms. Hearing transcript, pp. 146‐174 (Heileg); Deacero’s prehearing brief, p. 11; and

Deacero’s posthearing brief, pp. 14‐15.

Finally, according to the witness, a G3 Steel customer mentioned experiencing fewer wire

breaks, better tool life, and improved production “uptime” (i.e., less production downtime) with 4.75

mm wire rod, as opposed to using larger diameter wire rod. Hearing transcript, p. 147 (Heileg).

     64 Starting with 4.75 mm wire rod also expands Cavert’s capabilities to produce smaller diameter wire,

down to 16‐gauge (0.062‐inch diameter) wire as opposed to 14‐gauge (0.08‐inch diameter) wire with 5.5

millimeter wire rod. Hearing transcript, pp. 149‐150 (Spittler); Deacero’s prehearing brief, pp. 10‐11; and

Deacero’s posthearing brief, p. 15.

     65 Another advantage of using smaller diameter (4.75 mm) wire rod is enhanced product quality as

fewer draws reduce the likelihood of imparting drawing defects and work hardening and brittleness in

the wire. Deacero’s prehearing brief, p. 11; and Deacero’s posthearing brief, pp. 15‐16.

     66 Domestic producers’ prehearing brief, p. 27.

     67 Deacero’s prehearing brief, p. 3; hearing transcript pp. 217‐218 (Campbell); and Deacero’s

posthearing brief, pp. 1, 10, 13, and 16.

     68 Hearing transcript, p. 70 (Kerkvliet and Nystrom).

     69 Hearing transcript, pp. 70 (Price), 72 (Goettl), and 73‐74 (Kerkvliet).

     70 Hearing transcript, p. 72 (Goettl).

     71 Carbon and Certain Alloy Steel Wire Rod from China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248

(Preliminary), USITC Publication 4458, March 2014, pp. I‐13 – I‐18; Carbon and Certain Alloy Steel Wire

Rod from Brazil, Canada, Indonesia, Mexico, Moldova, Trinidad and Tobago, and Ukraine, Inv. Nos. 701‐

TA‐417 and 731‐TA‐953, 954, 957‐959, 961, and 962 (Review), USITC Publication 4014, June 2008, pp. I‐

22 – I‐24; and Carbon and Certain Alloy Steel Wire Rod from China, Germany, and Turkey, Inv. Nos. 731‐

TA‐1099‐1101 (Preliminary), USITC Publication 3832, January 2006, pp. I‐6 – I‐7.
I‐31

specialized conveyor unique to the wire rod industry. The equipment used to produce wire rod

is much the same throughout the world and without significant differences in production

technology.72   

U.S. and foreign wire rod manufacturers have made capital investments in their

production facilities to improve processing efficiencies and product quality. Standards of

product quality (e.g., tighter dimensional tolerances, control over residuals, and coil weight)

have become higher across the entire range of wire rod products largely in response to

customer demands for improved performance on the customer's equipment. These

improvements have tended to blur the distinctions among quality terms over time.73   

Melting stage

There are two primary process routes by which steel for rod is made in the United

States and in foreign countries: the integrated process, which employs blast furnaces and basic

oxygen furnaces (“BOFs”), and the nonintegrated (or “minimill”) production process, which

utilizes an electric arc furnace (“EAF”) to produce raw steel. In both processes, pig iron, ferrous

scrap, and/or direct reduced iron (“DRI”)74 are charged into BOFs or EAFs. In the United States,

steel for rod production is melted from ferrous scrap in an EAF, along with other raw materials

that may also be added as part of the EAF charge.75 Alloy agents are added to the liquid steel to

impart specific properties to finished steel products. The molten steel is poured or tapped from

the furnace to a ladle, which is an open topped, refractory lined vessel that has an off‐center

opening in its bottom and is equipped with a nozzle. Meanwhile, the primary steelmaking

vessel (either EAF or BOF) may be charged with new materials to begin another refining cycle.

                                                            

     72 Carbon and Certain Alloy Steel Wire Rod from China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248

(Preliminary), USITC Publication 4458, March 2014, p. I‐13.

     73 Carbon and Certain Alloy Steel Wire Rod from China, Germany, and Turkey, Invs. Nos. 731‐TA‐1099‐

1101 (Preliminary), USITC Publication 3832, January 2006, p. I‐8.

74 The advantage of using DRI or pig iron (BOF steel) is the low levels of residual elements (e.g.,

copper, chromium, nickel, molybdenum, and tin) and reduced gaseous content (particularly nitrogen)

that they impart to the steel.  Compared to BOF steel, EAF scrap‐based steel contains higher levels of

certain residuals, which adversely affect yields and drawing efficiencies, and limit such scrap‐based steel

use in certain critical applications. 75 Minimills use ferrous scrap as their primary raw material but may add DRI or hot‐briquetted iron

and/or pig iron to the mix, depending on the specifications for the end product and the relative costs of

the raw materials.  Minimills that produce high quality rod products, such as high carbon, cold heading

quality, tire cord quality, and/or other special quality wire rod may use less ferrous scrap and more DRI

than other steelmakers, however the production process in general does not change.

        Both steelmaking processes are increasingly overlapped in terms of chemistries (and are not

considered material differences), with increasing blast furnace use of scrap and EAF use of DRI and pig

iron.  Carbon and Certain Alloy Steel Wire Rod from China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248

(Preliminary), USITC Publication 4458, March 2014, p. I‐14.
I‐32

Molten steel typically is treated in a ladle metallurgy station, where its chemistry is

refined to give the steel those properties required for specific applications. At the ladle

metallurgy, or secondary steel making, station the chemical content (particularly that of carbon

and sulfur) is adjusted, and alloying agents may be added.76 The steel may be degassed

(eliminating oxygen and hydrogen) at low pressures.77 Ladle metallurgy stations are equipped

with electric arc power to adjust the temperature of the molten steel for optimum casting and

to allow it to serve as a holding reservoir for the casting stage.

                                                            

76 Boron can be added as ferroboron to molten steel (in concentrations of 0.0015–0.0030 percent or

15–30 parts per million (ppm)) to increase the hardenability of the steel.  However, because of boron’s

high reactivity with any dissolved oxygen and nitrogen in the molten steel, ferroboron is the last

addition at the ladle metallurgy station, under controlled conditions, and only after the molten steel is

“killed” (deoxidized or degassed).  Shieldalloy Metallurgical Corp., “Boron,” Ferroalloys & Alloying

Additives Online Handbook, November 23, 2000.

       Boron enhances the ductility (drawability) of low carbon steels, hardness of cold heading grade

steels, and heat treatability and tensile strength of higher carbon steels.  Carbon and Certain Alloy Steel

Wire Rod from China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248 (Preliminary), USITC Publication 4458,

March 2014, p. I‐14.

       Chinese wire rod often contains trace additions of boron (exceeding 0.0008 percent or 8 ppm) for it

to be classified as alloy steel rather than carbon steel.  In July 2010, the Chinese government removed a

VAT rebate for carbon steel exports but continued offering the rebate for alloy steel exports.  

Subsequently, Chinese producers reportedly added boron to claim the rebate for their alloy steel

exports, rather than for metallurgical purposes.  HTSUS (2014), “Chapter 72 Iron and Steel, Note 1(f)

Other Alloy Steel,” January 1, 2014, p. XV 72‐2; and Carbon and Certain Alloy Steel Wire Rod from China,

Inv. Nos. 701‐TA‐512 and 731‐TA‐1248 (Preliminary), USITC Publication 4458, March 2014, p. I‐14.

       Articles appearing in the industry and trade press mention boron additions to wire rod as a means of

both avoiding Chinese export taxes and of gaining tax rebates.  See, e.g., Frizell, Samuel, “Chinese Wire

Rod Imports Spike,” American Metal Market, August 19, 2013; Nagi, Catherine, “Chinese Rod Hits Shores

But Avoids Import Data,” American Metal Market, January 11, 2013; and Cowden, Michael, “Chinese

Wire Rod Imports Rising: Trader,” American Metal Market, May 22, 2012.

     77 Liquid steel absorbs gasses from the atmosphere and from the materials used in the steelmaking

process.  These gasses, chiefly oxygen and hydrogen, cause embrittlement, voids, and nonmetallic

inclusions.  Low pressures, such as in a vacuum, aid the release of oxygen in gas form without the need

for additions of deoxidizers such as silicon, aluminum, or titanium, which form nonmetallic inclusions.  

Additionally, carbon content may be reduced more easily at low pressure (because it combines with

oxygen to form carbon monoxide and is released in gas form), resulting in a more ductile steel.  

Moreover, hydrogen gas causes embrittlement, low ductility, and blow holes in steel; vacuum treatment

more easily removes hydrogen from the steel.  Hence the use of deoxidizing processes results in more

efficient process and cleaner steel.
I‐33

Casting stage

Once molten steel with the requisite properties has been produced, it is cast into a form

that can enter the rolling process. Continuous (strand) casting is the method primarily used in

the United States. In strand casting, the ladle containing molten steel is transferred from the

ladle metallurgy station to the caster and the molten steel is poured at a controlled rate into a

tundish (reservoir dam), which in turn controls the rate of flow of the molten steel in to the

molds at the top of the caster. The tundish may have a special design or employ

electromagnetic stirring to ensure homogeneity of the steel. The strand caster is designed to

produce billets in the desired cross sectional dimensions, based on the dimensions of the rod

and the design of the rolling mill. Billets may be sent directly (“hot charged”) into the rolling mill

or, depending upon the rolling mill's schedule, sent to a storage yard. While in storage, they

may be inspected and subjected to one or more conditioning operations (e.g., grinding or

turning) to prepare them for hot rolling. This preparation is more common with cold heading

quality rods intended to be made into fasteners.78   

Rolling stage

The wire rod rolling process determines the rod’s size (diameter) and dimensional

precision,  depth of decarburization, surface defects and seams, amount of mill scale, structural

grain size, and within limits set by the chemistry, tensile strength and other physical properties.  

There is little or no difference among the wire rod rolling mills in the United States, or between

U.S. mills and their foreign competitors.79 A larger billet will produce a heavier coil. Also, usable

coil size may be limited by the capabilities of the wire drawer’s equipment and machinery.

Modern rod rolling mills consist of five parts: a roughing mill, an intermediate mill, a pre

finishing mill, a no twist finishing mill, and a coiler combined with a conveyor cooling bed along

which the coiled rod travels prior to being collected, tied, compacted, and readied for

shipment. Wire rod mills typically consist of 22 to 29 rolling stands and the specialized Stelmor

conveyor deck;80  the need for uniform metallurgical properties requires close temperature

control accomplished by accelerating or retarding the rod’s cooling as it is rolled and conveyed

                                                            

     78 The purpose of these surface treatments is to make the steel billet softer and more ductile

(annealing); in the case of surface grinding, seam and folds are removed.

     79 The rolling process, however, can be optimized for various quality levels.  The rolling process for

higher quality steel, such as for cold heading quality and other surface sensitive products, must be

designed to maximize surface integrity.  This is managed by the number of rolling stands used to get to a

specific end diameter, the design of the reductions taken at each step, and the design of the guiding

equipment used to keep the steel moving on the proper path through the mill.

     80 The Stelmor conveyor deck allows for controlled cooling of the wire rod.  The cooling speed imparts

certain physical characteristics, thereby enabling producers to produce a wider range of wire rod

qualities.  Likewise, the Stelmor deck may be optimized for specific end products.  For example, ***.  

Most, if not all, U.S. wire rod producers have installed controlled cooling capacities.
I‐34

along the Stelmor deck. This is accomplished by water quench, forced air drafts, or by lowering

removable hoods overtop the deck. Metallurgical quality, temperature, and dimensional

tolerance usually are inspected in‐line.

Exiting the reheat furnace, the billet is initially reduced on the roughing mill (which

usually consists of approximately five stands). It then is passed through and successively

reduced in size on several more stands, termed intermediate rolling. After the last intermediate

rolling stand, the rolling mill usually splits into dual lines and the product is passed along to a

pre finishing mill which reduces it further in diameter. Rod mills often employ a “twist” mill for

primary and intermediate rolling, but the final rolling is nearly always on a no twist Morgan vee

mill (the rolls in each of approximately five stands are set at 90‐degree angles to allow the rod

to be rolled without twisting). This produces a nearly uniform non‐oriented grain structure in

the steel.

Cooling stage

After exiting the last finishing stand, the rod is coiled into concentric loops and placed

on a conveyor which moves the hot wire rod along while it cools. During rolling, the rod is water

cooled as it travels along the Stelmor deck; cooling practices are varied depending on the

designated end use of the rod and the customer’s preferences. The speed at which the rod is

cooled affects the consistency and formation of its metallurgical structure (grain structure and

physical properties such as tensile strength). It also affects scale buildup, which determines

yield losses at the wire drawer. The cooling rate may be varied through the use of removable

covers (insulating hoods which may be independently raised or lowered) over the deck or

blown air cooling, or a combination of the two, or through varying the speed of the roller table.  

The end user often specifies the cooling practice of the rod purchased.

At the end of the cooling deck, workers crop the ends of each rod to remove the part of

the rod which may be of lower quality due to uneven temperature control; the cropped ends

are also used for testing and inspection. The rod is then collected onto a carrier, transferred to

a “c” hook, compacted, tied, and readied for shipment, or for further finishing or in‐house

fabrication. Figure I‐1 illustrates the reheat through cooling stages of the wire rod production

process.
I‐35

Figure I-1 

Wire rod: Reheat and rolling process 

Source: POSCO Web site, http://www.steel-n.com/esales/general/us/catalog/wire_rod/, accessed March 10, 2008. 

Domestic producers manufacture various types of wire rod on essentially the same

equipment, in the same facilities, and with the same production personnel. While changes to

production processes are limited, changes in chemical composition, alloying elements and

other raw materials, stand fittings, and cooling speed determine the quality of the wire rod

produced. The basic equipment, machinery, facilities, and production personnel, however,

remain, the same for the production of industrial quality, tire cord quality, welding quality, and

cold heading quality wire rod.
I‐36

DOMESTIC LIKE PRODUCT ISSUES

In its original determinations and full first five‐year reviews, the Commission defined the

domestic like product as all wire rod products, which included grade 1080 tire cord and tire

bead quality wire rod excluded from Commerce’s scope, and it defined the domestic industry as

all domestic producers of wire rod.81 In its notice of institution in these current second five‐year

reviews, the Commission solicited comments from interested parties regarding the appropriate

domestic like product and domestic industry.82 The domestic producers indicated in their

responses to the Commission’s notice of institution in these current reviews that they agree

with the Commission’s definitions of domestic like product and domestic industry. Respondent

Deacero indicated in its response that it “does not object” to the Commission’s definitions of

the domestic like product and domestic industry and respondent Ternium did not comment on

the definitions in its response.83  

In their prehearing brief, domestic producers ArcelorMittal USA, Gerdau, Evraz, and

Keystone again noted that they agree with the Commission’s domestic like product definition in

the original investigations and first five‐year reviews and added that no respondent has

challenged that definition.84 Yenakiieve also indicated in its prehearing brief that it does not

disagree with the Commission’s definition of the domestic like product.85

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.

                                                            

81 Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Germany, Indonesia, Mexico,

Moldova, Trinidad and Tobago, Turkey, and Ukraine: Investigations Nos. 701‐TA‐417‐421 (Final) and

Investigations Nos. 731‐TA‐953, 954, 956‐959, 961, and 905 (Final), USITC Publication 3546, October

2002, p. 7; and Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Indonesia, Mexico,

Moldova, Trinidad and Tobago, and Ukraine, Investigation Nos. 701‐TA‐417 and 731‐TA‐953, 954, 957‐

959, 961, and 962 (Review), USITC Publication 4014, June 2008, pp. 8‐10.

82 Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia, Mexico, Moldova, Trinidad and  

Tobago, and Ukraine: Institution of five‐year reviews, 78 FR 33103, June 3, 2013.

83 Response of ArcelorMittal USA LLC, Cascade Steel Rolling Mills Inc., Evraz Rocky Mountain Steel,

Gerdau Ameristeel US Inc., Keystone Consolidated Industries, Inc., and Nucor Corp., July 2, 2013, p. 31;

and Response of Deacero S.A. de C.V. and Deacero USA, Inc., July 3, 2013, p. 15.

84 Prehearing brief of domestic producers ArcelorMittal USA, Gerdau, Evraz, and Keystone (hereinafter

referred to as “Domestic producers’ prehearing brief”), p. 5.

85 Yenakiieve’s prehearing brief, p.  5.
I‐37

U.S. MARKET PARTICIPANTS

U.S. producers

During the original investigations, 12 firms supplied the Commission with complete

information on their U.S. operations with respect to wire rod. These 12 firms accounted for

more than *** percent of U.S. production of wire rod products during 2001.86 During the full

first five‐year reviews, 10 firms supplied the Commission with information on their U.S.

operations. These 10 firms accounted for all known production of wire rod in the United States

during 2007.87  

In these current second five‐year reviews, the Commission issued U.S. producers’

questionnaires to 10 firms, all of which provided the Commission with information on their wire

rod operations. These 10 firms are believed to account for all known U.S. production of wire

rod in 2013.88 Presented in table I‐11 is a list of current domestic producers of wire rod and

each company’s position on the continuation of the orders, production locations(s), related

and/or affiliated firms, and share of reported production of wire rod in 2008‐13.

                                                            

86 The 12 U.S. producers that supplied the Commission with complete questionnaire information

during the original investigations are: ***.

87 The 10 U.S. producers that supplied the Commission with usable questionnaire information during

the first five‐year reviews are: ArcelorMittal USA; Cascade; Charter Steel, Division of Charter

Manufacturing (“Charter”); Gerdau Ameristeel; Keystone; Nucor; Oklahoma Steel and Wire, which is the

wire products related firm of Mid American Steel and Wire Co. (“Mid American”); Republic Engineered

Products (“Republic”); Rocky Mountain Steel Mills (“Rocky Mountain”); and Sterling Steel Co., LLC

(“Sterling”).

88 The 10 U.S. producers that supplied the Commission with usable questionnaire information during

the second five‐year reviews are: ArcelorMittal USA, Cascade, Charter, Evraz Pueblo (formerly known as

Rocky Mountain), Gerdau, Keystone, Mid American, Nucor, Republic, and Sterling.
I‐38

Table I-11 

Wire rod: U.S. producers, positions on orders, U.S. production locations, related and/or affiliated 

firms, and shares of 2008-13 reported U.S. production 

Firm 

Position 

on orders 

U.S. production 

locations Parent firm 

Share of 

2008-13 

U.S. 

production

ArcelorMittal USA mixed1 Georgetown, SC East Chicago, IN ArcelorMittal SA (Luxembourg)2 ***

Cascade *** McMinnville, OR 

Schnitzer Steel Industries, Inc. 

(Portland, OR) ***

Charter ***

Cuyahoga Heights, OH 

Fostoria, OH 

Saukville, WI Charter Manufacturing (Mequon, WI) ***

Evraz Pueblo support Pueblo, CO Evraz North America (Chicago, IL)3 ***

Gerdau support 

Beaumont, TX 

Jacksonville, FL 

Perth Amboy, NJ (idled) Gerdau SA (Brazil)4 ***

Keystone support Peoria, IL Contran Corp. (Dallas, TX) ***

Mid American *** Madill, OK - ***

Nucor support 

Wallingford, CT 

Norfolk, NE 

Kingman, AZ 

Darlington, SC - ***

Republic ***5 Lorain, OH 

Industrias ICH (Mexico) (***) 

Grupo Simec (Mexico) (***)

Pacific Steel (Mexico) (***) ***

Sterling *** Sterling, IL Leggett & Platt, Inc. (Carthage, MO) ***

 100.0

1

 ArcelorMittal USA takes no position on the continuation of the order concerning Trinidad & Tobago. 

ArcelorMittal USA supports the continuation of all other orders. 

2

 ArcelorMittal SA has subsidiary wire rod producers in Algeria, Argentina, Bosnia and Herzegovina, 

Brazil, Canada, Costa Rica, Czech Republic, France, Germany, Mexico, Morocco, Poland, Spain, 

Trinidad & Tobago, and Ukraine. 

3 ***. 

4

 ***. 

5

 ***. 

6

 ***. 

Source: Compiled from data submitted in response to Commission questionnaires. 
I‐39

No domestic producer reported production of wire rod in a foreign trade zone. Five

domestic producers (***) reported that since January 1, 2008, they have been involved in toll

agreements regarding the production of wire rod.89  

Although no U.S. producers reported the direct imports of subject merchandise in these

second five‐year reviews and no U.S. producers reported domestic purchases of the subject

merchandise from U.S. importers, three U.S. producers reported that they are related to

foreign producers of the subject merchandise. Gerdau reported that it is a wholly‐owned

subsidiary of wire rod producer Gerdau SA of Brazil. ArcelorMittal USA reported that it is a

wholly‐owned subsidiary of ArcelorMittal SA (Luxembourg), which has subsidiary wire rod

producers in numerous countries, including subject countries Brazil, Mexico, Trinidad & Tobago,

and Ukraine. Republic reported that its parent company, Grupo Simec, owns Grupo San Luis, a

wire rod producer in Mexico.90

The domestic producers argue that no U.S. producer should be excluded from the

domestic industry as a related party. They note that U.S. producers Gerdau and ArcelorMittal

USA are primarily interested in U.S. production, did not benefit from affiliations with the

subject producers or importers of wire rod, did not import subject merchandise during 2008‐13,

and do not support revocation of any of the orders.91 Ukrainian respondent Yenakiieve also

indicated that it does not see a basis on which to exclude ArcelorMittal or Gerdau from the

domestic industry.92

U.S. importers

In the original investigations, 27 U.S. importing firms supplied the Commission with

usable information on their operations involving the importation of wire rod, accounting for

*** percent of U.S. imports of wire rod during 2001. Of the responding U.S. importers, one was

also a domestic producer: Charter ***. In the Commission’s full first five‐year reviews, 26 firms

supplied usable import data, accounting for approximately 73 percent of total U.S. imports of

wire rod in 2007, and 90 percent of subject imports in that year. Reporting U.S. importers of

wire rod at that time imported primarily from the subject countries of Brazil, Canada (no longer

subject), Mexico, Trinidad & Tobago, and nonsubject Germany. No domestic producer reported

direct imports during the Commission’s first five‐year review.

In these current second five‐year reviews, the Commission issued U.S. importers’

questionnaires to approximately 125 firms believed to be importers of wire rod, as well as to all  

                                                            

89 ***.

90 ***.

91 The domestic producers also noted that domestic producer Republic Steel also appears to be

focused on U.S. production and not benefiting from the affiliation, and does not support revocation of

any orders.  Domestic producers’ prehearing brief, pp. 5‐6.

92 Yenakiieve’s prehearing brief, p. 5.  
I‐40

U.S. producers of wire rod.93 Usable questionnaire responses were received from 37 importing

firms, representing virtually all U.S. imports of wire rod from Mexico in 2013, and 84.8 percent

of U.S. imports of wire rod from nonsubject countries in that year, primarily from China,

Canada, and Japan.94 There were no reported U.S. imports from Brazil, Indonesia, Moldova,

Trinidad & Tobago, or Ukraine during 2013. U.S. imports of wire rod from Brazil, Moldova, and

Ukraine largely ceased following the imposition of duties in 2002 and the U.S. imports of wire

rod from Indonesia and Trinidad & Tobago ceased after 2005 and 2008, respectively.

Table I‐12 lists all responding U.S. importers of wire rod from subject and nonsubject

sources, their locations, and their shares of U.S. imports during 2008‐13. Reported subject

imports were concentrated in a few firms. Five importers reported importing subject wire rod

from Mexico during 2008‐13, with *** alone accounting for *** percent of total reported

imports from Mexico during 2013. Thirty‐five importers reported U.S. imports of nonsubject

wire rod during 2008‐13, with the largest three nonsubject importers (***) accounting for

slightly more than one half of reported imports from nonsubject sources during 2008‐13.  

Table I-12 

Wire rod: Reporting U.S. importers, parent companies, sources of imports, locations, and shares 

of reported imports, 2008-13 

*                    *                    *                    *                    *                    *                    *

U.S. purchasers

The Commission received 36 usable questionnaire responses from firms that bought

wire rod during 2008‐13. The majority of purchasers (33 of 36) reported that they were end

users of wire rod, two reported that they were distributors, and one reported that it was an

independent wire producer and seller.  All 36 purchasers reported their firms’ total purchases

(by quantity) of wire rod by country in 2013.  Approximately 69.0 percent of total reported

purchases of wire rod was U.S.‐produced wire rod, 2.9 percent was from Brazil (all nonsubject

products including tire bead and tire cord), 0.2 percent was from Mexico, and the remaining

27.9 percent was wire rod from nonsubject countries (primarily Canada and China, but also

included Germany, the Netherlands, Korea, UAE, Japan, the United Kingdom, Turkey, Spain, and

South Africa). In general, responding U.S. purchasers were located in the Midwest and the

Southeast. The largest purchasers of wire rod in 2013 were ***.

                                                            

93 None of the U.S. producers reported direct imports of wire rod.

94 The questionnaire import coverage calculation for nonsubject countries is based on the share of

reported U.S. imports from nonsubject sources relative to such data as reported by official Commerce

import statistics. The questionnaire import coverage calculation for Mexico is based on an examination

of importing firms as reported in proprietary Customs documents.
I‐41

APPARENT U.S. CONSUMPTION AND U.S. MARKET SHARES

Data concerning apparent U.S. consumption of wire rod during 2008‐13 are shown in

table I‐13. U.S. market share data are presented in table I‐14.   

The quantity of apparent U.S. consumption fell from a six‐year high of *** short tons

during 2008 to a six‐year low of *** short tons in 2009. Apparent U.S. consumption generally

increased thereafter to 5.3 million short tons in 2013. The U.S. producers’ share of apparent

U.S. consumption, which fluctuated between *** and *** percent during 2008‐13, was at a six‐

year low during 2013. The share of U.S. consumption held by subject imports from Mexico

fluctuated during 2008‐13, but remained below *** percent in all annual periods. There were

no reported U.S. imports from Brazil, Indonesia, Moldova, or Ukraine during 2008‐13. There

were U.S. imports of wire rod from Trinidad & Tobago only during 2008. These imports

accounted for *** percent of apparent U.S. consumption in that year.

MERCHANT MARKET APPARENT U.S. CONSUMPTION AND U.S. MARKET SHARES

Data concerning merchant market apparent U.S. consumption of wire rod during 2008‐

13 are shown in table I‐15. U.S. merchant market share data are presented in table I‐16.95

The quantity of merchant market apparent U.S. consumption fell from a six‐year high of

*** short tons during 2008 to a six‐year low of *** short tons in 2009. Merchant market

apparent U.S. consumption generally increased thereafter to *** short tons in 2013. The U.S.

producers’ share of merchant market apparent U.S. consumption, which fluctuated between

*** and *** percent during 2008‐13, was at a six‐year low during 2013. The share of merchant

market U.S. consumption held by subject imports from Mexico fluctuated during 2008‐13, but

remained at or below *** percent in all annual periods. Imports from Trinidad & Tobago during

2008 accounted for *** percent of merchant market apparent U.S. consumption in that year.

                                                            

95 Merchant market apparent consumption does not include internal consumption and transfers to

related firms by U.S. producers.
I‐42

Table I-13 

Wire rod: U.S. shipments of domestic product, U.S. imports, and apparent U.S. consumption, 

2008-13

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

Quantity (short tons) 

U.S. producers' U.S. shipments 4,050,961 2,833,426 3,340,954 3,876,145 3,809,728 3,599,459

Imports from-- 

 Brazil 0 0 0 0 0 0

 Indonesia 0 0 0 0 0 0

 Mexico *** *** *** *** *** 10,333

 Moldova 0 0 0 0 0 0

 Trinidad & Tobago 21,794 0 0 0 0 0

 Ukraine 0 0 0 0 0 0

 Subtotal, subject *** *** *** *** *** 10,333

 1080 tire cord/tire bead from 

 subject sources 139,459 71,759 129,184 116,513 102,517 96,639

 All other sources1 1,536,768 777,083 1,284,771 1,059,512 1,391,895 1,593,718

 Subtotal, nonsubject 1,676,227 848,842 1,413,955 1,176,024 1,494,413 1,690,357

Total U.S. imports *** *** *** *** *** 1,700,690

Apparent U.S. consumption *** *** *** *** *** 5,300,149

Value (1,000 dollars) 

U.S. producers' U.S. shipments 3,485,005 1,651,451 2,246,759 3,012,054 2,826,974 2,529,487

Imports from-- 

 Brazil 0 0 0 0 0 0

 Indonesia 0 0 0 0 0 0

 Mexico *** *** *** *** *** 6,128

 Moldova 0 0 0 0 0 0

 Trinidad & Tobago 14,298 0 0 0 0 0

 Ukraine 0 0 0 0 0 0

 Subtotal, subject *** *** *** *** *** 6,128

 1080 tire cord/tire bead from 

 subject sources 126,654 50,808 91,621 103,073 84,521 64,506

 All other sources1 1,360,431 550,614 988,457 992,791 1,159,903 1,156,290

 Subtotal, nonsubject 1,487,085 601,423 1,080,078 1,095,863 1,244,424 1,220,797

Total U.S. imports *** *** *** *** *** 1,226,925

Apparent U.S. consumption *** *** *** *** *** 3,756,412

1

 The data presented are overstated by imports of wire rod of less than 5mm in diameter imported from 

Canada. ***. 

Source: Compiled from data submitted in response to Commission questionnaires. 
I‐43

Table I-14 

Wire rod: U.S. consumption and market shares, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

Quantity (short tons) 

Apparent U.S. 

consumption *** *** *** *** *** 5,300,149

Share of quantity (percent) 

U.S. producers' U.S. 

shipments *** *** *** *** *** 67.9

Imports from-- 

 Brazil 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

 Mexico *** *** *** *** *** 0.2

 Moldova 0.0 0.0 0.0 0.0 0.0 0.0

 Trinidad & Tobago *** 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 *** *** *** *** *** 0.2

 1080 tire cord/tire bead 

from 

 subject sources *** *** *** *** *** 1.8

 All other sources *** *** *** *** *** 30.1

 Subtotal, nonsubject *** *** *** *** *** 31.9

Total U.S. imports *** *** *** *** *** 32.1

Value (1,000 dollars) 

Apparent U.S. 

consumption *** *** *** *** *** 3,756,412

Share of value (percent) 

U.S. producers' U.S. 

shipments *** *** *** *** *** 67.3

Imports from-- 

 Brazil 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

 Mexico *** *** *** *** *** 0.2

 Moldova 0.0 0.0 0.0 0.0 0.0 0.0

 Trinidad & Tobago *** 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 *** *** *** *** *** 0.2

 1080 tire cord/tire bead 

from 

 subject sources *** *** *** *** *** 1.7

 All other sources *** *** *** *** *** 30.8

 Subtotal, nonsubject *** *** *** *** *** 32.5

Total U.S. imports *** *** *** *** *** 32.7

Source: Compiled from data submitted in response to Commission questionnaires. 
I‐44

Table I-15 

Wire rod: U.S. merchant market shipments of domestic product, U.S. imports, and merchant 

market apparent U.S. consumption, 2008-13 

*                    *                    *                    *                    *                    *                    *

Table I-16 

Wire rod: Merchant market U.S. consumption and market shares, 2008-13 

*                    *                    *                    *                    *                    *                    *
II‐1

PART II: CONDITIONS OF COMPETITION IN THE U.S. MARKET

U.S. MARKET CHARACTERISTICS

U.S. producers and importers typically sell wire rod directly to wire drawing firms and/or

produce and sell wire or wire products. Internal consumption and transfers to related firms

accounted for more than one‐quarter of U.S. producers’ U.S. shipments of domestically

produced wire rod in 2013.  U.S. shipments of domestically produced wire rod, in turn,

accounted for 67.9 percent of apparent U.S. consumption in 2013. Imports from the subject

countries were limited and accounted for 0.2 percent of the total U.S. market in 2013; and

imports from nonsubject countries (as well as grade 1080 tire bead and tire cord wire rod from

subject countries) accounted for 31.9 percent.1

Wire rod is used primarily in construction, automotive, energy, and agriculture

industries as a variety of downstream products. In the U.S. market, carbon quality wire rod is

most commonly consumed. As shown in figure II‐1, high and medium‐high carbon industrial

and standard quality wire rod and low and medium‐low carbon industrial and standard quality

wire rod accounted for more than three‐fourths U.S. producers’ U.S. shipments of wire rod

during 2013.2 Similarly, the majority of purchasers reported buying low and medium‐low

carbon industrial and standard quality rods.

Figure II-1 

Wire rod: U.S. producers’ U.S. shipments, by type, 2013 

* * * * * * *

CHANNELS OF DISTRIBUTION

The majority of wire rod sold in the United States is shipped to end users. U.S. producers

and importers of product from Trinidad & Tobago and nonsubject countries sold mainly to end

users while importers of wire rod from Mexico sold to end users in 2008‐09, to distributors in

2010‐11 and then split between both channels in 2012‐13 as shown in table II‐1.

 

1 U.S. shipments of wire rod imported from Mexico were sold in small quantities during each year

between 2008 and 2013; U.S. shipments of wire rod imported from Trinidad & Tobago were sold in

2008. There were no imports from Brazil, Indonesia, Moldova, and Ukraine during 2008‐13. 2 Ten U.S. producers and two importers of subject product from Mexico reported their U.S.

shipments by type of wire rod in 2013.  
II‐2

Table II-1 

Wire rod: U.S. producers’ and importers’ share of reported U.S. shipments, by sources and 

channels of distribution, 2008-20131

Item Calendar year 

 2008 2009 2010 2011 2012 2013 

Share of quantity (percent) 

U.S. producers' U.S. shipments to: 

 Distributors 12.3 7.3 4.4 12.0 13.3 13.1

 End users 87.7 92.7 95.6 88.0 86.7 86.9

U.S. importers' U.S. shipments of imports 

from Mexico to: 

 Distributors *** *** *** *** *** ***

 End users *** *** *** *** *** ***

U.S. importers' U.S. shipments of imports 

from Trinidad & Tobago to: 

 Distributors *** *** *** *** *** ***

 End users *** *** *** *** *** ***

U.S. importers' U.S. shipments of imports 

from all other sources to: 

 Distributors *** *** *** *** *** ***

 End users *** *** *** *** *** ***

1

 There were no subject imports from Brazil, Indonesia, Moldova, and Ukraine between 2008 and 2013. 

Source: Compiled from data submitted in response to Commission questionnaires. 

GEOGRAPHIC DISTRIBUTION

U.S. producers and importers from Mexico reported selling wire rod to all regions in the

contiguous United States (table II‐2). Five of the 10 responding producers and one of four

responding importers from Mexico reported selling nationwide. The sole responding importer

of wire rod from Trinidad & Tobago reported that it only sold to markets ***. The majority of

U.S. producers’ sales (79.2 percent) were shipped between 101 and 1,000 miles, 13.7 percent

was shipped within 100 miles of their production facility, and 7.2 percent was shipped over

1,000 miles. Importers of wire rod from Mexico shipped the majority of their product (***

percent) over 1,000 miles and the remaining *** percent was shipped between 101 and 1,000

miles. The importer of wire rod from Trinidad & Tobago reported that *** percent of its sales

were shipped *** from its firm’s U.S. point of shipment.
II‐3

Table II-2 

Wire rod: Geographic market areas in the United States served by U.S. producers and importers, 

by number of responding firms 

Region U.S. producers 

Importers of product 

from Mexico 

Importers of product from 

Trinidad & Tobago 

Northeast 9 1 *** 

Midwest 10 1 *** 

Southeast 9 2 *** 

Central Southwest 8 2 *** 

Mountain 7 1 *** 

Pacific Coast 7 3 *** 

Other1

1 0 *** 

1

 All other U.S. markets, including AK, HI, PR, and VI, among others. 

Source: Compiled from data submitted in response to Commission questionnaires.

SUPPLY AND DEMAND CONSIDERATIONS

U.S. supply

Domestic production

Based on available information, U.S. producers of wire rod have the ability to respond to

changes in demand with moderate changes in the quantity of shipments of U.S.‐produced wire

rod to the U.S. market. The main contributing factors to this degree of responsiveness of supply

are the availability of unused capacity and the ability to produce alternative products; however,

other factors such as insufficient export markets and low levels of inventories tend to moderate

this degree of responsiveness.  

Industry capacity

Domestic capacity utilization decreased irregularly from 73.1 percent in 2008 to 72.0

percent in 2013. Domestic capacity decreased by 8.5 percent and U.S. production fell by 9.9

percent from 2008 to 2013. This relatively moderate level of capacity utilization suggests that

U.S. producers may have moderate excess capacity to increase production of product in

response to an increase in prices.

Alternative markets

U.S. producers’ exports, as a share of total shipments, did not exceed 1.4 percent

between 2008 and 2013. U.S. producers’ export shipments declined from 1.0 percent in 2008 to

0.7 percent in 2013 indicating that U.S. producers may have limited ability to shift shipments

between the U.S. market and other markets in response to price changes. Three U.S. producers

stated that it would be difficult to shift their shipments to other markets. U.S. producers

reported tariff barriers to trade in other markets, specifically in Argentina, Brazil, and Honduras.
II‐4

Internal consumption and transfers to related firms

U.S. producers’ internal consumption increased from *** percent of total shipments in

2008 to *** percent in 2013. Their transfers to related firms increased from *** percent of

total shipments in 2008 to *** percent in 2013.

Inventory levels

U.S. producers’ inventories increased from 5.7 percent of total shipments in 2008 to 7.4

percent in 2013. These inventory levels suggest that U.S. producers may have some ability to

respond to changes in demand with changes in the quantity shipped from inventories.

Production alternatives

Nine of ten responding U.S. producers stated that they could switch production from

wire rod to other products. Other products that producers reportedly produce on the same

equipment as wire rod are concrete reinforcing bar (rebar) and other nonsubject bar and rod

products. The relatively large volume of these other products produced on shared equipment

increases domestic producers’ ability to switch production to wire rod.

Changes in supply

Six of 10 U.S. producers, 9 of 20 importers, and 17 of 32 responding purchasers reported

changes that affected U.S. supply since 2008. The majority of firms noted the fluctuating U.S.

capacity due to plant closures in 2009 (Gerdau’s mill in Perth Amboy, New Jersey and

ArcelorMittal's plant in Georgetown, South Carolina), the re‐opening of mills in 2011

(ArcelorMittal's plant in Georgetown, South Carolina), and the added capacity of Nucor’s plant

in Darlington, South Carolina in 2013.3 Other changes include: increased cost for raw material

inputs and energy, increased transportation costs and delivery times, and increased imports of

Chinese product.  

Supply constraints

The majority of purchasers reported that they experienced no supply constraints.

