U.S. International Trade Commission

Publication 4462 May 2014

Washington, DC 20436

Certain Steel Threaded Rod 

From Thailand

Investigation No 731‐TA‐1214 (Final)
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

Nathanael Comly, Investigator 

Michele Breaux, Investigator 

Karen Taylor, Industry Analyst 

James Fetzer, Economist 

Mary Klir, Accountant 

Mara Alexander, Statistician 

Carolyn Holmes, Statistical Assistant 

Courtney McNamara, Attorney 

James McClure, Supervisory Investigator 
U.S. International Trade Commission

Washington, DC 20436 

www.usitc.gov

Publication 4462 May 2014

Certain Steel Threaded Rod 

From Thailand

Investigation No 731‐TA‐1214 (Final)

 

CONTENTS

Page

Determination................................................................................................................................. 1 

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

Part I: Introduction.............................................................................................................. I-1

Background................................................................................................................................ I-1

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

Statutory criteria ................................................................................................................... I-2

Organization of report........................................................................................................... I-3

Market summary....................................................................................................................... I-3

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

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

Nature and extent of subsidies and sales at LTFV .................................................................... I-5

Subsidies................................................................................................................................ I-5

Sales at LTFV.......................................................................................................................... I-5

The subject merchandise .......................................................................................................... I-6

Commerce’s scope ................................................................................................................ I-6

Tariff treatment..................................................................................................................... I-7

The product............................................................................................................................... I-7

Description and applications................................................................................................. I-7

Manufacturing processes...................................................................................................... I-9

Domestic like product issues................................................................................................... I-10

Part II: Supply and demand information ............................................................................. II-1

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

U.S. purchasers......................................................................................................................... II-1

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

Geographic distribution ........................................................................................................... II-3

Supply and demand considerations......................................................................................... II-4

U.S. supply ............................................................................................................................ II-4

U.S. demand ......................................................................................................................... II-8 

i 
CONTENTS

Page

Part II: Supply and demand information--Continued ................................................................

Substitutability issues............................................................................................................. II-11

Lead times .......................................................................................................................... II-11

Knowledge of country sources........................................................................................... II-12

Factors affecting purchasing decisions............................................................................... II-12

Comparison of U.S.-produced and imported threaded rod............................................... II-14

Elasticity estimates................................................................................................................. II-18

U.S. supply elasticity........................................................................................................... II-18

U.S. demand elasticity ........................................................................................................ II-18

Substitution elasticity......................................................................................................... II-18

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

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

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

U.S. producers’ U.S. shipments and exports........................................................................... III-2

U.S. producers’ inventories..................................................................................................... III-3

U.S. producers’ imports and purchases.................................................................................. III-3

U.S. employment, wages, and productivity ............................................................................ III-4

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

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

U.S. imports.............................................................................................................................IV-3

Critical circumstances..............................................................................................................IV-6

Negligibility..............................................................................................................................IV-9

Cumulation considerations...................................................................................................IV-10

Presence in the market .....................................................................................................IV-10

Geographical markets .......................................................................................................IV-11

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

U.S. market shares ................................................................................................................IV-12

ii
CONTENTS

Page

Part V: Pricing data.............................................................................................................V-1

Factors affecting prices............................................................................................................V-1

Raw material costs ...............................................................................................................V-1

U.S. inland transportation costs...........................................................................................V-1

Pricing practices .......................................................................................................................V-2

Pricing methods....................................................................................................................V-2

Sales terms and discounts....................................................................................................V-3

Price data..................................................................................................................................V-4

Price trends...........................................................................................................................V-9

Price comparisons ................................................................................................................V-9

Lost sales and lost revenue ....................................................................................................V-12

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

Introduction.............................................................................................................................VI-1

Operations on threaded rod ...................................................................................................VI-1

Capital expenditures and total assets.................................................................................VI-2

Capital and investment........................................................................................................VI-2

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

The industry in India...............................................................................................................VII-3

The industry in Thailand.........................................................................................................VII-4

U.S. inventories of imported merchandise ............................................................................VII-5

U.S. importers’ outstanding orders........................................................................................VII-5

Antidumping or countervailing duty orders in third-country markets..................................VII-5

Information on nonsubject countries....................................................................................VII-6

iii
CONTENTS

Page

Appendixes

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

B. List of hearing witnesses................................................................................................... B-1

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

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

E. Itochu and Fastenal price data......................................................................................... E-1

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

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

iv
UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation No. 731-TA-1214 (Final)

CERTAIN STEEL THREADED ROD FROM THAILAND

DETERMINATION

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

International Trade Commission (Commission) determines,2 pursuant to section 735(b) of the 

Tariff Act of 1930 (19 U.S.C. ' 1673d(b)) (the Act), that an industry in the United States is not 

materially injured or threatened with material injury, and the establishment of an industry in 

the United States is not materially retarded by reason of imports from Thailand of certain steel 

threaded rod, provided for primarily in subheading 7318.15.50 of the Harmonized Tariff 

Schedule of the United States, that have been found by the Department of Commerce 

(Commerce) to be sold in the United States at less than fair value (LTFV).

BACKGROUND

The Commission instituted this investigation effective June 27, 2013, following receipt of 

a petition filed with the Commission and Commerce by All America Threaded Products Inc., 

Denver, Colorado; Bay Standard Manufacturing Inc., Brentwood, California; and Vulcan 

Threaded Products Inc., Pelham, Alabama. The final phase of the investigation was scheduled 

by the Commission following notification of a preliminary determination by Commerce that 

imports of certain steel threaded rod from Thailand were being sold at LTFV within the meaning 

of section 733(b) of the Act (19 U.S.C. ' 1673b(b)). Notice of the scheduling of the final phase 

of the Commission=s investigation and of a public hearing to be held in connection therewith 

was given by posting copies of the notice in the Office of the Secretary, U.S. International Trade 

Commission, Washington, DC, and by publishing the notice in the Federal Register of January 

17, 2014 (79 FR 3245). The hearing was held in Washington, DC, on March 20, 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 Commissioner Rhonda Schmidtlein was not a member of the Commission at the time of the 

vote.

1

 

 

Views of the Commission

Based on the record in the final phase of this investigation, we find that an industry in 

the United States is not materially injured or threatened with material injury by reason of 

imports of certain steel threaded rod from Thailand found by the U.S. Department of 

Commerce (“Commerce”) to be sold in the United States at less than fair value.

I. Background

The petitions in the steel threaded rod (“STR”) investigations were filed on June 27, 

2013, by Vulcan Threaded Products, Inc. (“Vulcan”), All America Threaded Products, Inc. (“All 

America”), and Bay Standard Manufacturing Inc. (“Bay Standard”) (collectively “Petitioners”), 

U.S. producers of STR.1

 Petitioners appeared at the hearing and submitted prehearing and 

posthearing briefs as well as final comments. No respondent party appeared at the hearing or 

submitted briefs. 

Unless otherwise noted, U.S. industry data cited herein are based on the questionnaire 

responses of five producers, accounting for nearly all of U.S. production of STR in 2013.

2

 U.S. 

import data are based on official Commerce import statistics from a single tariff subheading 

because several large importers did not provide responses to the Commission’s 

questionnaires.3

 The Commission received usable responses to its questionnaires from six 

foreign producers or exporters of STR in India, accounting for the majority of U.S. imports of 

subject merchandise from India during the period of investigation (“POI”), which encompasses 

January 2011 through December 2013.4

 The Commission did not receive any responses to its 

questionnaires from any foreign producers or exporters of STR from Thailand.5

II. Domestic Like Product

A. In General

In determining whether an industry in the United States is materially injured or 

threatened with material injury by reason of imports of subject merchandise, the Commission 

first defines the “domestic like product” and the “industry.”6

 Section 771(4)(A) of the Tariff Act 

1 The petitions concerned STR from both India and Thailand. Commerce had not yet made its 

final dumping and subsidy determinations in its investigations of STR from India as of the time the 

record closed in the Commission’s investigation of STR from Thailand. 2 Confidential Report (“CR”) at I-5; Public Report (“PR”) at I-4. 3 CR at I-5; PR at I-4. Petitioners reported that the majority of imports of subject merchandise 

are reported under Harmonized Tariff Schedule of the United States (“HTSUS”) 7318.15.5056 and that 

the majority of merchandise entered under this subheading is subject merchandise. CR at I-5 n.5; PR at 

I-4 n.5. 

4 CR/PR at VII-3. 5 CR at VII-5; PR at VII-4. 

6 19 U.S.C. § 1677(4)(A).

3 

 
 

of 1930, as amended (“the Tariff Act”), defines the relevant domestic industry as the 

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

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

the product.”7 In turn, the Tariff Act defines “domestic like product” as “a product which is like, 

or in the absence of like, most similar in characteristics and uses with, the article subject to an 

investigation.”8

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

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

“most similar in characteristics and uses” on a case-by-case basis.9

 No single factor is 

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

facts of a particular investigation.10 The Commission looks for clear dividing lines among 

possible like products and disregards minor variations.11 Although the Commission must accept 

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

sold at less than fair value,12 the Commission determines what domestic product is like the 

imported articles Commerce has identified.13

7 19 U.S.C. § 1677(4)(A).

8 19 U.S.C. § 1677(10).

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

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

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

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

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

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

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

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

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

1996).

10 See, e.g., S. Rep. No. 96-249 at 90-91 (1979). 11 Nippon, 19 CIT at 455; Torrington, 747 F. Supp. at 748-49; see also S. Rep. No. 96-249 at 90-91

(Congress has indicated that the like product standard should not be interpreted in “such a narrow 

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

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

interpreted in such a fashion as to prevent consideration of an industry adversely affected by the 

imports under consideration.”). 12 See, e.g., USEC, Inc. v. United States, 34 Fed. Appx. 725, 730 (Fed. Cir. 2002) (“The ITC may not 

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

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

492 U.S. 919 (1989).

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

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

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

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

determination defining six like products in investigations in which Commerce found five classes or 

kinds).

4 

 
 

B. Product Description

Commerce defined the scope of the imported merchandise under investigation as 

follows: 

Steel threaded rod is certain threaded rod, bar, or studs, of 

carbon quality steel, having a solid, circular cross section, of any 

diameter, in any straight length, that have been forged, turned, 

cold-drawn, cold-rolled, machine straightened, or otherwise coldfinished, and into which threaded grooves have been applied. In 

addition, the steel threaded rod, bar, or studs subject to this 

investigation are nonheaded and threaded along greater than 25 

percent of their total length. A variety of finishes or coatings, such 

as plain oil finish as a temporary rust protectant, zinc coating (i.e., 

galvanized, whether by electroplating or hot-dipping), paint, and 

other similar finishes and coatings, may be applied to the 

merchandise. Included in the scope of this investigation are steel 

threaded rod, bar, or studs, in which: (1) iron predominates, by 

weight, over each of the other contained elements; (2) the carbon 

content is 2 percent or less, by weight; and (3) none of the 

elements listed below exceeds the quantity, by weight, 

respectively indicated: 

• 1.80 percent of manganese, or

• 1.50 percent of silicon, or

• 1.00 percent of copper, or

• 0.50 percent of aluminum, or

• 1.25 percent of chromium, or

• 0.30 percent of cobalt, or

• 0.40 percent of lead, or

• 1.25 percent of nickel, or

• 0.30 percent of tungsten, or

• 0.012 percent of boron, or

• 0.10 percent of molybdenum, or

• 0.10 percent of niobium, or

• 0.41 percent of titanium, or

• 0.15 percent of vanadium, or

• 0.15 percent of zirconium.

Steel threaded rod is currently classifiable under subheadings 

7318.15.5051, 7318.15.5056, 7318.15.5090 and 7318.15.2095 of 

the Harmonized Tariff Schedule of the United States (‘‘HTSUS’’). 

Although the HTSUS subheadings are provided for convenience 

and customs purposes, the written description of the 

merchandise is dispositive. Excluded from the scope of this 

5 
 

investigation are: (a) threaded rod, bar, or studs which are 

threaded only on one or both ends and the threading covers 25 

percent or less of the total length; and (b) threaded rod, bar, or 

studs made to American Society for Testing and Materials 

(‘‘ASTM’’) A193 Grade B7, ASTM A193 Grade B7M, ASTM A193 

Grade B16, and ASTM A320 Grade L7.14 

The scope encompasses carbon steel rod threaded along greater than 25 percent of its 

length. The great majority of STR is made from low-carbon steel, which is easier to cut than 

steel with higher levels of carbon, and is threaded along its entire length. Rod threaded along 

its entire length is a versatile product as it can be cut to the desired length at a construction 

site. Petitioners estimate that fully threaded STR that is three-eighths inch in diameter or 

greater accounts for the great majority of the U.S. market for low-carbon STR, with STR that is 

exactly three-eighths inch in diameter accounting for about 60 percent. Petitioners estimate 

that STR with diameters of less than three-eighths inch accounts for less than ten percent of the 

U.S. market. Standard lengths of STR are two, three, six, ten, and twelve feet. STR that is 

threaded only on one end or both ends, but not in the middle, accounts for a small share of the 

U.S. STR market. Such products are usually ordered for specific applications where the 

customer knows the exact length that is required.15

STR is primarily used in non-residential construction applications to suspend support 

systems such as those for electrical conduit, pipes for plumbing, HVAC ductwork, and sprinkler 

systems. Normally, one end of the STR is fastened to the ceiling and the other end is fastened 

to the support that holds the pipes or ductwork or sprinkler system. Other applications include 

structural tie-downs in earthquake and hurricane restraint systems for roofing, headless screws 

and general fasteners, and bolts to join pipe joints in the waterworks industry. The product is 

also used for basic industrial repairs.16 

C. Domestic Like Product Analysis

In the preliminary determinations, the Commission defined a single domestic like 

product, STR, that was coextensive with the scope of the investigations. The Commission 

determined that, although STR can vary in terms of length, diameter, finishes, and whether it is 

fully or partially threaded, there did not appear to be any clear dividing lines based on physical 

characteristics. The Commission further determined that all types of STR have common 

characteristics (threaded grooves and ease of cutting to size) and end uses (noncritical bolting 

applications), and STR is not interchangeable with threaded rod made from other materials. 