However, 10 of 35 of responding purchasers reported issues with supply from about one‐half of

U.S. producers, particularly during 2011. Several purchasers reported that there was a lack of

domestic capacity that resulted in delays in delivery times during 2011.4 Thee purchasers, ***,

***, and ***, reported sporadic allocation issues with several U.S. producers including:

ArcelorMittal USA, Charter, Evraz, Georgetown, Gerdau, Keystone, Nucor, and Sterling Steel.

Additionally, *** reported that several mills (Charter, Evraz, Georgetown, Gerdau, Keystone,

 

3 According to Gerdau, the Perth Amboy facility could be brought back on line if demand warranted.

Hearing transcript, p. 78 (Kerkvliet); Domestic producers’ posthearing brief, p. 2. 4 For example, ***. ***. ***.
II‐5

and Nucor) were unable to produce the grade and quality it required. *** reported that Gerdau

was unable to supply normal quantities of wire rod during the first half of 2013 due to “major

software implementation.”5

  

However, according to U.S. producers, the delays in shipments occurred due to limited

regional availability of the product which entails longer domestic shipping times into a specific

local region. However, U.S. producers stated that the domestic industry, as a whole, has

sufficient capacity to supply U.S. demand.6 According to Nucor, “Any reported supply

constraints reflect isolated incidents at individual mills, rather than the domestic industry's

ability to supply the U.S. market as a whole.”7

  

Supply of subject imports

The sensitivity of supply of wire rod imports from Brazil, Indonesia, Mexico, Moldova,

Trinidad & Tobago, and Ukraine to changes in price in the U.S. market depends upon such

factors as the existence of excess capacity, the levels of inventories, and the existence of export

markets. The Commission received no questionnaire responses from Moldovan suppliers in

these reviews. Relevant information for Brazil, Indonesia, Mexico, Trinidad & Tobago, and

Ukraine follows.

 

5 According to Gerdau, ***. Domestic producers’ posthearing brief, exhibit 1, p. 38.

6 Hearing transcript, pp. 86‐87 (Nystrom and Ashby). 7 Nucor stated that it has always been able to fulfill its customers’ demands. Nucor’s posthearing

brief, exhibit 1, p. 4‐5.  
II‐6

Subject imports from Brazil

The Commission received one questionnaire response from Brazilian producer of wire

rod, ArcelorMittal Brasil.8 Based on available information, ArcelorMittal Brasil has the ability to

respond to changes in demand with small‐to‐moderate changes in the quantity of shipments of

wire rod to the U.S. market. The main contributing factors to this degree of responsiveness of

supply are the ability to produce alternative products and the existence of alternate markets;

however, other factors such as the levels of unutilized capacity and inventories tend to

moderate this degree of responsiveness.  

Industry capacity

Reported capacity remained constant at *** short tons during 2008‐13. ArcelorMittal

Brasil’s reported capacity utilization decreased from *** percent in 2008 to *** percent in

2013.

Alternative markets

ArcelorMittal Brasil reported that *** of its shipments were either shipped to its home

market or were consumed internally (figure II‐2). Its total exports, as a share of total shipments,

declined from *** percent in 2008 to *** percent in 2013. ArcelorMittal Brasil exported

primarily to countries ***; there were no reported exports to the United States during 2008‐13.

It reported that ***. The main reasons included: ***.

Figure II-2 

Wire rod: Shares of total shipments of wire rod by Brazilian producer, by destination, 2008-13 

* * * * * * *

Inventory levels

ArcelorMittal Brasil’s inventories, relative to total shipments, increased from ***

percent in 2008 to *** percent in 2013.

Production alternatives

ArcelorMittal Brasil reported that it produces *** on the same equipment and

machinery used to produce wire rod. It reported that its production ***.  

 

8 According to ***, ArcelorMittal Brasil accounted for *** percent of total wire rod rolling capacity in

Brazil during 2013.
II‐7

Subject imports from Indonesia

The Commission received one questionnaire response from Indonesian producer of wire

rod, Ispat Indo.9 Based on available information, Ispat Indo has the ability to respond to

changes in demand with moderate changes in the quantity of shipments of wire rod to the U.S.

market. The main contributing factors to this degree of responsiveness of supply are the

availability of unused capacity and the existence of alternate markets; however, other factors

such as low levels of inventories and the inability to produce alternate products tend to

moderate this degree of responsiveness.

Industry capacity

Reported capacity remained constant at *** short tons during 2008‐13. Ispat Indo’s

reported capacity utilization decreased from *** percent in 2008 to *** percent in 2013.

Alternative markets

Ispat Indo reported that *** of its shipments were shipped to its home market (figure II‐

3). Its total exports, as a share of total shipments, declined from *** percent in 2008 to ***

percent in 2013. Ispat Indo exported *** to Asia; there were no reported exports to the United

States during 2008‐13. It reported that ***. It reported that ***.

Figure II-3 

Wire rod: Shares of total shipments of wire rod by Indonesian producer, by destination, 2008-13 

* * * * * * *

Inventory levels

Ispat Indo’s inventories, as a share of total shipments, decreased from *** percent in

2008 to *** percent in 2013.

Production alternatives

Ispat Indo reported that it does not produce other products on the same equipment and

machinery used to produce wire rod.  

 

9 According to ***, Ispat Indo accounted for *** percent of total wire rod rolling capacity in

Indonesia during 2013.
II‐8

Subject imports from Mexico

The Commission received three questionnaire responses from Mexican producers of

wire rod.10 Based on available information, producers of wire rod from Mexico have the ability

to respond to changes in demand with moderate‐to large changes in the quantity of shipments

of wire rod to the U.S. market. The main contributing factors to this degree of responsiveness

of supply are the existence of alternate markets; the ability to produce alternate products, and

some unused capacity; and however, low levels of inventories tend to moderate this degree of

responsiveness.

Industry capacity

Mexican producers’ capacity utilization fluctuated during 2008‐13, increasing from 88.5

percent in 2008 to 98.1 percent in 2011 before falling to 85.0 percent in 2013. Reported

capacity increased from 2.4 million short tons in 2008 to 2.8 million short tons in 2013.  

Alternative markets

Mexican producers reported that *** of their shipments was either shipped to its home

market or was consumed internally (figure II‐4). Their total exports, as a share of total

shipments, increased from *** percent in 2008 to 16.0 percent in 2013. Mexican producers

exported primarily to ***.  Mexican producers Deacero and Ternium both reported that ***.

Deacero also stated that ***. ArcelorMittal Las Truchas reported that ***.

Figure II-4 

Wire rod: Shares of total shipments of wire rod by Mexican producers, by destination, 2008-13 

* * * * * * * 

Inventory levels

Mexican producers’ inventories, as a share of total shipments, fluctuated during 2008‐

13, increasing from 5.5 percent in 2008 to 7.6 percent in 2012 before falling to 6.7 percent in

2013.

Production alternatives

All three Mexican producers reported that they produce other products on the same

equipment and machinery used to produce wire rod. Mexican producer Ternium reported ***.  

 

10 According to hearing testimony, these three producers are the principal wire rod producers in

Mexico. Hearing transcript, p. 153 (Campbell). See Part IV for more information.
II‐9

Subject imports from Trinidad & Tobago

The Commission received one questionnaire response from Trinidad & Tobago

producer, ArcelorMittal Point Lisas.11 Based on available information, this producer of wire rod

from Trinidad & Tobago has the ability to respond to changes in demand with large changes in

the quantity of shipments of wire rod to the U.S. market. The main contributing factors to this

degree of responsiveness of supply are the levels of unutilized capacity and inventories,

existence of alternate markets, and the ability to produce alternate products.

Industry capacity

ArcelorMittal Point Lisas’ capacity remained constant at *** short tons during 2008‐13.

Its capacity utilization fluctuated during 2008‐13, increasing from *** percent in 2008 to ***

percent in 2011 before falling to *** percent in 2013.  

Alternative markets

ArcelorMittal Point Lisas reported that *** of its shipments were exported, with ***

percent of its shipments wire rod sold in its home market (figure II‐5). Its total exports, as a

share of total shipments, increased from *** percent in 2008 to *** percent in 2011 before

falling to *** percent in 2013. ArcelorMittal Point Lisas exported primarily to ***. It reported

that ***.

Figure II-5 

Wire rod: Shares of total shipments of wire rod by Trinidad & Tobago producer, by destination, 

2008-13 

* * * * * * *

Inventory levels

ArcelorMittal Point Lisas’ inventories, as a share of total shipments, increased from ***

percent in 2008 to *** percent in 2011 before falling to *** percent in 2013.

Production alternatives

ArcelorMittal Point Lisas reported that it produces *** using the same machinery and

equipment it uses to produce wire rod. It reported that ***.

 

11 ArcelorMittal Point Lisas accounted for all known production of wire rod in Trinidad & Tobago

during 2008‐13.
II‐10

Subject imports from Ukraine

The Commission received two questionnaire responses from Ukrainian producers of

wire rod.12 Based on available information, producers of wire rod from Ukraine have the ability

to respond to changes in demand with large changes in the quantity of shipments of wire rod to

the U.S. market. The main contributing factors to this degree of responsiveness of supply are

the availability of unused capacity, the existence of alternate markets, and the ability to

produce alternate products; however, low levels of inventories tend to moderate this degree of

responsiveness.

Industry capacity

Ukrainian producers’ capacity utilization fluctuated during 2008‐13, increasing from ***

percent in 2008 to *** percent in 2010 before falling to *** percent in 2013. Reported capacity

increased from *** short tons in 2008 to *** short tons in 2013.  

Alternative markets

Ukrainian producers reported that *** of their shipments were exported (figure II‐6).

Their total exports, as a share of total shipments, increased from *** percent in 2008 to ***

percent in 2010 before falling to *** percent in 2013. Ukrainian producers did not export to the

United States during 2008‐13. ArcelorMittal Kryvyi Rih reported that ***. Ukrainian producer

Yenakiieve Steel reported that ***. It also noted that ***.

Figure II-6 

Wire rod: Shares of total shipments of wire rod by Ukrainian producers, by destination, 2008-13 

* * * * * * *

Inventory levels

Ukrainian producers’ inventories, as a share of total shipments, increased *** from ***

percent in 2008 to *** percent in 2013.

Production alternatives

Both Ukrainian producers reported that ***. ArcelorMittal Kryvyi Rih reported that ***.

Yenakiieve Steel reported that ***.

 

12 According to ***, the two Ukrainian producers (ArcelorMittal Kryvyi Rih and Yenakiieve Iron and

Steel Works) accounted for *** in Ukraine in 2013.
II‐11

Nonsubject imports

The largest sources of nonsubject imports during 2008‐13 were China, Canada, and

Japan. Combined, these countries accounted for 80.3 percent of nonsubject imports in 2013.

New suppliers

Seventeen of 36 purchasers reported new suppliers including, Nucor Steel’s new mill in

Darlington, South Carolina and Kingman, Arizona; Beitai Steel (China); Duferco (nonsubject

importer); Samsung Steel; Metal One; and Tangshan (China). Eighteen of 34 purchasers

anticipate new suppliers to enter into the market, with several of the purchasers noting an

increase of suppliers from China.

U.S. demand

Based on available information, the overall demand for wire rod is likely to experience

moderate changes in response to changes in price. The main contributing factors are the lack of

substitute products, which reduces responsiveness, and the large cost share of wire rod in most

of its end‐use products which increases the potential to import downstream products, thus

increasing demands’ responsiveness to price changes.

End uses

U.S. demand for wire rod depends on the demand for a variety of U.S.‐produced

downstream products. Reported end uses include fasteners, wire garment hangers, wire mesh,

nails, concrete reinforcing mesh, baling wire, industrial wire, tire cord/bead, shelving wire, sod

staples, suspension springs, and PC strand. All ten responding U.S. producers, 20 of 21

responding importers, 29 of 36 purchasers, and all 8 responding foreign producers reported no

changes in end uses. A few firms noted an increase in wire rod consumption in certain

applications, particularly the automotive sector.  

Business cycles

Short‐term demand for wire rod tends to be cyclical and follow trends in the

construction industry. Five of ten U.S. producers, 6 of 23 importers, and 17 of 32 purchasers

indicated that the market was subject to business cycles. Several firms noted that demand for

wire rod is driven by downstream products used in the automotive and construction industry

which is seasonal. Several firms noted that demand tends to fall in the winter when

construction slows down.  

The majority of firms (5 of 6 producers, 17 of 20 importers, and 15 of 27 purchasers)

reported that wire rod is not subject to distinct conditions of competition. However, several

firms noted that they must compete with foreign producers of finished wire products. Other

firms noted the volume of U.S. imports of wire rod, particularly the increasing imports of wire

rod from China.
II‐12

Five of 8 producers, 2 of 10 importers, and 14 of 19 purchasers reported that there have

been changes to business cycles and/or conditions of competition since 2008. Three producers

and 5 purchasers stated that the market has not recovered from the economic recession and

the recovery of the construction industry has been slow. Two producers and one purchaser

reported that conditions of competition have changed due to the growing imports of wire rod

from China. One purchaser noted the consolidation of mills, as well as the new production or

expansion of existing production capacity has changed the condition of competition since 2008.

One producer (***) reported that there are now shorter lead times for customers to place

orders, averaging 30‐33 day rolling schedule.

Apparent U.S. consumption

Apparent U.S. consumption of wire rod fluctuated during 2008‐13, falling in 2009 during

the general economic recession and then slowly beginning to recover during 2010‐13. Overall,

apparent U.S. consumption in 2013 was *** percent lower than in 2008.

Demand trends

Table II‐3 presents firm responses regarding U.S. demand for wire rod since 2008. While

firm responses in table II‐3 are varied, the majority of firms described similar trends and factors

in their narrative responses. The majority of producers and importers noted the financial

recession and its negative effect on demand for wire rod, particularly in the construction

industry. Four producers and five importers reported that while demand has improved since

the recession, demand has not returned to pre‐recession levels.  Several importers reported an

improved and increased demand for wire rod in residential and commercial construction, and

the automotive market. The majority of purchasers attributed an increased or fluctuated

demand to the financial recession and a slowly recovering market. Several purchasers noted

that demand in the construction market has recovered slightly but has still not reached 2008

levels. Three purchasers reported that demand for wire rod has decreased in the United States

because firms have moved to importing finished products versus producing the finished good

that uses wire rod domestically. A plurality of firms expect demand to increase over the next

two years. In their narrative responses, the majority of firms reported that they anticipate

demand for wire rod to continue to slowly increase, particularly in automotive markets and

construction.  
II‐13

Table II-3 

Wire rod: Firms’ responses regarding U.S. demand, by number of responding firms 

Item 

Number of firms reporting 

Increase No change Decrease Fluctuate 

Demand inside the United States since 2008:

 U.S. producers 0 2 8 0 

Importers 7 5 6 5 

Purchasers 9 1 13 11 

Foreign producers 0 2 3 1 

Anticipated demand inside the United States: 

 U.S. producers 4 2 1 3 

Importers 7 8 2 7 

Purchasers 13 2 5 13 

Foreign producers 5 1 0 1 

Demand for purchasers' final products since 2008:

 Purchasers 11 1 8 15 

Source: Compiled from data submitted in response to Commission questionnaires.

Substitute products

Substitutes for wire rod are very limited. All U.S. producers, the majority of importers

(21 of 23) and purchasers (31 of 35), and all foreign producers (8) reported that there were no

substitutes and did not anticipate any future changes in substitutes.13 Two importers and four

purchasers identified substitutes for wire rod.14 *** reported that rebar can be substituted for

wire rod in concrete reinforcement. *** reported that aluminum and welding can be used in

place of wire rod for fastening components. *** reported that plastic and glass can be

substituted for wire rod in refrigerator shelves and stamped steel can be substituted in HVAC

screens. *** reported that plastic strapping and twine can be used in place of wire rod for tying

up bales of materials to be recycled as well as tying up finished goods for shipping. ***

reported that synthetics can be substituted for wire rod for static load suspenders. All three

 

13 Purchasers were asked if smaller diameter wire rod (4.75 mm) was interchangeable with wire rod

with a diameter of 5.00 mm or greater. Twenty‐one of 35 responding purchasers reported that smaller

diameter wire rod was interchangeable with wire rod. Purchasers reported that they use smaller wire

rod in the following applications: nails, bailing wire, multiple fencing applications, and wire mesh

products. One purchaser, ***, reported that using the smaller diameter wire rod has reduced its

production costs because the 4.75 mm rod takes less draft (or die) to reduce the same wire gauge as

when using 5.550 mm wire rod thereby increasing the speed of production; it reported that using less

dies results in decreased electricity as well as lubricant.   14 While not a direct substitute, *** reported that imported finished products was a substitute for

wire rod used in manufacturing domestically produced products. It reported that the price of imported

finished products (fasteners) has an effect on its wire rod purchasing decisions. It stated that is has to

purchase at a highly competitive price in order to stay competitive, as a manufacturer, with fasteners

coming in from China.
II‐14

purchasers reported that changes in price of these substitutes do not affect the price for wire

rod.  

The majority of firms (all 10 producers, 25 of 26 importers, 30 of 33 purchasers, and all 8

foreign producers) reported that there have not been changes in substitutes since 2008.

Additionally, the majority of U.S. producers (all 10), importers (24 of 26), purchasers (28 of 31),

and foreign producers (all 8) reported that they do not anticipate new substitutes in the near

future. However, one importer and three purchasers reported that there have been changes in

substitutes since 2008 and that they anticipate new substitutes. *** reported that due to

weight restrictions based on improved vehicle efficiencies, customers are looking to reduce the

weight of parts while maintaining strength, therefore, suggesting that new substitutes will be

created to replace wire rod. *** reported that there has been advancement in  

the use of carbon fiber, rubber belting, and synthetics as substitutes for wire rod and ***

identified plastics for bail ties.  

Cost share

Wire rod accounts for a large share of the cost of the end‐use products in which it is

used, although cost shares vary widely due to the wide range of products that use wire rod.

Eight producers, six importers and 35 purchasers reported the cost share of wire rod in final

products which ranged from 29 percent to 100 percent. Wire rod accounted for 60 percent or

greater of the total cost in 83 of the 104 final products reported by firms. Cost share

information for products most commonly reported by firms include:  

 40 to 90 percent of the cost of various types of wire

 60 to 90 percent of the cost of various meshes

 45 to 85 percent of the cost of nails, staples, and fasteners

 60 to 80 percent of the cost of chain link and barbed wire for fencing

 33 to 60 percent of the cost of tire cord/tire bead

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported wire rod depends upon

such factors as relative prices, quality (e.g., grade standards, reliability of supply, defect rates,

etc.), and conditions of sale (e.g., price discounts/rebates, lead times between order and

delivery dates, payment terms, product services, etc.). Based on available information, staff

believes that where there are identical forms of wire rod, there is usually a high degree of

substitutability between domestically produced wire rod and wire rod imported from subject

sources. For common types of wire rod (such as industrial or standard quality), product typically

will be highly substitutable with other product of the same specification even when the

products are not identical, although there may be a need for retooling of the process to adjust

to small differences. For specialty grades, however, not all sources can produce each product,
II‐15

and even differences between wire rod with the same specifications from different sources may

limit the degree of substitution.15

Lead times

Wire rod is primarily produced‐to‐order. U.S. producers reported that 97.0 percent of

their commercial shipments were produced‐to‐order, with lead times averaging 20‐45 days.

The remaining 3.0 percent of domestic producers’ commercial shipments came from

inventories, with lead times averaging 3‐7 days. Mexican importer *** reported that *** of its

commercial shipments were produced‐to‐order, with lead times averaging *** days. Mexican

importer *** reported that *** percent of its commercial shipments were produced‐to‐order,

with lead times averaging *** days; the remaining *** percent of its commercial shipments

came from inventories, with lead times averaging *** days.

Knowledge of country sources

Thirty‐five purchasers indicated they had marketing/pricing knowledge of domestic

product, 15 of Mexican product, 5 of Brazilian product, 1 of Indonesian product, and 24 of

nonsubject countries. No purchasers reported marketing/pricing knowledge of product from

Moldova, Trinidad & Tobago, and Ukraine.

As shown in table II‐4, most purchasers and their customers never make purchasing

decisions based on the country of origin. Many purchasers reported that they always or usually

make purchasing decisions based on the producer; however, the majority of purchasers

reported that their customers do not make purchasing decisions based on the producer. Of the

17 purchasers that reported that they always or usually make decisions based the

manufacturer, 11 firms cited quality; other reasons cited include availability, price, supplier

reliability, and transportation costs.

 

15 Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Germany, Indonesia, Mexico,

Moldova, Trinidad and Tobago, Turkey, and Ukraine: Investigation Nos. 701‐TA‐417 and 731‐TA‐953,

954, 957‐959, 961, and 962 (Review), USITC Publication 4014, June 2008, p. II‐11.
II‐16

Table II-4 

Wire rod: Purchasing decisions based on producer and country of origin, by number of reporting 

firms 

Purchaser/customer decision Always Usually Sometimes Never 

Purchaser makes decision based on producer 8 9 12 8 

Purchaser’s customers make decision based on producer 1 1 15 17 

Purchaser makes decision based on country 3 4 16 12 

Purchaser’s customers make decision based on country 0 2 16 16 

Source: Compiled from data submitted in response to Commission questionnaires. 

Factors affecting purchasing decisions

The most often cited top three factors firms consider in their purchasing decisions for

wire rod were quality (33 firms), price (30 firms), and availability (16 firms) as shown in table II‐

5. Quality was the most frequently cited first most important factor (cited by 14 firms), followed

by price (12 firms); quality was the most frequently reported second most important factor (16

firms); and price and availability were the most frequently reported third most important factor

(10 firms).  

Table II-5 

Wire rod: Ranking of factors used in purchasing decisions as reported by U.S. purchasers, by 

number of reporting firms 

Factor First Second Third Total 

Quality 14 16 3 33 

Price 12 8 10 30 

Availability 1 5 10 16 

Other1 9 7 13 29 

1

 Other factors delivery, payment terms, extension of credit, supplier-customer relationship, total cost, 

traditional supplier for the first factor; supplier reliability, delivery time, product range and product 

specifications for the second factor; and delivery time, supplier relationship, payment terms, product 

range, reliability of supplier, and traditional supplier for the third factor. 

Source: Compiled from data submitted in response to Commission questionnaires. 

Purchasers were asked to identify the factors that determine the quality of wire rod.

Purchasers reported several specific factors including: grade; meeting specifications;

uniformity; chemical properties; tensile strength; surface quality and condition; formability;

drawability; workability;  diameter tolerance; steel purity; packaging; and factors related to the

shape, consistent dimensions, size tolerance, and roundness. More generally, purchasers

sought minimal problems when manufacturing which included minimal breakage and welds as

expected. According to purchaser ***, “Carbon and alloy steel wire rod is not a homogenous

product. The end uses of wire rod vary greatly. The technical requirements for the different
II‐17

types of wire rod vary greatly. This variation in technical and quality requirements is most

significant in the specialty value added products such as welding quality wire rod.”16

The majority of purchasers (24 of 36) reported that they “usually” purchase the lowest‐

priced product for their purchases, 12 reported “sometimes”, 1 reported “always” and 1

reported “never”. When asked if they purchased wire rod from one source although a  

comparable product was available at a lower price from another source, 23 purchasers

reported reasons including quality and consistency of product, payment terms, shorter lead

times, delivery reliability, product availability, low minimum order requirements, technical

service, product specifications, use of long‐term contracts, supplier loyalty, and length of time

to fill order. Fourteen of 34 responding purchasers reported that certain types of product were

only available from a single source.17 One purchaser (***) reported that 50 percent of its

proprietary specifications are currently not produced in the United States. One purchaser (***)

stated that the C1090 5.5 mm wire rod is only available from Japanese and German producers.

Importance of specified purchase factors

Purchasers were asked to rate the importance of 15 factors in their purchasing decisions

(table II‐6). The factors rates as “very important” by more than half of responding purchasers

were price (36), availability (34), product consistency (33), delivery time (30), reliability of

supply (30), quality meets industry standards (29), U.S. transportation costs (25), and delivery

terms (20).  

Table II-6 

Wire rod: 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 

Delivery terms 20 14 2 

Delivery time 30 5 1 

Discounts offered 7 24 5 

Extension of credit 13 17 6 

Minimum quantity requirements 6 17 13 

Packaging 15 18 4 

Price 36 1 0 

Product consistency 33 4 0 

Product range 7 25 5 

Quality exceeds industry standards 10 18 8 

Quality meets industry standards 29 6 1 

Reliability of supply 30 6 0 

Technical support/service 14 19 4 

U.S. transportation costs 25 10 2 

Source: Compiled from data submitted in response to Commission questionnaires. 

 

16 Purchaser questionnaire response, section III‐15. 17 Eight of these 14 purchasers noted that the 4.75 mm wire rod is not produced in the United States

and is only available from Canadian and Mexican producers.
II‐18

Supplier certification

Twenty‐nine of 34 responding purchasers require that all of the wire rod they purchase

be certified. Purchasers reported that the time to qualify a new supplier ranged from 30 to 365

days. Twelve of 35 responding purchasers reported that domestic or foreign supplier has failed

in its attempt to qualify product, or had lost its approved status since 2008. Four purchasers

identified domestic suppliers with product quality issues including: Nucor Steel, ArcelorMittal

(U.S.‐based), CMC, Evraz, Gerdau, Keystone, Charter Steel, and Georgetown. Three purchasers

reported that Chinese suppliers have failed to qualify product due to quality issues. According

to ***, it is very difficult for mills to produce wire rod that consistently meets welding quality

standards. It reported that it has tested many suppliers since 2008, of which many have either

never been approved or lost their approved supplier status because of poor performance and

lack of supply. *** stated that approximately 60 percent of the suppliers qualify and 40 percent

do not receive an approved supplier status.  

Changes in purchasing patterns

Purchasers were asked about changes in their purchasing patterns from different

sources since 2008 (table II‐7); reasons reported for changes in sourcing included price,

availability, and product range. Twenty of 34 responding purchasers reported that they had

changed suppliers since 2008. Most purchasers noted the large number of wire rod suppliers

and stated that they change suppliers most often because of price and availability.  

Table II-7 

Wire rod: Changes in purchase patterns from U.S., subject, and nonsubject countries 

Source of purchases 

Did not 

purchase Decreased Increased Constant Fluctuated

United States 1 9 11 5 10 

Brazil 30 0 2 0 2 

Indonesia 33 0 0 0 0 

Mexico 16 10 4 0 5 

Moldova 33 0 0 0 0 

Trinidad & Tobago 31 1 0 0 2 

Ukraine 33 0 0 0 0 

All other sources 7 5 10 7 5 

Source: Compiled from data submitted in response to Commission questionnaires. 

Importance of purchasing domestic product

Purchasing U.S.‐produced product was not an important factor in purchasers’ decisions.

In aggregate, the 34 responding purchasers reported that approximately 80.6 percent of their

total purchases of wire rod in 2013 did not require domestic product. Twenty of 35 responding

purchasers reported that they were required to purchase some domestic product by law or

regulation (e.g., “Buy American” provisions) which accounted for 14.6 percent of total

purchases in 2013; ten purchasers reported that approximately 3.7 percent of total purchases
II‐19

had domestic requirements by customers; and four purchasers reported that approximately 1.2

percent of total purchases in 2013 were required domestic product for other reasons including

specific product requirements or application end‐use.  

Comparisons of domestic products, subject imports, and nonsubject imports

Purchasers were asked a number of questions comparing wire rod produced in the

United States, subject countries, and nonsubject countries. First, purchasers were asked for a

country‐by‐country comparison on the same 15 factors (table II‐8) for which they were asked to

rate the importance. 18

Purchaser responses were sparse except for comparisons between U.S.‐Mexico, U.S.‐

Brazil, and U.S.‐nonsubject countries.  In general, purchasers indicated that U.S. product was

superior in terms of delivery times and technical support in most country comparisons.  When

comparing products from the United States and Brazil, most purchasers reported that U.S.

product was superior to Brazilian product in terms of delivery time and U.S. transportation

costs, and a plurality ranked U.S. superior in availability, delivery terms, technical

support/service. Most U.S. purchasers reported that U.S. product was comparable to product

from Brazil for all other characteristics.  

When comparing products from the United States and Mexico, most purchasers

reported that the products were comparable in the majority of factors. The exceptions to these

were delivery time, wherein a plurality of purchasers reported that the U.S. product was

superior, as well as product range and technical support/service wherein a plurality reported

the products were comparable.  

When comparing domestic product with product imported from nonsubject countries,

most purchasers reported that the products were comparable in most factors. The exceptions

were availability, delivery terms, and technical support, wherein a plurality of purchasers

reported that domestic product was superior. The majority of purchasers reported that

domestic product was superior in terms of delivery times. Additionally, purchasers were split on

price, wherein 12 purchasers reported that the products were comparable in price and 12

purchasers reported that nonsubject prices were lower.  

 

18 Purchasers did not provide country comparisons for the following country pairs: Brazil vs. Moldova;

Brazil vs. Ukraine; Indonesia vs. Mexico; Indonesia vs. Moldova; Indonesia vs. Trinidad & Tobago;

Indonesia vs. Ukraine; Mexico vs. Ukraine; Moldova vs. Ukraine; Trinidad vs. Ukraine; and Ukraine vs.

nonsubject countries.
II‐20

Table II-8 

Wire rod: Purchasers’ comparisons between U.S.-produced and imported product 

Factor 

U.S. vs. Brazil 

U.S. vs. 

Indonesia U.S. vs. Mexico 

U.S. vs. 

Moldova 

S C S S C I S C I S C I 

Availability 3 3 1 3 0 0 8 11 2 1 0 1

Delivery terms 3 2 2 3 0 0 7 12 2 1 1 0

Delivery time 4 1 2 3 0 0 10 9 2 1 0 1

Discounts offered 2 5 0 2 1 0 5 12 4 0 2 0

Extension of credit 1 4 2 2 0 1 1 16 3 0 1 1

Minimum quantity requirements 3 4 0 3 0 0 3 16 1 1 0 1

Packaging 1 5 1 2 1 0 4 16 1 0 2 0

Price1 0 5 1 2 1 0 4 12 5 0 2 0

Product consistency 2 4 1 3 0 0 5 16 0 1 1 0

Product range 2 3 2 2 1 0 6 10 5 0 1 1

Quality exceeds industry 

standards 2 3 2 3 0 0 6 14 0 1 0 1

Quality meets industry 

standards 2 4 1 3 0 0 3 17 0 1 1 0

Reliability of supply 2 4 1 2 1 0 7 13 1 0 1 1

Technical support/service 3 3 1 3 0 0 9 10 2 1 1 0

U.S. transportation costs1 4 3 0 3 0 0 6 12 3 1 1 0

Factor 

U.S. vs. Trinidad 

& Tobago U.S. vs. Ukraine 

U.S. vs. 

nonsubject 

countries 

Brazil vs. 

Indonesia 

 S C I S C I S C I S C I 

Availability 2 2 0 1 0 0 12 10 4 1 0 0

Delivery terms 2 2 0 1 0 0 13 10 3 1 0 0

Delivery time 2 1 1 1 0 0 19 4 3 1 0 0

Discounts offered 0 3 0 0 1 0 3 17 4 0 1 0

Extension of credit 0 3 1 0 0 1 3 19 3 0 1 0

Minimum quantity requirements 2 1 1 1 0 0 8 14 3 0 1 0

Packaging 0 4 0 0 1 0 4 20 1 0 1 0

Price1 0 4 0 0 1 0 1 12 12 0 1 0

Product consistency 1 3 0 1 0 0 3 17 5 1 0 0

Product range 0 4 0 0 1 0 2 20 3 1 0 0

Quality exceeds industry 

standards 1 2 1 1 0 0 3 17 6 1 0 0

Quality meets industry 

standards 1 2 0 1 0 0 2 20 2 0 1 0

Reliability of supply 1 2 1 0 1 0 6 15 4 0 1 0

Technical support/service 2 1 1 1 0 0 13 10 2 0 1 0

U.S. transportation costs1 2 2 0 1 0 0 8 14 3 0 1 0

Table continued on following page.
II‐21

Table II-8--Continued 

Wire rod: Purchasers’ comparisons between U.S.-produced and imported product 

Factor 

Brazil vs. 

Mexico 

Brazil vs. 

Trinidad & 

Tobago 

Brazil vs. 

nonsubject 

countries 

Indonesia vs. 

nonsubject 

countries 

S C I S C I S C I S C I 

Availability 1 3 1 0 1 0 0 4 0 0 0 1

Delivery terms 1 4 0 0 1 0 0 4 0 0 0 1

Delivery time 1 3 1 0 1 0 1 3 0 0 0 1

Discounts offered 1 4 0 0 1 0 1 3 0 0 0 1

Extension of credit 0 5 0 0 1 0 0 4 0 0 0 1

Minimum quantity requirements 0 4 1 0 1 0 0 4 0 0 0 1

Packaging 2 3 0 0 1 0 1 3 0 0 0 1

Price1 0 4 1 0 1 0 0 4 0 0 0 1

Product consistency 3 3 0 0 1 0 0 4 0 0 0 1

Product range 2 3 0 0 1 0 0 4 0 0 0 1

Quality exceeds industry 

standards 3 2 0 0 1 0 0 4 0 0 0 1

Quality meets industry 

standards 1 4 0 0 1 0 0 4 0 0 0 1

Reliability of supply 1 4 0 0 1 0 0 4 0 0 0 1

Technical support/service 2 3 0 0 1 0 0 4 0 0 0 1

U.S. transportation costs1 0 4 1 0 1 0 0 5 0 0 1 0

Factor 

Mexico vs. 

Moldova 

Mexico vs. 

Trinidad & 

Tobago 

Mexico vs. 

nonsubject 

countries 

Moldova vs. 

Trinidad & 

Tobago 

 S C I S C I S C I S C I 

Availability 0 1 0 1 1 0 2 7 3 0 0 1

Delivery terms 0 0 1 1 1 0 2 7 3 0 1 0

Delivery time 1 0 0 1 1 0 4 5 3 0 0 1

Discounts offered 0 0 1 0 2 0 2 9 1 0 1 0

Extension of credit 0 1 0 0 2 0 1 10 1 0 1 0

Minimum quantity requirements 0 1 0 1 1 0 1 10 1 0 0 1

Packaging 0 0 1 0 2 0 2 9 1 0 1 0

Price1 0 1 0 0 2 0 0 7 5 0 1 0

Product consistency 0 0 1 0 2 0 1 10 1 0 1 0

Product range 0 0 1 0 1 0 2 6 3 0 0 1

Quality exceeds industry 

standards 0 0 1 0 2 0 1 8 3 0 0 1

Quality meets industry 

standards 0 1 0 0 1 0 1 8 2 0 1 0

Reliability of supply 0 1 0 1 1 0 2 8 2 0 0 1

Technical support/service 0 0 1 1 1 0 2 9 1 0 1 0

U.S. transportation costs1 0 2 0 1 1 0 3 9 0 0 1 0

Table continued on following page.
II‐22

Table II-8--Continued 

Wire rod: Purchasers’ comparisons between U.S.-produced and imported product 

Factor 

Moldova vs. nonsubject 

countries 

Trinidad & Tobago vs. 

nonsubject countries 

S C I S C I 

Availability 0 0 1 0 2 1

Delivery terms 0 1 0 0 3 0

Delivery time 0 0 1 0 3 0

Discounts offered 0 1 0 0 2 0

Extension of credit 0 1 0 0 3 0

Minimum quantity requirements 0 0 1 0 2 0

Packaging 0 1 0 0 3 0

Price1 0 1 0 0 2 1

Product consistency 0 1 0 0 2 0

Product range 0 0 1 0 2 0

Quality exceeds industry standards 0 0 1 0 2 1

Quality meets industry standards 0 1 0 0 2 0

Reliability of supply 0 1 1 0 1 2

Technical support/service 0 1 0 0 3 0

U.S. transportation costs1 0 1 0 0 3 0

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. 

In order to determine whether U.S.‐produced wire rod can generally be used in the

same applications as imports from subject countries, U.S. producers, importers, and purchasers

were asked whether the products can “always,” “frequently,” “sometimes,” or “never” be used

interchangeably. As shown in table II‐9, most U.S. producers reported that wire rod from all

country pairs was “always” interchangeable and a majority of importers reported that wire rod

from all country pairs was “always” or “frequently” interchangeable. Purchasers were more

divided in their responses. Several firms noted that product interchangeability depends on the

mill, not the country in which the wire rod is produced. The majority of firms reported that the

interchangeability depends on the end application and the quality of wire rod required; low

quality wire rod used in IQ or mesh will tend to be more interchangeable, however, wire rod

used to make cold heading fasteners or tie cord will be more difficult to interchange. Importer

*** noted that for the non‐standard grades of alloy welding rods, there are no U.S mills that

produce the very tight chemistry ranges required, and therefore it sources from the

Netherlands. One purchaser reported that wire rod from Mexico or China often has poor

surface quality with rust. *** reported that wire rod from Moldova and Ukraine is lower in

quality and therefore, low carbon wire rod used for mesh making is the only type that is

interchangeable. *** stated that “Wire rod produced in Mexico can be interchangeable;

however, some grades are not regularly produced in the U.S. and therefore, availability is

limited. Wire rod imported from the other countries that are used to make automotive parts
II‐23

are tested extensively and approved by the automaker for specific parts and performance;

therefore, it has limit interchangeability.”19  

Table II-9 

Wire rod: Interchangeability between wire rod 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 

purchasers reporting 

A F S N A F S N A F S N 

U.S. vs. subject countries: 

 U.S. vs. Brazil 8 1 0 0 2 5 0 0 5 1 3 1

 U.S. vs. Indonesia 8 1 0 0 1 5 1 0 2 1 2 0

 U.S. vs. Mexico 8 1 1 0 1 10 2 0 8 7 7 0

 U.S. vs. Moldova 8 1 0 0 1 3 2 0 2 0 3 0

 U.S. vs. Trinidad & Tobago 8 1 0 0 1 7 1 0 4 2 3 0

 U.S. vs. Ukraine 8 1 0 0 1 4 1 0 2 0 1 0

Subject countries comparisons: 

 Brazil vs. Indonesia 7 1 0 0 1 4 2 0 2 0 3 1

 Brazil vs. Mexico 7 1 0 0 1 5 2 0 2 3 4 1

 Brazil vs. Moldova 7 1 0 0 1 4 1 0 1 0 2 0

 Brazil vs. Trinidad & Tobago 7 1 0 0 1 4 1 0 2 1 2 1

 Brazil vs. Ukraine 7 1 0 0 1 4 1 0 1 0 1 0

 Indonesia vs. Mexico 7 1 0 0 1 5 2 0 3 1 3 0

 Indonesia vs. Moldova 7 1 0 0 1 4 1 0 1 0 2 0

 Indonesia vs. Trinidad & Tobago 7 1 0 0 1 4 1 0 2 1 2 0

 Indonesia vs. Ukraine 7 1 0 0 1 4 1 0 1 0 1 0

 Mexico vs. Moldova 7 1 0 0 1 5 1 0 1 0 2 0

 Mexico vs. Trinidad & Tobago 7 1 0 0 1 5 2 0 3 0 4 0

 Mexico vs. Ukraine 7 1 0 0 1 5 1 0 1 0 2 0

 Moldova vs. Trinidad & Tobago 7 1 0 0 1 4 1 0 2 0 2 0

 Moldova vs. Ukraine 7 1 0 0 1 4 1 0 1 0 1 0

 Trinidad & Tobago vs. Ukraine 7 1 0 0 1 4 1 0 1 0 1 0

Nonsubject countries 

comparisons: 

 U.S. vs. nonsubject 9 1 0 0 2 9 5 2 8 15 6 1

 Brazil vs. nonsubject 7 1 0 0 2 4 1 1 2 3 3 0

 Indonesia vs. nonsubject 7 1 0 0 2 4 1 1 2 1 2 0

 Mexico vs. nonsubject 7 1 0 0 2 5 2 1 3 7 4 0

 Moldova vs. nonsubject 7 1 0 0 2 3 2 1 2 1 2 0

 Trinidad & Tobago vs. nonsubject 7 1 0 0 3 4 2 1 2 1 3 0

 Ukraine vs. nonsubject 7 1 0 0 2 3 2 1 2 1 1 0

Note.—A=Always, F=Frequently, S=Sometimes, N=Never.

Source: Compiled from data submitted in response to Commission questionnaires. 

 

19 Importer questionnaire response, section III‐30.
II‐24

As can be seen from table II‐10, 17 responding purchasers reported that domestically‐

produced product “always” met minimum quality specifications.20 The majority of purchasers

reported that they did not have any knowledge of the quality specifications of wire rod from

most subject countries. However, seven of seventeen responding purchasers reported that the

Mexican product “always” met minimum quality specifications.

Table II-10 

Wire rod: Ability to meet minimum quality specifications, by source and number of reporting 

firms1 

Source Always Usually Sometimes 

Rarely or 

never Don’t know 

United States 17 16 0 1 0 

Brazil 2 2 1 0 26 

Indonesia 0 0 1 0 28 

Mexico 7 9 1 0 16 

Moldova 0 1 0 0 28 

Trinidad & Tobago 1 2 0 0 26 

Ukraine 0 0 0 0 29 

Other: Canada 3 3 0 0 0 

Other: China 8 12 1 0 0 

Other: Turkey 3 7 0 0 0 

1

 Purchasers were asked how often domestically produced or imported wire rod meets minimum quality 

specifications for their own or their customers’ uses.

Source: Compiled from data submitted in response to Commission questionnaires. 

In addition, producers, importers, and purchasers were asked to assess how often

differences other than price were significant in sales of wire rod from the United States,

subject, or nonsubject countries. As seen in table II‐11, most producers reported that there

were “never” differences other than price and most importers reported that there were

“sometimes” or “never” differences other than price. Purchaser responses were more divided.

The most common difference reported by firms was shorter delivery and lead times. Other

differences included: grade ranges, purity levels, steel quality, technical support, availability of

ultra‐high carbon for certain end‐use applications, and availability of smaller diameter wire rod.  

 

20 ***. Purchaser questionnaire response, section III‐13.
II‐25

Table II-11 

Wire rod: Significance of differences other than price between wire rod 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 

purchasers reporting 

A F S N A F S N A F S N 

U.S. vs. subject countries: 

 U.S. vs. Brazil 0 0 3 6 1 0 2 2 3 2 2 4 

 U.S. vs. Indonesia 0 0 3 6 1 0 2 2 3 0 0 3 

 U.S. vs. Mexico 0 0 3 6 3 2 3 2 4 4 7 7 

 U.S. vs. Moldova 0 0 3 6 1 0 2 1 4 0 0 2 

 U.S. vs. Trinidad & Tobago 0 0 3 6 1 1 3 1 3 2 1 3 

 U.S. vs. Ukraine 0 0 3 6 1 0 2 1 2 0 0 2 

Subject countries comparisons: 

 Brazil vs. Indonesia 0 0 2 6 1 0 2 2 2 0 0 2 

 Brazil vs. Mexico 0 0 2 6 2 0 2 2 2 2 3 2 

 Brazil vs. Moldova 0 0 2 6 1 0 2 1 2 0 0 1 

 Brazil vs. Trinidad & Tobago 0 0 2 6 1 0 2 1 2 1 1 1 

 Brazil vs. Ukraine 0 0 2 6 1 0 2 1 2 0 0 1 

 Indonesia vs. Mexico 0 0 2 6 2 0 2 2 2 0 1 2 

 Indonesia vs. Moldova 0 0 2 6 1 0 2 1 2 0 0 1 

 Indonesia vs. Trinidad & Tobago 0 0 2 6 1 0 2 1 2 0 1 1 

 Indonesia vs. Ukraine 0 0 2 6 1 0 2 1 2 0 0 1 

 Mexico vs. Moldova 0 0 2 6 2 0 2 1 2 0 0 1 

 Mexico vs. Trinidad & Tobago 0 0 2 6 2 0 2 1 2 1 1 2 

 Mexico vs. Ukraine 0 0 2 6 2 0 2 1 2 0 0 1 

 Moldova vs. Trinidad & Tobago 0 0 2 6 1 0 2 1 2 0 1 1 

 Moldova vs. Ukraine 0 0 2 6 1 0 2 1 2 0 0 1 

 Trinidad & Tobago vs. Ukraine 0 0 2 6 1 0 2 1 2 0 0 1 

Nonsubject countries 

comparisons: 

 U.S. vs. nonsubject 0 0 2 8 5 4 4 3 6 7 9 8 

 Brazil vs. nonsubject 0 0 1 7 3 1 2 2 2 2 2 2 

 Indonesia vs. nonsubject 0 0 1 7 3 1 2 2 2 1 1 2 

 Mexico vs. nonsubject 0 0 1 7 4 1 2 1 2 3 6 2 

 Moldova vs. nonsubject 0 0 1 7 3 1 2 1 2 1 1 1 

 Trinidad & Tobago vs. nonsubject 0 0 1 7 3 1 2 2 2 1 1 2 

 Ukraine vs. nonsubject 0 0 1 7 3 1 2 1 2 1 1 2 

Note.--A = Always, F = Frequently, S = Sometimes, N = Never. 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐26

ELASTICITY ESTIMATES

This section discusses elasticity estimates. Although parties were encouraged to

comment on these estimates in their prehearing or posthearing briefs, none commented.  

U.S. supply elasticity

The domestic supply elasticity21 for wire rod measures the sensitivity of the quantity

supplied by U.S. producers to changes in the U.S. market price of wire rod. 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 existence of inventories, and the availability of alternate markets for U.S.‐produced wire

rod. Analysis of these factors earlier indicates that the U.S. industry is likely to be able to slightly

increase or decrease shipments to the U.S. market; an estimate in the range of 1 to 3 is

suggested.  

U.S. demand elasticity

The U.S. demand elasticity for wire rod measures the sensitivity of the overall quantity

demanded to a change in the U.S. market price of wire rod. 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 the wire rod in the production of any downstream

products. Based on the available information, the aggregate demand for wire rod is likely to be

moderately elastic; a range of ‐0.5 to ‐0.75 is suggested.  

Substitution elasticity

The elasticity of substitution depends upon the extent of product differentiation

between the domestic and imported products.22 Product differentiation, in turn, depends upon

such factors as quality (e.g., chemistry, appearance, etc.) and conditions of sale (e.g.,

availability, sales terms/ discounts/ promotions, etc.). Based on available information, the

elasticity of substitution between U.S.‐produced wire rod and imported wire rod is likely to be

in the range of 3 to 5.

 

21 A supply function is not defined in the case of a non‐competitive market. 22 The substitution elasticity measures the responsiveness of the relative U.S. consumption levels of

the subject imports and the domestic like products to changes in their relative prices. This reflects how

easily purchasers switch from the U.S. product to the subject products (or vice versa) when prices

change.
III‐1

PART III: CONDITION OF THE U.S. INDUSTRY

OVERVIEW

From 2008 to 2013, the domestic wire rod industry experienced production

curtailments and resumptions, capacity expansions, facilities openings or re‐openings, and

facilities shutdowns.1 Nucor opened a new wire rod mill at its Darlington, South Carolina, facility

in October 2013, and reopened a previously idled facility at Kingman, Arizona, in November

2010. ArcelorMittal’s Georgetown, South Carolina facility, Evraz Pueblo’s Pueblo, Colorado

facility, and Keystone’s Peoria, Illinois facility underwent production curtailments and

resumptions during 2008‐12. Gerdau idled the rolling mill at its facility in Perth Amboy, New

Jersey, in August 2009, after having closed the melt shop at this facility in February 2007.2 The

rolling mill remains idled at this time and would require ***.3 Gerdau also invested in melting

and rolling capacity expansions at its Jacksonville, Florida, facility during 2008‐10. Table III‐1

summarizes important events that have occurred in the U.S. industry since January 2008.

BACKGROUND

Information in this section is based on the questionnaire responses of 10 producers that

are believed to have accounted for all known U.S. production during 2013.

CHANGES IN EXISTING OPERATIONS

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 wire

rod since 2008. Eight domestic producers indicated that they had experienced such changes;

their responses are presented in table III‐2.

 

     1

 Previously, during 2002‐06, the industry underwent extensive restructuring through bankruptcies,

corporate consolidations, facilities acquisitions, and new entrants.  See Carbon and Certain Alloy Steel

Wire Rod from Brazil, Canada, Indonesia, Mexico, Moldova, Trinidad and Tobago, and Ukraine, Inv. Nos.

701‐TA‐417 and 731‐TA‐953, 954, 957‐959, 961, and 962 (Review), USITC Publication 4014, June 2008,

pp. III‐1 to III‐2 and table III‐1.

     2 American Metal Market, “Melt Shop Closure Saves Money for Ameristeel,” February 8, 2007.

     3 ***. Domestic producers’ posthearing brief, exhibit 1, “Responses to Commissioner questions,

Gerdau’s Perth Amboy facility,” pp. 58‐60. For further information, see exhibit 24, “***.”
III‐2

Table III-1 

Wire rod: Survey of industry events, 2008-13

Period Company

Description of event 

(curtailment, expansion, opening, reopening, resumption, shutdown)

January 2008 Keystone Curtailment and resumption: Resumption of operations after a late-December 

outage was hindered by various difficulties at the Peoria, IL, facility, which reportedly 

resulted in an estimated 6,000-7,000 tons of lost production.

January 2008 Gerdau Expansion: Investment plans were announced for boosting the annual rolling 

capacity by 400,000 at the Jacksonville, FL, facility, with completion anticipated by 

2010. Rolling capacity expansion would enable Gerdau to match the recently 

expanded melting capacity at this facility which currently exceeds 1 million tons.

OctoberNovember 2008 Keystone Curtailment and resumption: The Peoria, IL, facility was reopened after a 

temporary shutdown for furnace maintenance, but management placed a majority of 

employees on a week-to-week layoff schedule, due to reportedly “generally slow” 

business conditions.

October 2008- 

January 2009 

ArcelorMittal Curtailment and resumption: The Georgetown, SC, facility, was temporarily idled in 

October-November 2008 and again in December 2008- January 2009, as part of 

parent company ArcelorMittal SA’s plans to cutback fourth-quarter 2008 output of all 

steel mill products by 30 percent worldwide and by 35 percent in the United States, 

which resulted in the temporary lay-offs of some 300 employees. Although the facility 

reopened in January 2009, 51 employees were permanently laid-off. 

NovemberDecember 2008 Evraz Pueblo Curtailment and resumption: The bar and rod mill at the Pueblo, CO, facility was 

temporarily idled due to lack of customer orders.

June 2009 Gerdau Shutdown: Halting of production announced at the Perth Amboy, NJ, rolling mill, 

followed by addition of another shift at the Beaumont, TX, facility to meet customer 

orders and to stock the warehouse. 

July 2009 ArcelorMittal Shutdown: Georgetown, SC, facility closed down, after labor negotiations failed to 

reach agreement for keeping the facility open. Halting in late June of the melt shop 

(with 1 million tons of annual capacity) and in early July of the rolling-mill operations 

(with 750,000 tons of annual capacity) affected some 265 hourly employees and 53 

salaried employees. 

November 2010 Nucor Reopening: Restarted operations at Kingman, AZ, facility, previously acquired in 

2003 from the former North Star Steel Co., to produce both wire rods and concrete 

reinforcing bars. This rolling mill has an anticipated output capacity rating of 500,000 

tons annually, but the July 2009 air-quality permit limited production to 350,000 tons 

annually. Other Nucor bar mills with excess melting capacity supply billets to the 

Kingman rolling mill. 

January 2011 ArcelorMittal Reopening: Georgetown, SC, facility resumed production. This facility, being 

capable of melting 1 million short tons of crude steel and rolling 750,000 tons of wire 

rod annually, actually rolled about 380,000 tons annually between 2006 and 2008. 

With plans to continue the previous practice of rolling to order, rather than also for 

building-up warehouse inventory, initial production was estimated to reach about 

264,000 tons of wire rods annually. Reopening of this facility was anticipated to bring 

back 185 union employees, under a new labor agreement that was ratified back in 

June 2010, and 44 managers. 

Fourth-quarter 

2012 

ArcelorMittal Curtailment: Operations at the Georgetown, SC, facility were cutback from three to 

two shifts, along with laying-off of 30 employees. 

October 2013 Nucor Opening: Shipments commenced from the newly constructed wire-rod mill at the 

Darlington, SC facility. This new wire-rod mill has an annual output capacity rating of 

300,000 tons and is capable of producing wire rods with diameters down to 5.5 mm 

and coiled bars up to 2 inches in diameter, in a full range of low-, medium-, and highcarbon contents. 

Source: American Metal Market, Metal Bulletin, and individual company Internet web sites. 
III‐3

Table III-2 

Wire rod: Changes in the character of U.S. operations since January 1, 2008 

*                    *                    *                    *                    *                    *                    *

ANTICIPATED CHANGES IN EXISTING OPERATIONS

The Commission asked domestic producers to report anticipated changes in the

character of their operations relating to the production of wire rod. Four domestic producers

(***) indicated that they do not anticipate any changes in the character of their operations. The

responses of the remaining six domestic producers appear in table III‐3.

Table III-3 

Wire rod: Anticipated changes in the character of U.S. operations

*                    *                    *                    *                    *                    *                    *

U.S. PRODUCTION, CAPACITY, AND CAPACITY UTILIZATION

Table III‐4 presents U.S. producers’ production, capacity, and capacity utilization. U.S.

capacity for wire rod fell from 2008 to 2010, increased in 2011, and fell thereafter to a level

that was 8.5 percent lower than reported for 2008. Domestic production fluctuated during the

six‐year period to a level in 2013 that is 9.9 percent lower than that reported in 2008. Capacity

utilization also fluctuated during 2008‐13 ranging from a high of 75.6 percent (2012) to a low of

53.6 percent (2009).

Table III-4 

Wire rod: U.S. producers’ production, capacity, and capacity utilization, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

Quantity (short tons) 

Capacity 5,546,751 5,295,752 4,965,095 5,173,168 5,131,954 5,073,815

Production 4,055,641 2,837,165 3,384,322 3,907,416 3,879,060 3,655,088

Ratio (percent) 

Capacity utilization 73.1 53.6 68.2 75.5 75.6 72.0

Note.— ***. 

Source: Compiled from data submitted in response to Commission questionnaires. 

While aggregate production quantity declined overall from 2008 to 2013 with most

firms reporting decreases in production over the period, three firms (***) reported overall

increases in production, ranging between *** and *** percent from 2008 to 2013.  

Although six U.S. producers reported no changes in the capacity to produce wire rod,

one firm (***) reported overall declines in capacity and three firms (***) reported overall

increases in capacity. ***.  

Gerdau reported *** the closure of its Perth Amboy, New Jersey rolling mill in August

2009. The Gerdau facility, which is dedicated to wire rod production and has an annual capacity

of 750,000 short tons, remains idled at this time and would require six months to one year to
III‐4

resume wire rod production.4 Staff adjusted the capacity data presented in this report to

exclude Gerdau’s idled 750,000 annual short ton capacity at its Perth Amboy, New Jersey

facility during the last half of 2009 and during 2010‐13. This is consistent with the manner in

which the Commission defines capacity,5 as well as with the manner in which domestic capacity

data are treated by independent market research.6 The annual wire rod capacity reported by

*** for Gerdau’s Perth Amboy facility ***.7  

Although ArcelorMittal reported ***.8 James Sanderson, President of the Steelworkers

Local 7898 that represents steelworkers at the ArcelorMittal plant in Georgetown, South

Carolina, testified at the Commission’s hearing  that “In 2008, we basically were in operation

and we went down in 2009 and we stayed down until the later part of 2011 and actually started

production in 2012.”9 However, because production did resume, and, consistent with the

manner in which the firm’s capacity data are treated in independent market research, staff did

not adjust the reported data.

CONSTRAINTS ON CAPACITY

All U.S. producers, ***, reported constraints in the manufacturing process. Reported

constraints in the manufacturing process for the U.S. producers include melting capacity, which

is constrained by environmental air permits; steel availability; speed of equipment, rolling

capacity, employee resources, market conditions, and import competition. Three U.S.

producers (***) that collectively accounted for *** of domestic production in 2013 specifically

noted that they are not operating at full capacity due to the market conditions and that

weakened demand due to import competition limits their ability to produce more wire rod.

 

4 Carbon and Certain Alloy Steel Wire Rod from China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248

(Preliminary), USITC Publication 4458 (March 2014), p. III‐3; and Domestic producers’ prehearing brief, p.

56.5 In its instructions that accompanied the questionnaires issued in these reviews, the Commission

defined capacity as follows: The level of production that your establishment(s) could reasonably have

expected to attain during the specified periods.  Assume normal operating conditions (i.e., using

equipment and machinery in place and ready to operate; normal operating levels (hours per

week/weeks per year) and time for downtime, maintenance, repair, and cleanup; and a typical or

representative product mix).

6 ***.

7 Ibid.

8 The overall annual plant capacity reported by ArcelorMittal USA for Georgetown is *** short tons,

*** short tons of which are allocated for wire rod. The overall annual plant capacity for Indiana Harbor is

*** short tons, *** short tons of which are allocated for wire rod.

9 Hearing transcript, p. 77 (Sanderson).
III‐5

ALTERNATIVE PRODUCTS

All producers *** reported production or anticipating production of other products,

including rebar, on the same equipment and machinery used to produce wire rod. Table III‐5

presents the U.S. wire rod producers’ overall capacity and production of wire rod and other

products produced on the same production equipment used to produce wire rod. U.S.

producers were asked to describe the constraints that set the limits on their firm’s ability to

shift production capacity between products. *** stated that they can readily shift between

coiled reinforcing bar and coiled carbon wire rod and *** indicated that it has some ability to

shift between wire rod and rebar. However, *** stated that it cannot easily shift production

between wire rod and rebar. *** reported that their ability to switch production is dependent

on customer demand for those products. Charter stated ***. Republic ***.

Table III-5 

Wire rod: U.S. producers’ overall capacity, production, and capacity utilization, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

Overall capacity 8,164,642 7,959,617 7,740,303 7,918,772 8,010,018 8,918,066

Production: 

 Subject merchandise 4,055,641 2,837,164 3,384,322 3,907,416 3,879,060 3,655,088

 Rebar 1,099,208 758,281 790,189 808,532 879,761 1,070,115

Other bar/rod products 1,155,617 631,750 977,433 1,123,174 1,122,994 1,488,908

 Subtotal, nonsubject 

 production 2,254,825 1,390,031 1,767,622 1,931,706 2,002,755 2,559,023

Total production 6,310,466 4,227,195 5,151,944 5,839,122 5,881,815 6,214,111

 Ratio (percent) 

Overall capacity utilization 77.3 53.1 66.6 73.7 73.4 69.7

 Share of quantity (percent) 

Share of production: 

 Subject merchandise 64.3 67.1 65.7 66.9 66.0 58.8

 Rebar 17.4 17.9 15.3 13.8 15.0 17.2

Other bar/rod products 18.3 14.9 19.0 19.2 19.1 24.0

 Subtotal, nonsubject 

 production 35.7 32.9 34.3 33.1 34.0 41.2

Total production 100.0 100.0 100.0 100.0 100.0 100.0

Note.— ***. 

Source: Compiled from data submitted in response to Commission questionnaires. 

U.S. PRODUCERS’ U.S. SHIPMENTS AND EXPORTS

Table III‐6 presents U.S. producers’ U.S. shipments, export shipments, and total

shipments.  
III‐6

Table III-6 

Wire rod: U.S. producers’ U.S. shipments, exports shipments, and total shipments, 2008-131 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

Commercial U.S. shipments 2,954,594 2,032,965 2,414,644 2,944,416 2,815,567 2,595,200

Internal consumption *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Subtotal, U.S. shipments 4,050,961 2,833,426 3,340,954 3,876,145 3,809,728 3,599,459

Export shipments 39,707 39,301 42,049 34,687 26,748 24,319

Total shipments 4,090,668 2,872,727 3,383,003 3,910,832 3,836,476 3,623,778

 Value (1,000 dollars) 

Commercial U.S. shipments 2,590,276 1,194,142 1,668,054 2,340,739 2,143,895 1,875,625

Internal consumption *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Subtotal, U.S. shipments 3,485,005 1,651,451 2,246,759 3,012,054 2,826,974 2,529,487

Export shipments 31,925 22,886 26,912 28,888 31,597 22,566

Total shipments 3,516,930 1,674,337 2,273,671 3,040,942 2,858,571 2,552,053

 Unit value (dollars per short ton) 

Commercial U.S. shipments 877 587 691 795 761 723

Internal consumption *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Subtotal, U.S. shipments 860 583 672 777 742 703

Export shipments 804 582 640 833 1,181 928

Total shipments 860 583 672 778 745 704

 Share of quantity (percent) 

Commercial U.S. shipments 72.2 70.8 71.4 75.3 73.4 71.6

Internal consumption *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Subtotal, U.S. shipments 99.0 98.6 98.8 99.1 99.3 99.3

Export shipments 1.0 1.4 1.2 0.9 0.7 0.7

Total shipments 100.0 100.0 100.0 100.0 100.0 100.0

 Share of value (percent) 

Commercial U.S. shipments 73.7 71.3 73.4 77.0 75.0 73.5

Internal consumption *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Subtotal, U.S. shipments 99.1 98.6 98.8 99.1 98.9 99.1

Export shipments 0.9 1.4 1.2 0.9 1.1 0.9

Total shipments 100.0 100.0 100.0 100.0 100.0 100.0

1

 Several U.S. producers included tolling activity in their shipment data. Further information concerning 

the tolling activity reported by U.S. producers is included in the section of Part I entitled “U.S. Producers.” 

***. 

Source: Compiled from data submitted in response to Commission questionnaires. 
III‐7

The quantity of U.S. producers’ U.S. shipments declined steeply from 2008 to 2009,

increased from 2009 to 2011, and fell to a level in 2013 that was 11.1 percent lower than the

level reported in 2008.  The value and unit value of U.S. producers’ U.S. shipments followed a

similar trend, declining overall by 27.3 percent and 18.3 percent, respectively.  

Commercial U.S. shipments accounted for between 70.8 and 75.3 percent of U.S.

producers’ total shipments of wire rod during 2008‐13, whereas internal consumption

accounted for between *** and *** percent of U.S. producers’ total shipments of wire rod and

transfers to related firms accounted for between *** and *** percent.10 Seven firms, ***,

reported internally consuming or transferring wire rod to a related firm to produce a

downstream product. U.S. producers reported internal consumption and company transfers of

wire rod for the production of nails, garment hangers, wire shelving, prestressed concrete

strand, oil tempered and other high carbon wire, drawn wire (including tire bead, high carbon

and fine wire quality), cold finished bars, cold headed parts, mesh, agricultural fencing,

armoring wire, galvanized wire, concrete reinforcing mesh, and bed spring components.

U.S. producers’ total exports of wire rod accounted for between 0.7 to 1.4 percent of

their total shipments during 2008‐13. Five out of ten producers reported exports of wire rod,

predominately to Canada and Mexico, as well as to ***. U.S. producers contend that it is hard

to compete in export markets due to the lower priced product there, particularly from the

Chinese producers. Evraz does export some high end value products to Mexico.11

 

10 Aggregate domestic producers’ internal consumption fell from *** short tons in 2008 to *** short

tons in 2009, before generally increasing to *** short tons in 2013. Aggregate domestic producers’

company transfers fell from *** short tons in 2008 to *** short tons in 2009, before generally increasing

to *** short tons in 2013. Domestic company representatives present at the Commission’s hearing

testified that such transfers are made at market prices. Hearing transcript, pp. 83‐84 (Stirnaman

(Keystone), Nystron (Nucor), and Kerkvliet (Gerdau)). 11 Carbon and Certain Alloy Steel Wire Rod from China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248

(Preliminary), USITC Publication 4458, March 2014, p. III‐6.
III‐8

U.S. PRODUCERS’ U.S. SHIPMENTS, BY APPLICATION  

Table III‐7 presents U.S. producers’ U.S. shipments by type in 2013. All U.S. producers

reported U.S. shipments of high/medium‐high carbon industrial/standard quality wire rod and

all *** reported U.S. shipments of low/medium‐low carbon industrial/standard quality wire

rod. These two types of wire rod together accounted for more than three‐fourths of all types of

U.S. producers’ U.S. shipments during 2013.  

Table III-7 

Wire rod: U.S. producers’ U.S. shipments, by type, 2013 

Item 

Quantity 

(short tons) 

Share 

(percent) 

Number of 

reporting firms

Low/medium-low carbon industrial/standard quality 1,768,913 49.1 9

High/medium-high carbon industrial/standard quality 1,002,954 27.9 10

Tire cord or tire bead quality *** *** ***

Welding quality *** *** ***

Cold heading quality (“CHQ”) *** *** ***

Other specialty carbon and alloy quality *** *** ***

All other wire rod *** *** ***

 Total, U.S. shipments 3,599,459 100.0 10

Source: Compiled from data submitted in response to Commission questionnaires. 

Cold heading quality (“CHQ”) wire rod, which accounted for *** percent of all types of

U.S. producers’ U.S. shipments in 2013, is produced by *** domestic producers and welding

quality wire rod, which accounted for *** percent of all types of U.S. producers’ U.S. shipments

in 2013, is produced by *** domestic producers. *** is the largest domestic producer of these

types of wire rod. *** together accounted for almost all domestic production of tire cord or tire

bead quality wire rod, which accounted for *** percent of all types of U.S. producers’ U.S.

shipments in 2013.12 Other specialty carbon and alloy quality wire rod is produced by five  

 

12 ArcelorMittal makes a wide variety of wire rod grades at its facilities, including low, medium, high

carbon, tire cord, tire bead, and welding wire rod. Evraz produces low carbon mesh and industrial grade

wire rod, however its product mix is weighted heavily toward high and medium carbon steels. Evraz also

produces medium carbon grades of wire rod for the furniture and bedding spring rod business, as well

as high carbon rod for the making of PC strand, rubber reenforcement and wire row. In addition, Evraz

produces welding quality wire rod. Carbon and Certain Alloy Steel Wire Rod from China, Inv. Nos. 701‐

TA‐512 and 731‐TA‐1248 (Preliminary), USITC Publication 4458 (March 2014), p. III‐8.
III‐9

producers (the largest of which is ***) and all other wire rod is produced by three producers

(the largest of which is ***).13

U.S. producers were asked to describe the qualitative differences among the different

types of wire rod. Three firms (***) said there were no or little differences. Other firms stated

that wire rod is on a continuum of grades, qualities, chemistry variances, and end uses and that

the qualitative differences between each relate to charge design and scrap cost to create a

higher carbon product. One firm stated that some overlap occurs especially if higher quality

materials are used in a lower quality application. For example, CHQ could be used in some

industrial quality applications or welding wire could be used in industrial quality applications.

One firm stated that CHQ, other special carbon and alloy, and tire cord are the highest quality.  

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. shipments, and total shipments during 2008‐13.

U.S. producers’ inventories of wire rod fell sharply from 2008 to 2009, remained relatively

stable through 2011, before increasing to a six‐year high in 2013. Overall, inventories were 15.4

percent higher in 2013 than in 2008, with *** accounting for the largest share of the increase.

Inventories relative to total shipments fluctuated during 2008‐13, ranging from a low of 4.9

percent in 2011 to a high of 7.4 percent in 2013.

Table III-8 

Wire rod: U.S. producers’ inventories, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

U.S. producers' end-of-period inventories 231,279 195,717 196,677 193,261 235,848 266,868

 Ratio (percent) 

Ratio of inventories to-- 

 U.S. production 5.7 6.9 5.8 4.9 6.1 7.3

 U.S. shipments 5.7 6.9 5.9 5.0 6.2 7.4

 Total shipments 5.7 6.8 5.8 4.9 6.1 7.4

Source: Compiled from data submitted in response to Commission questionnaires. 

 

13 Gerdau produces a wide variety of wire rod types ranging from low to high carbon rod, welding

rod, cold‐heading quality rod and many other special types of rod as well. Carbon and Certain Alloy Steel

Wire Rod from China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248 (Preliminary), USITC Publication 4458

(March 2014), p. III‐8.
III‐10

U.S. PRODUCERS’ IMPORTS AND PURCHASES

U.S. producers reported no direct imports or domestic purchases of domestically

produced or imported wire rod from the subject countries during 2008‐13. *** U.S. producer

(***) reported the domestic purchase of *** wire rod *** during ***. *** explained that this

domestic purchase of wire rod produced by *** was for resale purposes.  

Republic, as well as two other U.S. producers (Gerdau and ArcelorMittal USA), reported

that they are related to foreign producers of the subject merchandise. Republic reported that

its parent company, Grupo Simec, owns Grupo San Luis, a wire rod producer in Mexico. ***.

Gerdau reported that it is a wholly‐owned subsidiary of wire rod producer Gerdau SA of Brazil.

Gerdau SA did not provide a response to the Commission’s foreign producer questionnaire in

these reviews. ArcelorMittal USA reported that it is a wholly‐owned subsidiary of ArcelorMittal

SA (Luxembourg), which has subsidiary wire rod producers in numerous countries, including

subject countries Brazil, Mexico, Trinidad & Tobago, and Ukraine. There were no reported

imports of subject merchandise from Brazil or Ukraine during 2008‐13 and there were no

reported imports of subject merchandise from Trinidad & Tobago by ArcelorMittal firms during

2008‐13.  

Table III‐9 presents data on ArcelorMittal USA’s U.S. production and U.S. imports of wire

rod from Mexico during 2008‐13 as reported by the following ArcelorMittal related firms:  ***.

These data show that the ratio of ArcelorMittal’s U.S. imports from *** to its U.S. production

remained below *** percent during every annual period 2008‐13, except for 2010 at which

point the ratio ***, as ArcelorMittal experienced the closure of its Georgetown facility and the

idling of its Indiana Harbor facility. The ratio of ArcelorMittal’s U.S. imports from *** to its U.S.

production increased from *** percent in 2008 to *** percent in 2010 and ranged between ***

percent and *** percent during 2011‐13. The vast majority (i.e., ***) of ArcelorMittal’s U.S.

imports from “all other sources” are from ***.  

Table III-9 

Wire rod: ArcelorMittal’s U.S. production, imports, and import ratios to U.S. production, 2008-13

*                    *                    *                    *                    *                    *                    *

In response to an argument concerning its regional supply policy, ArcelorMittal reported

that it “employs a commercial coordination policy that ***.” It added that “***.” In response to

a Commission question concerning whether or not it considers the United States to be part of

an integrated North American steel market, ArcelorMittal noted that “***.”14

 

14 Domestic producers’ posthearing brief, exh. 1, pp. 56‐57.
III‐11

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

Table III‐10 shows U.S. producers’ employment‐related data during 2008‐13. Several

employment‐related indicators fell steeply from 2008 to 2009 and recovered somewhat

thereafter to levels below those reported in 2008. The level of production‐related workers

(PRWs), total hours worked, and total wages paid fell overall by 6.3, 10.2, and 8.0 percent,

respectively, from 2008 to 2013.  Although seven domestic producers reported overall declines

in the number of PRWs, the largest declines in the reported data were primarily attributed to

the employment indicators reported by ***. The President of the Steelworkers Local 7898,

representing steelworkers at the ArcelorMittal Georgetown facility, testified at the hearing that

the closure of ArcelorMittal’s Georgetown mill from July 2009 until January 2011 “put 307

steelworkers out of work for an extended period of time and put a strain on the community...”15

Reported industry aggregate hourly wages, unit labor costs, and productivity fluctuated during

2008‐13, but were slightly higher in 2013 than in 2008.

Table III-10 

Wire rod: Average number of production and related workers, hours worked, wages paid to such 

employees, hourly wages, productivity, and unit labor costs, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

Production related workers (PRWs) (number) 2,339 2,083 2,173 2,239 2,269 2,192

Total hours worked (1,000 hours) 4,741 3,825 4,220 4,552 4,587 4,258

Hours worked per PRW (hours) 2,027 1,836 1,942 2,033 2,022 1,943

Wages paid ($1,000) 170,467 128,170 145,939 166,385 174,648 156,838

Hourly wages (dollars per hour) $35.96 $33.51 $34.58 $36.55 $38.07 $36.83

Productivity (short tons per 1,000 hours) 855.4 741.7 802.0 858.4 845.7 858.4

Unit labor costs (dollars per short ton) $42.03 $45.18 $43.12 $42.58 $45.02 $42.91

Source: Compiled from data submitted in response to Commission questionnaires. 

 

15 Hearing transcript, pp. 48‐49 (Sanderson).
III‐12

FINANCIAL EXPERIENCE OF U.S. PRODUCERS

Background

This section of the report presents the wire rod financial results of ten U.S. producers.  Wire

rod financial results were reported primarily on the basis of U.S. generally accepted accounting

principles (GAAP) and for calendar‐year periods.16  While no single U.S. producer accounts for the

majority of overall wire rod sales volume, the three largest volume producers accounted for ***

percent of total sales volume during 2008‐13:  ***.  The remaining producers ranged from ***

percent of total sales volume (***) to *** percent of total sales volume (***).

The majority of the industry’s wire rod revenue reflects commercial sales (73.3 percent of

total sales), followed by transfers (*** percent of total sales) and a relatively small amount

classified as internal consumption (*** percent of total sales).  While most U.S. producers also

reported transfers, only *** reported that transfers are the majority of their wire rod revenue.17  

Internal consumption was only reported by ***.18  Several U.S. producers also included tolling

activity in their trade information and financial results.  Revenue and other financial elements

specific to wire rod tolling operations are not presented separately in the relevant tables below.19   

 

16 The exceptions were Gerdau, reporting its financial results on the basis of International Financial

Reporting Standards (IFRS) and Charter, reporting its financial results for fiscal‐year periods ending August

31.17 ***.  March 6, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.  March

5, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.  March 4, 2014 e‐mail

with attachment from *** to USITC auditor.  March 5, 2014 e‐mail with attachment from *** to USITC

auditor.  March 28, 2014 e‐mail with attachment from *** to USITC auditor.  March 7, 2014 e‐mail with

attachment from counsel on behalf of *** to USITC auditor.  February 28, 2014 e‐mail with attachment from

*** to USITC auditor.   18 ***.  March 5, 2014 e‐mail with attachment from *** to USITC auditor.  ***.  March 7, 2014 e‐mail

with attachment from counsel on behalf of *** to USITC auditor.     19 Tolling activity introduces a limited degree of potential double counting with respect to wire rod sales

volume.  Given the eliminating effect of toll‐processing fees that are included in revenue and in cost of

goods sold, tolling activity in general does not appear to distort or otherwise undermine the validity of the

industry’s consolidated financial results.   
III‐13

Four producers, ***, reported that they purchase primary raw materials from related

parties:  ***.20 21  

With respect to inputs other than raw material which are purchased from a related

company, ***.22 23   

Operations on wire rod

Table III‐11 presents income‐and‐loss data for the U.S. industry’s wire rod operations.   

Table III‐12 presents a variance analysis of these financial results.24  Table III‐13 presents selected

company‐specific financial information.   

 

20 *** U.S. producer questionnaires, response to question III‐7.  ***.  March 18, 2014 e‐mail with

attachment from *** to USITC auditor.          21 ***.  March 28, 2014 e‐mail with attachment from *** to USITC auditor.           22 *** U.S. producer questionnaire, response to question III‐7.

23 With regard to input purchases from related companies, the Commission’s standard practice requires

the elimination of the related company’s profit or loss from the relevant COGS reported in the financial

section of the U.S. producer questionnaire.  The intent of this adjustment is for the related company’s actual

cost to be recognized in determining the financial results reported to the Commission.  The U.S. producers

referenced above generally indicated that they complied with the Commission’s requested input valuation.  

***.  *** U.S. producer questionnaire, response to question III‐7.    24 The Commission’s variance analysis is calculated in three parts:  sales variance, COGS variance, and

sales, general and administrative (SG&A) expenses variance.  Each part consists of a price variance (in the

case of the sales variance) or a cost variance (in the case of the COGS and SG&A expenses variances) and a

volume (quantity) variance.  The sales or cost variance is calculated as the change in unit price/cost times

the new volume, while the volume variance is calculated as the change in volume times the old unit

price/cost.  Summarized at the bottom of table III‐12, the price variance is from sales, the cost/expense

variance is the sum of those items from COGS and SG&A, respectively, and the net volume variance is the

sum of the price, COGS, and SG&A volume variances.   

Most U.S. producers indicated that product mix did not change substantially during 2008‐13 which

generally enhances the utility of the Commission’s variance analysis.  USITC auditor prehearing notes.  ***.  