The Commission concluded that all STR is produced using common manufacturing facilities, 

employees, and production processes and that almost all shipments of STR by domestic 

producers were made to distributors and master distributors. The Commission found that 

14 Steel Threaded Rod from Thailand: Final Determination of Sales at Less Than Fair Value and 

Affirmative Final Determination of Critical Circumstances, 79 Fed. Reg. 14476 (Mar. 14, 2014). 15 CR at I-10 – I-12; PR at I-7 – I-9. 

16 CR at I-10 – I-12; PR at I-7 – I-9. 

6 

 
 

there was nothing in the record to contradict petitioners’ assertion that customers view STR as 

a single product category. It also found that there is some variation in STR prices according to 

length, finish, size, and other such features.17 

The record in the final phase of these investigations does not contain any new 

information concerning the domestic like product factors, and there is no argument that the 

Commission should adopt a definition of the domestic like product different from that in the 

preliminary determinations.18 Therefore, for the same reasons set forth in the preliminary 

determinations, we find one domestic like product that is coextensive with the scope definition. 

III. Domestic Industry 

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

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

a major proportion of the total domestic production of the product.”19 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. 

A. Related Parties

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

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

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

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

are themselves importers.20 Exclusion of such a producer is within the Commission’s discretion 

based upon the facts presented in each investigation.

21

17 Certain Steel Threaded Rod from India and Thailand, Inv. No. 701-TA-498 and 731-TA-1213-

1214 (Preliminary), USITC Pub. 4420 (Aug. 2013) at 7-9. 

18 The information in the record pertaining to the domestic like product factors is largely

unchanged from that in the preliminary phase. CR at I-10 – I-14; PR at I-7 – I-10. Petitioners argue that 

the Commission should define the domestic like product to be STR, coextensive with the definition of 

the scope of the subject merchandise, as it did in its preliminary determinations. Petitioners’ Prehearing 

Brief at 3-5.

19 19 U.S.C. § 1677(4)(A).

20 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). 21 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

7 

 

(Continued...)
 

The record indicates that six domestic producers produced STR during the POI: Vulcan, 

All America, Bay Standard, All Ohio, Interstate, and Conklin & Conklin.22 Conklin & Conklin did 

not respond to the Commission’s questionnaire.23 Of the five responding domestic producers, 

four (***, ***, ***, and ***) are subject to possible exclusion under the related parties 

provision because each imported subject merchandise during the POI.24 Petitioners argue that 

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

under the related party provision.25 

For the reasons discussed below, we do not exclude any firm from the domestic industry 

as a related party.

***. ***, a ***, was the *** largest domestic producer, accounting for *** percent of 

domestic production during the POI.26 Its production volumes *** over the POI.27 *** ratio of 

subject imports to its domestic production was *** percent in 2011, 2012, and 2013, 

respectively.28 *** explained that it imported subject merchandise from *** because ***.

29 

*** ratio of operating income to net sales ***.

30 31

We find that appropriate circumstances do not exist to exclude *** from the domestic 

industry. Because it is a *** and imported ***, *** interests appear to lie principally in 

domestic production. 

***. ***, another ***, was the *** largest domestic producer, accounting for ***

percent of domestic production during the POI.32 Its production volumes *** over the POI.33 

*** ratio of subject imports to its domestic production was *** percent ***, which was the ***

during the POI that it imported subject merchandise from ***.

34 *** explained that it imported 

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

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

United States, 790 F. Supp. at 1168. 22 Petition at Exhibit 1. 

23 CR/PR at III-1 n.1. 24 CR at III-8; PR at III-3; CR/PR at Table III-5. 

25 Petitioners’ Prehearing Brief at 5-8. 

26 CR/PR at Table III-1. 27 CR/PR at Table III-5. 

28 CR/PR at Table III-5. 

29 *** Importer Questionnaire Response. 

30 CR/PR at Table VI-2.

31 Commissioner Pinkert does not rely upon the importing companies’ financial performance as 

a factor in determining whether there are appropriate circumstances to exclude them from the 

domestic industry in these investigations. The record is not sufficient to infer from their profitability on 

U.S. operations whether they have derived a specific benefit from importing. See Allied Mineral 

Products v. United States, 28 CIT 1865-67 (2004). 

32 CR/PR at Table III-1. 

33 CR/PR at Table III-5. 

34 CR/PR at Table III-5. 

8 

 

(...Continued)
 

subject merchandise because ***.

35 *** ratio of operating income to net sales was *** than 

the industry average in 2011 and 2012 but *** than the industry average in 2013.36 

We find that appropriate circumstances do not exist to exclude *** from the domestic 

industry as a related party. Because it is a *** and imported ***, *** interests appear to lie 

principally in domestic production. 

***. *** accounted for *** percent of domestic production during the POI.37 Its 

production quantities *** overall during the POI.38 *** ratio of subject imports to its domestic 

production was *** percent, *** percent, and *** percent in 2011, 2012, and 2013, 

respectively.39 During the preliminary phase, *** reported that it imported subject 

merchandise ***.

40 *** ratio of operating income to net sales was *** than the industry 

average in 2011 and 2012, but *** than the industry average in 2013.41 *** with respect to 

these investigations of STR from India and Thailand.42

In the preliminary determinations, we found appropriate circumstances did not exist to 

exclude *** from the domestic industry because the firm “accounts for such a small share of 

domestic production that, even if *** were excluded, the aggregate financial data for the 

domestic industry would be essentially unchanged.” We also emphasized a lack of clear 

correlation between the firm’s import activities and its financial performance.43 These facts 

remain true; moreover, during the POI, *** domestic production increased and its ratio of 

imports to net sales declined. On balance, and in the absence of any contrary argument, we 

find that appropriate circumstances do not exist to exclude *** from the domestic industry.44 

***. *** accounted for *** percent of domestic production during the POI.45 Its 

production volumes *** overall during the POI.46 *** ratio of subject imports to its domestic 

production was *** percent in 2011, 2012, and 2013, respectively.

47 *** reported that it 

imported subject merchandise ***.

48 *** ratio of operating income to net sales was *** than 

35 *** Importer Questionnaire Response. 36 CR/PR at Table VI-2. 

37 CR/PR at Table III-1. 

38 CR/PR at Table III-5. 

39 CR/PR at Table III-5. 

40 *** Preliminary Phase Importer Questionnaire Response. 41 CR/PR at Table VI-2. 42 CR/PR at Tables III-1 & III-5. 

43 Confidential Preliminary Determination, EDIS Doc. 867794 at 16-17. 44 Chairman Williamson excludes *** from the domestic industry because he finds that ***

principal interest lies in importing rather than domestic production. The factual findings on the 

domestic industry defined by the majority are also applicable to the domestic industry as he defines it, 

in light of *** share of domestic production. CR/PR at Table VI-2, note. 45 CR/PR at Table III-1. 

46 CR/PR at Table III-5. 47 CR at Table III-5. 

48 *** Importer Questionnaire Response. 