March 4, 2014 e‐mail with attachment from *** to USITC auditor.    
III‐14

Table III-11 

Wire rod: Results of operations of U.S. producers, 2008-13

Item 

Fiscal year 

2008 2009 2010 2011 2012 2013 

Quantity (short tons) 

Commercial sales 2,993,932 2,072,311 2,456,711 2,979,103 2,842,314 2,619,518

Internal consumption *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

 Total net sales quantity 4,126,388 2,881,432 3,384,018 3,920,918 3,836,475 3,623,777

Value ($1,000) 

Commercial sales 2,621,392 1,217,068 1,694,976 2,369,626 2,175,493 1,898,192

Internal consumption *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Total net sales value 3,547,031 1,679,395 2,274,325 3,048,561 2,858,572 2,552,054

Cost of goods sold: 

 Raw materials 2,146,334 991,037 1,395,604 1,975,923 1,801,045 1,579,821

 Direct labor 184,687 109,149 132,708 156,676 152,847 139,485

 Other factory costs 785,656 552,772 555,675 611,227 668,696 639,029

 Total cost of goods sold 3,116,677 1,652,958 2,083,987 2,743,826 2,622,588 2,358,335

Gross profit 430,354 26,437 190,338 304,735 235,984 193,719

SG&A expenses 83,259 69,352 91,584 86,722 87,633 86,025

Operating income or (loss) 347,095 (42,915) 98,754 218,013 148,351 107,694

Interest expense 21,662 16,828 10,972 8,532 1,552 3,424

Other expenses 11,226 12,672 11,590 10,953 9,984 8,452

Other income items 848 845 1,075 856 406 612

Net income or (loss) 315,055 (71,570) 77,267 199,384 137,221 96,430

Depreciation/amortization 53,415 52,222 46,948 46,192 47,134 48,420

Estimated cash flow from operations 368,470 (19,348) 124,215 245,576 184,355 144,850

Ratio to net sales (percent) 

 Raw materials 60.5 59.0 61.4 64.8 63.0 61.9

 Direct labor 5.2 6.5 5.8 5.1 5.3 5.5

 Other factory costs 22.1 32.9 24.4 20.0 23.4 25.0

 Cost of goods sold 87.9 98.4 91.6 90.0 91.7 92.4

 Gross profit1 12.1 1.6 8.4 10.0 8.3 7.6

 SG&A expenses 2.3 4.1 4.0 2.8 3.1 3.4

 Operating income or (loss) 9.8 (2.6) 4.3 7.2 5.2 4.2

 Net income or (loss) 8.9 (4.3) 3.4 6.5 4.8 3.8

 Table continued on next page. 
III‐15

Table III-11-- Continued 

Wire rod: Results of operations of U.S. producers, 2008-13

Item 

Fiscal year 

2008 2009 2010 2011 2012 2013 

Ratio to cost of goods sold (percent) 

 Raw materials 68.9 60.0 67.0 72.0 68.7 67.0 

 Direct labor 5.9 6.6 6.4 5.7 5.8 5.9 

 Other factory costs 25.2 33.4 26.7 22.3 25.5 27.1 

Unit values (dollars per short ton) 

Commercial sales 876 587 690 795 765 725 

Internal consumption *** *** *** *** *** ***

Transfers *** *** *** *** *** ***

 Total net sales 860 583 672 778 745 704 

 Cost of goods sold: 

 Raw materials 520 344 412 504 469 436

 Direct labor 45 38 39 40 40 38

 Other factory costs 190 192 164 156 174 176

 Total cost of goods sold 755 574 616 700 684 651

 Gross profit 104 9 56 78 62 53

 SG&A expenses 20 24 27 22 23 24

 Operating income or (loss) 84 (15) 29 56 39 30

Number of firms reporting 

 Operating losses 1 5 2 1 2 3

 Data 10 10 10 10 10 10

1 The following reconciles period-to-period changes in the components of the COGS-to-sales ratio to 

corresponding changes in gross profit ratio. A period-to-period change that increases the COGS-to-sales ratio 

yields a corresponding decline in gross profit ratio, while a period-to-period change that decreases the COGS-tosales ratio yields a corresponding increase in gross profit ratio. 

Item 

Fiscal year 

2008-09 2009-10 2010-11 2011-12 2012-13 

Ratio to net sales (percent) 

 Raw materials (1.5) 2.4 3.5 (1.8) (1.1)

 Direct labor 1.3 (0.7) (0.7) 0.2 0.1

 Other factory costs 10.8 (8.5) (4.4) 3.3 1.6

 Cost of goods sold 10.6 (6.8) (1.6) 1.7 0.7

 Gross profit (10.6) 6.8 1.6 (1.7) (0.7)

Source: Compiled from data submitted in response to Commission questionnaires. 
III‐16

Table III-12 

Wire rod: Variance analysis on the operations of U.S. producers, 2008-13

Item 

Fiscal year 

2008-09 2009-10 2010-11 2011-12 2012-13 

 Total net revenue: Value ($1,000) 

 Price variance (797,475) 302,006 413,397 (124,334) (148,036)

 Volume variance (1,070,161) 292,924 360,839 (65,655) (158,482)

 Total net sales variance (1,867,636) 594,930 774,236 (189,989) (306,518)

 Cost of sales: 

 Raw materials: 

 Cost variance 507,735 (231,708) (358,896) 132,323 121,372

 Volume variance 647,562 (172,859) (221,423) 42,555 99,852

 Net raw material variance 1,155,297 (404,567) (580,319) 174,878 221,224

 Direct labor: 

 Cost variance 19,817 (4,521) (2,913) 455 4,888

 Volume variance 55,721 (19,038) (21,055) 3,374 8,474

 Net direct labor variance 75,538 (23,559) (23,968) 3,829 13,362

 Other factory costs: 

 Cost variance (4,153) 93,513 32,610 (70,633) (7,406)

 Volume variance 237,037 (96,416) (88,162) 13,164 37,073

 Net other factory cost 

i

232,884 (2,903) (55,552) (57,469) 29,667

 Net cost of sales: 

 Cost variance 523,399 (142,716) (329,199) 62,145 118,854

 Volume variance 940,320 (288,313) (330,640) 59,093 145,399

 Total net cost of sales 

i

1,463,719 (431,029) (659,839) 121,238 264,253

 Gross profit variance (403,917) 163,901 114,397 (68,751) (42,265)

 SG&A expenses: 

 Expense variance (11,213) (10,135) 19,392 (2,779) (3,250)

 Volume variance 25,120 (12,097) (14,530) 1,868 4,858

 Total SG&A variance 13,907 (22,232) 4,862 (911) 1,608

 Operating income variance (390,010) 141,669 119,259 (69,662) (40,657)

 Summarized as: 

 Price variance (797,475) 302,006 413,397 (124,334) (148,036)

 Net cost/expense variance 512,186 (152,852) (309,806) 59,367 115,604

 Net volume variance (104,721) (7,485) 15,668 (4,695) (8,225)

Source: Compiled from data submitted in response to Commission questionnaires. 

 
III‐17

Table III-13 

Wire rod: Results of operations of U.S. producers, by firm, 2008-13

*            *            *            *            *            *            *

Sales volume

Table III‐13 shows that all U.S. producers reported lower sales volume between 2008 and

2009.  In general, U.S. producers attributed this pattern to the impact of the recession on wire rod

demand.25  *** reported lower sales volume between 2008 and 2009 (*** percent and ***

percent, respectively), their volume declines on a percentage basis were *** compared to the

other U.S. producers.  ***.26  ***.27   

*** reported the *** company‐specific percentage decline in sales volume between 2008

and 2009 (***).  ***.28  ***.29  

Sales value

In addition to the underlying base price, wire rod revenue includes surcharges related to

primary inputs, as well as fuel costs associated with freight.  In general, however, application of

surcharges is not uniform among the U.S. producers.   With regard to companies indicating that

their revenue includes surcharges, ***.30   ***.31  ***.32

Other companies, primarily referencing raw material inputs, generally indicated that they

do not use surcharges.  ***.33  ***.34  ***.35  ***.36  ***.37  ***.38   

As shown in table III‐13, the period‐to‐period directional trend of company‐specific average

sales values was the same for all U.S. producers.  Directionally, the trend of average sales value and

 

25 USITC auditor notes (prehearing).  ***.  March 5, 2014 e‐mail with attachment from *** to USITC

auditor.           26 March 4, 2014 e‐mail with attachment from *** to USITC auditor.

27 ***.   February 28, 2014 e‐mail with attachment from *** to USITC auditor.

28 March 6, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.

29 ***.  March 4, 2014 e‐mail with attachment from *** to USITC auditor.

30 March 5, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.    31 March 5, 2014 e‐mail with attachment from *** to USITC auditor.

32 March 4, 2014 e‐mail with attachment from *** to USITC auditor.    33 March 6, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.

34 March 4, 2014 e‐mail with attachment from *** to USITC auditor.

35 March 4, 2014 e‐mail with attachment from *** to USITC auditor.

36 March 28, 2014 e‐mail with attachment from *** to USITC auditor.  ***.  Ibid.   37 March 7, 2014 e‐mail with attachment from counsel on behalf of *** to USITC auditor.

38 February 28, 2014 e‐mail with attachment from *** to USITC auditor.
III‐18

average raw material cost was also the same.39  While company‐specific average sales values were

generally in a similar range, *** average sales values compared to the other U.S. producers.40

Cost of goods sold and gross profit

On an overall basis, the total cost of raw materials in table III‐11 reflects a composite of

inputs which includes various grades of ferrous scrap, DRI, alloys, and steel billets.41  As a share of

wire rod COGS, raw material costs ranged from a low of 60.0 percent in 2009 to a high of 72.0

percent in 2011.      

Other factory costs, the second largest component of total wire rod COGS, was at its highest

level as a share of total COGS in 2009, at 33.4 percent, and at its lowest level in 2011, at 22.3

percent.42  Notwithstanding the importance of fixed and semi‐fixed manufacturing costs (see

 

39 Notwithstanding the fact that average sales value and average raw material costs reflect the same

directional trend, the corresponding magnitude of company‐specific changes in average sales value and

average raw material costs were not necessarily the same.  ***.  March 4, 2014 e‐mail with attachment

from *** to USITC auditor.   40 ***.  March 5, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.  ***.  

Ibid.   

***.  March 4, 2014 e‐mail with attachment from *** to USITC auditor.   41 While the directional trend of company‐specific average raw material costs was almost uniformly the

same (see table III‐13), the relatively wide range of company‐specific average raw material costs appears to

reflect differences such as company‐specific product mix, as well as variations in underlying raw material.   

With regard to its primary raw materials, *** referenced scrap and indicated that it accounts for ***

percent of COGS.  February 28, 2014 e‐mail with attachment from *** to USITC auditor.  *** reported that

scrap and alloys represent their primary raw material inputs.  ***.  March 5, 2014 e‐mail with attachments

(incl. revised table II‐6) from *** to USITC auditor.  March 4, 2014 e‐mail with attachment from *** to USITC

auditor.  March 5, 2014 e‐mail with attachment from *** to USITC auditor.  *** reported that its primary

raw material inputs are scrap, pig iron, and alloys.  March 4, 2014 e‐mail with attachment from *** to USITC

auditor.  *** listed scrap, DRI, additives, and fluxes as the primary raw material inputs.  March 6, 2014 e‐

mail with attachments (incl. revised table II‐6) from *** to USITC auditor.  ***.  March 28, 2014 e‐mail with

attachment from *** to USITC auditor.  ***.  March 7, 2014 e‐mail with attachment from counsel on behalf

of *** to USITC auditor.     42 This pattern, in general, is consistent with changes in underlying wire rod production and sales

volumes.  Other factory costs represent a combination of fixed, variable, and mixed (semi‐fixed/semi‐

variable) costs which differ by company based on factors such as manufacturing operations, product mix,

and company‐specific accounting choices regarding cost assignment.  All things being equal, the directional

trend of other factory costs (on an average basis and as a share of total COGS), would tend to be the

opposite of the directional trend of corresponding production and sales volume due to the presence of fixed

manufacturing costs and changes in fixed cost absorption.  ***.  March 5, 2014 e‐mail with attachment from

*** to USITC auditor.

In addition to fixed cost absorption, changes in the relative and absolute levels of other factory costs also

reflect additional company‐specific factors; e.g., in 2008 and 2009, ***.  March 18, 2014 e‐mail with

attachment from *** to USITC auditor.  ***.  March 7, 2014 e‐mail with attachment from counsel on behalf

of *** to USITC auditor.  ***.    
III‐19

footnote 42), other factory costs also include energy costs (e.g., electricity and natural gas) which,

to a large extent, are variable in terms of cost behavior.43  As described by *** and similar to the

pattern reported by other U.S. producers, ***.44          

Table III‐11 shows that direct labor, the smallest component of COGS, ranged from a low of

5.7 percent of total COGS in 2011 to a high of 6.6 percent in 2009.  Notwithstanding the more

variable nature of direct labor, the higher share of direct labor in 2009 is generally consistent with

lower production and sales volumes in that year.

As shown in table III‐11, overall sales volume declined substantially between 2008 and

2009, recovered somewhat between 2009 and 2011, and then declined between 2011 and 2013.  

While metal margin (the difference between average sales value and average raw material cost) as

a ratio to sales was lower in the second half of the period, the ratio increased between 2011 and

2013 (see table III‐13). 45  In general and given the pattern of metal margin, the industry’s declining

gross profitability between 2011 and 2013 appears to be more related to factors such as the direct

and indirect impact of reduced sales volume and increasing levels of other factory costs (on a

relative basis) (see note 1 to table III‐11).46   

*** reported the *** company‐specific gross profit ratios and were *** companies to

report operating losses throughout most of the period (see table III‐13).  As described by ***.47  

***.48

***, which generated the *** company‐specific gross profit ratios for most of the period,

confirmed that this pattern primarily reflects the ***.49  ***.50    

 

43 March 6, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.  March 5,

2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.  March 4, 2014 e‐mail with

attachment from *** to USITC auditor.  March 5, 2014 e‐mail with attachment from *** to USITC auditor.  

March 7, 2014 e‐mail with attachment from counsel on behalf of *** to USITC auditor.  February 28, 2014 e‐

mail with attachment from *** to USITC auditor.       44 March 4, 2014 e‐mail with attachment from *** to USITC auditor.      45 As a general term (i.e., not specific to wire rod in particular), “metal margin” usually refers to the

difference between current sales value and the corresponding relevant market price for the primary metal

input, in this case ferrous scrap.  For purposes of this report, “metal margin” refers to the difference

between average sales value and average raw material costs, as recognized for financial reporting purposes.  

As shown in Table III‐13, company‐specific metal margins were not uniform.  In addition to variations in

underlying cost classification, direct comparability of metal margin is, in all likelihood, also limited by

company‐specific differences such as the timing of raw material purchases and corresponding inventory

turnover (raw material, work in process, and finished goods).

46 For example and as shown in table III‐13, ***.  March 4, 2014 e‐mail with attachment from *** to

USITC auditor.        47 March 6, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.  ***.    48 March 4, 2014 e‐mail with attachment from *** to USITC auditor.

49 ***.  February 28, 2014 e‐mail with attachment from *** to USITC auditor.   50 March 28, 2014 e‐mail with attachment from *** to USITC auditor
III‐20

SG&A expenses and operating income or (loss)

Table III‐13 shows that larger‐volume wire rod producers reported SG&A expense ratios

(SG&A expenses divided by total revenue) which were generally in a similar range.  While company‐

specific variations in the level of SG&A expenses generally appear to be consistent with changes in

corresponding sales volume,51 several of the large‐volume producers (***) reported patterns of

SG&A expenses which appear somewhat unusual.  In response to questions regarding the pattern

of their SG&A expenses, the following explanations were provided:  ***;52  ***;53  ***.54   

As shown in table III‐11, the industry’s SG&A expense ratio peaked in 2009 (4.1 percent) and

then fluctuated somewhat lower but remained above the lowest level reported (2.3 percent in

2008).  The absence of substantial changes in the industry’s SG&A expense ratio indicates that

SG&A expenses were generally a secondary factor in terms of explaining wire rod operating results;

i.e., revenue and cost factors impacting financial results at the gross level appear to be more

important.  

Capital expenditures and research and development expenses

Table III‐14 presents capital expenditures and research and development (R&D) expenses by

firm.

Table III-14 

Wire rod: Capital expenditures and research and development expenses of U.S. producers, 2008-13 

*            *            *            *            *            *            *

***.55  ***.56  The following company‐specific capital expenditures were also noteworthy:  

***;57 and ***.58

As shown in table III‐14, R&D expenses were reported by less than half the U.S. producers

and were ***.59  ***.60  ***.61   

 

51 ***. March 6, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.  March

7, 2014 e‐mail from *** to USITC auditor.    52 March 4, 2014 e‐mail with attachment from *** to USITC auditor.

53 March 18, 2014 e‐mail with attachment from *** to USITC auditor.   54 March 12, 2014 e‐mail with attachment from counsel on behalf of *** to USITC auditor.  ***.  March

18, 2014 e‐mail with attachment from counsel on behalf of *** to USITC auditor.         55 March 7, 2014 e‐mail with attachment from counsel on behalf of *** to USITC auditor.   56 March 5, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor. 57 ***.  February 28, 2014 e‐mail with attachment from *** to USITC auditor.     58 March 4, 2014 e‐mail with attachment from *** to USITC auditor

59 March 4, 2014 e‐mail with attachment from *** to USITC auditor.

60 March 6, 2014 e‐mail with attachments (incl. revised table II‐6) from *** to USITC auditor.

61 March 7, 2014 e‐mail with attachment from counsel on behalf of *** to USITC auditor.
    

IV‐1

PART IV: U.S. IMPORTS AND THE FOREIGN INDUSTRIES

U.S. IMPORTS

Overview

In these second five‐year reviews, the Commission issued U.S. importers’ questionnaires

to approximately 125 firms believed to be importers of wire rod,1 as well as to all U.S.

producers of wire rod.2 Usable questionnaire responses were received from 37 firms:  5 firms

representing almost all U.S. imports of wire rod from Mexico in 2013 (based on proprietary

Customs information and questionnaire responses)3 and 35 firms representing 95.0 percent of

U.S. imports of wire rod from nonsubject countries (based on official U.S. import statistics for

nonsubject countries) during 2008‐13. There were no reported U.S. imports from Brazil,4

Indonesia, Moldova, Trinidad & Tobago, or Ukraine during 2013.5 U.S. imports of wire rod from

Brazil, Moldova, and Ukraine largely ceased following the imposition of duties in 2002 and the

U.S. imports of wire rod from Indonesia and Trinidad & Tobago ceased after 2005 and 2008,

respectively.

In light of the data coverage by the Commission’s questionnaires, import data in this

report are based on official Commerce statistics for wire rod imported from Trinidad & Tobago

and nonsubject sources and on questionnaire responses for wire rod imported from Mexico. All

imports of wire rod from Brazil reported in official statistics are believed to be grade 1080 tire

                                                      

1 The Commission issued questionnaires to those firms identified in the responses to the

Commission’s notice of institution, along with firms that, based on a review of data provided by U.S.

Customs and Border Protection (“Customs”), may have accounted for more than one percent of total

imports during 2008‐13 under the following HTS subheadings: 7213.91.3011, 7213.91.3015,

7213.91.3020, 7213.91.3092 (deleted on July 1, 2008), 7213.91.3093 (added on July 1, 2008),

7213.91.4500, 7213.91.6000, 7213.99.0030, 7213.99.0090, 7227.20.0000,  7227.20.0030, 7227.20.0080,

7227.90.6010,  7227.90.6020, 7227.90.6080 (deleted on July 1, 2008), and 7227.90.6085 (added on July

1, 2008).

2 None of the U.S. producers reported direct imports of wire rod.

3 Proprietary Customs information indicates that the only other sizeable importer of merchandise

from Mexico under the applicable HTS numbers for wire rod was ***. However, in response to the

Commission’s importer questionnaire, *** reported that it has not imported wire rod into the United

States from any country since January 1, 2008. 4 Import data reported for Brazil in official statistics have been reclassified in this report as

nonsubject 1080 tire cord and tire bead. 5 One U.S. importer of wire rod from Trinidad & Tobago provided a response to the Commission’s

questionnaire. (***) reported U.S. imports of *** short tons ($***) of wire rod from Trinidad & Tobago

during 2008, accounting for *** percent of total U.S. imports of wire rod from Trinidad & Tobago in

2008 based on Census data. *** is believed to have accounted for virtually all U.S. imports of wire rod

from Trinidad & Tobago during 2008. *** did not provide a response to the Commission’s importer

questionnaire.
    

IV‐2

cord and tire bead wire rod and have therefore been classified as nonsubject imports in this

report. No other subject country reported U.S. imports of the excluded grade 1080 tire cord or

tire bead based on questionnaire data. Also, U.S. imports of wire rod with a diameter of 4.75

mm to 5.00 mm shipped to the United States by Deacero in Mexico have been found by

Commerce on remand to be outside the scope of the order and have been removed from

official U.S. imports from Mexico (as well as the calculation of apparent consumption)

presented in this report.6 Certain data and other information concerning Deacero’s production

and U.S. imports and U.S. purchases of Deacero’s smaller diameter wire rod are presented

separately in appendix F.

One importer (***) reported entering or withdrawing wire rod from a foreign trade

zone. The firm, which accounted for *** percent of responding U.S. importers’ U.S. imports

from nonsubject sources during 2008‐13, provided data concerning its nonsubject U.S. imports

of wire rod from ***. Another importer (***) reported entering or withdrawing wire rod from a

bonded warehouse. The importer, which accounted for *** percent of responding U.S.

importers’ U.S. imports from nonsubject sources during 2008‐13, provided data concerning its

nonsubject U.S. imports of wire rod from ***. *** reported imports of wire rod under the

temporary importation under bond (“TIB”) program. ***.

Imports from subject and nonsubject countries

Table IV‐1 presents information on subject U.S. imports of wire rod from Brazil,

Indonesia, Mexico, Moldova, Trinidad & Tobago, Ukraine, and imports from all other sources

during 2008‐13. There were no reported U.S. imports of subject wire rod from Brazil, Indonesia,

Moldova, and Ukraine during 2008‐13 and U.S. imports of wire rod Trinidad & Tobago ceased

after 2008. During 2008, U.S. imports of wire rod from Trinidad & Tobago amounted to 21,794

short tons ($14.3 million) and accounted for *** percent of total U.S. imports of wire rod. The

quantity of imports of wire rod from Mexico, which accounted for *** percent of total U.S.

imports of wire rod in 2008, fluctuated during 2008‐13 but was higher in 2013 than in 2008.

During 2013, U.S. imports of subject wire rod from Mexico amounted to 10,333 short tons ($6.1

million) and accounted for 0.6 percent of total wire rod imports. Imports of wire rod from

nonsubject sources decreased by 49.4 percent from 2008 to 2009 but fluctuated thereafter,

reaching a level in 2013 that was 0.8 percent higher than that reported in 2008.  

Table IV‐1 also presents data on the ratio of U.S. imports to U.S. production. Imports of

wire rod from subject sources were less than *** percent of U.S. production during 2008‐13,

while imports of wire rod from nonsubject sources ranged from 29.9 to 46.2 percent of U.S.

production. Total imports of wire rod were equivalent to 46.5 percent of U.S. production in

2013, or *** percentage points higher than reported in 2008.

                                                      

6 The data presented for U.S. imports from nonsubject sources, however, are overstated by imports

of wire rod of less than 5mm in diameter imported from Canada.  ***.
    

IV‐3

Table IV-1 

Wire rod: U.S. imports, by source, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

U.S. imports from-- 

 Brazil1

 0 0 0 0 0 0

Indonesia 0 0 0 0 0 0

Mexico2 *** *** *** *** *** 10,333

Moldova 0 0 0 0 0 0

Trinidad & Tobago 21,794 0 0 0 0 0

Ukraine 0 0 0 0 0 0

 Subtotal, subject *** *** *** *** *** 10,333

1080 tire cord/bead 

from subject sources1

 139,459 71,759 129,184 116,513 102,517 96,639

All other sources3 1,536,768 777,083 1,284,771 1,059,512 1,391,895 1,593,718

 Subtotal, nonsubject 1,676,227 848,842 1,413,955 1,176,024 1,494,413 1,690,357

Total U.S. imports *** *** *** *** *** 1,700,690

 Value ($1,000) 

U.S. imports from-- 

 Brazil1 0 0 0 0 0 0

Indonesia 0 0 0 0 0 0

Mexico2 *** *** *** *** *** 6,128

Moldova 0 0 0 0 0 0

Trinidad & Tobago 14,298 0 0 0 0 0

Ukraine 0 0 0 0 0 0

 Subtotal, subject *** *** *** *** *** 6,128

1080 tire cord/bead 

from subject sources1

 126,654 50,808 91,621 103,073 84,521 64,506

All other sources3 1,360,431 550,614 988,457 992,791 1,159,903 1,156,290

 Subtotal, nonsubject 1,487,085 601,423 1,080,078 1,095,863 1,244,424 1,220,797

Total U.S. imports *** *** *** *** *** 1,226,925

 Unit value (dollars per short ton) 

U.S. imports from-- 

 Brazil1

 (4) (4) (4) (4) (4) (4) 

Indonesia (4) (4) (4) (4) (4) (4) 

Mexico2 *** *** *** *** *** 593

Moldova (4) (4) (4) (4) (4) (4) 

Trinidad & Tobago 656 (4) (4) (4) (4) (4) 

Ukraine (4) (4) (4) (4) (4) (4) 

 Subtotal, subject *** *** *** *** *** 593

1080 tire cord/bead 

from subject sources1

 908 708 709 885 824 667

All other sources3 885 709 769 937 833 726

 Subtotal, nonsubject 887 709 764 932 833 722

Total U.S. imports *** *** *** *** *** 721

Table continued on following page. 
    

IV‐4

Table IV-1--Continued 

Wire rod: U.S. imports, by source, 2008-13 

Item 2008 2009 2010 2011 2012 2013

 Share of quantity (percent)

U.S. imports from-- 

 Brazil1

 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

Mexico2 *** *** *** *** *** 0.6

Moldova 0.0 0.0 0.0 0.0 0.0 0.0

Trinidad & Tobago *** *** *** *** *** 0.0

Ukraine 0.0 0.0 0.0 0.0 0.0 0.0

 Subtotal, subject *** *** *** *** *** 0.6

1080 tire cord/bead from 

subject sources1 *** *** *** *** *** 5.7

All other sources3 *** *** *** *** *** 93.7

 Subtotal, nonsubject *** *** *** *** *** 99.4

Total U.S. imports 100.0 100.0 100.0 100.0 100.0 100.0

 Share of value (percent)

U.S. imports from-- 

 Brazil1

 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

Mexico2 *** *** *** *** *** 0.5

Moldova 0.0 0.0 0.0 0.0 0.0 0.0

Trinidad & Tobago *** 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 *** *** *** *** *** 0.5

1080 tire cord/bead from 

subject sources1 *** *** *** *** *** 5.3

All other sources3 *** *** *** *** *** 94.2

 Subtotal, nonsubject *** *** *** *** *** 99.5

Total U.S. imports 100.0 100.0 100.0 100.0 100.0 100.0

 Ratio to U.S. production (percent)

U.S. imports from-- 

 Brazil1

 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

Mexico2 *** *** *** *** *** 0.3

Moldova 0.0 0.0 0.0 0.0 0.0 0.0

Trinidad & Tobago 0.5 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 *** *** *** *** *** 0.3

1080 tire cord/bead from 

subject sources1

 3.4 2.5 3.8 3.0 2.6 2.6

All other sources3 37.9 27.4 38.0 27.1 35.9 43.6

 Subtotal, nonsubject 41.3 29.9 41.8 30.1 38.5 46.2

Total U.S. imports *** *** *** *** *** 46.5 1

 Official import statistics for Brazil have been reclassified as 1080 tire cord/tire bead imports from subject sources. 

The 1080 tire cord/bead imports are excluded from the scope, but remain as part of the domestic like product. 2

 U.S. imports from Mexico rely on questionnaire data so as to exclude U.S. imports of smaller diameter wire rod 

produced by Mexican producer Deacero. Data presented do not include imports ***. 3

 U.S. imports from nonsubject sources are overstated by imports of wire rod of less than 5mm in diameter imported 

from Canada. ***. 

4

 Undefined. 

Source: Compiled from data submitted in response to Commission questionnaires and from official statistics of the 

U.S. Department of Commerce.
    

IV‐5

Table IV‐2 presents data for U.S. imports of wire rod from the top ten nonsubject

sources. Imports of wire rod from all nonsubject sources combined fell from 2008 to 2009 but

fluctuated upward from 2009 to 2013. The leading nonsubject source of wire rod imports

during 2013 was China; such imports currently are subject to ongoing antidumping and

countervailing duty investigations.7 U.S. imports from China, which accounted for 36.4 percent

of total imports in 2013, fluctuated during 2008‐13. U.S. imports from China were 49.1 percent

higher in 2013 than in 2008. Other leading sources of wire rod imports from nonsubject

countries include Canada and Japan, which accounted for 28.3 and 15.1 percent of total

imports in 2013, respectively.

                                                      

7 Carbon and Certain Alloy Steel Wire Rod from China, Inv. Nos. 701‐TA‐512 and 731‐TA‐1248

(Preliminary), USITC Publication 4458 (March 2014). The Commission made affirmative preliminary

determinations on March 20, 2014 (79 FR 16373, March 25, 2014).
    

IV‐6

Table IV-2 

Wire rod: Imports from nonsubject countries and nonsubject wire rod, by source, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

U.S. imports from-- 

 China 415,125 8,416 16,931 357 242,047 618,818

Canada1 535,752 342,094 542,513 501,045 491,132 480,813

Japan 232,038 125,007 216,463 236,084 262,275 257,503

Brazil2 139,459 71,759 129,184 116,513 102,517 96,639

Germany 124,567 44,529 60,308 91,892 72,565 73,016

United Kingdom 13,314 26,960 56,422 46,323 70,107 56,395

Korea 18,020 13,461 16,687 9,868 25,575 37,567

Turkey 148,332 97,057 189,372 109,574 165,819 33,182

Spain 6,129 18,594 36,623 19,574 28,743 32,725

South Africa 0 0 28,188 11,454 11,316 1,629

All other sources 43,491 100,965 121,263 33,342 22,316 2,070

Nonsubject imports 1,676,227 848,842 1,413,955 1,176,024 1,494,413 1,690,357

 Share of total imports (percent)

3

U.S. imports from-- 

 China *** *** *** (4) *** 36.4

Canada *** *** *** *** *** 28.3

Japan *** *** *** *** *** 15.1

Brazil2 *** *** *** *** *** 5.7

Germany *** *** *** *** *** 4.3

United Kingdom *** *** *** *** *** 3.3

Korea *** *** *** *** *** 2.2

Turkey *** *** *** *** *** 2.0

Spain *** *** *** *** *** 1.9

South Africa *** *** *** *** *** 0.1

All other sources *** *** *** *** *** 0.1

Nonsubject imports *** *** *** *** *** 99.4

1

 U.S. imports from nonsubject sources are overstated by imports of wire rod of less than 5mm in 

diameter imported from Canada. ***. 

2

 Consistent with the treatment in table IV-1, all U.S. imports from Brazil have been classified as 

nonsubject 1080 tire cord/tire bead quality merchandise. 

3

 Total U.S. imports are presented in table IV-1. 

4

 ***. 

Source: Compiled from data submitted in response to Commission questionnaires and from official 

statistics of the U.S. Department of Commerce. 
    

IV‐7

U.S. SHIPMENTS OF IMPORTS, BY APPLICATION

Table IV‐3 presents responding U.S. importers’ U.S. shipments of imports, by type and

source, in 2013. *** firms reported subject U.S. imports of wire rod from Mexico during 2013,

*** of which were high/medium‐high or low/medium‐low carbon industrial/standard quality

wire rod. Thirty‐one U.S. importers of wire rod from nonsubject sources reported data

concerning their U.S. shipments, by type, during 2013. Slightly more than one‐half of these U.S.

shipments were high/medium‐high or low/medium‐low carbon industrial/standard quality wire

rod and about one‐quarter were CHQ wire rod. U.S. importers also reported smaller amounts of

welding, tire cord/tire bead, and other specialty carbon and alloy quality wire rod from

nonsubject sources during 2013.

Table IV-3 

Wire rod: U.S. importers’ U.S. shipments, by type, 2013 

Item 

Quantity 

(short tons) 

Share 

(percent) 

Number of 

reporting firms

Mexico 

Low/medium-low carbon industrial/standard quality *** *** ***

High/medium-high carbon industrial/standard quality *** *** ***

Tire cord or tire bead quality *** *** ***

Welding quality *** *** ***

Cold heading quality (“CHQ”) *** *** ***

Other specialty carbon and alloy quality *** *** ***

All other wire rod *** *** ***

 Total, U.S. shipments *** *** ***

Nonsubject

Low/medium-low carbon industrial/standard quality 457,004 34.2 15

High/medium-high carbon industrial/standard quality 250,825 18.8 11

Tire cord or tire bead quality 69,811 5.2 8

Welding quality *** *** ***

Cold heading quality (“CHQ”) 340,682 25.5 8

Other specialty carbon and alloy quality *** *** ***

All other wire rod *** *** ***

 Total, U.S. shipments 1,334,336 100.0 31

Source: Compiled from data submitted in response to Commission questionnaires. 
    

IV‐8

U.S. IMPORTERS’ IMPORTS SUBSEQUENT TO DECEMBER 31, 2013

The Commission requested importers to indicate whether they had imported or

arranged for the importation of wire rod for delivery after December 31, 2013. Twenty‐six

importers reported that they imported or arranged for imports of wire rod in 2014 and eight

indicated they had no such arrangements. Table IV‐4 presents data reported by U.S. importers

concerning their arranged imports of wire rod.

Table IV-4 

Wire rod: U.S. importers' arranged imports, 2014 

Item 

2014 

Jan-Mar Apr-June July-Sept Oct-Dec 

Quantity (short tons) 

U.S. importers' imports arranged from--

 Brazil 0 0 0 0

 Indonesia 0 0 0 0

 Mexico *** *** 0 0

 Moldova 0 0 0 0

 Trinidad & Tobago 0 0 0 0

 Ukraine 0 0 0 0

 All other sources1 278,358 238,743 25,307 25,376

 Total, all sources *** *** 25,307 25,376

1

 Other sources reported are: ***. 

Source: Compiled from data submitted in response to Commission questionnaires. 
    

IV‐9

U.S. IMPORTERS’ INVENTORIES

Table IV‐5 presents data for inventories of U.S. imports of wire rod in the United States.

As the data illustrate, inventories of subject imports were present in the United States in minor

quantities only during 2008 and 2011. *** accounted for all of the inventories of subject

imports from Trinidad & Tobago held in the United States during *** and *** accounted for all

of the inventories of subject imports from Mexico held in the United States during ***. These

inventories accounted for less than *** percent of U.S. shipments of such imports during 2008‐

13 as reported by responding U.S. importers. The inventory levels of nonsubject imports were

higher than subject imports, and were equivalent to between 4.6 and 8.8 percent of U.S.

shipments of such imports during 2008‐13. Nineteen importers of wire rod from nonsubject

sources reported holding inventories. During 2013, the leading nonsubject importers holding

inventories of wire rod in the United States were ***.  

Table IV-5 

Wire rod: U.S. importers’ end-of-period inventories of imports, by source, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

Imports from Mexico: 

 Inventories (short tons) *** *** *** *** *** ***

 Ratio to U.S. imports (percent) *** *** *** *** *** ***

 Ratio to U.S. shipments of imports (percent) *** *** *** *** *** ***

Imports from Trinidad & Tobago: 

 Inventories (short tons) *** *** *** *** *** ***

 Ratio to U.S. imports (percent) *** *** *** *** *** ***

 Ratio to U.S. shipments of imports (percent) *** *** *** *** *** ***

Imports from nonsubject sources: 

 Inventories (short tons) 106,455 61,033 72,308 61,769 90,584 105,991

 Ratio to U.S. imports (percent) 8.3 9.4 6.7 6.9 4.5 7.8

 Ratio to U.S. shipments of imports (percent) 8.5 8.8 6.8 6.8 4.6 7.9

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 compete with each other and with the

domestic like product and has generally considered four factors: (1) fungibility, (2) presence of

sales or offers to sell in the same geographical markets, (3) common or similar channels of

distribution, and (4) simultaneous presence in the market. Additional information concerning

fungibility, geographical markets, and simultaneous presence in the market is presented below.

Fungibility

Different countries sell different ranges of wire rod grades in the United States. U.S.

producers’ and U.S. importers’ U.S. shipments, by type, for 2013 were presented earlier in this
    

IV‐10

report at tables III‐7 and IV‐3. The first two categories, low and medium‐low carbon industrial

and standard quality wire rod, and high and medium‐high carbon industrial and standard

quality wire rod (other than tire cord and tire bead) are typically classified as “standard,”

“commodity,” or “industrial” grades. The next four categories, tire cord and tire bead wire rod,

welding quality wire rod, CHQ wire rod, and other specialty carbon and alloy quality wire rod,

are considered “specialty quality” or “specialty” grades. The remaining “all other” category

includes any other types of wire rod.  

During 2013, 77.0 percent of U.S. producers’ total U.S. shipments were of the standard

grades. The remaining 23.0 percent of total U.S. shipments were comprised of specialty grades,

which were dominated by CHQ wire rod, with lesser amounts of tire cord/tire bead, welding,

and other specialty carbon and alloy quality wire rod. *** firms reported subject U.S. imports of

wire rod from Mexico during 2013, *** of which were high/medium‐high or low/medium‐low

carbon industrial/standard quality wire rod.  

Presence in the market

As previously indicated, there were no U.S. imports of subject wire rod from Brazil,

Indonesia, Moldova, or Ukraine during 2008‐13. According to official import statistics for

calendar year 2008, subject wire rod was imported into the United States from Trinidad &

Tobago during four months of the year and subject wire rod was imported into the United

States from Mexico during nine months of that year. Subject U.S. imports from Mexico entered

the U.S. market during at least nine months during 2009‐13 (i.e., nine months of 2009, eleven

months of 2010, ten months of 2011, and 12 months of 2012 and 2013).8

Geographical markets9

As noted previously, wire rod produced in the United States is shipped nationwide.

During 2008, imports from Trinidad & Tobago entered the United States through New Orleans,

Louisiana; Philadelphia, Pennsylvania; and San Juan, Puerto Rico. During 2008‐13, imports from

Mexico entered the United States through Laredo and El Paso, Texas; Los Angeles, California;

Nogales, Arizona; Seattle, Washington; New Orleans, Louisiana; and Mobile, Alabama. The vast

majority of imports from Mexico entered through Laredo, Texas.

                                                      

8 The analysis of the monthly presence of Mexican wire rod in the U.S. market excludes ***

nonsubject smaller diameter wire rod. ***.

9 Additional information on geographic markets may be found in Part II of this report.
    

IV‐11

SUBJECT COUNTRY PRODUCERS

Table IV‐6 presents 2013 capacity, production, and export data, for the subject

countries, based on data from questionnaires, GTIS/GTA export data, and ***.  

Table IV-6 

Wire rod: Comparison of capacity, production, net capacity changes, exports, and net exports, in subject 

countries, 2013 

Item 

Capacity Production Net capacity change (2008-13)

Published Reported Published Reported Published Reported

 Quantity (1,000 short tons)

Brazil *** *** *** *** *** ***

Indonesia *** *** *** *** *** ***

Mexico *** 2,758 *** 2,345 *** 341

Moldova *** ***1 ***1 ***1 *** ***1

Trinidad & Tobago *** *** ***2 *** *** ***

Ukraine *** *** *** *** *** ***

 Total *** *** *** *** *** ***

Item 

Exports Net exports

Published Reported Published

 Quantity (1,000 short tons)

Brazil 293 *** (56)

Indonesia 563 *** (456)3

Mexico 361 380 319

Moldova 1024 (

1

) 904

Trinidad & Tobago 1214 *** 1194

Ukraine 1,454 *** 1,420 1

 The “reported” capacity data presented for Moldova in this table are data published by *** because Moldova Steel 

Works, the sole producer of wire rod in Moldova, did not provide a response to the Commission’s questionnaire in 

these reviews. The “published” and “reported” production data presented are an estimate provided by the domestic 

interested parties in their response to the notice of institution. Global Trade Information Systems Inc., Global Trade 

Atlas (GTIS/GTA), does not publish external trade data for Moldova. 2

 The “published” production data presented for Trinidad & Tobago are those reported by the Trinidadian producer in 

response to the Commission’s questionnaire because country-specific production data for Trinidad & Tobago are not 

prepared and published by ***. GTIS/GTA does not publish external trade data for Trinidad & Tobago. 3

 Export and net export data presented for Indonesia (published) are for 2012, the most recent available year. 4

 Data for Moldova’s and Trinidad & Tobago’s imports and exports were constructed from the reported exports and 

imports, respectively, of their trading partners whose data were reported to GTIS/GTA. 

Note.—GTIS/GTA export and net export data presented may include grade 1080 tire cord and tire bead wire rod. 

Note.—The data presented above are compiled from common sources to maintain data consistency. However, these 

data do not include capacity estimates for the operations of Master Steel of Indonesia or for Simec and Talleres y 

Aceros of Mexico. Moreover, published data do include capacity for certain operations for which the production of 

wire rod is uncertain or disputed (see below). 

Source: “Published” data from *** and GTIS/GTA (HS 7213.91 (Bars And Rods, Hot-Rolled, In Irregularly Wound 

Coils, Of Iron Or Nonalloy Steel, Of Circular Cross-Section Measuring Less Than 14 Mm In Diameter), 7213.99 

(721399, Bars And Rods, Hot-Rolled, In Irregularly Wound Coils, Of Iron Or Nonalloy Steel, nesoi), 7227.20 (Bars 

And Rods Of Silico-Manganese Steel, Hot-Rolled, In Irregularly Wound Coils), and 7227.90 (Bars And Rods Of Alloy 

Steel (Other Than Stainless), Hot-Rolled, In Irregularly Wound Coils); “Reported” data from Commission 

questionnaire responses. 
    

IV‐12

The Commission asked U.S. importers and producers of wire rod in the subject countries

to identify tariff or nontariff barriers to trade (for example, antidumping or countervailing duty

findings or remedies, tariffs, quotas, or regulatory barriers) concerning their exports of wire rod

to countries other than the United States. The Commission also asked the subject foreign

producers to identify ongoing investigations in countries other than the United States that

could result in tariff or non‐tariff barriers to trade for their exports of wire rod. Responding

firms provided the following information concerning barriers to trade:

 Colombia is currently conducting a global safeguard investigation on wire rod,

as well as rebar and wire round. Although a final determination has not been

issued, Colombia imposed a provisional safeguard tariff of 21.29 percent on

imports of wire rod in 2013.  

 Malaysia imposed an antidumping duty order against imports of wire rod from

Indonesia in 2013.  According to Malaysia’s Ministry of International Trade and

Industry, the antidumping duty rates were nil for P.T. Ispat Indo and 25.20

percent for all other producers and exporters.

 Mexico imposed an antidumping duty order against wire rod imports from

Ukraine.  

 There are ongoing antidumping investigations in Russia, Belarus, and

Kazakhstan concerning wire rod produced in Ukraine.

 Australia initiated an investigation into alleged dumping of rod in coils from

Indonesia, Taiwan, and Turkey, according to anti‐dumping notice 2014/27,

published on April 10, 2014.
    

IV‐13

THE INDUSTRY IN BRAZIL

Overview

During the original investigations, the Commission identified five producers of wire rod

in Brazil. Three firms, accounting for *** percent of Brazilian production of wire rod, provided

data in response to the Commission's questionnaire in the original investigations: Barra Mansa,

Belgo‐Mineira (“Belgo”), and Gerdau. Barra Mansa estimated that it accounted for *** percent

of Brazilian production in 2001, Belgo estimated that it accounted for *** percent, and Gerdau

estimated that it accounted for *** percent. The three responding Brazilian firms collectively

accounted for all exports of the subject merchandise from Brazil to the United States.10  

Responses to the Commission's foreign producer questionnaire in the Commission’s first

five‐year reviews were received from ArcelorMittal Brasil (successor to Belgo) and Gerdau

(Aҫominas and Aҫos Longos), while Barra Mansa, part of Votorantim Metais’ Steel Business

Unit, did not respond. ArcelorMittal Brasil estimated that it accounted for *** percent of

Brazilian production in 2007, and Gerdau estimated that it accounted for *** percent of

production of wire rod in Brazil during that year, totaling *** percent coverage of the wire rod

industry in Brazil.11  

The following five firms were identified by parties as currently operating producers of

wire rod in Brazil in these current second five‐year reviews: ArcelorMittal Brasil, Votorantim

Metals/Barra Mansa, Companhia Siderúrgica Nacional (“CSN”), Gerdau Aҫos Brasil, and Villares

Metals.12 Gerdau Aҫos Brasil and ArcelorMittal Brasil together are estimated to account for ***

percent of total wire rod capacity in Brazil. Gerdau Aҫos Brasil is believed to be the largest wire

rod producer in Brasil, accounting for *** percent of total wire rod rolling capacity during 2013

according to data published by ***. ArcelorMittal Brasil, the second largest wire rod producer

in Brazil, was the only wire rod producer in Brazil that responded to the Commission's foreign  

                                                      

10 The following 2001 data were provided by the three responding Brazilian firms in the original

investigations: capacity (*** short tons); production (*** short tons); capacity utilization (*** percent);

exports/shipments (*** percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008

(INV‐FF‐058), table IV‐14. 11 The following 2007 data were provided by the two responding Brazilian firms in the first five‐year

reviews: capacity (*** short tons); production (*** short tons); capacity utilization (*** percent);

exports/shipments (*** percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008

(INV‐FF‐058), table IV‐14. 12 *** reports that CSN does not currently have the capacity to produce wire rod in Brazil but is

expected to have *** short tons of capacity in 2014. The following additional firm in Brazil was identified

by *** as having wire rod rolling capacity during 2013: *** (approximately *** short tons of capacity).

*** estimated that this firm accounted for approximately *** percent of total wire rod rolling capacity

in Brazil during 2013.
    

IV‐14

producer questionnaire in these second five‐year reviews.13 There were no reported exports of

the subject merchandise to the United States during 2008‐13.14 According to ***, production in

Brazil during 2013 was *** short tons. Reported production by ArcelorMittal Brasil was ***

short tons, yielding a theoretical coverage of *** percent of Brazilian production during 2013 by

the responding firm. *** firm‐by‐firm capacity data indicate that ArcelorMittal Brasil accounted

for *** percent of total wire rod rolling capacity in Brazil during 2013. Total wire rod rolling

capacity and production data reported by *** include grade 1080 tire cord and tire bead wire

rod, which are believed to have accounted for all exports of wire rod to the United States

during 2008‐13.15  

Table IV‐7 presents data published by *** on overall Brazilian capacity, production, and

consumption of wire rod.  Also presented in the tabulation are calculated net exports/imports

(i.e., production minus consumption).16

Table IV-7 

Wire rod: Overall Brazilian capacity, production, consumption, and calculated net exports/imports 

*                    *                    *                    *                    *                    *                    *

The *** data show that although capacity increased from 2008 to 2009, it remained

constant thereafter. According to ***, there was an increase in the wire rod rolling capacity in

Brazil in the amount of *** short tons during 2008‐13 and projections indicate that the capacity

to produce wire rod in Brazil are expected to climb in 2014 and 2015. Three new mills were

forecasted to come online in Brazil during 2014‐15. The three mills are GV do Brasil in

Pindamonhangaba (2014), CSN in Volta Redonda (2014), and Siderurgica Latino‐Americana S/A

(Silat) in Caucaia (2015), with an estimated combined capacity of approximately *** short tons

in 2014 and *** short tons in 2015. In addition, the Brazilian group Vetorial is the corporate

entity to which the Paraguayan government reportedly plans to lease the Aceros del Paraguay

                                                      

13 Numerous attempts were made by Commission staff to contact Gerdau Aҫos Brasil directly and

through its U.S. affiliate, domestic producer Gerdau Ameristeel, in order to secure a questionnaire

response. However, the firm did not provide a response to the Commission’s foreign producer

questionnaire. 14 As previously noted in this report, U.S. imports of subject wire rod from Brazil largely ceased

following the imposition of duties in 2002. Table IV‐1 indicates that there are believed to have been no

U.S. imports of subject wire rod during 2008‐13.

15 According to Customs data, more than *** percent of imports reported from Brazil was imported

from ***. No antidumping duties were levied against those entries and ***. Therefore, official import

statistics are believed to be 1080 tire cord/bead or other nonsubject wire rod and have been reclassified

as such for purposes of this report.

16 This calculation may differ from GTA data on exports and imports, primarily due to rounding.
    

IV‐15

(Acepar) S.A. mill,17 with production of wire rod and concrete reinforcing bar intended for both

the Brazilian and Paraguayan markets.18  

According to ***, production and consumption of wire rod in Brazil fluctuated upward

from 2009 to 2013 and are expected to increase further in 2014 and 2015. Capacity reported by

*** for 2013 for all Brazilian producers was *** short tons, and production was *** short tons,

or *** percent of published capacity. Brazilian production of wire rod exceeded consumption in

2009‐11, while consumption exceeded production in 2012‐13. *** projections for production

and consumption in Brazil indicate that it will once again become a net exporter of wire rod

during 2014‐15.  

Operations on wire rod

Data provided by ArcelorMittal Brasil concerning its wire rod operations in Brazil during

calendar years 2008‐13 are presented in table IV‐8.  

Table IV-8 

Wire rod: Brazilian producer ArcelorMittal Brasil’s capacity, production, shipments, and 

inventories, 2008-13 

*                    *                    *                    *                    *                    *                    *

ArcelorMittal Brasil’s capacity and production

As previously noted, *** data indicate that ArcelorMittal Brasil accounted for ***

percent of total wire rod rolling capacity in Brazil during 2013. ArcelorMittal Brasil’s capacity to

produce wire rod in Brazil, which was based on operating *** hours per week and *** weeks

per year, remained constant at *** short tons during 2008‐13. The firm’s production fluctuated

during 2008‐13, but was *** percent lower at *** short tons in 2013 than reported in 2008.

Capacity utilization was *** percent during 2013 and ranged between *** and *** percent

during 2008‐13.

                                                      

17 Acepar’s integrated mill, located in Villa Hayes, Paraguay, produces wire rod with diameters

ranging from 5.5 mm to 12.0 mm. See: “Acepar, “Productos, Alambrones para trefileria” (“Products,

Wire rods for wire drawing”), http://www.acepar.com.py/productos.html (in Spanish).

18 The Paraguayan government took over the Acepar mill, which was previously privatized in 1997, as

the operators were unable to meet the privatization obligations to increase output of wire rod and

concrete reinforcing bar. Acepar’s capacity utilization rate declined in each successive year since 2006,

to only *** percent of its *** metric tons (*** short tons) of annual production capacity by 2013. ***.
    

IV‐16

In addition to the production of wire rod, ArcelorMittal Brasil reported the production

of *** using shared equipment and machinery in its facilities in Brazil. Table IV‐9 presents

ArcelorMittal Brasil’s overall capacity and production of wire rod and other products produced

on the same production equipment used to produce wire rod.  

Table IV-9 

Wire rod: Brazilian producer ArcelorMittal Brasil’s overall capacity, production, and capacity 

utilization, 2008-13 

*                    *                    *                    *                    *                    *                    *

ArcelorMittal Brasil estimated that wire rod accounted for *** percent of its 2013 total

sales. The overall production data presented indicate that wire rod accounted for between ***

and *** percent of the firm’s overall production on the same machinery and equipment as wire

rod during 2008‐13. *** was reported by the firm to be the constraint that set the limit on its

production capacity and *** was the constraint that set the limit on its ability to shift

production capacity between products. ArcelorMittal Brasil reported ***. It explained ***. It

estimated ***. The Brazilian producer reported that ***.

Shipments of wire rod produced in Brazil

ArcelorMittal Brasil’s total shipments of wire rod fell overall by *** percent from 2008

to 2013. The firm’s internal consumption and home market together accounted for the majority

of the firm’s total shipments of wire rod, and an increasing share during 2008‐13. During 2013,

internal consumption and home market shipments accounted for *** percent of the firm’s total

shipments of wire rod.

ArcelorMittal Brasil’s export shipments of wire rod decreased absolutely overall from

*** short tons in 2008 to *** short tons in 2013. The firm reported that there were no exports

of subject wire rod to the United States during 2008‐13. ArcelorMittal Brasil reported that its

principal *** markets include ***, its principal *** markets include ***, and that its *** export

markets include ***.  

Detailed information on the export destinations for Brazilian wire rod as published by

the Global Trade Information Systems Inc., Global Trade Atlas (GTIS/GTA), is presented in table

IV‐10. These data include grade 1080 tire cord and tire bead, which is not subject to these

reviews, and are therefore overstated.
    

IV‐17

Table IV-10 

Wire rod: Brazil’s exports, by destination, 2008-13 

Destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

United States 144,438 79,433 125,993 114,440 102,006 105,979 

Argentina 19,978 29,766 25,225 23,505 10,865 24,729 

Korea 28,703 8,756 35,700 45,308 18,345 22,421 

Chile 20,890 12,510 17,809 2,603 3,831 20,835 

Malaysia - 2,163 13,098 9,793 13,265 14,247 

Canada 18,755 12,426 18,346 34,278 28,372 12,732 

Colombia 83,618 75,003 50,125 45,989 29,350 10,542 

Peru 70,159 56,841 26,666 14,017 6,087 9,845 

Portugal 10,623 15,344 8,009 4,453 2,348 8,975 

Nigeria - 36,596 - 440 5,510 7,647 

All other 253,626 375,587 185,398 186,218 53,480 54,554 

World 650,790 704,426 506,372 481,044 273,459 292,505 

 Value ($1,000)

United States 120,679 48,512 82,639 94,688 76,714 65,759 

Argentina 14,871 13,082 14,771 15,392 7,456 15,389 

Korea 19,286 4,038 25,250 40,144 14,880 15,017 

Chile 13,774 5,157 9,991 1,642 2,259 11,338 

Malaysia - 1,127 7,800 7,989 10,797 10,586 

Canada 12,653 6,421 9,575 23,678 20,422 8,059 

Colombia 60,343 32,783 27,232 27,578 17,522 5,769 

Peru 53,147 25,049 14,363 9,130 3,695 5,446 

Portugal 8,553 7,415 4,993 3,107 1,470 4,055 

Nigeria - 14,781 - 236 2,949 4,057 

All other 198,767 163,159 107,180 124,643 35,730 33,078 

World 502,073 321,524 303,792 348,227 193,894 178,553 

Table continued on the following page. 
    

IV‐18

Table IV-10--Continued 

Wire rod: Brazil’s exports, by destination, 2008-13 

Destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Unit value (per short ton) 

United States 836 611 656 827 752 620 

Argentina 744 439 586 655 686 622 

Korea 672 461 707 886 811 670 

Chile 659 412 561 631 590 544 

Malaysia - 521 595 816 814 743 

Canada 675 517 522 691 720 633 

Colombia 722 437 543 600 597 547 

Peru 758 441 539 651 607 553 

Portugal 805 483 623 698 626 452 

Nigeria - 404 - 535 535 531 

All other 784 434 578 669 668 606 

World 771 456 600 724 709 610 

 Share of quantity (percent) 

United States 22.2 11.3 24.9 23.8 37.3 36.2 

Argentina 3.1 4.2 5.0 4.9 4.0 8.5 

Korea 4.4 1.2 7.1 9.4 6.7 7.7 

Chile 3.2 1.8 3.5 0.5 1.4 7.1 

Malaysia - 0.3 2.6 2.0 4.9 4.9 

Canada 2.9 1.8 3.6 7.1 10.4 4.4 

Colombia 12.8 10.6 9.9 9.6 10.7 3.6 

Peru 10.8 8.1 5.3 2.9 2.2 3.4 

Portugal 1.6 2.2 1.6 0.9 0.9 3.1 

Nigeria - 5.2 - 0.1 2.0 2.6 

All other 39.0 53.3 36.6 38.7 19.6 18.7 

World 100.0 100.0 100.0 100.0 100.0 100.0 

Note.-Data include grade 1080 tire cord and tire bead. 

Source: Compiled from GTIS/GTA, as reported by the Foreign Trade Secretariate SECEX in Brazil to 

GTIS (HS codes 7213.91, 7213.99, 7227.20, and 7227.90). 
    

IV‐19

ArcelorMittal Brasil’s shipments, by type

Table IV‐11 presents data on ArcelorMittal Brasil’s total shipments, by type, during

2013. As the data indicate, high/medium‐high carbon industrial/standard quality wire rod and

low/medium‐low carbon industrial/standard quality wire rod together accounted for

approximately *** of ArcelorMittal Brasil’s total shipments during 2013.  

Table IV-11 

Wire rod: ArcelorMittal Brasil’s total shipments, by type, 2013 

*                    *                    *                    *                    *                    *                    *

THE INDUSTRY IN INDONESIA

Overview

Seven producers of wire rod in Indonesia were identified in the Commission's original

investigations. Data presented in the Commission’s final report were obtained from one

producer, PT Ispat Indo, which reported that it accounted for *** percent of Indonesian wire

rod production and *** percent of exports to the United States in 2001.19 In the first five‐year

reviews, the Commission received no questionnaire responses from Indonesian producers.20  

According to ***, there are six firms in Indonesia that maintain wire rod rolling capacity:

Gunung Garuda in Bekasi (estimated *** short tons of capacity), PT Ispat Indo in Surubaya

(estimated *** short tons of capacity),21 PT Krakatau Steel in Cilegon and Growth Sumatra in

Medan (each estimated at *** short tons of capacity), Hanil Jaya Metalworks in Surabaya

(estimated *** short tons of capacity), and Budidharma Jakarta in Jakarta (estimated *** short

tons of capacity).22 A second published source, SBB’s The World Steel Capacity Book 2010,

identified PT Ispat Indo, Krakatau, and a producer not identified by ***, Master Steel – as

                                                      

19 The following 2001 data were provided by PT Ispat Indo in the original investigations: capacity (***

short tons); production (*** short tons); capacity utilization (*** percent); exports/shipments (***

percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008 (INV‐FF‐058), table IV‐22.

20 The following published *** 2007 data for Indonesia were presented in the Commission’s first five‐

year review staff report, as no questionnaire responses were provided by Indonesian producers:

capacity (*** short tons); production (*** short tons); capacity utilization (*** percent); and

exports/shipments (*** percent). Staff Report, May 15, 2008 (INV‐FF‐058), table IV‐14. 21 PT Ispat Indo’s reported capacity of *** short tons is larger than reported by ***. 22 According to company websites for Growth Sumatra and Hanil Jaya, these firms may produce bar

rather than wire rod. Growth Steel company website, http://gs.growthsteelgroup.com/fm_encrypt.php,

accessed on May 3, 2014; Hanil Jaya company website,

http://www.haniljayasteel.com/main/page4.html , accessed on May 3, 2014. No company website was

found for Budidharma Jakarta.
    

IV‐20

producers in Indonesia with annual capacities of approximately *** tons, plus a smaller fourth

producer, Gunung Steel.23

PT Ispat lndo, which was identified by domestic interested parties to be the largest wire

rod producer in Indonesia today,24 responded to the Commission’s foreign producer

questionnaire in these second five‐year reviews. There were no reported exports of the subject

merchandise to the United States during 2008‐13.25 According to ***, production in Indonesia

during 2013 was *** short tons. Reported production by PT Ispat Indo was *** short tons,

yielding a theoretical coverage of *** percent of Indonesian production during 2013 by the

responding firm. *** firm‐by‐firm capacity data indicate that PT Ispat Indo accounted for ***

percent of total wire rod rolling capacity in Indonesia during 2013, although this figure is based

on capacity calculated for the six firms identified earlier, and does not include Master Steel.

Table IV‐12 presents data published by *** on Indonesian capacity, production, and

consumption of wire rod.  Also presented in the tabulation are calculated net exports/imports

(i.e., production minus consumption).26      

Table IV-12 

Wire rod: Overall Indonesian capacity, production, consumption, and calculated net 

exports/imports 

*                    *                    *                    *                    *                    *                    *

These data indicate that capacity in Indonesia has remained unchanged at *** short

tons since at least 2008 and projections indicate no changes in capacity during 2014 and 2015.

Production of wire rod in Indonesia increased from 2009 to 2011 but was lower in 2013.

Projections indicate that production of wire rod is expected to once again increase during 2014

                                                      

23 Krakatua Steel’s wire rod mill began operating in 1979 with a production capacity of 200,000

(metric) tons per year. Following modifications and expansions during 1992‐99, the mill is capable of

producing 450,000 (metric) tons of wire rod per year.  According to its 2013 annual report, the company

produced 220,269 (metric) tons of wire rod in 2013 and sold 223,899 (metric) tons domestically, with no

export sales.  The company accounts for an estimated 22 percent of the Indonesian wire rod market.  

Krakatau Steel, “About Us / Production Facilities,” found at http://www.krakatausteel.com; Krakatau

Steel, “Challenges for Stronger Growth,” 2013 annual report, pp. 50, 52, and 66. Master Steel (PT The

Master Steel Mfc) was established in 1972 and sells “high quality wire rod in different sizes, grades and

standards” that are “produced to international specifications.” Master Steel, “Products / Wire,” found at

http://www.themastersteel.com. The company is believed by one published source to have 500,000

metric tons of wire rod capacity at its Jakarta facility, with an unconfirmed additional wire rod mill in

Gresik, East Java.  The company reports an on‐going modernization and expansion project including a

500,000 (metric) ton wire‐rod and bar combi‐mill, expected to increase capacity in 2014.  Master Steel,

“Brief Profile” found at http://www.themastersteel.com; SBB, The World Steel Capacity Book 2012, p. 2;

and “Indonesia’s Master Steel adding new long plants,” Steel Business Briefing, 21 September 2007.

24 Response of the Domestic Interested Parties, July 2, 2013, p. 21.

25 As previously noted in this report, U.S. imports of wire rod from Indonesia ceased after 2005.

26 This calculation may differ from GTA data on exports and imports, primarily due to rounding.
    

IV‐21

and 2015. Capacity reported by *** for 2013 for all Indonesian producers was *** short tons,

and production was *** short tons, yielding a capacity utilization of *** percent. Since 2010,

Indonesia consumed more wire rod than it produced and projections indicate that Indonesia

will remain a net importer of wire rod during 2014‐15.  

Operations on wire rod

Data provided by PT Ispat Indo concerning its wire rod operations in Indonesia during

calendar years 2008‐13 are presented in table IV‐13.  

Table IV-13 

Wire rod: Indonesian producer PT Ispat Indo’s capacity, production, shipments, and inventories, 

2008-13 

*                    *                    *                    *                    *                    *                    *

PT Ispat Indo’s capacity and production in Indonesia

As previously noted, *** data indicate that PT Ispat Indo accounted for *** percent of

total wire rod rolling capacity in Indonesia during 2013. According to ***, there has been no

change in the wire rod rolling capacity in Indonesia during 2008‐13. In fact, PT Ispat Indo’s

capacity to produce wire rod in Indonesia, which was based on operating *** hours per week

and *** weeks per year, remained constant at *** short tons during 2008‐13. The firm’s

production fluctuated during 2008‐13, but was *** percent lower at *** short tons in 2013

than reported in 2008. Capacity utilization was *** percent during 2013 and ranged between

*** and *** percent during 2008‐13.

PT Ispat Indo reported the production of no other products in addition to wire rod using

shared equipment and machinery in its facilities in Indonesia. PT Ispat Indo estimated that wire

rod accounted for *** percent of its 2013 total sales. The firm reported *** set the limit on its

production capacity and that since it produces no other products it does not shift production

capacity between products. It added *** limit the availability to shift such production. PT Ispat

Indo reported ***. The firm further reported ***. The Indonesia producer reported that ***.

The firm explained ***.

Shipments of wire rod produced in Indonesia

PT Ispat Indo’s total shipments of wire rod fell from 2008 to 2010, increased in 2011,

and fell thereafter. The firm’s total shipments fell overall by *** percent from 2008 to 2013.

The firm’s home market shipments accounted for the majority of the firm’s total shipments of

wire rod and an increasing share during 2008‐13. During 2013, internal consumption and home

market shipments accounted for *** percent of the firm’s total shipments of wire rod.

PT Ispat Indo’s export shipments of wire rod have fallen absolutely and as a share of

total shipments overall from *** percent in 2008 to *** percent in 2013. The firm reported that

there were no exports of subject wire rod to the United States or the European Union during
    

IV‐22

2008‐13. Principal *** markets for PT Ispat Indo’s wire rod include *** and *** export markets

include ***.  

Detailed information on the export destinations for Indonesian wire rod as published by

the GTIS/GTA for 2008‐12 is presented in table IV‐ 14.27 These data include grade 1080 tire cord

and tire bead, which is not subject to these reviews, and may therefore be overstated.

Table IV-14 

Wire rod: Indonesia’s exports, by destination, 2008-12

Destination 

Calendar year 

2008 2009 2010 2011 2012 

 Quantity (short tons) 

Australia 26,590 20,423 7,343 33,308 31,832 

Bangladesh 5,464 7,726 7,509 12,911 11,498 

Pakistan 4,944 11,208 14,166 12,062 2,402 

New Zealand 3,337 2,112 3,751 2,907 1,751 

United Arab Emirates 6,212 - - - 1,720 

Philippines 9,177 5,843 5,010 10,364 1,580 

Malaysia 2,310 - 56 16,445 1,239 

Sri Lanka 5,022 4,073 1,540 4,308 1,293 

India 34,505 16,967 9,204 2,186 1,048 

Brunei Darussalam - - - 1,578 794 

All other1 109,971 126,652 97,878 85,303 802 

World 207,533 195,002 146,457 181,372 55,960 

 Value ($1,000)

Australia 20,450 10,017 4,129 22,326 19,956 

Bangladesh 4,540 3,646 4,858 9,012 8,344 

Pakistan 3,458 5,620 8,285 8,522 1,700 

New Zealand 2,258 1,079 2,145 1,976 1,153 

United Arab Emirates 4,930 - - - 1,201 

Philippines 6,739 3,127 3,145 7,302 1,109 

Sri Lanka 1,548 - 31 11,054 789 

Malaysia 3,461 2,397 1,194 3,129 1,107 

India 21,985 8,219 5,261 1,575 714 

Brunei Darussalam - - - 1,053 526 

All other1 73,076 61,773 58,202 59,542 639 

World 142,446 95,880 87,250 125,490 37,238 

Table continued on the following page. 

                                                      

27 GTIS/GTA data for Indonesia are not yet available for calendar year 2013.
    

IV‐23

Table IV-14--Continued 

Wire rod: Indonesia’s exports, by destination, 2008-12 

Destination 

Calendar year 

2008 2009 2010 2011 2012 

 Unit value (per short ton) 

Australia 769 491 562 670 627 

Bangladesh 831 472 647 698 726 

Pakistan 700 501 585 707 708 

New Zealand 677 511 572 680 658 

United Arab Emirates 794 - - - 698 

Philippines 734 535 628 705 702 

Malaysia 670 - 554 672 637 

Sri Lanka 689 589 775 726 856 

India 637 484 572 720 681 

Brunei Darussalam - - - 667 662 

All other1 664 488 595 698 797 

World 686 492 596 692 665 

 Share of quantity (percent) 

Australia 12.8 10.5 5.0 18.4 56.9 

Bangladesh 2.6 4.0 5.1 7.1 20.5 

Pakistan 2.4 5.7 9.7 6.7 4.3 

New Zealand 1.6 1.1 2.6 1.6 3.1 

United Arab Emirates 3.0 - - - 3.1 

Philippines 4.4 3.0 3.4 5.7 2.8 

Sri Lanka 1.1 - 0.0 9.1 2.2 

Malaysia 2.4 2.1 1.1 2.4 2.3 

India 16.6 8.7 6.3 1.2 1.9 

Brunei Darussalam - - - 0.9 1.4 

All other1 53.0 64.9 66.8 47.0 1.4 

World 100.0 100.0 100.0 100.0 100.0 

1

 Prior to 2012, Iran was the single largest destination for Indonesian exports of wire rod. Exports to Iran 

dropped to zero in 2012. 

Note.--Data for Indonesia are not yet available for calendar year 2013. Data include grade 1080 tire cord 

and tire bead. 

Source: Compiled from GTIS/GTA, as reported by “Statistics Indonesia” to GTIS (HS codes 7213.91, 

7213.99, 7227.20, and 7227.90). 
    

IV‐24

PT Ispat Indo’s shipments, by type

Table IV‐15 presents data on PT Ispat Indos’s total shipments, by type, during 2013. As

the data indicate, high/medium‐high carbon industrial/standard quality wire rod and

low/medium‐low carbon industrial/standard quality wire rod together accounted for ***

percent of PT Ispat Indo’s total shipments during 2013.  

Table IV-15 

Wire rod: PT Ispat Indo’s total shipments, by type, 2013 

*                    *                    *                    *                    *                    *                    *

THE INDUSTRY IN MEXICO

Overview

At the time of the original investigations, six Mexican firms were believed to have

produced wire rod. Two firms, accounting for *** percent of Mexican production of wire rod,

provided data in response to the Commission’s questionnaire in the original investigations:

Hylsa and Siderurgica Lazaro Cardenas Las Truchas (“Sicartsa”). These two firms reported that

they collectively accounted for *** percent of exports to the United States during 2001.

According to official Commerce statistics, exports by these firms to the United States in 2001

accounted for *** percent of U.S. imports of subject wire rod from Mexico in 2001.28

The following seven firms were identified as producers of wire rod in Mexico in the

Commission’s first five‐year reviews: Aceros Nacionales, Aceros San Luis, AHMSA‐Altos Hornos

de Mexico, Atlax, Deacero, Sicartsa, and Hylsa. Responses to the Commission’s questionnaire

were received from producers Deacero, Hylsa, and Sicartsa. By their estimation, these three

producers accounted for *** percent of production in Mexico during 2007 (***).29

In their responses to the Commission’s notice of institution in these current second five‐

year reviews, the interested parties identified the following five producers of wire rod in

Mexico: ArceIorMittaI LasTruchas (successor to Sicartsa), Aceros San Luis, Altos Hornos de

Mexico (“AHMSA”), Ternium México SA de CV (“Ternium”) (successor to Hylsa), and Talleres y

Aceros. *** identified the following additional firms in Mexico as having wire rod rolling

capacity during 2013: Aceros Nacionales SA de CV; Camesa; Deacero; and Siderurgica Tultitlan

                                                      

28 The following 2001 data were provided by the two responding Mexican firms in the original

investigations: capacity (*** short tons); production (*** short tons); capacity utilization (*** percent);

exports/shipments (*** percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008

(INV‐FF‐058), table IV‐24.

29 The following 2007 data were provided by the three responding Mexican firms in the first five‐year

reviews: capacity (*** short tons); production (*** short tons); capacity utilization (*** percent);

exports/shipments (*** percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008

(INV‐FF‐058), table IV‐24.
    

IV‐25

(“Sidertul”). Hearing testimony suggested that Aceros Nationales, Sidertul, and Camesa do not

produce wire rod in Mexico. 30 Aceros Camesa, AHMSA, and Sidertul provided questionnaire

responses in these second five‐year reviews indicating that they are not wire rod producers.

Deacero, Ternium, and ArcelorMittal las Truchas provided responses to the

Commission’s foreign producer questionnaire in these second five‐year reviews. Hearing

testimony indicates that these three companies are the principal producers of wire rod in

Mexico,31 although Talleres y Aceros and Simec also are believed to produce wire rod. 32 33

Mexican wire rod producer Deacero is the largest manufacturer of wire rod in Mexico,

accounting for *** percent of total wire rod production in Mexico during 2013. According to

***, production in Mexico during 2013 was *** short tons. Aggregate reported production by

the three responding wire rod producers in Mexico was 2.345 million short tons, yielding a

theoretical coverage of *** percent of Mexican production during 2013 by the responding

firms. *** firm‐by‐firm capacity data indicate that the three responding Mexican producers

accounted for *** wire rod rolling capacity in Mexico during 2013, other than that attributed to

AHMSA, Aceros Nationales, Siderurgica Tultitlan, and Camesa.  

                                                      

30 Mexican wire rod producer Deacero testified at the Commission’s hearing that it had acquired

Aceros Nationales in 1999 and the production facilities were shut down and the assets sold outside

Mexico. Deacero also testified that Sidertul is a producer of rebar in Mexico that was acquired by

Gerdau in 2007 and Camesa is a producer of wire and wire rope in Mexico. Hearing transcript, p. 153

(Campbell).   31 Hearing transcript, p. 153 (Campbell).

32 Talleres y Aceros (sometimes identified as TYASA) is located in Orizaba, Veracruz, and produces a

variety of long products, including wire rod and products produced from wire rod.   Talleres y Aceros,

“Talleres y Aceros, fabricante de productos TA,” found at talleresyaceros.com.mx.  TYASA reported that

it maintained annual wire rod capacity of *** tons during 2008‐13. TYASA stated that it is focused on

*** sales, exporting only to ***, and that it produced *** tons of wire rod in 2013. Letter from *** to

Mary Messer, May 16, 2014.

33 Grupo Simec, known for commercial purposes as Simec, is a diversified manufacturer, processor

and distributor of SBQ steel and structural steel products with production and commercial operations in

the United States, Mexico and Canada. On May 30, 2008, Simec acquired all the capital stock of Aceros

DM, and certain affiliated companies (“Grupo San”), with corrugated rebar and other long product

operations in San Luis Potosí, Mexico.  Simec operates five minimills in Mexico, with a wire rod rolling

mill in its Aceros DM / San Luis Potosí location.  Simec sold 21,400 tons of wire rod in 2012, 100 percent

of which was sold within Mexico.  Simec’s Aceros DM / San Luis Potosí location, with installed capacity of

400,000 tons, produced 388,047 tons of finished product in 2012, distributed as follow (in percent):  

rebar (78), light structurals (5), wire rod (5), electro‐welded wire mesh (5), and electro‐welded wire

mesh panel (7).  See generally  Grupo Simec, Form 20‐F, Annual Report Pursuant To Section 13 or 15(D)

Of The Securities Exchange Act Of 1934 for the fiscal year ended December 31, 2012.
    

IV‐26

Table IV‐16 presents data published by *** on overall Mexican capacity, production, and

consumption of wire rod.  Also presented in the tabulation are calculated net exports/imports

(i.e., production minus consumption).34  

Table IV-16 

Wire rod: Overall Mexican capacity, production, consumption, and calculated net exports/imports 

*                    *                    *                    *                    *                    *                    *

The *** data show that capacity to produce wire rod in Mexico remained constant at

*** short tons during 2008‐13 and projections indicate that there is no change in capacity

expected in 2014 and 2015. According to ***, production of wire rod in Mexico increased from

2009 to 2011 but fell thereafter. Production is expected to increase during 2014 and 2015.

Capacity reported by *** for 2013 for all Mexican producers was *** short tons, and

production was *** short tons, yielding a capacity utilization of *** percent for the Mexican

wire rod industry. Mexican production of wire rod exceeded consumption during 2008‐13 and

*** projections for production and consumption in Mexico indicate that it will continue to be a

net exporter of wire rod during 2014‐15.

                                                      

34 The net export/import calculation may differ from GTA data on exports and imports, primarily due

to rounding. Also, note that the data reported by *** for Mexico are overstated, as they include not only

the data for firms believed to have not been producers of wire rod, but also include the data for grade

1080 tire cord and tire bead wire rod and smaller diameter wire rod produced by Deacero that have

been excluded by the Department of Commerce from the scope of the orders.  
    

IV‐27

Operations on wire rod

Aggregate data provided by ArcelorMittal Las Truchas, Deacero, and Ternium

concerning their wire rod operations in Mexico during calendar years 2008‐13 are presented in

table IV‐17.  

Table IV-17 

Wire rod: Mexican producers ArcelorMittal Las Truchas, Deacero, and Ternium’s capacity, 

production, shipments, and inventories, 2008-13 

Item 

Actual experience 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

Capacity 2,417,205 2,304,946 2,482,603 2,606,163 2,625,106 2,757,570

Production 2,139,484 2,096,645 2,279,689 2,556,411 2,566,149 2,344,862

End-of-period inventories 119,699 156,624 159,165 192,768 194,722 159,917

Shipments: 

 Internal consumption/ 

 Transfers *** *** *** *** *** ***

Home market shipments *** *** *** *** *** ***

 Export shipments to: 

 United States *** *** *** *** *** ***

 European Union *** *** *** *** *** ***

 Asia *** *** *** *** *** ***

 All other markets *** *** *** *** *** ***

 Total exports *** 193,724 290,724 419,479 379,513 379,963

 Total shipments 2,185,456 2,063,393 2,279,900 2,525,125 2,558,539 2,378,082

 Ratios and shares (percent) 

Capacity utilization 88.5 91.0 91.8 98.1 97.8 85.0

Inventories/production 5.6 7.5 7.0 7.5 7.6 6.8

Inventories/total 

shipments 5.5 7.6 7.0 7.6 7.6 6.7

Share of total shipments: 

 Internal consumption/ 

 Transfers *** *** *** *** *** ***

 Home market shipments *** *** *** *** *** ***

 Export shipments to: 

 United States *** *** *** *** *** ***

 European Union *** *** *** *** *** ***

 Asia *** *** *** *** *** ***

 All other markets *** *** *** *** *** ***

 Total exports *** 9.4 12.8 16.6 14.8 16.0

 Total shipments 100.0 100.0 100.0 100.0 100.0 100.0

Continued on the following page. 
    

IV‐28

Table IV-17--Continued 

Wire rod: Mexican producers ArcelorMittal Las Truchas, Deacero, and Ternium’s capacity, 

production, shipments, and inventories, 2008-13 

Item 

Actual experience 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Value (1,000 dollars) 

Shipments: 

 Home market shipments *** *** *** *** *** ***

 Export shipments to: 

 United States *** *** *** *** *** ***

 European Union *** *** *** *** *** ***

 Asia *** *** *** *** *** ***

 All other markets *** *** *** *** *** ***

 Total exports *** *** *** *** *** ***

 Total shipments1 905,006 509,493 710,507 986,036 965,352 833,112

 Unit value (dollars per short ton) 

Shipments: 

 Home market shipments *** *** *** *** *** ***

 Export shipments to: 

 United States *** *** *** *** *** ***

 European Union *** *** *** *** *** ***

 Asia *** *** *** *** *** ***

 All other markets *** *** *** *** *** ***

 Total exports *** *** *** *** *** ***

 Total shipments1 810 486 545 689 653 583

1

 Excludes internal consumption for which value data were not gathered. 

Note.—Principal *** markets include ***. Principal ** markets include ***. *** export markets include ***. 