9 

 
 

the industry average for each year of the POI.49 *** with respect to these investigations of STR 

from India and Thailand.50

We find that appropriate circumstances do not exist to exclude *** from the domestic 

industry as a related party. As an initial matter, *** accounts for such a small share of domestic 

production that, even if it were excluded, the aggregate data for the domestic industry would 

be essentially unchanged.51 In addition, even though *** production volumes *** over the POI, 

its ratio of imports to net sales *** overall during the POI, and in 2012 and 2013, its U.S. 

production was considerably larger than its imports of subject merchandise. Moreover, it does 

not appear that *** derived a significant benefit from its importation of subject STR from ***

because its financial results were *** the industry average throughout the POI.

For the foregoing reasons, we define the domestic industry as all U.S. producers of steel 

threaded rod.52 

Cumulation53 IV.

For purposes of evaluating the volume and price effects for a determination of material 

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

Commission to cumulate subject imports from all countries as to which petitions were filed 

and/or investigations self-initiated by Commerce on the same day, if such imports compete 

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

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

generally has considered four factors:

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

countries and between subject imports and the domestic like product, 

including consideration of specific customer requirements and other 

quality-related questions;

49 CR/PR at Table VI-2. 

50 CR/PR at Tables III-1 & III-5. 51 CR/PR at Table VI-2, note.

52 Chairman Williamson defines the domestic industry as all U.S. producers of STR except for 

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

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

imported into the United States during the most recent 12 months for which data are available 

preceding the filing of the petition shall be deemed negligible. 19 U.S.C. §§ 1671b(a), 1673b(a), 

1677(24)(A)(i), 1677(24)(B); see also 15 C.F.R. § 2013.1 (developing countries for purposes of 19 U.S.C. § 

1677(36)). Negligibility is not an issue in the investigations of STR from India and Thailand. Based on 

official Commerce statistics, subject imports from India and Thailand each exceeded the requisite 3 

percent statutory negligibility threshold for the most recent 12-month period preceding the filing of the 

petition for which data are available. From June 2012 to May 2013, U.S. imports from India accounted 

for 27.9 percent of total U.S. imports of STR by quantity, and U.S. imports from Thailand accounted for 

28.9 percent of total U.S. imports. CR at IV-13 – IV-14, PR at IV-9 – IV-10.

10

 
 

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

subject imports from different countries and the domestic like product;

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

imports from different countries and the domestic like product; and

(4) whether the subject imports are simultaneously present in the market.54

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

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

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

product.55 Only a “reasonable overlap” of competition is required.

56

The threshold requirement for cumulation is satisfied because petitioners filed the 

petitions on STR from India and Thailand on the same day, June 27, 2013.57 As discussed 

below, we find there to be a reasonable overlap of competition between subject imports from 

both countries, and between subject imports from each source and the domestic like product. 

Fungibility. The record indicates that STR, when produced to the desired length, 

diameter, and finish, is generally fungible.58 All responding U.S. producers, almost all 

responding importers, and most purchasers reported that STR, regardless of whether it was

produced in the United States, India, or Thailand, was “always” or “frequently” 

interchangeable.59 A majority of purchasers found the domestic like product comparable with 

subject imports from India and Thailand with respect to each of 18 factors.60 When asked 

whether differences other than price are ever significant to purchasers choosing between the 

domestic like product and subject imports or among subject imports, all responding U.S. 

producers and most responding importers and purchasers indicated that differences other than 

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

731-TA-278-280 (Final), USITC Pub. 1845 (May 1986), aff’d, Fundicao Tupy, S.A. v. United States, 678 F. 

Supp. 898 (Ct. Int’l Trade), aff’d, 859 F.2d 915 (Fed. Cir. 1988). 55 See, e.g., Wieland Werke, AG v. United States, 718 F. Supp. 50 (Ct. Int’l Trade 1989).

56 The Statement of Administrative Action (SAA) to the Uruguay Round Agreements Act (URAA), 

expressly states that “the new section will not affect current Commission practice under which the 

statutory requirement is satisfied if there is a reasonable overlap of competition.” H.R. Rep. No. 103-

316, Vol. I at 848 (1994) (citing Fundicao Tupy, S.A. v. United States, 678 F. Supp. at 902; see Goss 

Graphic Sys., Inc. v. United States, 33 F. Supp. 2d 1082, 1087 (Ct. Int’l Trade 1998) (“cumulation does not 

require two products to be highly fungible”); Wieland Werke, AG, 718 F. Supp. at 52 (“Completely 

overlapping markets are not required.”). 57 None of the statutory exceptions to cumulation applies.

58 CR at II-16; PR at II-11. 59 CR at II-21 – II-22; PR at II-14. 60 CR/PR at Table II-17.

11

 
 

price were only “sometimes” or “never” a significant factor in comparing the domestic like 

product with subject imports or in comparing subject imports with each other.61 

Channels of Distribution. The record indicates that subject imports from both countries 

and the domestic like product were sold to distributors and end users throughout the POI. The 

large majority of shipments of both the domestic like product and imports from India and 

Thailand were to distributors.62 

Geographic Overlap. The record reflects that the market for STR is nationwide and that 

the domestic like product and subject merchandise from India and Thailand are sold throughout 

the United States.63 

Simultaneous Presence in Market. Subject imports from India and Thailand and the 

domestic like product were present throughout the POI, with subject imports entering the 

United States every month of the POI, except in November and December 2013 when there 

were no imports from Thailand.64 Petitioners report that they sell STR in the U.S. market every 

day.65 

Conclusion. Because the antidumping and countervailing duty petitions were filed on 

the same day, and the record indicates that there is a reasonable overlap of competition 

between and among the subject imports and the domestic like product, we analyze subject 

imports from India and Thailand on a cumulated basis for our analysis of whether there is 

material injury by reason of subject imports. 

V. No Material Injury by Reason of Subject Imports

A. Legal Standards

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

Commission determines whether an industry in the United States is materially injured or 

threatened with material injury by reason of the imports under investigation.66 In making this 

determination, the Commission must consider the volume of subject imports, their effect on 

prices for the domestic like product, and their impact on domestic producers of the domestic

like product, but only in the context of U.S. production operations.67 The statute defines 

“material injury” as “harm which is not inconsequential, immaterial, or unimportant.”68 In 

61 CR at II-22 – II-23; PR at II-14 – II-16; CR/PR at Table II-8. 

62 CR at II-2 – II-3; PR at II-2; CR/PR & Table II-1. 

63 CR/PR at Table II-2. 

64 CR at IV-15; PR at IV-10; CR/PR at Tables V-3 – V-8.

65 Petitioners’ Prehearing Brief at 16. 

66 19 U.S.C. §§ 1671d(b), 1673d(b).

67 19 U.S.C. § 1677(7)(B). The Commission “may consider such other economic factors as are 

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

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

68 19 U.S.C. § 1677(7)(A).

12

 
 

assessing whether the domestic industry is materially injured by reason of subject imports, we 

consider all relevant economic factors that bear on the state of the industry in the United 

States.69 No single factor is dispositive, and all relevant factors are considered “within the 

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

industry.”70

Although the statute requires the Commission to determine whether the domestic 

industry is “materially injured or threatened with material injury by reason of” unfairly traded 

imports,71 it does not define the phrase “by reason of,” indicating that this aspect of the injury 

analysis is left to the Commission’s reasonable exercise of its discretion.72 In identifying a 

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

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

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

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

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

merely a temporal, nexus between subject imports and material injury.73

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

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

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

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

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

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

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

injury threshold.74 In performing its examination, however, the Commission need not isolate 

69 19 U.S.C. § 1677(7)(C)(iii).

70 19 U.S.C. § 1677(7)(C)(iii). 71 19 U.S.C. §§ 1671d(a), 1673d(a). 72 Angus Chemical Co. v. United States, 140 F.3d 1478, 1484-85 (Fed. Cir. 1998) (“{T}he statute 

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

951 (Ct. Int’l Trade 1996).

73 The Federal Circuit, in addressing the causation standard of the statute, observed that “{a}s 

long as its effects are not merely incidental, tangential, or trivial, the foreign product sold at less than 

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

2003). This was further ratified in Mittal Steel Point Lisas Ltd. v. United States, 542 F.3d 867, 873 (Fed. 

Cir. 2008), where the Federal Circuit, quoting Gerald Metals, Inc. v. United States, 132 F.3d 716, 722 

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

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

caused by LTFV goods.’” See also Nippon Steel Corp. v. United States, 458 F.3d 1345, 1357 (Fed. Cir. 

2006); Taiwan Semiconductor Industry Ass’n v. USITC, 266 F.3d 1339, 1345 (Fed. Cir. 2001). 74 SAA at 851-52 (“{T}he Commission must examine other factors to ensure that it is not 

attributing injury from other sources to the subject imports.”); S. Rep. 96-249 at 75 (1979) (the 

Commission “will consider information which indicates that harm is caused by factors other than lessthan-fair-value imports.”); H.R. Rep. 96-317 at 47 (1979) (“in examining the overall injury being 

experienced by a domestic industry, the ITC will take into account evidence presented to it which 

demonstrates that the harm attributed by the petitioner to the subsidized or dumped imports is 

13

 

(Continued...)
 

the injury caused by other factors from injury caused by unfairly traded imports.75 Nor does 

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

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

such as nonsubject imports, which may be contributing to overall injury to an industry.76 It is 

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

determination.77

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

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

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

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

the subject imports.”78 79 Indeed, the Federal Circuit has examined and affirmed various 

Commission methodologies and has disavowed “rigid adherence to a specific formula.”80

attributable to such other factors;” those factors include “the volume and prices of nonsubsidized 

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

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

developments in technology and the export performance and productivity of the domestic industry”); 

accord Mittal Steel, 542 F.3d at 877. 75 SAA at 851-52 (“{T}he Commission need not isolate the injury caused by other factors from 

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

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

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

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

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

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

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

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

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

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

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

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

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

domestic market prices.”).

76 S. Rep. 96-249 at 74-75; H.R. Rep. 96-317 at 47. 77 See Nippon Steel Corp., 345 F.3d at 1381 (“an affirmative material-injury determination under 

the statute requires no more than a substantial-factor showing. That is, the ‘dumping’ need not be the 

sole or principal cause of injury.”).

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

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

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

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

States Steel Group v. United States, 96 F.3d 1352, 1362 (Fed. Cir. 1996) and S. Rep. 96-249 at 75. 

79 Commissioner Pinkert does not join this paragraph or the following three paragraphs. He 

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

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

14

 

(...Continued)

(Continued...)
 

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

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

of price-competitive nonsubject imports. The Commission interpreted the Federal Circuit’s 

guidance in Bratsk as requiring it to apply a particular additional methodology following its 

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

presence of price-competitive nonsubject imports.81 The additional “replacement/benefit” test 

looked at whether nonsubject imports might have replaced subject imports without any benefit 

to the U.S. industry. The Commission applied that specific additional test in subsequent cases, 

including the Carbon and Certain Alloy Steel Wire Rod from Trinidad and Tobago determination 

that underlies the Mittal Steel litigation.

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

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

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

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

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

subject imports.82 Accordingly, we do not consider ourselves required to apply the 

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

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

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

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

adequate explanation, to non-attribution issues when it performs its causation analysis.83

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

Mittal Steel explains as follows:

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

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

obligation to consider an important aspect of the problem if it failed to consider whether nonsubject or non-LTFV imports would have replaced LTFV subject imports during the period of 

investigation without a continuing benefit to the domestic industry. 444 F.3d at 1369. Under 

those circumstances, Bratsk requires the Commission to consider whether replacement of the 

LTFV subject imports might have occurred during the period of investigation, and it requires the 

Commission to provide an explanation of its conclusion with respect to that factor. 

542 F.3d at 878. 80 Nucor Corp. v. United States, 414 F.3d 1331, 1336, 1341 (Fed. Cir. 2005); see also Mittal Steel, 

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

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

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

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

(recognizing the Commission’s alternative interpretation of Bratsk as a reminder to conduct a nonattribution analysis).

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

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

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

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

15

 

(...Continued)

(Continued...)
 

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

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

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

the agency’s institutional expertise in resolving injury issues.84

B. Conditions of Competition and the Business Cycle 

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

injury by reason of subject imports.

1. Demand Considerations 

Demand for STR depends on demand for the downstream products in which STR is 

used.85 STR is generally used in commercial construction, where it is cut to length on site and 

used to suspend electrical conduit, pipes for plumbing, HVAC ductwork, and sprinkler pipes for 

fire protection systems.86 STR accounts for a relatively small although highly variable share of 

the cost of the end-use products in which it is commonly used,87 and most questionnaire 

respondents reported no substitutes for STR in the applications in which it is used.88 

The main U.S. purchasers of STR are master distributors, which buy large quantities or 

containers from manufacturers for resale to smaller distributors, and distributors that resell STR 

along with many other fastening products.89 As a whole, these distributors sell to a wide 

variety of firms in the commercial construction industry, but individual distributors tend to 

focus on specific industry segments, such as electrical, plumbing, and general construction.90

Questionnaire respondents reported that U.S. demand for STR follows general economic 

and commercial construction trends.91 Most U.S. producers, importers, and purchasers 

reported that demand either fluctuated or did not change during the POI, and about an equal 

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

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

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

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

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

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

and difficult, and is a matter for the judgment of the ITC.”). 85 CR at II-11 – II-12; PR at II-8. 

86 CR at I-10 – I-12, II-1; PR at I-7 – I-9, II-1. STR is also used, among other things, as structural 

tie-downs in earthquake and hurricane roofing restraint systems, as headless screws in general fastener 

applications, to bolt together pipe joints in the waterworks industry, for joint restraint systems for 

underground piping, and for basic industrial repairs. Id.

87 CR at II-15; PR at II-11. 88 CR at II-15; PR at II-9. 

89 CR at I-4 & II-2; PR at I-3, II-1; CR/PR at Table II-1. 

90 CR at I-4; PR at I-3. 

91 CR at II-13; PR at II-9. 

16

 

(...Continued)
 

number indicated that demand increased or decreased.

92 Most purchasers reported that 

demand for their products has not changed since January 1, 2011.93 Petitioners assert that 

demand for STR increased as activity in the nonresidential construction sector improved.