Source: Compiled from data submitted by ArcelorMittal Las Truchas, Deacero (adjusted to remove 

nonsubject smaller diameter wire rod), and Ternium in response to the Commission’s foreign producer 

questionnaire. 
    

IV‐29

Capacity and production in Mexico

The reported capacity to produce wire rod in Mexico by the three responding

producers, which was based on operating *** hours per week and *** weeks per year,

fluctuated upward by 14.1 percent from 2.4 million short tons in 2008 to 2.8 million short tons

in 2013. The firms’ aggregate production increased irregularly during 2008‐12, but fell in 2013.

Aggregate reported production was 9.6 percent higher at 2.3 million short tons in 2013 than

reported in 2008. Capacity utilization was 85.0 percent during 2013, the lowest reported for

any year during 2008‐13.

In addition to the production of wire rod, all three responding Mexican producers

reported the production of *** using shared equipment and machinery in their wire rod

facilities in Mexico. Deacero subsequently clarified its response to the Commission’s

questionnaire by stating that it “can only produce wire rod, which is coiled, on certain rebar

mills that can produce coiled rebar.”35 Table IV‐18 presents the reported aggregate overall

capacity and production of wire rod and other products produced on the same production

equipment used to produce wire rod in Mexico.  

Table IV-18 

Wire rod: Mexican producers ArcelorMittal Las Truchas, Deacero, and Ternium’s overall capacity, 

production, and capacity utilization, 2008-13 

*                    *                    *                    *                    *                    *                    *

ArcelorMittal Las Truchas, Deacero, and Ternium estimated that wire rod accounted for

***, ***, and *** percent of their 2013 total sales, respectively. The overall production data

presented indicate that subject wire rod accounted for between *** and *** percent of the

firms’ aggregate overall production on the same machinery and equipment as wire rod during

2008‐13. The capacity to produce wire rod is affected by ***. *** were reported by the firms to

be the primary constraints that set the limit on their production capacity. Several factors that

constrain the firms’ ability to shift production capacity between product lines were reported:

***.

ArcelorMittal Las Truchas and Ternium reported that they experienced ***. Deacero

reported ***.36  All three responding Mexican producers reported that ***.

                                                      

35 Deacero’s prehearing brief, p. 29

36 The domestic interested parties noted in their response to the Commission’s notice of institution in

these reviews that Deacero completed the construction of a new wire rod mini‐mill in Saltillo, Mexico in

2011, with annual rolling capacity of 800,000 to 1 million tons per year. They also noted that Deacero

***. Response of Domestic Industry, July 2, 2013, p. 23. Deacero indicated that these claims are

inaccurate with respect to wire rod. Deacero’s prehearing brief, pp. 23‐24.
    

IV‐30

Shipments of wire rod produced in Mexico

The three responding producers’ total shipments of wire rod fluctuated during 2008‐13,

but were 8.8 percent higher in 2013 than reported in 2008. The firms’ internal consumption

and home market together accounted for the majority of the firms’ total shipments of wire rod,

but they accounted for an overall declining share of total shipments during most of the years

2008‐13. During 2013, internal consumption and home market shipments together accounted

for *** percent of the firms’ total shipments of wire rod.

The three responding producers’ export shipments of wire rod decreased in the

aggregate from 2008 to 2009, and increased until 2011 before declining again in 2013. Total

exports were *** percent higher in 2013 than reported in 2008. Aggregate exports of subject

wire rod to the United States increased from 2008 to 2010, but fluctuated thereafter to a level

in 2013 that was *** percent higher than that reported in 2008. The Mexican producers

reported that their principal *** markets include ***, its principal *** markets include ***, and

*** export markets include ***.  

Detailed information on the export destinations for Mexican wire rod as published by

the GTIS/GTA is presented in table IV‐19. These data include grade 1080 tire cord and tire bead,

which is not subject to these reviews, and are therefore overstated. In addition, smaller

diameter wire rod produced by Deacero (diameter of 4.75 mm to 5.0 mm) is also believed to be

included in the data reported by the GTIS/GTA.
    

IV‐31

Table IV-19 

Wire rod: Mexico’s exports, by destination, 2008-13 

Destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

Colombia 25,688 41,192 53,327 94,777 92,319 192,108 

Canada 36,063 7,784 38,791 68,806 77,973 42,446 

Ecuador 15,941 15,873 18,051 48,192 34,869 22,868 

United States 11,885 28,432 694,233 91,504 36,560 21,251 

Guatemala 40,992 46,157 32,123 46,355 30,043 19,005 

Argentina - - - - - 15,103 

Dominican Republic 8,541 4,254 39 - - 12,153 

El Salvador 16,660 23,834 23,723 18,270 26,895 9,609 

Peru 11,855 21,621 22,585 45,959 36,219 7,537 

Chile - 5,549 10,832 - 5,056 5,029 

All other 84,038 31,461 22,159 69,574 23,896 13,789 

World 251,663 226,156 915,863 483,437 363,831 360,899 

 Value ($1,000 dollars)

Colombia 20,606 16,234 28,859 63,164 57,574 113,192 

Canada 30,447 4,716 21,495 45,611 45,524 23,940 

Ecuador 15,841 6,012 10,975 32,518 22,445 15,147 

United States 12,365 15,950 80,068 55,818 23,958 12,468 

Guatemala 26,751 20,526 18,263 30,664 19,437 11,399 

Argentina - - - - - 9,221 

Dominican Republic 8,809 1,779 21 - - 8,183 

El Salvador 12,857 10,487 11,188 11,950 17,839 5,936 

Peru 13,034 10,545 13,453 33,236 24,186 4,640 

Chile - 3,071 7,102 - 3,409 3,103 

All other 64,151 12,863 11,632 45,677 15,484 9,316 

World 204,861 102,182 203,055 318,637 229,855 216,544 

Table continued on the following page. 
    

IV‐32

Table IV-19--Continued 

Wire rod: Mexico’s exports, by destination, 2008-13 

Destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Unit value (per short ton) 

Colombia 802 394 541 666 624 589 

Canada 844 606 554 663 584 564 

Ecuador 994 379 608 675 644 662 

United States 1,040 561 115 610 655 587 

Guatemala 653 445 569 661 647 600 

Argentina - - - - - 611 

Dominican Republic 1,031 418 538 - - 673 

El Salvador 772 440 472 654 663 618 

Peru 1,099 488 596 723 668 616 

Chile - 553 656 - 674 617 

All other 763 409 525 657 648 676 

World 814 452 222 659 632 600 

 Share of quantity (percent) 

Colombia 10.2 18.2 5.8 19.6 25.4 53.2 

Canada 14.3 3.4 4.2 14.2 21.4 11.8 

Ecuador 6.3 7.0 2.0 10.0 9.6 6.3 

United States 4.7 12.6 75.8 18.9 10.0 5.9 

Guatemala 16.3 20.4 3.5 9.6 8.3 5.3 

Argentina - - - - - 4.2 

Dominican Republic 3.4 1.9 0.0 - - 3.4 

El Salvador 6.6 10.5 2.6 3.8 7.4 2.7 

Peru 4.7 9.6 2.5 9.5 10.0 2.1 

Chile - 2.5 1.2 - 1.4 1.4 

All other 33.4 13.9 2.4 14.4 6.6 3.8 

World 100.0 100.0 100.0 100.0 100.0 100.0 

Note.-Data include grade 1080 tire cord and tire bead wire rod and smaller diameter wire rod produced by 

Deacero, which are not merchandise subject to the order concerning Mexico. 

Source: Compiled from GTIS/GTA, as reported to GTIS by the Instituto Nacional de Estadistica y 

Geografia (INEGI) (HS codes 7213.91, 7213.99, 7227.20, and 7227.90). 
    

IV‐33

Shipments, by type

Table IV‐20 presents data on the three responding producers’ total shipments, by type,

during 2013. As the data indicate, high/medium‐high carbon industrial/standard quality wire

rod and low/medium‐low carbon industrial/standard quality wire rod together accounted for

*** percent of the Mexican producers’ total shipments during 2013.  

Table IV-20 

Wire rod: Total shipments of wire rod produced in Mexico, by type, 2013 

*                    *                    *                    *                    *                    *                    *

THE INDUSTRY IN MOLDOVA

Overview

The only firm believed to be producing wire rod in Moldova, Moldova Steel Works,

provided data in response to the Commission's questionnaire in the original investigations.37

Moldova Steel Works also provided data in the first five‐year reviews.38 The structure of the

wire rod industry in Moldova has changed little since the imposition of the original order, with

Moldova Steel Works accounting for all known production in Moldova.39 However, the firm did

not submit a response to the Commission's foreign producer questionnaire in these second

five‐year reviews.  

Table IV‐21 presents data published by *** on overall Moldovan capacity. The *** data

show that capacity remained unchanged from 2008 to 2013. Projections for 2014 and 2015

indicate no change in the capacity to produce wire rod in Moldova is expected. Production and

consumption data for Moldova are not published by ***.

                                                      

37 The following 2001 data were provided by Moldova Steel Works in the original investigations:

capacity (*** short tons); production (*** short tons); capacity utilization (*** percent);

exports/shipments (*** percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008

(INV‐FF‐058), table IV‐28.

38 The following 2007 data were provided by Moldova Steel Works in the first five‐year reviews:

capacity (*** short tons); production (*** short tons); capacity utilization (*** percent);

exports/shipments (*** percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008

(INV‐FF‐058), table IV‐28.

39 The domestic interested parties reported that, since the last sunset review, the ownership of

Moldova Steel Works has changed. It stated that the Moldovan producer is currently managed by

Metallinvest Holding, Russia’s largest iron ore miner. This company is not affiliated with Ukrainian

producer Yenakiieve’s parent company, MetInvest. Response of Domestic Industry, July 2, 2013, pp. 25‐

26; and Hearing transcript, pp. 200‐201 (Lewis).  
    

IV‐34

Table IV-21 

Wire rod: Overall Moldovan capacity, production, consumption, and calculated net 

exports/imports 

*                    *                    *                    *                    *                    *                    *

Operations on wire rod

Moldova Steel Works reportedly produces low‐carbon and high‐carbon wire rod, as well

as welding quality and CHQ wire rod in Moldova.40 Time series data reported by *** indicate

that the capacity to produce wire rod in Moldova has remained unchanged at *** short tons

during 2008‐13. Other sources estimate the Moldovan plant’s overall capacity to produce rolled

products at *** short tons.41 In addition, the domestic interested parties estimated Moldova

Steel Works’ production of wire rod in 2012 at 174,809 short tons and its 2012 capacity

utilization for rolled products at approximately about 37 percent.42 The domestic interested

parties also reported that, although Moldova Steel Works essentially ceased exports of wire rod

to the United States following the imposition of the antidumping duty order, the producer

remains ***.43  

Detailed information on the export destinations for Moldovan wire rod as published by

GTIS/GTA is presented in table IV‐22.

                                                      

40 Response of Domestic Industry, July 2, 2013, p. 25. 41 ***, as cited in Response of Domestic Industry, July 2, 2013, p. 26.

42 Response of Domestic Industry, July 2, 2013, p. 26.

43 ***, as cited in Response of Domestic Industry, July 2, 2013, p. 26.
    

IV‐35

Table IV-22 

Wire rod: Exports from Moldova, 2008-13 

Reporting destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

Romania 99,901 28,948 8,338 35,412 93,979 59,854

Poland 101,312 30,633 25,354 15,025 14,707 34,158

Ukraine 10,882 2,256 5,721 35,084 23,147 5,678

Slovakia 26,199 5,434 3,799 125 368 737

Russia 62,259 35,902 26,860 9,877 2,287 611

Georgia 0 0 0 0 0 405

Czech Republic 1,919 0 588 0 0 140

Azerbaijan 0 0 136 274 1,226 138

Brazil 12,381 29,233 75,620 540 9,296 0

Canada 0 0 5,523 0 0 0

All other countries 62,945 21,552 10,468 3,062 625 0

Total reporting 

countries 377,798 153,960 162,405 99,399 145,635 101,721

 Value (1,000) 

Romania 87,863 13,254 4,368 22,882 51,814 31,821

Poland 77,580 12,747 14,221 10,585 9,535 19,499

Ukraine 10,507 1,145 3,225 25,589 16,621 3,969

Slovakia 23,511 2,475 2,143 88 204 419

Russia 49,811 16,781 15,106 6,888 1,526 373

Georgia 0 0 0 0 0 242

Czech Republic 1,491 0 346 0 0 83

Azerbaijan 0 0 95 211 836 94

Brazil 9,434 15,340 38,847 356 5,733 0

Canada 0 0 3,169 0 0 0

All other countries 50,028 11,587 5,817 2,796 428 0

Total reporting 

countries 310,225 73,329 87,336 69,395 86,696 56,499

Table continued on next page. 
    

IV‐36

Table IV-22--Continued

Wire rod: Exports from Moldova, 2008-13 

Reporting destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Unit value (dollars per short ton) 

Romania 879 458 524 646 551 532

Poland 766 416 561 705 648 571

Ukraine 966 507 564 729 718 699

Slovakia 897 455 564 707 554 568

Russia 800 467 562 697 667 610

Georgia 0 0 0 0 0 599

Czech Republic 777 0 589 0 0 593

Azerbaijan 0 0 698 768 682 679

Brazil 762 525 514 659 617 0

Canada 0 0 574 0 0 0

All other countries 795 538 556 913 684 0

Total reporting 

countries 821 476 538 698 595 555

 Share of quantity (percent) 

Romania 26.4 18.8 5.1 35.6 64.5 58.8

Poland 26.8 19.9 15.6 15.1 10.1 33.6

Ukraine 2.9 1.5 3.5 35.3 15.9 5.6

Slovakia 6.9 3.5 2.3 0.1 0.3 0.7

Russia 16.5 23.3 16.5 9.9 1.6 0.6

Georgia 0.0 0.0 0.0 0.0 0.0 0.4

Czech Republic 0.5 0.0 0.4 0.0 0.0 0.1

Azerbaijan 0.0 0.0 0.1 0.3 0.8 0.1

Brazil 3.3 19.0 46.6 0.5 6.4 0.0

Canada 0.0 0.0 3.4 0.0 0.0 0.0

All other countries 16.7 14.0 6.4 3.1 0.4 0.0

Total reporting 

countries 100.0 100.0 100.0 100.0 100.0 100.0

Note.--Data may include 1080 tire cord and tire bead. 

Source: Compiled from GTIS/GTA based on partner country imports from Moldova using HS codes: 

7213.91, 7313.99, 7227.20, and 7227.90. Accessed on March 29, 2014, and not all reporting countries 

had provided 2013 data as of the date compiled.
    

IV‐37

THE INDUSTRY IN TRINIDAD & TOBAGO

Overview

One firm, accounting for all Trinidadian production of wire rod, provided data in

response to the Commission’s questionnaire in the original investigations: Caribbean Ispat.44

The successor firm to Carribean Ispat, ArcelorMittal Point Lisas, responded to the Commission’s

questionnaire in the first sunset reviews.45 The structure of the wire rod industry in Trinidad &

Tobago has changed little since the final investigations and the first five‐year reviews, with one

producer accounting for all production in the country. ArcelorMittal Point Lisas, which

accounted for all known production of wire rod in Trinidad & Tobago, provided a response to

the Commission’s questionnaire in these current second five‐year reviews.  

Table IV‐23 presents data published by *** on overall Trinidadian capacity. The ***data

show that capacity remained unchanged from 2008 to 2013. Projections for 2014 and 2015

indicate no change in the capacity to produce wire rod in Trinidad & Tobago is expected.

Production and consumption data are not published by ***.

Table IV-23 

Wire rod: Overall Trinidadian capacity, production, consumption, and calculated net 

exports/imports 

*                    *                    *                    *                    *                    *                    *

Operations on wire rod

Data provided by ArcelorMittal Point Lisas concerning its wire rod operations in Trinidad

& Tobago during calendar years 2008‐13 are presented in table IV‐24.  

Table IV-24 

Wire rod: Trinidadian producer ArcelorMittal Point Lisas’ capacity, production, shipments, and 

inventories, 2008-13 

*                    *                    *                    *                    *                    *                    *

                                                      

44 The following 2001 data were provided by Caribbean Ispat in the original investigations: capacity

(*** short tons); production (*** short tons); capacity utilization (*** percent); exports/shipments (***

percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008 (INV‐FF‐058), table IV‐31.

45 The following 2007 data were provided by the ArcelorMittal Point Lisas in the first five‐year

reviews: capacity (*** short tons); production (*** short tons); capacity utilization (*** percent);

exports/shipments (*** percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008

(INV‐FF‐058), table IV‐14.
    

IV‐38

Capacity and production in Trinidad & Tobago

ArcelorMittal Point Lisas’ capacity to produce wire rod in Trinidad & Tobago, which was

based on operating *** hours per week and *** weeks per year, remained constant at ***

short tons during 2008‐13. The firm’s production fluctuated during 2008‐13, but was ***

percent higher at *** short tons in 2013 than reported in 2008. Capacity utilization was ***

percent during 2013 and ranged between *** and *** percent during 2008‐13.

In addition to the production of wire rod, ArcelorMittal Point Lisas reported ***. Table

IV‐25 presents ArcelorMittal Point Lisas’ overall production and capacity ***.  

Table IV-25 

Wire rod: Trinidadian producer ArcelorMittal Point Lisas’ overall capacity, production, and 

capacity utilization, 2008-13 

*                    *                    *                    *                    *                    *                    *

ArcelorMittal Point Lisas estimated that wire rod accounted for *** percent of its 2013

total sales. The overall production data presented indicate that wire rod accounted for between

*** and *** percent of the firm’s overall production during 2008‐13. In response to a request

for information pertaining to the constraints that set the limits on production capacity,

ArcelorMittal Point Lisas indicated that “***.” The firm added that “***.”  Concerning the firm’s

ability to shift production capacity between wire rod and rebar in coil, ArcelorMittal Point Lisas

noted “***.” In response to a request for information concerning changes experienced in the

character of operations, ArcelorMittal Point Lisas reported the following:

 ***.   

 ***.

The Trinidadian producer reported ***.    

Shipments of wire rod produced in Trinidad & Tobago

ArcelorMittal Point Lisas’ total shipments of wire rod fluctuated upward, reaching ***

during 2011 before declining in 2012 and 2013. The firm’s total shipments were *** percent

higher in 2013 than in 2008. The firm reported *** internal consumption of wire rod during

2008‐13 and home market shipments accounted for *** generally declining share of total

shipments (i.e., ranging from *** percent of total shipments of wire rod during 2008‐13).

ArcelorMittal Point Lisas’ export shipments of wire rod, which accounted for *** of the

firm’s total wire rod shipments during 2008‐13, generally increased from 2008 to 2011, but fell

thereafter to a level in 2013 that was *** percent higher than reported in 2008. ArcelorMittal

Point Lisas reported that its principal *** market is *** and that *** export markets include

***. The firm noted that, since 2008, it has increased its exports to ***. The firm reported that

there were no exports of subject wire rod to the United States during 2009‐13. Detailed

information on the export destinations for Trinidadian wire rod as published by GTIS/GTA is

presented in table IV‐26.
    

IV‐39

Table IV-26 

Wire rod: Exports from Trinidad & Tobago, 2008-13 

Destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

El Salvador 17,181 0 9,833 23,817 16,955 21,790

Nicaragua 9,309 1,238 10,189 16,391 14,907 19,370

France 30,600 15,900 24,363 15,364 15,538 18,515

Guatemala 7,783 0 6,796 9,323 9,056 16,009

Peru 0 0 20,470 42,789 32,790 11,595

Ecuador 8,889 8,967 28,898 42,871 37,371 10,487

Brazil 45,037 0 39,435 85,345 15,351 4,865

Chile 0 0 0 0 0 3,142

Honduras 7,859 0 8,734 4,940 264 2,008

Colombia 0 0 14,432 11,363 45,533 1,829

All other countries 72,129 66,990 248,334 14,793 38,748 410

Total reporting 

countries 198,787 93,095 411,484 266,996 226,513 110,020

 Value (1,000) 

El Salvador 13,669 0 6,379 19,230 12,985 14,973

Nicaragua 6,434 1,222 6,427 11,799 11,122 12,716

France 27,969 8,670 15,277 11,218 11,380 12,455

Guatemala 6,275 0 5,973 7,916 6,679 10,744

Peru 0 0 13,691 32,256 24,504 8,082

Ecuador 5,966 5,129 17,751 31,473 27,546 7,078

Brazil 44,088 0 25,516 61,896 11,310 3,091

Chile 0 0 0 0 0 2,259

Honduras 7,573 0 5,849 6,207 5,668 3,357

Colombia 0 0 9,086 8,766 33,003 1,282

All other countries 49,816 36,117 25,531 11,295 27,943 232

Total reporting 

countries 161,789 51,138 131,480 202,057 172,138 76,270

Table continued on next page. 
    

IV‐40

Table IV-26--Continued 

Wire rod: Exports from Trinidad & Tobago, 2008-13 

Destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Unit value (dollars per short ton) 

El Salvador 796 0 649 807 766 687

Nicaragua 691 987 631 720 746 656

France 914 545 627 730 732 673

Guatemala 806 0 879 849 738 671

Peru 0 0 669 754 747 697

Ecuador 671 572 614 734 737 675

Brazil 979 0 647 725 737 635

Chile 0 0 0 0 0 719

Honduras 964 0 670 1,257 21,468 1,672

Colombia 0 0 630 771 725 701

All other countries 691 539 103 764 721 566

Total reporting 

countries 814 549 320 757 760 693

 Share of quantity (percent) 

El Salvador 8.6 0.0 2.4 8.9 7.5 19.8

Nicaragua 4.7 1.3 2.5 6.1 6.6 17.6

France 15.4 17.1 5.9 5.8 6.9 16.8

Guatemala 3.9 0.0 1.7 3.5 4.0 14.6

Peru 0.0 0.0 5.0 16.0 14.5 10.5

Ecuador 4.5 9.6 7.0 16.1 16.5 9.5

Brazil 22.7 0.0 9.6 32.0 6.8 4.4

Chile 0.0 0.0 0.0 0.0 0.0 2.9

Honduras 4.0 0.0 2.1 1.9 0.1 1.8

Colombia 0.0 0.0 3.5 4.3 20.1 1.7

All other countries 36.3 72.0 60.4 5.5 17.1 0.4

Total reporting 

countries 100.0 100.0 100.0 100.0 100.0 100.0

Note.--Data may include 1080 tire cord and tire bead. 

Source: Compiled from GTIS/GTA based on partner country imports from Trinidad & Tobago using HS 

codes 7213.91, 7313.99, 7227.20, and 7227.90. Accessed on March 29, 2014 and not all reporting 

countries had provided 2013 data as of the date compiled. 
    

IV‐41

Shipments, by type

Table IV‐27 presents data on ArcelorMittal Point Lisas’ total shipments, by type, during

2013. High/medium‐high carbon industrial/standard quality wire rod and low/medium‐low

carbon industrial/standard quality wire rod together accounted for *** percent of ArcelorMittal

Point Lisas’ total shipments during 2013. *** of the firm’s wire rod shipments during 2013 was

accounted for by ***.

Table IV-27 

Wire rod: Trinidadian producer ArcelorMittal Point Lisas’ total shipments, by type, 2013 

*                    *                    *                    *                    *                    *                    *

THE INDUSTRY IN UKRAINE

Overview

The Commission identified three producers of wire rod in Ukraine during the time of the

original investigations. The data presented in the Commission's final report during those

original investigations were submitted by Krivorozhstal, which reported that in 2001 it

accounted for *** percent of Ukrainian production of subject wire rod and *** percent of

subject exports to the United States. Exports by this firm accounted for *** percent of U.S.

imports of subject wire rod from Ukraine in 2001, according to official Commerce statistics.46  

Six firms were identified as wire rod producers in Ukraine during the first five‐year

reviews: ArcelorMittal Kryvyi Rih (successor firm to Krivorozhstal), Makeevka Metallurgical

Integrated Plant (or Makiyivka Metallurgical Plant), Yenakiievskyi Metalurhiynyi Zavod VAT (or

Yenakievo Metallurgical Plant), PJSC Donetskiy Steel Mill, PJSC Enakiivskiy Steel Mill, and PJSC

Dniprovskiy Steel Mill. ln the first five‐year reviews, the Commission received a questionnaire

response from the largest producer in Ukraine, ArcelorMittal Kryvyi Rih, accounting for an

estimated *** percent of 2007 wire rod production in Ukraine. According to ***, there was no

listed capacity for wire rod for any producer in Ukraine other than ArcelorMittal Kryvyi Rih at

the time of the first five‐year reviews. Accordingly, the data presented on Ukrainian production

of wire rod for the first five‐year reviews were believed to represent at least the majority of (if

not all) production of wire rod in Ukraine.47

                                                      

46 The following 2001 data were provided by Krivorozhstal in the original investigations: capacity (***

short tons); production (*** short tons); capacity utilization (*** percent); exports/shipments (***

percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008 (INV‐FF‐058), table IV‐34. 47 The following 2007 data were provided by ArcelorMittal Kryvyi Rih in the first five‐year reviews:

capacity (*** short tons); production (*** short tons); capacity utilization (*** percent);

exports/shipments (*** percent); and inventories/shipments (*** percent). Staff Report, May 15, 2008

(INV‐FF‐058), table IV‐34.
    

IV‐42

The domestic interested parties indicated in their response to the Commission’s notice

of institution in these current second five‐year reviews that there are three main producers of

wire rod in Ukraine today (Makiyivka Metallurgical Plant (“Makiyivka”), ArcelorMittal Kryvyi Rih,

and the Yenakievo Steel Group (formerly Yenakievo Metallurgical Plant). *** identifies four

facilities with wire rod rolling capacity in Ukraine during 2013: ArcelorMittal Kryvyi Rih,

Makeevsky Iron and Steel (“Makeevsky”), Donetsk Electrometallurgical Mill (“Donetsk”), and

Euro Finance.48 Hearing testimony by Ukrainian respondent, however, indicates that only

Yenakiieve Iron and Steel Works (“Yenakiieve”) and ArcelorMittal Kryvyi Rih currently produce

wire rod in Ukraine.49   

Both ArcelorMittal Kryvyi Rih and Yenakiieve responded to the Commission's foreign

producer questionnaire in these second five‐year reviews. There were no reported exports of

the subject merchandise to the United States by either firm during 2008‐13. According to ***,

wire rod production in Ukraine during 2013 was *** short tons. Reported production by

ArcelorMittal Kryvyi Rih and Yenakiieve combined was *** short tons, theoretically yielding full

coverage of Ukrainian production during 2013 by the responding firms.  

Table IV‐28 presents data published by *** on overall Ukrainian capacity, production,

and consumption of wire rod.  Also presented in the tabulation are calculated net

exports/imports (i.e., production minus consumption).50 As previously indicated, the *** data

are for four Ukrainian firms (ArcelorMittal Kryvyi Rih, Donetsk, Euro Finance, and Makeevsky).51  

Table IV-28 

Wire rod: Overall Ukrainian capacity, production, consumption, and calculated net 

exports/imports 

*                    *                    *                    *                    *                    *                    *

Although the *** data show that capacity increased by *** short tons from 2010 to

2013 and projections indicate that the capacity to produce wire rod in Ukraine is expected to

climb by *** in 2014, the additional capacity reported by *** is for firms that are not believed

to be producers of wire rod in Ukraine (***). According to ***, there was an increase in the

wire rod rolling capacity in Ukraine in the amount of ***  

                                                      

48 According to the company website for Donetsk, this firm appears to produce bar but not wire rod.

Donetsk company website, http://www.mechel.com/sector/steel/demz/production/, accessed on May

5, 2014. No company websites were found for Makiyivka , Makeevsky, or Euro Finance.

49 The company representative for Yenakiieve explained that, in October 2010, Yenakiieve obtained a

controlling interest in Makiyivka. Yenakiieve permanently decommissioned its own wire production

facilities resulting in the permanent elimination of that production capacity and it resumed production

of wire rod solely at facilities leased from Makiyivka in 2011. Hearing transcript, p. 160 (Dimitrova).

50 This calculation may differ from GTA data on exports and imports, primarily due to rounding.

51 The two responding producers in Ukraine (ArcelorMittal Kryvyi Rih and Yenakiieve) accounted for

*** percent of total wire rod rolling capacity and *** percent of wire rod production in Ukraine during

2013 as reported by the ***.
    

IV‐43

short tons during 2011‐12 ***. Another increase in the aggregate wire rod rolling capacity in

the amount of *** short tons was reported for 2013 by ***.

According to ***, production of wire rod in Ukraine increased from 2009 to 2010 but fell

thereafter. Consumption fluctuated during 2008‐13 within a range of *** short tons.

Production and consumption are expected to increase in 2014 and 2015. Capacity reported by

*** for 2013 was *** short tons, and production was *** short tons, or *** percent of

published capacity. Ukrainian production of wire rod exceeded consumption during 2008‐13.

*** projections for production and consumption in Ukraine indicate that it will continue to be a

net exporter of wire rod during 2014‐15.

Operations on wire rod

Data provided by ArcelorMittal Kryvyi Rih and Yenakiieve concerning their wire rod

operations in Ukraine during calendar years 2008‐13 are presented in table IV‐29. According to

reported data, ArcelorMittal Kryvyi Rih was the larger of the two producers, accounting for ***

percent of reported wire rod production in Ukraine in 2013, whereas Yenakiieve was the

smaller of the two responding producers, accounting for *** percent of reported 2013 wire rod

production in Ukraine.  

Table IV-29 

Wire rod: Ukrainian producers ArcelorMittal Kryvyi Rih and Yenakiieve’s capacity, production, 

shipments, and inventories, 2008-13 

*                    *                    *                    *                    *                    *                    *

Capacity and production in Ukraine

ArcelorMittal Kryvyi Rih’s and Yenakiieve’s capacity to produce wire rod in Ukraine was

based on operating *** hours per week and *** weeks per year. ArcelorMittal Kryvyi Rih’s wire

rod capacity ***.  Yenakiieve’s wire rod capacity ***. The firm reported no data for 2010, as its

mill underwent “decommissioning” during 2010. Aggregate reported capacity for wire rod in

Ukraine fell from 2008 to 2010, increased in 2011, and fell thereafter to a level that was ***

percent higher than the level reported in 2008. Aggregate reported production fluctuated

during 2008‐13, but was *** percent higher at *** short tons in 2013 than reported in 2008.

Capacity utilization was *** percent during 2013 and ranged between *** and *** percent

during 2008‐13.

In addition to the production of wire rod, ArcelorMittal Kryvyi Rih and Yenakiieve

reported *** using shared equipment and machinery in its wire rod facilities in Ukraine. Table

IV‐30 presents aggregate reported overall capacity and production of wire rod and other

products produced on the same production equipment used to produce wire rod in Ukraine.  
    

IV‐44

Table IV-30 

Wire rod: Ukrainian producers ArcelorMittal Kryvyi Rih and Yenakiieve’s overall capacity, 

production, and capacity utilization, 2008-13 

*                    *                    *                    *                    *                    *                    *

ArcelorMittal Kryvyi Rih and Yenakiieve estimated that wire rod accounted for *** and

*** percent of their 2013 total sales, respectively. The overall production data presented

indicate that wire rod accounted for *** percent of the firms’ overall production on the same

equipment as wire rod during 2008‐13. *** were reported by the firms to be constraints that

set the limits on their production capacities. *** were the constraints that set the limit on

Yenakiieve Steel’s ability to shift production capacity between products. ArcelorMittal Kryvyi

Rih reported that it has ***.  

In response to a request for information concerning any changes in the character of its

operations, ArcelorMittal Kryvyi Rih indicated ***. Yenakiieve reported ***.

Yenakiieve supplemented its response with the following narrative: ***.

Both responding Ukrainian producers indicated ***. The Ukrainian producers also

reported that they ***.

Shipments of wire rod produced in Ukraine

Aggregate total shipments of wire rod produced in Ukraine fluctuated during 2008‐13,

but were *** percent higher in 2013 than reported in 2008. Exports accounted for the majority

of the firms’ aggregate total shipments of wire rod, accounting for *** to *** percent of total

shipments during 2008‐13. During 2013, internal consumption and home market shipments

combined accounted for *** percent of total shipments of wire rod.

Aggregate export shipments of wire rod fluctuated during 2008‐13, but were higher in

2013 than in 2008. The firms reported that there were no exports of subject wire rod to the

United States during 2008‐13. Principal *** markets for wire rod produced in Ukraine include

***. Principal *** markets include ***. *** export markets include ***. Detailed information

on the export destinations for wire rod produced in Ukraine as published by GTIS/GTA is

presented in table IV‐31.

Shipments, by type

Table IV‐32 presents aggregate data on total wire rod shipments reported by

ArcelorMittal Kryvyi Rih and Yenakiieve, by type, during 2013. As the data indicate,

high/medium‐high carbon industrial/standard quality wire rod and low/medium‐low carbon

industrial/standard quality wire rod together accounted for *** percent of wire rod shipped by

the Ukrainian producers during 2013.  
    

IV‐45

Table IV-31 

Wire rod: Ukraine’s exports, by destination, 2008-13 

Destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

Israel 36,721 40,664 84,494 93,128 133,190 212,862 

Nigeria 65,961 72,008 110,488 107,093 121,857 128,201 

Turkey 70,179 49,146 80,274 77,241 76,714 122,009 

Jordan 275,748 268,923 271,225 282,043 266,120 114,915 

Senegal 29,347 82,969 85,662 68,867 96,413 77,702 

Bulgaria 90,987 45,865 46,404 56,748 51,419 70,785 

Romania 139,808 157,787 201,511 147,538 71,248 61,606 

Iran 46,409 4,000 165,346 51,726 52,253 53,704 

Iraq - 1,315 - 343 12,901 43,410 

Italy 8,669 22,243 70,560 68,504 19,836 43,176 

All other 867,671 902,631 869,184 946,668 786,715 525,795 

World 1,631,498 1,647,552 1,985,147 1,899,899 1,688,665 1,454,167 

 Value ($1,000 dollars)

Israel 20,312 13,113 37,637 56,611 74,022 106,827 

Nigeria 49,771 26,857 54,194 66,734 71,288 67,178 

Turkey 48,569 16,860 35,594 47,379 43,153 62,230 

Jordan 178,677 98,716 128,125 173,600 150,013 59,639 

Senegal 23,296 31,942 40,587 43,343 56,771 41,178 

Bulgaria 68,819 17,721 20,874 34,398 28,197 35,857 

Romania 105,682 56,710 97,443 91,061 41,001 32,818 

Iran 30,651 1,388 69,076 30,800 27,393 25,456 

Iraq - 447 - 210 6,878 21,602 

Italy 5,218 8,215 30,945 39,832 10,808 22,507 

All other 571,806 328,489 405,748 584,869 454,141 277,297 

World 1,102,802 600,458 920,223 1,168,837 963,666 752,589 

Table continued on the following page. 
    

IV‐46

Table IV-31--Continued 

Wire rod: Ukraine’s exports, by destination, 2008-13 

Destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Unit value (per short ton) 

Israel 553 322 445 608 556 502 

Nigeria 755 373 490 623 585 524 

Turkey 692 343 443 613 563 510 

Jordan 648 367 472 616 564 519 

Senegal 794 385 474 629 589 530 

Bulgaria 756 386 450 606 548 507 

Romania 756 359 484 617 575 533 

Iran 660 347 418 595 524 474 

Iraq - 340 - 612 533 498 

Italy 602 369 439 581 545 521 

All other 659 364 467 618 577 527 

World 676 364 464 615 571 518 

 Share of quantity (percent) 

Israel 2.3 2.5 4.3 4.9 7.9 14.6 

Nigeria 4.0 4.4 5.6 5.6 7.2 8.8 

Turkey 4.3 3.0 4.0 4.1 4.5 8.4 

Jordan 16.9 16.3 13.7 14.8 15.8 7.9 

Senegal 1.8 5.0 4.3 3.6 5.7 5.3 

Bulgaria 5.6 2.8 2.3 3.0 3.0 4.9 

Romania 8.6 9.6 10.2 7.8 4.2 4.2 

Iran 2.8 0.2 8.3 2.7 3.1 3.7 

Iraq - 0.1 - 0.0 0.8 3.0 

Italy 0.5 1.4 3.6 3.6 1.2 3.0 

All other 53.2 54.8 43.8 49.8 46.6 36.2 

World 100.0 100.0 100.0 100.0 100.0 100.0 

Note.-Data include grade 1080 tire cord and tire bead. 

Source: Compiled from GTIS/GTA reported to GTIS by the State Customs Committee of Ukraine (HS 

codes 7213.91, 7213.99, 7227.20, and 7227.90). 

  

Table IV-32 

Wire rod: Total shipments reported by Ukrainian producers ArcelorMittal Kryvyi Rih and 

Yenakiieve, by type, 2013 

*                    *                    *                    *                    *                    *                    * 
    

IV‐47

GLOBAL MARKET

Production

Global production of wire rod has grown considerably in recent years.  According to one

published source,52 global production increased by *** percent between 2009 and 2013 (table

IV‐33). In terms of sheer volume, China, the world’s largest producer, accounted for the

greatest production increase over this period, and it is forecasted to lead global production in

the coming years as well. China accounted for *** percent of worldwide production in 2013.

Production in China grew between 2009 and 2013 period from *** short tons to ***short tons,

an increase of *** percent. Production growth in China is forecasted to *** thereafter from ***

short tons in 2014 to *** short tons in 2018, an increase of *** percent. Data compiled by ***

on historical, current, and projected global production of wire rod are presented in tables IV‐33

and IV‐34.53  

Table IV-33 

Wire rod: Global and regional production of wire rod, 2009-13 

*                    *                    *                    *                    *                    *                    *

Table IV-34 

Wire rod: Forecasts of global and regional production of wire rod, 2014-18 

*                    *                    *                    *                    *                    *                    *

Consumption

U.S. producers indicated that demand for wire rod outside the United States has

fluctuated or decreased since 2008, and anticipate these trends to continue (table IV‐35). Other

market participants were more divided in their views. The majority of foreign producers noted

that demand for wire rod in their home markets fell during the worldwide financial recession of

2008‐09 but has generally recovered and the majority of the foreign producers anticipate that

demand will increase in their home markets.

                                                      

     52 ***.

     53 Published sources of data for wire rod are believed to consist of carbon and alloy (other than

stainless) steel wire rods including grade 1080 tire cord and tire bead wire rod. Data may also include

tool steel, high nickel steel, ball bearing steel, and free machining steel products.
    

IV‐48

Table IV-35 

Wire rod: Firms’ responses regarding demand outside the United States, by number of 

responding firms 

Item Number of firms reporting 

Increase No change Decrease Fluctuate 

Demand outside the United States since 

2008:

 U.S. producers 0 1 3 4 

Importers 6 5 1 7 

Purchasers 9 1 7 1 

Foreign producers 1 1 3 3 

Demand in home market since 2008:

 Foreign producers 3 2 1 2 

Anticipated demand outside the United 

States:

 U.S. producers 0 0 2 7 

Importers 6 7 0 4 

Purchasers 9 3 2 6 

Foreign producers 5 2 0 1 

Anticipated demand in home market:

 Foreign producers 7 1 0 0 

Source: Compiled from data submitted in response to Commission questionnaires.