94 As 

measured by apparent U.S. consumption of STR, demand increased from *** million pounds in 

2011 to *** million pounds in 2012 and *** million pounds in 2013.

95 

2. Supply Considerations

Sources of supply to the U.S. market during the POI included the domestic industry, 

subject imports, and imports from nonsubject sources.96

The domestic industry was the largest source of STR, supplying about half of the U.S. 

market during the POI.97 Vulcan and All America are the largest of the six known manufacturers 

of STR in the United States.98 All producers except *** reported that they produced or 

anticipated producing other products (***) on the same equipment and machinery used to 

produce STR. However, ***.

99 

During the POI, cumulated subject imports from India and Thailand were the secondlargest source of supply to the U.S. market.100 The largest responding producers of threaded 

rod in India are Maharaja International, Mangal Steel Enterprises Limited, Meeras International, 

and Sunil Industries.101 No threaded rod producer from Thailand responded to the 

Commission’s questionnaire,102 although Petitioners assert that Tycoons Worldwide Group is 

the largest producer in Thailand and likely accounts for the vast majority of STR exports to the 

United States from Thailand.103

Imports of STR from nonsubject sources held the third-largest share of the U.S. market 

during the POI.104 The largest nonsubject sources of U.S. STR imports are Taiwan and China.105 

92 CR at II-13; PR at II-9; CR/PR at Table II-3.

93 CR at II-13; PR at II-9. 

94 Petitioners’ Posthearing Brief, Responses to Commission’s Questions at 2.

95 CR/PR at Table IV-7. Apparent consumption is calculated using official import data from 

HTSUS subheading 7318.15.5056. According to Petitioners, as noted above, the majority of imports of 

subject merchandise are reported under HTSUS subheading 7318.15.5056, and the majority of 

merchandise entered under this subheading is subject merchandise. CR at I-5 n.5; PR at I-4 n.5. 96 CR/PR at Table IV-8.

97 CR/PR at Table IV-8.

98 CR/PR at I-4. 99 CR at III-4 – III-5; PR at III-2. *** is the only domestic producer that uses its equipment 

primarily in the production of ***. CR at III-4; PR at III-2. 

100 CR/PR at Table IV-8.

101 CR/PR at I-4.

102 CR/PR at I-4.

103 CR at I-4 n.4; PR at I-3 n.4. 104 CR/PR at Table IV-8.

105 CR at II-11; PR at II-7 – II-8. 

17

 
 

STR imports from China have been subject to an antidumping duty order since April 2009.106 

Petitioners assert that imports of STR from China fell after the order was imposed,107 but 

imports from China continue to have a U.S. market presence.108

3. Substitutability

We find a high degree of substitutability among domestically produced STR and STR 

from both subject import sources.109 As explained above, all domestic producers, almost all 

responding importers, and the majority of responding purchasers reported that the domestic 

like product and subject imports were “always” or “frequently” interchangeable and that 

differences other than price were only “sometimes” or “never” a significant factor in STR 

sales.110 Buy America policies were reported to affect only a very small portion of purchases.111 

4. Other Conditions

The primary raw material used to manufacture STR is low-carbon steel wire rod, or in 

the case of larger-diameter STR, low-carbon steel bar.112 Raw materials (including wire rod) 

accounted for approximately 65 percent of the cost of goods sold (“COGS”) for STR during the 

POI.113 The price of carbon steel wire rod increased slightly during 2011 and then declined with 

minor fluctuations until 2013, for an overall decrease of almost 18 percent during the POI.114

C. Volume of Subject Imports

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

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

absolute terms or relative to production or consumption in the United States, is significant.”115

The volume of cumulated subject imports was 34.8 million pounds in 2011, 42.8 million 

pounds in 2012, and 46.4 million pounds in 2013.

116 As explained above, demand as measured 

by apparent U.S. consumption rose *** percent from 2011 to 2013.

117 The volume of 

106 Certain Steel Threaded Rod from China: Notice of Antidumping Duty Order, 70 Fed. Reg. 

17154 (Apr. 14, 2009). See also Certain Steel Threaded Rod from China, Inv. No. 731-TA-1145 (Final), 

USITC Pub. 4070 (Apr. 2009) at 3. 107 Tr. at 11 (Upton).

108 CR/PR at Table IV-8.

109 CR/PR at II-16; PR at II-11. 110 CR at II-21 – II-23; PR at II-14 – II-16; CR/PR at Tables II-8 & II-9. 111 Tr. at 88 (Upton). 112 CR at I-13 & V-1; PR at I-9, V-1.

113 CR/PR at V-1. 114 CR/PR at V-1 & Figure V-1. 115 19 U.S.C. § 1677(7)(C)(i).

116 CR/PR at Table IV-2. 117 CR/PR at Table C-1.

18

 
 

cumulated imports of STR rose at a higher rate, increasing 33.2 percent from 2011 to 2013, 

although the rate of increase slowed at the end of the POI.

118 

The share of apparent U.S. consumption held by cumulated subject imports, by 

quantity, increased from *** percent in 2011 to *** percent in 2012 and then to *** percent in 

2013, for an overall increase of *** percentage points.119 The domestic industry’s market 

share, by quantity, remained relatively stable during the POI, decreasing slightly from ***

percent in 2011 to *** percent in 2012 before increasing to *** percent in 2013.

120 Nonsubject 

imports’ share of apparent U.S. consumption, by quantity, decreased from *** percent in 2011

to *** percent in 2013 before decreasing further to *** percent in 2013.

121 Cumulated subject 

imports were equivalent to *** percent of U.S. production in 2011, *** percent in 2012, and 

*** percent in 2013.

122 

We find that the volume of cumulated subject imports, and the increase in that volume, 

is significant both in absolute terms and relative to consumption and production in the United 

States.123 However, for reasons we discuss below, we do not find significant adverse price 

118 CR/PR at Table C-1. Cumulated subject imports increased 22.9 percent from 2011 to 2012 

but only 8.4 percent from 2012 to 2013. Id.

119 CR/PR at Tables IV-8 & C-1. 

120 CR/PR at Tables IV-8 & C-1. 121 CR/PR at Tables IV-8 &C-1. Nonsubject imports, by quantity, were 32.9 million pounds in 

2011, 36.8 million pounds in 2012, and 35.1 million pounds in 2013. CR/PR at Tables IV-2 & C-1. 122 CR/PR at Table IV-2. 

123 Petitioners contend that HTSUS 7318.15.5056 is a unique and discrete subheading covering 

most of the subject merchandise. Petitioners’ Prehearing Brief at 17, n.71, Petitioners’ Posthearing Brief 

at 2-3. Petitioners further contend that U.S. importers have reported to the Commission that virtually 

all of their subject imports were classified under this HTS subheading during the POI. Id. Accordingly, 

petitioners argue that official import statistics for HTS 7318.15.5056 are “a nearly perfect proxy” for 

evaluating the volume of subject imports during the POI. Petitioners’ Posthearing Brief at 3, Tr. at 41 

(Waite). Notwithstanding this assertion, petitioners also argue that the official import statistics 

understate the volume of subject imports from India in 2012. Posthearing Brief at Responses to 

Commission’s Questions at 5, Attachment A. Petitioners assert that the export data reported by the 14 

Indian producers which responded to the Commission’s questionnaires in the preliminary phase track 

the official import statistics for 2010 and 2011 but diverge significantly in 2012, when Indian producers 

reported a significantly higher volume of exports than is reflected in the reported imports for HTSUS 

7318.15.5056. Id. (stating that Indian producers reported total exports of *** million pounds in 2012, 

but only 20.7 million pounds were reported for the same year under HTSUS 7318.15.5056); see also 

Hearing Tr. at 33-34, 77-80. Petitioners further assert that the accuracy and reliability of the 

questionnaire responses is supported by the fact that the largest Indian exporter’s questionnaire 

response corresponds with data in the ZEPOL ImportIQ database, both of which vary from the official 

import statistics by between *** million pounds. Id. 