Data compiled by *** on historical, current, and forecast global consumption of wire

rod are presented in tables IV‐36 through IV‐37. 54 Worldwide consumption of wire rod

increased by *** percent between 2009 and 2013. Consumption in China grew during this

period from *** short tons to *** short tons during this period, an increase of *** percent.

Global consumption is forecast to continue to grow in the coming years, with the growth evenly

distributed in all major markets. Consumption growth in China is forecasted to *** during 2014‐

18 from *** short tons to *** short tons, an increase of *** percent.

Table IV-36 

Wire rod: Global and regional apparent consumption of wire rod, 2009-13 

*                    *                    *                    *                    *                    *                    *

Table IV-37 

Wire rod: Forecasts of global and regional apparent consumption of wire rod, 2014-18 

*                    *                    *                    *                    *                    *                    *

                                                      

     54 See Part II of this report for the individual perspectives of U.S. producers, importers, and purchasers

on demand in the United States and in other markets.
    

IV‐49

Prices

The Commission asked producers, importers, and purchasers to compare market prices

of wire rod in U.S. and non‐U.S. markets. Responding producers and importers indicated prices

generally fluctuate with the price of raw materials in the market. As the price of scrap

increases, the price of wire rod will increase.55  

Six domestic producers were able to compare U.S. and non‐U.S. market prices, and

reported that U.S. producer prices are generally higher than foreign producer prices.56 Some

producers cited higher prices for attracting increasing imports to the U.S. market rather than

foreign markets,57 and another specifically highlighted increasing import volumes from China

and Mexico.58 One producer noted that prices in both the U.S. and even Canadian markets were

being pushed down by Chinese imports.59 Another producer noted that Chinese prices are the

lowest of any major market.60  

Twelve importers were able to provide price comparisons between the United States

and Canada, China, Japan, Korea, the Netherlands. In a general comparison, two importers

reported that prices in the United States are higher, typically 12‐percent or $100 per ton,

respectively.61 One importer described how prices are “generally the same” in both Canada and

the United States, as these markets are integrated.62 Other importers mentioned that high‐

quality grade wire rod imported from Japan is higher priced than the corresponding U.S.

product,63 that Korean wire rod is cheaper by $200 per metric ton,64 and that wire rod

originating from the Netherlands is comparable in price in both the U.S. and other foreign

markets.65 In comparing prices between China and the United States, an importer noted that

Chinese prices are lower by $68‐$80 per ton.66 Another importer reported that wire rod sells for

$550 per metric ton in the Chinese market compared to over $800 per metric ton in the U.S.

market.67  

                                                      

     55 ***’s producer questionnaire responses, IV‐14; and ***’s importer questionnaire responses, III‐19.

     56 ***’s producer questionnaire responses, IV‐22.

     57 ***’s producer questionnaire responses, IV‐22.

     58 ***’s producer questionnaire response, IV‐22.

     59 ***’s producer questionnaire response, IV‐22.

     60 ***’s producer questionnaire response, IV‐22.

     61 ***’s importer questionnaire responses, III‐27.

     62 ***’s importer questionnaire response, III‐27.

     63 ***’s importer questionnaire response, III‐27.

     64 ***’s importer questionnaire response, III‐27.

     65 ***’s importer questionnaire response, III‐27.

     66 ***’s importer questionnaire response, III‐ 27.

     67 ***’s importer questionnaire response, III‐27.
    

IV‐50

Published price data are available from several reputable sources, although often such

data are available by subscription only and cannot be reproduced without consent of their

publisher. These data, however, are collected based on different product categories, timing,

and commercial considerations, and thereby 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 via the Commission’s

questionnaires according to precise product definitions.

As reported by MEPS, world prices for wire rod increased irregularly between January

2008 and March 2014, increasing from $*** per short ton to $*** per short ton during that

time, but below the peak price of $*** per short ton in July 2008.68 Figure IV‐1 presents the

average world price of wire rod between January 2008 and March 2014. Figure IV‐2 presents

prices of wire rod by regions between January 2008 and March 2014.

Figure IV-1 

Wire rod: Average world price per short ton for wire rod, January 2008-March 2014 

*                    *                    *                    *                    *                    *                    *

Figure IV-2 

Wire rod: Prices per short ton by region, January 2008-March 2014 

*                    *                    *                    *                    *                    *                    *

                                                      

     68 Original data are published in metric tons, and were converted to short tons using the following

conversion factor: 1 metric ton = 1.1023 short tons. MEPS, World Carbon Steel Product Prices, found at

http://www.meps.co.uk, retrieved on March 19‐25, 2014. Prices are an arithmetic average of the low

transaction values identified in the EU, Asia, and North America, converted into U.S. dollars.
    

IV‐51

As presented in table IV‐38, country‐specific monthly transaction prices for wire rod are

also compiled by MEPS,69 and show monthly price fluctuations across major producing

countries. According to data compiled by MEPS, U.S. negotiated transaction prices for U.S.‐

produced wire rod rose since the beginning of 2008 to a peak in July and August of that year,

before bottoming out in May 2009.  Wire rod subsequently rose until March 2011, but not as

high as the peak back in summer of 2008, and declined through November 2013. Between

December 2013 and March 2014, prices rose to regain the level of December 2010.

Table IV-38 

Wire rod: Negotiated transaction prices (ex-mill) for wire rod, by country and by month, 

January 2008-March 2014 

*                    *                    *                    *                    *                    *                    *

Prices in Canada closely followed U.S. prices, with the price differential ranging between

$*** below U.S. prices in November 2008 and $*** above U.S. prices in December 2012. The

gap between U.S. and Canadian prices has continued to widen since the narrowest difference

($*** below U.S. prices) in November 2013 through March 2014.

In Europe, major steel market price trends for wire rod also followed those in the United

States, but with a higher average peak values in July and August 2008 ($*** above the U.S.

price level). In contrast, the subsequent price peaked occurred 2 months later (in May 2011)

and at lower average values ($***) compared to the U.S. price peak back in March 2011. In the

first three months of 2014, European average prices were $*** below those in the United

States for wire rod.

With regard to Asian markets, Chinese market prices were consistently below, by $***

per short ton, U.S. wire rod prices, throughout January 2008 to March 2014. Korean wire rod

market prices generally were below those in the United States, with notable exceptions during

July‐December 2010 (on average, $*** above U.S. prices) and November 2013‐February 2014

(on average, $*** above U.S. prices). Japanese market prices generally exceeded U.S. prices in

mid‐2009 through mid‐2012, fluctuating from $*** above U.S. prices to $*** below U.S. prices.

On average, Japanese market prices were $*** above U.S. prices over the January 2008‐March

2014 period.

                                                      

     69 MEPS, International Steel Review, January 2005‐March 2014 editions, p. 1.
    

IV‐52

Additional global supply and demand factors

Worldwide, the majority of wire rod rolling mill capacity during 2008‐13 resides in

China, with *** percent, by ***’s estimate. Apparent rolling mill capacity in China grew

between 2008 and 2013 from *** short tons to *** short tons, an increase of *** percent.

These capacity figures, while large, are less than published production levels.70 Outside of

China, *** percent of wire rod rolling mill capacity during this period resides in Europe; *** in

Asia, other than China; *** in Central and South America; *** percent in North America; and

*** percent in the CIS. Table IV‐39 presents regional rolling mill capacities for wire rod and their

respective shares of global capacity.

Table IV-39 

Wire rod: Global and regional rolling mill capacities, 2008-13, and forecasts of global and regional 

rolling mill capacities, 2014-15 

*                    *                    *                    *                    *                    *                    *

With respect to trade in wire rod, both imports and exports worldwide grew between

2008 and 2013. As shown in table IV‐40, between 2008 and 2013,71 worldwide wire rod imports

increased by 10.3 percent. Exports have similarly grown, as shown in table IV‐41; between 2008

and 2013, worldwide wire rod exports increased by 11.3 percent. The global export data show

that China is the world’s largest exporter of wire rod. Although global exports of wire rod from

China fell by 78.8 percent from 2008 to 2009, such exports grew by 643.0 percent from 2009 to

2013. Detailed information on the export destinations for wire rod produced in China as

published by GTIS/GTA is presented in table IV‐42.

                                                      

     70 Domestic producers— ArcelorMittal USA, Evraz Pueblo, Gerdau, and Keystone— noted that ***.

Domestic producers’ prehearing brief, footnote 31, pp. 59‐60.

     71 Import and export data for 2013 were not yet available for all countries that report to GTIS/GTA.
    

IV‐53

Table IV-40 

Wire rod: Global imports, 2008-13

Reporting entity 2008 2009 2010 2011 2012 2013 

Quantity (short tons) 

United States 1,752,637 892,368 1,596,012 1,322,409 1,588,189 1,775,744

Top import markets: 

 Korea 1,208,879 769,324 1,384,308 1,561,034 1,619,327 1,594,479

 Thailand 647,889 501,990 763,034 799,039 1,142,153 1,487,922

 Germany 1,461,553 1,122,675 1,381,995 1,432,678 1,395,396 1,405,477

 Netherlands 1,144,569 1,105,063 1,315,584 1,701,221 1,647,878 1,359,011

 Malaysia 312,074 316,573 493,031 428,901 663,697 937,076

 Italy 1,275,799 872,395 1,047,085 1,054,944 802,343 853,806

 Indonesia 202,352 181,172 246,443 285,424 511,780 775,941

 Algeria 414,547 526,260 354,765 499,227 557,489 719,362

 France 751,851 552,133 681,713 654,588 601,151 563,910

 Taiwan 703,757 163,038 351,699 313,870 365,653 517,874

 Subtotal 8,123,270 6,110,624 8,019,657 8,730,926 9,306,868 10,214,859

 All Other 8,909,684 6,987,414 8,368,810 8,969,995 8,656,774 8,724,313

Total 18,785,591 13,990,406 17,984,480 19,023,330 19,551,832 20,714,916

Value ($1,000)

United States 1,462,189 595,446 1,141,462 1,156,860 1,263,485 1,217,468

Top import markets: 

 Korea 958,831 427,038 908,861 1,196,229 1,098,504 1,004,791

 Thailand 580,097 324,460 559,359 675,990 844,701 945,046

 Germany 1,283,201 653,956 929,359 1,234,382 1,079,612 1,074,347

 Netherlands 827,235 451,207 592,695 773,850 699,589 586,267

 Malaysia 254,924 196,589 326,162 343,599 467,648 580,271

 Italy 1,133,275 508,276 693,711 890,683 607,867 620,035

 Indonesia 168,767 115,919 172,284 230,461 352,793 454,351

 Algeria 294,786 245,784 195,703 345,953 353,838 411,603

 France 667,067 340,242 472,288 591,637 476,462 422,370

 Taiwan 555,666 88,251 222,590 237,595 244,052 304,287

 Subtotal 6,723,850 3,351,722 5,073,012 6,520,379 6,225,066 6,403,368

 All Other 7,436,176 3,864,502 5,402,339 7,209,237 6,356,022 5,951,139

Total 15,622,215 7,811,670 11,616,813 14,886,476 13,844,572 13,571,975

Table continued on next page. 
    

IV‐54

Table IV-40--Continued

Wire rod: Global imports, 2008-13

Reporting entity 2008 2009 2010 2011 2012 2013 

 Unit value (per short ton)

United States $834 $667 $715 $875 $796 $686

Top import markets: 

 Korea 793 555 657 766 678 630

 Thailand 895 646 733 846 740 635

 Germany 878 582 672 862 774 764

 Netherlands 723 408 451 455 425 431

 Malaysia 817 621 662 801 705 619

 Italy 888 583 663 844 758 726

 Indonesia 834 640 699 807 689 586

 Algeria 711 467 552 693 635 572

 France 887 616 693 904 793 749

 Taiwan 790 541 633 757 667 588

 Subtotal 828 549 633 747 669 627

 All Other 835 553 646 804 734 682

Total 832 558 646 783 708 655

Note.‐‐HS codes included: 7213.91, 7213.99, 7227.20, and 7227.90. 

Source: Reported by GTIS/GTA. 
    

IV‐55

Table IV-41 

Wire rod: Global exports, 2008-13

Reporting entity 2008 2009 2010 2011 2012 2013 

Quantity (short tons) 

United States 145,815 151,913 177,046 191,942 167,925 149,341

Top 10 markets: 

 China 5,545,712 1,174,400 2,524,968 3,210,167 6,087,504 8,725,688

 Germany 2,264,025 1,701,298 2,069,053 2,193,541 2,274,289 2,042,663

 Japan 1,190,846 966,694 1,575,939 1,599,688 1,463,040 1,788,215

 Ukraine 1,631,483 1,647,537 1,985,129 1,899,882 1,688,650 1,454,154

 Czech Republic 621,843 638,757 772,511 871,262 948,862 938,712

 Spain 694,838 678,691 685,098 721,932 937,992 792,624

 Turkey 850,952 1,143,459 1,096,805 1,239,062 985,226 727,076

 Korea 473,690 635,359 502,623 504,893 589,268 716,841

 United Kingdom 638,388 549,777 746,309 612,855 669,620 679,671

 Italy 684,873 588,166 610,650 603,394 644,959 663,238

 Subtotal 14,596,650 9,724,139 12,569,085 13,456,675 16,289,411 18,528,882

 All other 7,228,898 7,054,274 8,259,399 8,024,719 6,463,567 5,770,590

Total 21,971,363 16,930,326 21,005,530 21,673,337 22,920,904 24,448,813

Value ($1,000)

United States 117,814 111,961 143,278 162,572 160,429 143,198

Top 10 markets 

 China 4,314,943 564,568 1,393,123 2,108,971 3,404,928 4,392,955

 Germany 1,939,840 940,555 1,325,841 1,774,878 1,565,412 1,379,100

 Japan 1,053,210 712,525 1,345,667 1,640,268 1,403,642 1,473,109

 Ukraine 1,102,802 600,458 920,223 1,168,837 963,666 752,589

 Czech Republic 527,673 337,341 472,244 670,219 627,811 596,301

 Spain 637,486 384,465 466,207 620,235 658,203 553,173

 Turkey 576,164 472,738 551,351 774,095 573,829 398,188

 Korea 356,397 363,988 363,719 431,267 443,799 472,712

 United Kingdom 529,219 283,599 455,020 482,787 457,221 437,341

 Italy 612,391 315,212 383,484 488,439 440,574 431,579

 Subtotal 11,650,125 4,975,449 7,676,878 10,159,996 10,539,085 10,887,048

 All other 5,759,194 3,439,548 4,666,643 5,844,100 4,398,537 3,719,079

Total 17,527,133 8,526,958 12,486,799 16,166,668 15,098,051 14,749,325

Table continued on next page. 
    

IV‐56

Table IV-41--Continued

Wire rod: Global exports, 2008-13

Reporting entity 2008 2009 2010 2011 2012 2013 

Unit value (per short ton)

United States $808 $737 $809 $847 $955 $959

Top 10 markets 

 China 778 481 552 657 559 503

 Germany 857 553 641 809 688 675

 Japan 884 737 854 1,025 959 824

 Ukraine 676 364 464 615 571 518

 Czech Republic 849 528 611 769 662 635

 Spain 917 566 680 859 702 698

 Turkey 677 413 503 625 582 548

 Korea 752 573 724 854 753 659

 United Kingdom 829 516 610 788 683 643

 Italy 894 536 628 809 683 651

 Subtotal 798 512 611 755 647 588

 All other 797 488 565 728 681 644

Total 798 504 594 746 659 603

Note.‐‐HS codes included: 7213.91, 7213.99, 7227.20, and 7227.90. 

Source: Reported by GTIS/GTA. 
    

IV‐57

Table IV-42 

Wire rod: Exports from China, by destination, 2008-13

Destination 2008 2009 2010 2011 2012 2013 

Quantity (short tons) 

South Korea 915,350 480,403 926,675 1,108,333 1,271,870 1,222,563 

Thailand 443,224 167,629 370,103 467,676 834,352 1,112,951 

Vietnam 447,015 149,758 277,148 250,939 429,878 754,186 

United States 426,677 6,863 11,079 1,316 332,368 691,899 

Indonesia 104,309 8,147 73,489 106,088 420,893 610,565 

Philippines 311,466 20,817 138,375 170,531 315,083 573,987 

Malaysia 129,140 44,607 157,091 187,347 367,269 492,963 

Singapore 123,554 20 42,371 28,195 177,378 325,377 

Japan 197,356 159,945 269,283 307,547 396,600 286,352 

Saudi Arabia 222,765 1,191 15,340 61,904 285,353 256,039 

All other 2,224,855 135,019 244,015 520,290 1,256,460 2,398,807 

 World 5,545,712 1,174,400 2,524,968 3,210,167 6,087,504 8,725,688 

 Value ($1,000)

South Korea 689,233 222,442 502,085 724,949 737,939 632,065 

Thailand 349,718 83,993 209,331 303,208 471,708 566,552 

Vietnam 295,595 70,263 151,498 165,516 242,043 379,269 

United States 361,597 3,449 6,285 1,245 178,155 340,534 

Indonesia 75,587 4,190 42,067 71,627 239,090 317,000 

Philippines 221,407 12,119 72,786 108,589 169,625 274,805 

Malaysia 107,857 21,754 85,400 122,797 207,593 256,762 

Singapore 90,518 14 22,115 17,625 97,847 161,012 

Japan 139,683 73,335 145,618 203,228 225,966 145,433 

Saudi Arabia 186,801 635 9,384 41,619 156,234 128,544 

All other 1,796,947 72,375 146,554 348,569 678,728 1,190,979 

 World 4,314,943 564,568 1,393,123 2,108,971 3,404,928 4,392,955 

Table continued on next page. 
    

IV‐58

Table IV-42--Continued 

Wire rod: Exports from China, by destination, 2008-13

Destination 2008 2009 2010 2011 2012 2013 

Unit value (per short ton)

South Korea 753 463 542 654 580 517

Thailand 789 501 566 648 565 509

Vietnam 661 469 547 660 563 503

United States 847 503 567 947 536 492

Indonesia 725 514 572 675 568 519

Philippines 711 582 526 637 538 479

Malaysia 835 488 544 655 565 521

Singapore 733 680 522 625 552 495

Japan 708 458 541 661 570 508

Saudi Arabia 839 533 612 672 548 502

All other 808 536 601 670 540 496 

 World 778 481 552 657 559 503

Share of quantity (percent)

South Korea 16.5 40.9 36.7 34.5 20.9 14.0

Thailand 8.0 14.3 14.7 14.6 13.7 12.8

Vietnam 8.1 12.8 11.0 7.8 7.1 8.6

United States 7.7 0.6 0.4 0.0 5.5 7.9

Indonesia 1.9 0.7 2.9 3.3 6.9 7.0

Philippines 5.6 1.8 5.5 5.3 5.2 6.6

Malaysia 2.3 3.8 6.2 5.8 6.0 5.6

Singapore 2.2 0.0 1.7 0.9 2.9 3.7

Japan 3.6 13.6 10.7 9.6 6.5 3.3

Saudi Arabia 4.0 0.1 0.6 1.9 4.7 2.9

All other 40.1 11.5 9.7 16.2 20.6 27.5 

 World 100.0 100.0 100.0 100.0 100.0 100.0

Note.‐‐HS codes included: 7213.91, 7213.99, 7227.20, and 7227.90. 

Source: Reported by GTIS/GTA. 
V‐1

PART V: PRICING DATA

FACTORS AFFECTING PRICES

Raw material costs

The primary inputs used in the production of wire rod are billets produced from steel

scrap, natural gas, and electricity. Different types of steel scrap are used in different types of

wire rod, with busheling scrap used to produce higher‐end product and heavy melt used to

produce less‐specialized wire rod.1 As discussed in greater detail in Part III of this report, raw

materials as a share of cost of goods sold (“COGS”) ranged from 60.0 percent to 72.0 percent,

with a weighted average of 67.2 percent during 2008‐13.

Steel scrap prices fluctuated between January 2008 and December 2013, peaking during

the last week of July 2008 and then falling to a period low in the second week of November

2008 (figure V‐1). Prices of all three steel scrap materials increased irregularly from the end of

2008 through the end of 2010 and then continued to fluctuate, decreasing slightly from the first

week of January 2011 through the last week of December 2013.  

Figure V-1 

U.S. ferrous scrap prices: Weekly scrap prices, January 2008-March 2014 

Source: American Metal Market LLC. 

                                                      

1 Carbon and Certain Alloy Steel Wire Rod From Brazil, Canada, Germany, Indonesia, Mexico,

Moldova, Trinidad and Tobago, Turkey, and Ukraine: Investigation Nos. 701‐TA‐417 and 731‐TA‐953,

954, 957‐959, 961, and 962 (Review), USITC Publication 4014, June 2008, p. V‐1.

0

100

200

300

400

500

600

700

800

900

1000

Dollars per short ton

Shredded auto scrap No. 1 heavy melt No. 1 busheling
V‐2

The majority of producers reported that raw material costs are the primary factor in

pricing wire rod. However, three producers reported that although raw material costs have

been increasing, they have been unable to recover those costs due to low‐priced wire rod

imports, primarily from China. The majority of producers (8 of 10) reported that they expect

steel scrap costs to continue fluctuating monthly; three of these producers expect raw material

costs to trend upward.

Energy prices have also fluctuated since 2008; however, the price fluctuations for

natural gas prices were more pronounced than those for electricity (figure V‐2). Overall, U.S.

natural gas prices decreased during the period.2 U.S. natural gas prices peaked in mid‐2008 and

then fell steeply until October 2009 when prices began to rise. Prices of natural gas decreased

irregularly between January 2010 and May 2012, and then increased irregularly through

December 2013 and into 2014. Electricity process fluctuated seasonally but with no significant

net changes.3  

Figure V-2 

U.S. natural gas and electricity prices for industrial customers, monthly, January 2008-February 

2014 

Source: U.S. Energy Information Administration, http://www.eia.doe.gov, retrieved on May 6, 2014. 

                                                      

2 Annual U.S. natural gas prices for industrial customers fell 51.7 percent from $9.65 per thousand

cubic feet in 2008 to $4.66 per thousand cubic feet in 2013.

3 Average annual electricity prices for industrial customers fell 1/100 cent from 6.83 cents per

kilowatt‐hour to 6.82 cents per kilowatt‐hour between 2008 and 2013.  

0.00

1.00

2.00

3.00

4.00

5.00

6.00

7.00

8.00

9.00

0.00

2.00

4.00

6.00

8.00

10.00

12.00

14.00

2008 2009 2010 2011 2012 2013 2014

Cents per kilowatt-hour

Dollars per thousand cubic feet

U.S. natural gas industrial price Electricity industrial price
V‐3

Transportation costs to the U.S. market

Overseas transportation costs have declined overall since 2008. One index often used as

a broad measure of overseas shipping costs is the Baltic Dry Index.4 Increasing from 10,000 at

the beginning of 2008 to its peak of more than 11,500 by the first half of 2008, the index had

fallen to under 1,000 in the beginning of 2009 and did not rise above 5,000 through the rest of

the period (2009‐20013).  

Transportation costs for wire rod shipped from subject countries to the United States

averaged 8.8 percent for Brazil, 2.4 percent for Mexico, and 9.2 percent for Trinidad and

Tobago during 2008‐13.5 6 These estimates were derived from official import data and

represent the transportation and other charges on imports.7 8

The majority of importers (19 of 25) reported that the exporter arranged international

transportation to the customer.9

  Four foreign producers from Brazil, Indonesia, Mexico, and

Trinidad and Tobago reported that *** arranged transportation. Two of three Mexican

producers and both Ukrainian producers reported that *** arranged transportation. Three

foreign producers reported the cost of shipping wire rod to the United States in 2013; the

Brazilian producer reported that transportation cost was $*** per short ton; the Mexican

producer reported that transportation costs was $*** per short ton; and the Indonesian

                                                      

4 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 May 8, 2014. 5 Trinidad and Tobago data are based on 2008 import data.

6 There were no imports of subject product from Indonesia, Moldova, and Ukraine between 2008 and

2013.   7 The estimated transportation costs were obtained by comparing the customs and c.i.f. values for all

years combined (2008‐13) for HTS subheadings 7213.91.3011, 7213.91.3015, 7213.91.3020,

7213.91.3092, 7213.91.3093, 7213.91.4500, 7213.91.6000, 7213.99.0030, 7213.99.0090, 7227.20.0000,

7227.20.0030, 7227.20.0080, 7227.90.6010, 7227.90.6020, 7227.90.6080, and 7227.90.6085.   8 In the original investigations, transportation costs for wire rod were estimated using official import

data in 2001. Transportation costs averaged 14.4 percent for Brazil, 10.1 percent for Indonesia, 8.9

percent for Mexico, 11.6 percent for Moldova, 8.4 percent for Trinidad and Tobago, and 11.7 percent for

Ukraine. Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Germany, Indonesia, Mexico,

Moldova, Trinidad and Tobago, Turkey, and Ukraine, Inv. Nos. 701‐TA‐417‐421 and 731‐TA‐953, 954,

956‐959, 961, and 962 (Final), USITC Staff Report, p. V‐1.

9 Seven importers reported that the importer arranged international transportation; however, no

importer reported the cost of shipping wire rod to the United States.
V‐4

producer reported that the cost was $*** per short ton. The Ukrainian respondent estimated

that transportation and logistical costs would be $*** per short ton.10 11

U.S. inland transportation costs

All nine responding U.S. producers and 8 of 12 responding importers reported that they

typically arrange transportation to their customers. U.S. producers reported that their U.S.

inland transportation costs averaged 5 to 8 percent while importers reported costs of 1 to 14

percent.

PRICING PRACTICES

Pricing methods

As presented in table V‐1, U.S. producers and importers sell primarily on transaction‐by‐

transaction negotiations. However, firms also reported using contracts, set price lists, and other

methods including indexing prices to scrap and other raw material costs as well as current

market conditions. The majority of producers (9 of 12) and importers (17 of 21) reported that

they consider the cost of scrap steel when setting prices for wire rod. Three producers and

three importers reported that they use a separate surcharge for scrap prices.  

Table V-1 

Wire rod: U.S. producers’ and importers’ reported price setting methods, by number of 

responding firms1

Method U.S. producers Importers 

Transaction-by-transaction 8 19 

Contract 4 6 

Set price list 0 1 

Other 4 2 

1

 The sum of responses down may not add up to the total number of responding firms as each firm was 

instructed to check all applicable price setting methods employed.

Source: Compiled from data submitted in response to Commission questionnaires.

   

                                                      

10 This estimate includes $*** for inland U.S. freight costs and $*** for related lead time and other

discounts. Yenakiieve’s posthearing brief, pp. 14‐15.   11 Both domestic interested parties disagree with Yenakiieve’s freight estimates. Hearing transcript,

p. 107 (Price). Nucor suggests that it would cost approximately $*** per short ton to ship wire rod to the

United States. Nucor’s posthearing brief, p.19.  
V‐5

As shown in table V‐2, U.S. producers and importers reported their 2013 U.S.

commercial shipments of wire rod by type of sale. U.S. producers reported selling the majority

of their wire rod split between short‐term contracts and the spot market while both importers

of wire rod from Mexico reported selling *** of their product in ***.12  

Table V-2 

Wire rod: U.S. producers’ and importers’ shares of U.S. commercial shipments by type of sale, 

2013 

Type of sale U.S. producers 

Importers of product from 

Mexico 

Long-term contracts 3.5 *** 

Short-term contracts 51.2 *** 

Spot sales 45.3 *** 

Total 100.0 100.0 

Note.--Because of rounding, figures may not add to the totals shown. 

Source: Compiled from data submitted in response to Commission questionnaires.

The majority of purchasers (28 of 35) reported that they purchase product monthly, 5

purchase weekly, and 5 purchase daily, 4 purchase quarterly, and one purchases annually.13 All

35 responding purchasers reported that they did not expect their purchasing patterns to

change in the next two years. Most (25 of 34) purchasers contact 1 to 5 suppliers before making

a purchase.

Sales terms and discounts

U.S. producers and importers quote prices both on an f.o.b. and a delivered basis. Four

of 10 U.S. producers and 20 of 24 importers reported that they sold on a delivered basis. The

majority of producers (6 of 10) and importers (21 of 24) do not offer discounts. Two producers

and two importers reported that they offer quantity‐based discounts and two producers and

one importer reported that they offer total volume discounts. Five producers reported sales

terms of 1⁄2 percent 10 net 30, three reported net 30 days, two reported 1 percent 10 net 30

days, and one reported 3⁄4 percent 10 net 30 days. In contrast, 17 importers reported net 30

days, seven reported net 60 days, two reported 2/10 net 30 days, and one reported 1 percent

10 net 30 days.

Price leadership

Purchasers reported that Charter Steel, Keystone Steel & Wire, Nucor, and Gerdau were

price leaders.

                                                      

12 No importers from other subject countries reported their sale types.

13 Four purchasers indicated that their purchasing frequency varied throughout the year.  
V‐6

PRICE DATA

The Commission requested U.S. producers and importers to provide quarterly data for

the total quantity and f.o.b. value of the following wire rod products shipped to unrelated U.S.

customers during 2008‐13.

Product 1.—Industrial quality wire rod, grade C1006, 5.5 mm (7/32 inch) through 12 mm 

(15/32 inch) in diameter, for hangers, chain link fencing, collated nails and 

staples, grates, and other formed products (in green condition, e.g., NOT 

cleaned, coated, etc.). 

Product 2.--Industrial quality wire rod, grade C1008 through C1010, 5.5 mm (7/32 inch) 

through 12 mm (15/32 inch) in diameter, for hangers, chain link fencing, 

collated nails and staples, grates, and other formed products (in green condition, 

e.g., NOT cleaned, coated, etc.). 

Product 3.—Mesh quality wire rod, grades C1006 through C1015, 5.5 mm (7/32 inch) 

through 14 mm (9/16 inch) in diameter, for the manufacturing of concrete 

reinforcement products such as wire for A-82 applications (in green condition, 

e.g., NOT cleaned, coated, etc.). 

Product 4.—Grades C1050 through C1070, 5.5 mm (7/32 inch) through 6.5 mm (1/4 inch) in 

diameter, for spring applications excluding valve spring (in green condition, e.g., 

NOT cleaned, coated, etc.). 

Nine U.S. producers and two importers of wire rod from Mexico provided usable pricing

data for sales of the requested products, although not all firms reported pricing for all products

for all quarters.14 Pricing data reported by these firms accounted for approximately 31.0

percent of U.S. producers’ shipments of product and *** percent of U.S. shipments of subject

imports from Mexico during 2008‐13. Price data for products 1‐4 are presented in tables V‐3 to

V‐6 and figures V‐3 to V‐6.  

                                                      

14 Two importers, ***, provided price data for sales of the requested products. In addition, price data

for Deacero’s U.S. imports of smaller diameter wire rod from Mexico were reported and are presented

separately in appendix F.
V‐7

Table V-3 

Wire rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 11

 and 

margins of underselling/(overselling), by quarters, January 2008-December 2013 

Period 

United States Mexico 

Price 

(per short ton) 

Quantity

(short tons) 

Price

(per short ton) 

Quantity 

(short tons) 

Margin

(percent) 

2008: 

Jan.-Mar. $629.93 66,223 -- 0 --

Apr.-June 832.84 80,992 -- 0 --

July-Sept. 968.10 67,422 -- 0 --

Oct.-Dec. 765.95 33,674 -- 0 --

2009: 

Jan.-Mar. 587.37 31,373 -- 0 --

Apr.-June 499.70 30,834 -- 0 --

July-Sept. 527.86 70,119 -- 0 --

Oct.-Dec. 538.35 77,718 -- 0 --

2010: 

Jan.-Mar. 582.31 55,887 -- 0 --

Apr.-June 649.32 56,231 $*** *** ***

July-Sept. 621.07 49,317 *** *** ***

Oct.-Dec. 598.35 66,348 -- 0 --

2011: 

Jan.-Mar. 696.23 52,619 -- 0 --

Apr.-June 744.55 52,991 -- 0 --

July-Sept. 746.72 55,490 -- 0 --

Oct.-Dec. 726.84 57,352 *** *** ***

2012: 

Jan.-Mar. 740.49 51,424 *** *** ***

Apr.-June 742.20 50,288 *** *** ***

July-Sept. 665.61 51,449 *** *** ***

Oct.-Dec. 647.02 47,934 -- 0 --

2013: 

Jan.-Mar. 661.33 52,525 -- 0 --

Apr.-June 661.06 57,184 -- 0 --

July-Sept. 647.37 39,538 -- 0 --

Oct.-Dec. 623.74 60,619 -- 0 --

1

 Product 1: Industrial quality wire rod, grade C1006, 5.5 mm (7/32 inch) through 12 mm (15/32 inch) in 

diameter, for hangers, chain link fencing, collated nails and staples, grates, and other formed products (in 

green condition, e.g., NOT cleaned, coated, etc.).

Source: Compiled from data submitted in response to Commission questionnaires.

   
V‐8

Table V-4 

Wire rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 21

 and 

margins of underselling/(overselling), by quarters, January 2008-December 2013 

Period 

United States Mexico 

Price 

(per short ton) 

Quantity

(short tons) 

Price

(per short ton) 

Quantity 

(short tons) 

Margin

(percent) 

2008: 

Jan.-Mar. $608.01 112,341 -- 0 --

Apr.-June 803.18 104,554 $*** *** ***

July-Sept. 983.72 96,361 -- 0 --

Oct.-Dec. 827.86 24,431 *** *** ***

2009: 

Jan.-Mar. 571.40 26,070 *** *** ***

Apr.-June 500.46 76,105 *** *** ***

July-Sept. 527.13 100,010 *** *** ***

Oct.-Dec. 536.43 87,642 *** *** ***

2010: 

Jan.-Mar. 545.32 105,556 *** *** ***

Apr.-June 592.48 133,320 *** *** ***

July-Sept. 593.19 90,253 *** *** ***

Oct.-Dec. 596.34 78,875 *** *** ***

2011: 

Jan.-Mar. 682.67 124,344 -- 0 --

Apr.-June 725.59 147,345 -- 0 --

July-Sept. 725.42 124,031 -- 0 --

Oct.-Dec. 710.89 136,296 *** *** ***

2012: 

Jan.-Mar. 719.16 130,660 *** *** ***

Apr.-June 716.01 126,868 *** *** ***

July-Sept. 651.67 108,924 *** *** ***

Oct.-Dec. 636.10 80,176 -- 0 --

2013: 

Jan.-Mar. 644.23 109,879 -- 0 --

Apr.-June 661.44 96,010 -- 0 --

July-Sept. 630.02 82,624 -- 0 --

Oct.-Dec. 623.65 82,123 *** *** ***

1

 Product 2: Industrial quality wire rod, grade C1008 through C1010, 5.5 mm (7/32 inch) through 12 mm 

(15/32 inch) in diameter, for hangers, chain link fencing, collated nails and staples, grates, and other 

formed products (in green condition, e.g., NOT cleaned, coated, etc.).

Source: Compiled from data submitted in response to Commission questionnaires.
V‐9

Table V-5 

Wire rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 31

 and 

margins of underselling/(overselling), by quarters, January 2008-December 2013 

Period 

United States Mexico 

Price 

(per short ton) 

Quantity

(short tons) 

Price

(per short ton) 

Quantity 

(short tons) 

Margin

(percent) 

2008: 

Jan.-Mar. $600.10 157,970 -- 0 --

Apr.-June 793.82 145,963 -- 0 --

July-Sept. 999.38 123,287 -- 0 --

Oct.-Dec. 807.31 55,134 -- 0 --

2009: 

Jan.-Mar. 603.57 38,034 -- 0 --

Apr.-June 505.46 74,545 -- 0 --

July-Sept. 522.94 99,487 $*** *** ***

Oct.-Dec. 540.38 67,544 -- 0 --

2010: 

Jan.-Mar. 573.33 97,267 -- 0 --

Apr.-June 646.31 91,568 *** *** ***

July-Sept. 627.89 91,037 -- 0 --

Oct.-Dec. 612.42 74,798 *** *** ***

2011: 

Jan.-Mar. 681.09 108,039 -- 0 --

Apr.-June 731.76 102,588 -- 0 --

July-Sept. 737.61 101,646 -- 0 --

Oct.-Dec. 712.69 117,620 *** *** ***

2012: 

Jan.-Mar. 723.55 142,543 *** *** ***

Apr.-June 717.04 128,694 *** *** ***

July-Sept. 656.06 132,341 *** *** ***

Oct.-Dec. 629.73 103,770 -- 0 --

2013: 

Jan.-Mar. 641.09 122,648 -- 0 --

Apr.-June 657.91 125,272 -- 0 --

July-Sept. 630.92 109,866 -- 0 --

Oct.-Dec. 621.26 96,799 *** *** ***

1

 Product 3: Mesh quality wire rod, grades C1006 through C1015, 5.5 mm (7/32 inch) through 14 mm 

(9/16 inch) in diameter, for the manufacturing of concrete reinforcement products such as wire for A-82 

applications (in green condition, e.g., NOT cleaned, coated, etc.).

Source: Compiled from data submitted in response to Commission questionnaires.
V‐10

Table V-6 

Wire rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 41

 and 

margins of underselling/(overselling), by quarters, January 2008-December 2013 

Period 

United States Mexico 

Price 

(per short ton) 

Quantity

(short tons) 

Price

(per short ton) 

Quantity 

(short tons) 

Margin

(percent) 

2008: 

Jan.-Mar. $627.11 17,631 -- 0 --

Apr.-June 887.76 22,243 -- 0 --

July-Sept. 1,104.35 19,659 -- 0 --

Oct.-Dec. 923.51 12,244 -- 0 --

2009: 

Jan.-Mar. 643.94 9,758 -- 0 --

Apr.-June 559.51 12,149 -- 0 --

July-Sept. 577.72 15,681 -- 0 --

Oct.-Dec. 589.57 16,120 -- 0 --

2010: 

Jan.-Mar. 638.25 21,382 -- 0 --

Apr.-June 698.52 25,649 $*** *** ***

July-Sept. 709.34 11,310 *** *** ***

Oct.-Dec. 681.55 13,490 -- 0 --

2011: 

Jan.-Mar. 745.64 22,551 -- 0 --

Apr.-June 791.11 28,115 -- 0 --

July-Sept. 794.67 19,343 -- 0 --

Oct.-Dec. 767.57 19,378 *** *** ***

2012: 

Jan.-Mar. 758.35 27,350 *** *** ***

Apr.-June 766.40 30,372 *** *** ***

July-Sept. 716.99 15,614 *** *** ***

Oct.-Dec. 699.44 16,814 -- 0 --

2013: 

Jan.-Mar. 715.71 19,751 -- 0 --

Apr.-June 710.42 22,564 -- 0 --

July-Sept. 687.67 18,132 *** *** ***

Oct.-Dec. 701.67 14,469 *** *** ***

1

 Product 4: Grades C1050 through C1070, 5.5 mm (7/32 inch) through 6.5 mm (1/4 inch) in diameter, for 

spring applications excluding valve spring (in green condition, e.g., NOT cleaned, coated, etc.).