As explained in the staff report, import data are based on official statistics rather than 

questionnaire responses because several larger importers did not provide responses to the 

questionnaires in the final phase investigations. Moreover, the record indicates that the majority of 

subject merchandise is classified under HTSUS 7318.15.5056. CR at I-5 & n.5; PR at I-4 & n.5. 

Consequently, the official statistics provide the most complete data available for subject import volume 

19

 

(Continued...)
 

effects or a significant adverse impact on the domestic industry by reason of cumulated subject 

imports. 

We also observe that the record does not indicate that there was an overall noticeable 

decline in the volume of cumulated subject imports due to the pendency of the investigations. 

The monthly data indicate relatively consistent monthly levels of cumulated imports during 

most of 2013.124 Although subject imports from Thailand declined in October and left the U.S. 

market altogether in November and December, they had more than doubled the previous 

August. Furthermore, the decline in subject imports from Thailand during the last few months

of 2013 was largely offset by increased imports from India. In light of this, we do not conclude 

that the filing of the petition materially affected the volume of cumulated subject imports in 

2013 and decline to give reduced weight to the 2013 data in the record.125

D. Price Effects of the Subject Imports

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

subject imports, the Commission shall consider whether 

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

merchandise as compared with the price of domestic like 

products of the United States, and

(II) the effect of imports of such merchandise otherwise depresses 

prices to a significant degree or prevents price increases, which 

otherwise would have occurred, to a significant degree.126

We find that there is a high degree of substitutability between subject imports from 

India and Thailand and the domestic like product and that price is an important consideration in 

purchasing decisions. As explained above, all U.S. producers, almost all responding importers, 

and most purchasers reported that STR produced in the United States, India, and Thailand was 

“always” or “frequently” interchangeable. 127 All responding U.S. producers and most 

during the entire POI. Even if we were to accept petitioners’ assertion regarding the 2012 data, 

however, it would not change our conclusion that the volume of subject imports was significant during 

the POI. 124 Monthly import statistics classified under HTSUS 7318.15.5056, EDIS Doc. 531569. Monthly 

imports of STR from India typically fell within the range of *** pounds to *** pounds, with the exception 

of October and November 2013, in which imports from India increased to *** pounds and ***, 

respectively. Id. Monthly imports from Thailand likewise typically fell within the range of *** pounds to 

*** pounds and, although imports from Thailand declined to *** pounds in October 2013 and were zero 

in November and December 2013, they were *** pounds in August 2013. Id.

125 Moreover, no party has argued that 2013 data should be given reduced weight in these 

investigations. 

126 19 U.S.C. § 1677(7)(C)(ii). 127 CR at II-21 – II-22; PR at II-14. 

20

 

(...Continued)
 

importers and purchasers reported that differences other than price were only “sometimes” or 

“never” a significant factor in STR sales.128 

The Commission sought quarterly pricing data for six types of STR.129 Subject imports 

were generally priced higher than the domestic product.130 Cumulated subject imports 

oversold the domestic like product in *** out of 142 quarterly comparisons, by margins ranging 

from less than 1 percent to 220.9 percent, and undersold it in the remaining *** comparisons, 

with margins ranging from less than 1 percent to 39.2 percent.

131 Overselling by subject 

imports occurred with relatively greater frequency in the higher volume pricing products, 

products 1, 2, and 3, with the subject imports overselling the domestic like product in *** out 

of 72 quarterly comparisons.

132 Underselling was concentrated in pricing product 5, which 

represented a relatively lower volume of sales for both the domestic industry and subject 

128 CR at II-23; PR at II-16. 129 CR at V-5; PR at V-4. The pricing products consisted of the following: (1) low-carbon steel 

fully threaded rod, electroplated with zinc, 3/8 inch diameter, and 10 feet in length; (2) low-carbon steel 

fully threaded rod, electroplated with zinc, 3/8 inch diameter, and six feet in length; (3) low-carbon steel 

fully threaded rod, electroplated with zinc, 1/2 inch diameter, and 10 feet in length; (4) low-carbon steel 

fully threaded rod, plain, 3/4 inch diameter, and 12 feet in length; (5) low-carbon steel fully threaded 

rod, electroplated with zinc, 1/4 inch diameter, and 10 feet in length; and (6) low-carbon steel fully 

threaded rod, hot dipped galvanized, 5/8 inch diameter, and 12 feet in length. Id. The Commission 

received usable data from four U.S. producers and 22 importers, although not all responding firms 

reported for all quarters. Id. Pricing data reported by these firms accounted for *** percent of the 

domestic industry’s shipments of STR, *** percent of U.S. shipments of subject imports from India, and 

*** percent of U.S. shipments of subject imports from Thailand. CR at V-6; PR at V-4. 

130 Petitioners argue that the Commission’s analysis regarding price effects should focus on 

average unit value (“AUV”) data rather than the data that the Commission collected with respect to the 

pricing products. Petitioners’ Prehearing Brief at 18-19; Petitioners’ Posthearing Brief at 4-5; Petitioners’ 

Final Comments at 5-6. We do not rely on AUV data in analyzing price effects in these investigations for 

several reasons. First, prices for individual products vary widely. For example, U.S. producers’ prices for 

hot-dipped galvanized product 6 ranged from $0.92 to $1.00 per pound, and the price for the smaller 

diameter product 5 ranged from $0.74 to $0.78 per pound, while prices for products 1 through 4 ranged 

from $0.58 to $0.66 per pound. CR at V-23; PR at V-12. Consequently, product differences and product 

mix issues make a comparison of AUVs less reliable for analyzing price effects than the direct 

comparisons produced by the pricing product data. CR at V-22 – V-23; PR at V-11 – V-12. See Allegheny 

Ludlum Corp. v. United States, 287 F.3d 1365, 1373-74 (Fed. Cir. 2002). Further, as noted in the staff 

report, AUV data understate sales prices of subject imports. CR at V-22; PR at V-11. Although 

petitioners contend that the Commission could adjust AUV data to account for the markup, we decline 

to do so, observing that the markup percentages are only examples of how importers increase the 

prices. Thus, adding a markup to the AUV data does not make it more reliable than the direct 

comparisons in the pricing product data. Finally, we note that petitioners’ counsel indicated that staff 

had addressed the concerns petitioners previously expressed concerning the pricing data. CR at V-21 

n.7; PR at V-9 n.7. Indeed, petitioners have not identified any specific concerns with pricing product 

data that staff has not already addressed. Petitioners’ Final Comments at 8. Accordingly, we have 

followed our normal practice of relying on the pricing data concerning specific products.