Source: Compiled from data submitted in response to Commission questionnaires.
V‐11

Figure V-3 

Wire rod: Weighted-average prices and quantities of domestic and imported product, by quarters,

January 2008-December 2013 

*            *            *            *           *            *            *

Figure V-4 

Wire rod: Weighted-average prices and quantities of domestic and imported product, by quarters, 

January 2008-December 2013 

*            *            *            *           *            *            *

Figure V-5 

Wire rod: Weighted-average prices and quantities of domestic and imported product, by quarters, 

January 2008-December 2013 

*            *            *            *           *            *            *

Figure V-6 

Wire rod: Weighted-average prices and quantities of domestic and imported product, by quarters, 

January 2008-December 2013 

*            *            *            *           *            *            *

Price trends

Prices for wire rod fluctuated during 2008‐13 with prices generally falling from third

quarter 2008 peak levels into 2009, increasing during the latter half of 2009 through 2011, and

then falling during 2012‐13. Overall, prices for wire rod increased between the first quarter of

2008 and the last quarter in 2013. Table V‐7 summarizes the price trends, by country and by

product. As shown in the table, domestic price increases ranged from 2.6 percent to 11.9

percent during 2008‐13 while import price increases ranged from *** percent to *** percent.

Domestic prices for all four products steadily increased from first quarter of 2008 and then

peaked during the third quarter of 2011; domestic prices generally declined over the following

nine quarters. Available price data of wire rod imported from Mexico is sporadic but shows

similar price trends to domestic prices, with prices peaking in the fourth quarter of 2011 before

falling through the end of the period.
V‐12

Table V-7 

Wire rod: Summary of weighted-average f.o.b. prices for products 1-4 from the United States and 

Mexico 

Item 

Number of 

quarters 

Low price 

(per unit) 

High price 

(per unit) 

Change in 

price1

 (percent) 

Product 1

United States 24 499.70 968.10 (1.0)

Mexico 6 *** *** *** 

Product 2

United States 24 500.46 983.72 2.6 

Mexico 15 *** *** *** 

Product 3

United States 24 505.46 999.38 3.5 

Mexico 8 *** *** *** 

Product 4

United States 24 559.51 1,104.35 11.9 

Mexico 8 *** *** *** 1

 Percentage change from the first quarter in which data were available to the last quarter in which price data were 

available, based on rounded data.

Source: Compiled from data submitted in response to Commission questionnaires. 

Price comparisons

As shown in table V‐8, prices for wire rod imported from Mexico were below those for

U.S.‐produced product in 30 of 37 instances; margins of underselling ranged from *** to ***

percent. In the remaining 7 instances, prices for wire rod imported from Mexico were higher

than domestic prices, with margins of overselling ranging from *** to ***.15 16  

                                                      

15 In the original investigations, Brazilian product undersold domestic product in 38 of 47 possible

price comparisons, with an average margin of *** percent; Indonesian product undersold domestic

product in all 3 possible price comparisons, with an average margin of *** percent; product imported

from Mexico undersold domestic product in 37 of 46 possible comparisons, with an average margin of

*** percent; product imported from Moldova undersold domestic product in 19 of 22 possible price

comparisons, with an average margin of *** percent; product imported from Trinidad and Tobago

undersold domestic product in 36 of 52 possible price comparisons, with an average margin of ***

percent; product imported from Ukraine undersold domestic product in 21 of 22 possible price

comparisons, with an average margin of *** percent.  

Also in the original investigations, domestic producers alleged lost revenues from imports from Brazil

(*** allegations) and lost sales from imports from Brazil (*** allegations), Moldova (***), Mexico (***),

Trinidad and Tobago (***), and Ukraine (***). Domestic producers alleged *** lost revenues or lost

sales from imports from Indonesia. Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada,

Germany, Indonesia, Mexico, Moldova, Trinidad and Tobago, Turkey, and Ukraine, Inv. Nos. 701‐TA‐417‐

(continued...)
V‐13

Table V-8 

Wire rod: Instances of underselling/overselling and the range and average of margins, by product 

from Mexico, January/March 2008-October/December 2013 

Product 

Underselling Overselling 

Number 

of 

instances 

Range 

(percent) 

Average 

margin 

(percent) 

Number 

of 

instances 

Range 

(percent) 

Average 

margin 

(percent)

Product 1 4 *** *** 2 *** *** 

Product 2 12 *** *** 3 *** *** 

Product 3 6 *** *** 2 *** *** 

Product 4 8 *** *** 0 -- -- 

 Total 30 *** 9.6 7 *** (1.8) 

Source: Compiled from data submitted in response to Commission questionnaires.

                                                            

(...continued)

421 and 731‐TA‐953, 954, 956‐959, 961, and 962 (Final), USITC Staff Report, pp. V‐15‐V‐29 and tables V‐

11 and V‐12.

16 In the first reviews, product imported from Brazil undersold domestic product in all 3 possible price

comparisons, with an average margin of *** percent; Indonesian product undersold domestic product in

all 3 possible price comparisons, with an average margin of *** percent; product imported from Mexico

undersold domestic product in 26 of 54 possible comparisons, with margins of underselling ranging from

*** to *** percent; product imported from Moldova undersold domestic product in all 5 possible price

comparisons, with an average margin of *** percent; product imported from Trinidad and Tobago

undersold domestic product in 8 of 14 possible price comparisons, with margins of underselling ranging

from *** to *** percent; product imported from Ukraine undersold domestic product in all 6 possible

price comparisons, with an average margin of *** percent. Carbon and Certain Alloy Steel Wire Rod from

Brazil, Canada, Germany, Indonesia, Mexico, Moldova, Trinidad and Tobago, Turkey, and Ukraine, Inv.

Nos. 701‐TA‐417‐421 and 731‐TA‐953, 954, 956‐959, 961, and 962 (Final), USITC Staff Report, pp. V‐15‐

V‐29; and Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada,  Indonesia, Mexico, Moldova,

Trinidad and Tobago, and Ukraine, Inv. Nos. 701‐TA‐417 and 731‐TA‐953, 954, 957‐959, 961, and 962

(Review), USITC Staff Report, p. V‐26.

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 

78 FR 33063 

June 3, 2013 Initiation of Five-Year (“Sunset”) Review 

http://www.usitc.gov/trade_remedy/731_ad_7

01_cvd/investigations/2013/wire_rod/PDF/Co

mmerce%20initiation.pdf 

78 FR 33103 

June 3, 2013 

Carbon and Certain Alloy Steel Wire 

Rod From Brazil, Indonesia, Mexico, 

Moldova, Trinidad and Tobago, and 

Ukraine: Institution of five-year reviews 

http://www.usitc.gov/trade_remedy/731_ad_7

01_cvd/investigations/2013/wire_rod/PDF/Ins

titution.pdf 

78 FR 60316 

October 1, 

2013 

Carbon and Certain Alloy Steel Wire 

Rod From Brazil, Indonesia, Mexico, 

Moldova, Trinidad and Tobago, and 

Ukraine: Notice of Commission 

Determination To Conduct Full FiveYear Reviews 

http://www.usitc.gov/trade_remedy/731_ad_7

01_cvd/investigations/2013/wire_rod/PDF/No

tice%20to%20conduct%20full%20review.pdf 

78 FR 60850 

October 2, 

2013 

Carbon and Certain Alloy Steel Wire 

Rod From Brazil: Final Results of the 

Expedited Second Sunset Review of 

the Countervailing Duty Order 

http://www.usitc.gov/trade_remedy/731_ad_7

01_cvd/investigations/2013/wire_rod/PDF/Co

mmerce%20final%20results%20CVD.pdf 

78 FR 63450 

October 24, 

2013 

Carbon and Certain Alloy Steel Wire 

Rod From Brazil, Indonesia, Mexico, 

Moldova, Trinidad and Tobago, and 

Ukraine: Final Results of the Expedited 

Second Sunset Reviews of the 

Antidumping Duty Orders 

http://www.usitc.gov/trade_remedy/731_ad_7

01_cvd/investigations/2013/wire_rod/PDF/Co

mmerce%20final%20results%20AD.pdf 

78 FR 76653 

December 18, 

2013 

Carbon and Certain Alloy Steel Wire 

Rod From Brazil, Indonesia, Mexico, 

Moldova, Trinidad and Tobago, and 

Ukraine: Scheduling of full five-year 

reviews concerning the countervailing 

duty order on carbon and certain alloy 

steel wire rod from Brazil and the 

antidumping duty orders on carbon and 

certain alloy steel wire rod from Brazil, 

Indonesia, Mexico, Moldova, Trinidad 

and Tobago, and Ukraine 

http://www.usitc.gov/trade_remedy/731_ad_7

01_cvd/investigations/2013/wire_rod/PDF/Sc

heduling.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://usitc.gov/press_room/news_release/2013/er0906ll1.htm. A summary of the Commission’s votes 

concerning adequacy and the conduct of a full or expedited review can be found at 

http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11596. The Commission’s explanation 

of its determinations can be found at 

http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11597. 

B‐1

APPENDIX B

LIST OF HEARING WITNESSES

B‐3

CALENDAR OF PUBLIC HEARING

 Those listed below appeared as witnesses at the United States International Trade 

Commission’s hearing: 

Subject: Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia, Mexico, 

 Moldova, Trinidad and Tobago, and Ukraine 

Inv. Nos.: 701-TA-417 and 731-TA-953, 957-959, 961and 962 (Second Review) 

Date/Time: April 22, 2014 - 9:30 a.m. 

 Sessions will be held in connection with these investigations in the Main Hearing Room 

(room 101), 500 E Street, S.W., Washington, DC. 

EMBASSY WITNESSES: 

Embassy of Ukraine 

Washington, DC 

 Ihor Baranetskyi, Acting Head of the Economic Division

 Oleksandr Pakhil, Second Secretary 

Embassy of Mexico 

Washington, DC

Salvador Behar, Legal Counsel for International Trade

TIME

OPENING REMARKS: ALLOCATION:

In Support of Continuation (Kathleen W. Cannon, Kelley Drye 5 minutes

& Warren LLP) 

In Opposition to Continuation (Jay C. Campbell, White & Case LLP; 5 minutes

 and Craig A. Lewis, Hogan Lovells US LLP)

 
B‐4

In Support of the Continuation of TIME

 Antidumping and Countervailing Duty Orders: ALLOCATION:

 60 minutes total

Kelley Drye & Warren LLP 

Washington, DC 

on behalf of 

ArcelorMittal USA LLC 

Evraz Pueblo 

Gerdau Ameristeel US Inc. 

Keystone Consolidated Industries, Inc. 

 James Kerkvliet, Vice President of Sales and Marketing, 

 Gerdau Ameristeel US 

 Edward Goettl, Manager of Wire Rod Sales, Gerdau Ameristeel US 

 

 Vic Stirnaman, President, Keystone Consolidated Industries, Inc. 

Stephen Ashby, Director of Rod and Bar Sales, Evraz Pueblo 

James Sanderson, President, USW Local 7898 

Michael Kerwin, Director, Georgetown Economic Services 

Gina E. Beck, Economist, Georgetown Economic Services 

 Kathleen W. Cannon ) 

 Paul C. Rosenthal ) 

 ) – OF COUNSEL 

Benjamin Blase Caryl )

R. Alan Luberda ) 

 

Wiley Rein LLP 

Washington, DC 

on behalf of 

Nucor Corporation (“Nucor”) 

 Eric Nystrom, National Marketing Manager for Wire Rod, 

 SBQ, and Cold Finish Products, Nucor 

 Alan H. Price ) 

Daniel B. Pickard ) – OF COUNSEL 

Maureen E. Thorson ) 
B‐5

In Opposition to the Continuation of TIME

 Antidumping and Countervailing Duty Orders: ALLOCATION:

 60 minutes total

White & Case LLP 

Washington, DC 

on behalf of 

Deacero S.A.P.I de C.V. (“Deacero”) 

Deacero USA, Inc. (“Deacero USA”) 

 Sergio Gutierrez, Chief Executive Officer, Deacero 

 Eugenio Gutierrez, Vice President of Finance & 

 International Trade, Deacero 

 Daniel Gutierrez, Vice President of Industrial Sales, 

 Deacero 

 Luis Leal, International Trade Manager, Deacero 

 Charles Spittler, Chief Operating Officer, Cavert 

 Wire Company, Inc. 

 Bill Heileg, Co-Owner and Member, G3 Steel 

 Group LLC 

 David E. Bond ) 

 ) – OF COUNSEL 

 Jay C. Campbell ) 

Hogan Lovells US LLP 

Washington, DC 

on behalf of 

Public Joint Stock Company Yenakiieve Iron 

and Steel Works (“Yenakiieve”) 

 

 Elena Dimitrova, Head of Marketing, Commercial Service, 

 Sales Directorate, Metinvest Holding, LLC 

 Craig A. Lewis ) 

Jonathan T. Stoel ) – OF COUNSEL 

Wesley V. Carrington ) 

C‐1

APPENDIX C

SUMMARY DATA

Table C-1

Wire rod: Summary data concerning the U.S. market, 2008-13

2008 2009 2010 2011 2012 2013 2008-13 2008-09 2009-10 2010-11 2011-12 2012-13

U.S. consumption quantity:

Amount................................................. *** *** *** *** *** 5,300,149 *** *** *** *** *** ***

Producers' share (1)............................. *** *** *** *** *** 67.9 *** *** *** *** *** ***

Importers' share (1):

Brazil................................................. 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

Mexico............................................... *** *** *** *** *** 0.2 *** *** *** *** *** ***

Moldova............................................. 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Trinidad & Tobago............................. *** 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

Subtotal, subject sources................ *** *** *** *** *** 0.2 *** *** *** *** *** ***

1080 tire cord/tire bead...................... *** *** *** *** *** 1.8 *** *** *** *** *** ***

All others sources.............................. *** *** *** *** *** 30.1 *** *** *** *** *** ***

Subtotal, nonsubject sources.......... *** *** *** *** *** 31.9 *** *** *** *** *** ***

Total imports................................ *** *** *** *** *** 32.1 *** *** *** *** *** ***

U.S. consumption value:

Amount................................................. *** *** *** *** *** 3,756,412 *** *** *** *** *** ***

Producers' share (1)............................. *** *** *** *** *** 67.3 *** *** *** *** *** ***

Importers' share (1):

Brazil................................................. 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

Mexico............................................... *** *** *** *** *** 0.2 *** *** *** *** *** ***

Moldova............................................. 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Trinidad & Tobago............................. *** *** *** *** *** 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

Subtotal, subject sources................ *** *** *** *** *** 0.2 *** *** *** *** *** ***

1080 tire cord/tire bead...................... *** *** *** *** *** 1.7 *** *** *** *** *** ***

All others sources.............................. *** *** *** *** *** 30.8 *** *** *** *** *** ***

Subtotal, nonsubject sources.......... *** *** *** *** *** 32.5 *** *** *** *** *** ***

Total imports................................ *** *** *** *** *** 32.7 *** *** *** *** *** ***

U.S. imports from:

Brazil:

Quantity............................................. 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Value................................................. 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Unit value.......................................... (2

) (2) (2) (2) (2) (2) (2) (2) (2) (2) (2) (2)

Ending inventory quantity................... 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Indonesia:

Quantity............................................. 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Value................................................. 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Unit value.......................................... (2

) (2) (2) (2) (2) (2) (2) (2) (2) (2) (2) (2)

Ending inventory quantity................... 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Mexico:

Quantity............................................. *** *** *** *** *** 10,333 *** *** *** *** *** ***

Value................................................. *** *** *** *** *** 6,128 *** *** *** *** *** ***

Unit value.......................................... *** *** *** *** *** $593 *** *** *** *** *** ***

Ending inventory quantity................... *** *** *** *** *** 0 *** *** *** *** *** ***

Moldova:

Quantity............................................. 0 0 0 0 0 0(2) (2) (2) (2) (2) (2)

Value................................................. 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Unit value.......................................... (2

) (2) (2) (2) (2) (2) (2) (2) (2) (2) (2) (2)

Ending inventory quantity................... 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Trinidad & Tobago:

Quantity............................................. 21,794 00000 (100.0) (100.0) (

2

) (2) (2) (2)

Value................................................. 14,298 00000 (100.0) (100.0) (

2

) (2) (2) (2)

Unit value.......................................... $656 (2

) (2) (2) (2) (2) (2) (2) (2) (2) (2) (2)

Ending inventory quantity................... *** 0 0 0 0 0 *** *** (2

) (2) (2) (2)

Ukraine:

Quantity............................................. 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Value................................................. 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Unit value.......................................... (2

) (2) (2) (2) (2) (2) (2) (2) (2) (2) (2) (2)

Ending inventory quantity................... 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

Subtotal, subject sources: CDE FG

Quantity............................................. *** *** *** *** *** 10,333 *** *** *** *** *** ***

Value................................................. *** *** *** *** *** 6,128 *** *** *** *** *** ***

Unit value.......................................... *** *** *** *** *** $593 *** *** *** *** *** ***

Ending inventory quantity................... *** *** *** *** *** 0 *** *** *** *** *** ***

Table continued on next page............

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)

Reported data

Calendar year

Period changes

Comparison periods
Table C-1

Wire rod: Summary data concerning the U.S. market, 2008-13

2008 2009 2010 2011 2012 2013 2008-13 2008-09 2009-10 2010-11 2011-12 2012-13

U.S. imports from: 

 1080 tire cord/tire bead:

Quantity............................................. 139,459 71,759 129,184 116,513 102,517 96,639 (30.7) (48.5) 80.0 (9.8) (12.0) (5.7)

Value................................................. 126,654 50,808 91,621 103,073 84,521 64,506 (49.1) (59.9) 80.3 12.5 (18.0) (23.7)

Unit value.......................................... $908 $708 $709 $885 $824 $667 (26.5) (22.0) 0.2 24.7 (6.8) (19.0)

Ending inventory quantity................... 0 0 0 0 0 0(2

) (2) (2) (2) (2) (2)

All other sources:

Quantity............................................. 1,536,768 777,083 1,284,771 1,059,512 1,391,895 1,593,718 3.7 (49.4) 65.3 (17.5) 31.4 14.5

Value................................................. 1,360,431 550,614 988,457 992,791 1,159,903 1,156,290 (15.0) (59.5) 79.5 0.4 16.8 (0.3)

Unit value.......................................... $885 $709 $769 $937 $833 $726 (18.0) (20.0) 8.6 21.8 (11.1) (12.9)

Ending inventory quantity................... 106,455 61,033 72,308 61,769 90,584 105,991 (0.4) (42.7) 18.5 (14.6) 46.6 17.0

Subtotal, nonsubject sources:

Quantity............................................. 1,676,227 848,842 1,413,955 1,176,024 1,494,413 1,690,357 0.8 (49.4) 66.6 (16.8) 27.1 13.1

Value................................................. 1,487,085 601,423 1,080,078 1,095,863 1,244,424 1,220,797 (17.9) (59.6) 79.6 1.5 13.6 (1.9)

Unit value.......................................... $887 $709 $764 $932 $833 $722 (18.6) (20.1) 7.8 22.0 (10.6) (13.3)

Ending inventory quantity................... 106,455 61,033 72,308 61,769 90,584 105,991 (0.4) (42.7) 18.5 (14.6) 46.6 17.0

Total imports:

Quantity............................................. *** *** *** *** *** 1,700,690 *** *** *** *** *** ***

Value................................................. *** *** *** *** *** 1,226,925 *** *** *** *** *** ***

Unit value.......................................... *** *** *** *** *** $721 *** *** *** *** *** ***

Ending inventory quantity................... *** *** *** *** *** 105,991 *** *** *** *** *** ***

U.S. producers':

Average capacity quantity..................... 5,546,751 5,295,752 4,965,095 5,173,168 5,131,954 5,073,815 (8.5) (4.5) (6.2) 4.2 (0.8) (1.1)

Production quantity............................... 4,055,641 2,837,165 3,384,322 3,907,416 3,879,060 3,655,088 (9.9) (30.0) 19.3 15.5 (0.7) (5.8)

Capacity utilization (1)........................... 73.1 53.6 68.2 75.5 75.6 72.0 (1.1) (19.5) 14.6 7.4 0.1 (3.5)

U.S. shipments:

Quantity............................................. 4,050,961 2,833,426 3,340,954 3,876,145 3,809,728 3,599,459 (11.1) (30.1) 17.9 16.0 (1.7) (5.5)

Value................................................. 3,485,005 1,651,451 2,246,759 3,012,054 2,826,974 2,529,487 (27.4) (52.6) 36.0 34.1 (6.1) (10.5)

Unit value.......................................... $860 $583 $672 $777 $742 $703 (18.3) (32.3) 15.4 15.6 (4.5) (5.3)

Export shipments:

Quantity............................................. 39,707 39,301 42,049 34,687 26,748 24,319 (38.8) (1.0) 7.0 (17.5) (22.9) (9.1)

Value................................................. 31,925 22,886 26,912 28,888 31,597 22,566 (29.3) (28.3) 17.6 7.3 9.4 (28.6)

Unit value.......................................... $804 $582 $640 $833 $1,181 $928 15.4 (27.6) 9.9 30.1 41.8 (21.4)

Ending inventory quantity...................... 231,279 195,717 196,677 193,261 235,848 266,868 15.4 (15.4) 0.5 (1.7) 22.0 13.2

Inventories/total shipments (fn1)........... 5.7 6.8 5.8 4.9 6.1 7.4 1.7 1.2 (1.0) (0.9) 1.2 1.2

Production workers............................... 2,339 2,083 2,173 2,239 2,269 2,192 (6.3) (10.9) 4.3 3.0 1.3 (3.4)

Hours worked (1,000s).......................... 4,741 3,825 4,220 4,552 4,587 4,258 (10.2) (19.3) 10.3 7.9 0.8 (7.2)

Wages paid ($1,000)............................ 170,467 128,170 145,939 166,385 174,648 156,838 (8.0) (24.8) 13.9 14.0 5.0 (10.2)

Hourly wages........................................ $35.96 $33.51 $34.58 $36.55 $38.07 $36.83 2.4 (6.8) 3.2 5.7 4.2 (3.3)

Productivity (short tons per 1,000 hours) 855.4 741.7 802.0 858.4 845.7 858.4 0.3 (13.3) 8.1 7.0 (1.5) 1.5

Unit labor costs..................................... $42.03 $45.18 $43.12 $42.58 $45.02 $42.91 2.1 7.5 (4.5) (1.3) 5.7 (4.7)

Net sales:

Quantity............................................. 4,126,388 2,881,432 3,384,018 3,920,918 3,836,475 3,623,777 (12.2) (30.2) 17.4 15.9 (2.2) (5.5)

Value................................................. 3,547,031 1,679,395 2,274,325 3,048,561 2,858,572 2,552,054 (28.1) (52.7) 35.4 34.0 (6.2) (10.7)

Unit value.......................................... $860 $583 $672 $778 $745 $704 (18.1) (32.2) 15.3 15.7 (4.2) (5.5)

Cost of goods sold (COGS).................. 3,116,677 1,652,958 2,083,987 2,743,826 2,622,588 2,358,335 (24.3) (47.0) 26.1 31.7 (4.4) (10.1)

Gross profit of (loss)............................. 430,354 26,437 190,338 304,735 235,984 193,719 (55.0) (93.9) 620.0 60.1 (22.6) (17.9)

SG&A expenses................................... 83,259 69,352 91,584 86,722 87,633 86,025 3.3 (16.7) 32.1 (5.3) 1.1 (1.8)

Operating income or (loss).................... 347,095 (42,915) 98,754 218,013 148,351 107,694 (69.0) (

2

) (2) 120.8 (32.0) (27.4)

Capital expenditures............................. 54,283 35,731 48,287 54,987 95,351 163,405 201.0 (34.2) 35.1 13.9 73.4 71.4

Unit COGS........................................... $755 $574 $616 $700 $684 $651 (13.8) (24.0) 7.4 13.6 (2.3) (4.8)

Unit SG&A expenses............................ $20 $24 $27 $22 $23 $24 17.7 19.3 12.4 (18.3) 3.3 3.9

Unit operating income or (loss).............. $84 $(15) $29 $56 $39 $30 (64.7) (

2

) (2) 90.5 (30.5) (23.1)

COGS/sales (1).................................... 87.9 98.4 91.6 90.0 91.7 92.4 4.5 10.6 (6.8) (1.6) 1.7 0.7

Operating income or (loss)/sales (1)...... 9.8 (2.6) 4.3 7.2 5.2 4.2 (5.6) (12.3) 6.9 2.8 (2.0) (1.0)

Notes:

(1)--Report data are in percent and period changes are in percentage points.

(2)--Undefined. 

Source: Compiled from data submitted in response to Commission questionnaires and from official statistics of the U.S. Department of Commerce as adjusted.

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)

Reported data Period changes

Calendar year Comparison periods
C‐5

The pages that follow are a direct duplication of the historical data presented in table I‐1

of the Commission’s staff report in the first five‐year review of the orders.
I-5

Table I-1

Wire rod: Summary data from the original investigations and the current full five-year reviews, 1999-2007

(Quantity=short tons; value=1,000 dollars; unit values, unit labor costs, and unit financial data are per short ton)

Item 1999 2000 2001 2002 2003 2004 2005 2006 2007

U.S. consumption quantity:

 Amount *** *** *** 7,753,874 6,590,919 8,135,080 6,505,628 7,109,045 5,858,981

 Producers’ share1 *** *** *** 51.4 62.8 50.3 57.4 53.7 69.6

 Importer's share:

 Brazil1 2 *** *** *** *** 0.0 0.0 0.0 0.0 0.0

 Canada1

 *** *** *** *** *** *** *** *** ***

 Indonesia1 *** *** *** 0.5 0.0 0.4 0.0 0.0 0.0

 Mexico1 *** *** *** 1.6 0.3 0.8 0.2 0.1 0.1

 Moldova1 *** *** *** 0.2 0.0 0.0 0.0 0.0 0.0

 Ukraine1 *** *** *** 0.1 0.0 0.0 0.0 0.0 0.0

 Subtotal1 *** *** *** *** *** *** *** *** ***

 Trinidad & Tobago1 *** *** *** 5.0 2.2 3.2 1.6 1.9 1.6

 Subject subtotal1 *** *** *** *** *** *** *** *** ***

 Stelco1 *** *** *** *** *** *** *** *** ***

 Grade 1080 tire cord/tire bead1 2 (

2

) (2) (2) *** *** *** *** *** ***

 Other countries1 2 *** *** *** 29.2 22.8 35.2 30.7 35.9 16.9

 Total imports1 *** *** *** 48.6 37.2 49.7 42.6 46.3 30.4

U.S. consumption value:

 Amount *** *** *** 2,411,891 2,138,988 4,109,959 3,592,264 3,838,199 3,403,602

 Producers’ share1 *** *** *** 53.5 63.3 53.1 58.1 56.0 68.8

Importer's share:

 Brazil1 2 *** *** *** *** 0.0 0.0 0.0 0.0 0.0

 Canada1 2 *** *** *** *** *** *** *** *** ***

 Indonesia1 *** *** *** 0.4 0.0 0.4 0.0 0.0 0.0

 Mexico1 *** *** *** 1.4 0.3 0.8 0.2 0.1 0.1

 Moldova1 *** *** *** 0.2 0.0 0.0 0.0 0.0 0.0

 Ukraine1 *** *** *** 0.1 0.0 0.0 0.0 0.0 0.0

 Subtotal1 *** *** *** *** *** *** *** *** ***

 Trinidad & Tobago1 *** *** *** 4.5 1.8 3.0 1.4 1.7 1.4

 Subject subtotal1 *** *** *** *** *** *** *** *** ***

 Stelco1 *** *** *** *** *** *** *** *** ***

 Grade 1080 tire cord/tire bead1 2 (

2

) (2) (2) *** *** *** *** *** ***

 Other countries1 2 *** *** *** 25.8 21.6 31.8 28.5 32.4 16.9

 Total imports1 *** *** *** 46.5 36.7 46.9 41.9 44.0 31.2

Table continued on following page.
I-6

Table I-1--Continued

Wire rod: Summary data from the original investigations and the current full five-year reviews, 1999-2007

(Quantity=short tons; value=1,000 dollars; unit values, unit labor costs, and unit financial data are per short ton)

Item 1999 2000 2001 2002 2003 2004 2005 2006 2007

U.S. imports from--

 Brazil: 

 Quantity *** *** *** *** 00000

 Value *** *** *** *** 0 0 0 0 0

 Unit value $*** $*** $*** $*** -- -- -- -- --

 Canada:

 Quantity *** *** *** *** *** *** *** *** ***

 Value *** *** *** *** *** *** *** *** ***

 Unit value $*** $*** $*** $*** $*** $*** $*** $*** $***

 Indonesia:

 Quantity 69,805 86,940 60,065 40,863 0 29,937 333 0 0

 Value 14,884 19,669 13,116 10,494 0 17,247 262 0 0

 Unit value $213 $226 $216 $257 -- $576 $785 -- --

 Mexico:

 Quantity 122,038 159,818 266,925 123,380 19,986 68,498 11,480 4,256 8,244

 Value 29,449 39,337 64,309 34,548 6,296 33,332 6,283 2,032 4,263

 Unit value $241 $246 $241 $280 $315 $487 $547 $477 $517

 Moldova:

 Quantity 190,239 191,074 187,370 18,82600000

 Value 38,888 41,667 39,439 3,708 0 0 0 0 0

 Unit value $204 $216 $210 $197 -- -- -- -- --

 Ukraine:

 Quantity 193,003 367,712 258,526 11,159 0 0 738 0 0

 Value 35,568 75,568 49,770 2,446 0 0 501 0 0

 Unit value $184 $206 $193 $219 -- -- $680 -- --

 Subtotal:

 Quantity *** *** *** *** *** *** *** *** ***

 Value *** *** *** *** *** *** *** *** ***

 Unit value $*** $*** $*** $*** $*** $*** $*** $*** $***

 Trinidad & Tobago:

 Quantity 341,815 287,507 355,089 386,419 146,783 260,618 104,804 133,326 95,325

 Value 87,289 75,511 91,335 107,445 39,267 124,194 50,039 64,253 46,228

 Unit value $255 $263 $257 $278 $268 $477 $477 $482 $485

 Subject subtotal:

 Quantity *** *** *** *** *** *** *** *** ***

 Value *** *** *** *** *** *** *** *** ***

 Unit value $*** $*** $*** $*** $*** $*** $*** $*** $***

Table continued on following page.
I-7

Table I-1--Continued

Wire rod: Summary data from the original investigations and the current full five-year reviews, 1999-2007

(Quantity=short tons; value=1,000 dollars; unit values, unit labor costs, and unit financial data are per short ton)

Item 1999 2000 2001 2002 2003 2004 2005 2006 2007

U.S. imports from–

 Stelco:

 Quantity *** *** *** *** *** *** *** *** ***

 Value *** *** *** *** *** *** *** *** ***

 Unit value $*** $*** $*** $*** $*** $*** $*** $*** $***

 Grade 1080 tire cord/tire bead: 

 Quantity (2

) (2) (2) *** *** *** *** *** ***

 Value (2

) (2) (2) *** *** *** *** *** ***

 Unit value (2

) (2) (2) $*** $*** $*** $*** $*** $***

 All other countries:2 

 Quantity *** *** *** 2,262,306 1,505,183 2,859,490 1,997,826 2,554,966 992,163

 Value *** *** *** 622,360 462,923 1,308,240 1,024,997 1,244,511 574,316

 Unit value $*** $*** $*** $275 $308 $458 $513 $487 $579

 All countries:

 Quantity 2,787,291 2,987,084 3,066,218 3,765,047 2,453,575 4,039,783 2,773,119 3,294,798 1,782,699

 Value 807,586 899,451 875,963 1,121,780 784,088 1,927,796 1,505,063 1,690,689 1,063,201

 Unit value $290 $301 $286 $298 $320 $477 $543 $513 $596

U.S. producers’--

Capacity quantity *** *** *** 4,771,377 5,040,727 4,920,229 5,392,176 5,371,016 5,429,678

Production quantity *** *** *** 4,035,005 4,052,215 4,089,091 3,741,120 3,877,367 4,067,549

Capacity utilization *** *** *** 84.6 80.4 83.1 69.4 72.2 74.9

U.S. shipments:

 Quantity *** *** *** 3,988,827 4,137,344 4,095,297 3,732,509 3,814,247 4,076,282

 Value *** *** *** 1,290,111 1,354,900 2,182,163 2,087,201 2,147,510 2,340,401

 Unit value $*** $*** $*** $323 $327 $533 $559 $563 $574

Export shipments:

 Quantity *** *** *** *** *** *** *** *** ***

 Value *** *** *** *** *** *** *** *** ***

 Unit value $*** $*** $*** $*** $*** $*** $*** $*** $***

Table continued on following page.
I-8

Table I-1--Continued

Wire rod: Summary data from the original investigations and the current full five-year reviews, 1999-2007

(Quantity=short tons; value=1,000 dollars; unit values, unit labor costs, and unit financial data are per short ton)

Item 1999 2000 2001 2002 2003 2004 2005 2006 2007

U.S. producers’--

 Ending inventory quantity *** *** *** 250,935 136,816 140,019 164,647 174,288 152,512

 Inventories/total shipments1 *** *** *** *** *** *** *** *** ***

 Production workers *** *** *** 2,461 2,513 2,543 2,407 2,395 2,397

 Hours worked (1,000 hours) *** *** *** 5,545 5,378 5,474 4,919 5,296 5,174

 Wages paid (1,000 dollars) *** *** *** 140,328 139,194 145,620 143,664 161,223 161,821

 Hourly wages $*** $*** $*** $25.31 $25.88 $26.60 $29.21 $30.45 $31.28

 Productivity (tons/1,000 hours) *** *** *** 728 754 747 761 732 786

 Unit labor costs $*** $*** $*** $34.78 $34.35 $35.61 $38.40 $41.58 $39.78

 Net sales:

 Quantity *** *** *** 3,996,011 4,151,601 4,103,563 3,749,761 3,844,808 4,087,541

 Value *** *** *** 1,291,920 1,358,707 2,182,872 2,100,194 2,165,513 2,347,208

 Unit value $*** $*** $*** $323 $327 $532 $560 $563 $574

 Cost of goods sold (“COGS”) *** *** *** 1,188,586 1,361,436 1,819,855 1,887,745 2,024,653 2,219,518

 Gross profit or (loss) *** *** *** 103,334 (2,729) 363,017 212,449 140,860 127,690

 Operating income or (loss) *** *** *** 59,982 (45,952) 305,241 158,656 85,506 74,869

U.S. producers’--

 Unit COGS $*** $*** $*** $296 $328 $443 $503 $527 $543

 Unit operating income or (loss) $*** $*** $*** $16 ($11) $74 $42 $22 $18

 COGS/sales1 *** *** *** 92.0 100.2 83.4 89.9 93.5 94.6

 Operating income or (loss)/sales1 *** *** *** 4.6 (3.4) 14.0 7.6 3.9 3.2

 Capital expenditures *** *** *** 30,524 44,338 49,807 83,826 68,513 49,632

 1 In percent.

 2 Imports of Grade 1080 wire rod have been subtracted from U.S. imports of wire rod ***. Grade 1080 is included in imports from “all other sources.” See data files in the

original investigations. 

Note.--Because of the pending negative determination on remand regarding Trinidad & Tobago, throughout this report, data concerning Trinidad & Tobago are presented as

subject merchandise but appear separately from the subtotals of data concerning the other six subject countries. 

Source: INV-Z-162, table C-2a, for 1999-2001. Data for 2002-07 were compiled in response to Commission questionnaires and from official Commerce statistics.

D‐1

APPENDIX D

COMMENTS BY U.S. PRODUCERS, IMPORTERS, PURCHASERS, AND

FOREIGN PRODUCERS REGARDING THE EFFECTS OF THE ORDERS

AND THE LIKELY EFFECTS OF REVOCATION

D-3 

This appendix is confidential in its entirety

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E‐1

APPENDIX E

FINANCIAL RESULTS ON MERCHANT MARKET SALES AS REPORTED IN

THE MOST RECENTLY COMPLETED PRELIMINARY‐PHASE

INVESTIGATIONS

E‐3

Table E-1 

Wire rod: Results of merchant market operations of U.S. producers, fiscal years 2011-13

Item 

Fiscal year 

2011 2012 2013 

 Quantity (short tons) 

Total commercial sales quantity 2,979,103 2,842,314 2,619,518

 Value ($1,000) 

Total commercial sales value 2,369,626 2,175,493 1,898,192

Cost of goods sold 

 Raw materials 1,548,308 1,373,248 1,179,200

 Direct labor 110,752 109,358 97,527

 Other factory costs 479,006 524,800 485,620

 Total cost of goods sold 2,138,066 2,007,406 1,762,348

Gross profit 231,560 168,087 135,844

SG&A expenses 69,833 69,485 67,354

Operating income 161,727 98,602 68,490

Other income/(expense), net (12,445) (4,473) (4,103)

Net income 149,282 94,129 64,387

Depreciation/amortization 37,012 36,983 37,269

Cash flow 186,294 131,112 101,656

 Ratio to net sales (percent) 

Cost of goods sold 

 Raw materials 65.3 63.1 62.1

 Direct labor 4.7 5.0 5.1

 Other factory costs 20.2 24.1 25.6

 Total COGS 90.2 92.3 92.8

Gross profit 9.8 7.7 7.2

SG&A expenses 2.9 3.2 3.5

Operating income 6.8 4.5 3.6

Net income 6.3 4.3 3.4

Table continued on next page. 
E‐4

Table E-1--Continued

Wire rod: Results of merchant market operations of U.S. producers, fiscal years 2011-13

Item 

Fiscal year 

2011 2012 2013 

 Unit value (dollars per short ton) 

Commercial sales 795 765 725

Cost of goods sold 

 Raw materials 520 483 450

 Direct labor 37 38 37

 Other factory costs 161 185 185

 Total cost of goods sold 718 706 673

Gross profit 78 59 52

SG&A expenses 23 24 26

Operating income 54 35 26

 Number of firms reporting 

Operating losses *** *** ***

Data 10 10 10

Source: Compiled from data submitted in response to Commission questionnaires. Carbon and Certain 

Alloy Steel Wire Rod from China, Investigation Nos. 701-TA-512 and 731-TA-1248 (Preliminary), USITC 

Publication 4458, March 2014, table VI-1, pp. VI-2-VI-3. 
F‐1

APPENDIX F

SMALLER DIAMETER WIRE ROD FROM DEACERO

F‐3

This appendix is confidential in its entirety

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