131 CR at V-19; PR at V-9. 

132 CR/PR at Tables V-3 – V-5. 

21

 
 

imports than products 1, 2, and 3.

133 Consequently, we do not find the underselling by subject 

imports to be significant.

Additionally, the instances of underselling that occurred did not result in a significant 

loss of market share by the domestic industry. As discussed above, although the domestic 

industry’s share of the U.S. market declined slightly in 2012, it returned in 2013 to essentially 

the same level as in 2011.134 Thus, the subject imports’ gain in market share over the POI came 

predominantly at the expense of nonsubject imports rather than the domestic industry.135 

We also do not find that subject imports depressed prices to a significant degree. From 

the first quarter of 2011 to the final quarter of 2013, prices for domestically produced products 

2, 4, and 6 slightly increased while prices for domestically produced product 1 remained the 

same.136 In addition, although prices for domestically produced products 3 and 5 slightly 

declined, the decrease in price from the first quarter of 2011 to the final quarter of 2013 was 

only 1 cent per pound.137 Moreover, although the prices of several products decreased from 

peak levels in 2011 or 2012, we observe that the price declines that occurred were largely 

coincident with declines in raw material costs.138 Specifically, the price of steel wire rod, the 

main raw material used in the production of STR, increased in 2011 before declining sharply in 

January 2012 and then declining further for the next two years for an overall decline of almost 

18 percent by the end of 2013.

139 

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

otherwise would have occurred, to a significant degree during the POI. The domestic industry’s 

unit net sales value initially increased from $*** to $*** from 2011 to 2012 and then decreased 

to $*** in 2013.140 Similarly, the domestic industry’s unit COGS increased from $*** in 2011 to 

133 CR/PR at Table V-7. 

134 Petitioners argue that, when comparing pricing product data for the domestically produced 

product to the prices for the ***, subject imports undersold the domestic like product 50 percent of the 

time. Petitioners’ Final Comments at 7. Although we acknowledge this, CR at V-21 – V-22; PR at V-9, it 

does not change our conclusion because, as described above, any underselling did not result in any 

significant loss of market share by the domestic industry by the end of the POI. Moreover, although we 

base our analysis on the domestic industry as a whole, we note that *** (see responses to question III23 in the U.S. purchasers’ questionnaire), consistently undersold both other domestic producers and 

subject imports. Specifically, for products 1, 2, 3, and 4, *** prices were lower than *** prices for 

domestically produced STR as well as *** prices for STR from Thailand and *** prices for STR from India 

in the majority of comparisons. Responses to question IV-2 in the U.S. producers questionnaire for ***; 

responses to question III-3 in the U.S. importers questionnaire for ***. 135 CR/PR at Table C-1. 

136 CR/PR at Tables V-3, V-4, V-6 & V-8.

137 CR/PR at Tables V-5 & V-7. 

138 Compare CR/PR at Figure V-1 with CR/PR at Tables V-3 to V-8. 

139 CR/PR at V-1; CR/PR at Figure V-1. Although the domestic industry reported that the unit 

value of costs for steel increased slightly from $*** in 2011 to $*** in 2012, it fell to $*** in 2013. 

CR/PR at Table VI-1. 

140 CR/PR at Tables VI-1 & C-1. 

22

 
 

$*** in 2012 before declining to $*** in 2013.141 The domestic industry’s COGS as a ratio to 

net sales declined overall during the POI.

142 Given the overall declines in both unit COGS and 

the COGS/sales ratio, we do not find that subject imports prevented price increases, which 

otherwise would have occurred, to a significant degree.

We acknowledge that there are a number of confirmed allegations of lost sales and lost 

revenues. However, in light of the other information on the record concerning the 

predominant overselling by the subject imports, the lack of significant loss of market share by 

the domestic industry, the domestic industry’s relatively stable prices, and the absence of 

significant price depression or price suppression, we do not find that the confirmed lost sales 

and lost revenues allegations demonstrate significant price effects. Moreover, considering that 

the domestic industry was able to regain market share by the final year of the POI, we find that 

the responses to the lost sales and lost revenues allegations do not appear to reflect what was 

occurring in the market as a whole. 

Accordingly, based on the record in the final phase of these investigations, we do not 

find significant underselling, nor do we find that subject imports have depressed prices or 

prevented price increases, which otherwise would have occurred, to a significant degree. 

E. Impact of the Subject Imports143

Section 771(7)(C)(iii) of the Tariff Act provides that examining the impact of subject 

imports, the Commission “shall evaluate all relevant economic factors which have a bearing on 

141 CR/PR at Tables VI-1 & C-1. Petitioners argue that, although the domestic industry’s ratio of 

COGS to net sales decreased from 2012 to 2013, the 2013 ratio is still greater than the 2010 ratio found 

in the preliminary phrase. Petitioners’ Posthearing Brief, Responses to Commission’s Questions at 23. 

We have followed our usual practice in final phase investigations of analyzing data for a three-year 

period and note that, in their comments on the Commission’s questionnaires, petitioners did not assert 

that we should deviate from this standard practice. See Petitioners’ Comments on Draft Questionnaires 

for Final Investigation. 142 CR/PR at Tables VI-1 & C-1. COGS as a ratio to net sales was *** percent in 2011, *** percent 

in 2012, and *** percent in 2013. Id. 143 The statute instructs the Commission to consider the “magnitude of the dumping margin” in 

an antidumping proceeding as part of its consideration of the impact of imports. 19 U.S.C. § 

1677(7)(C)(iii)(V). As instructed by the statute, we have relied on the margins on STR from India 

Commerce published in its preliminary determination. 19 U.S.C. § 1677(35)(C)(ii). Commerce published 

notice of its preliminary determination regarding imports from India with antidumping duty margins of 

8.63 to 119.87 percent. Commerce published notice of its final determination regarding imports from 

Thailand with antidumping duty margins of 68.41 to 74.90 percent. CR at I-7 – I-8; PR at I-5 (citing Steel 

Threaded Rod from India: Preliminary Determination of Sales at Less Than Fair Value, Affirmative Final 

Determination of Critical Circumstance, in Part, and Postponement of Final Determination , 79 Fed. Reg. 

9164 (Feb. 18, 2014); Steel Threaded Rod from India: Preliminary Affirmative Countervailing Duty 

Determination and Alignment of Final Determination with Final Antidumping Determination, 78 Fed. 

Reg. 76815 (Dec. 19, 2013); Steel Threaded Rod from Thailand: Final Determination of Sales at Less Than 

Fair Value and Affirmative Final Determination of Critical Circumstances, 79 Fed. Reg. 14476 (Mar. 14, 

2014)). 

23

 
 

the state of the industry.”144 These factors include output, sales, inventories, capacity 

utilization, market share, employment, wages, productivity, profits, cash flow, return on 

investment, ability to raise capital, research and development, and factors affecting domestic 

prices. No single factor is dispositive and all relevant factors are considered “within the context 

of the business cycle and conditions of competition that are distinctive to the affected 

industry.”

Many of the domestic industry’s trade and employment indicators improved or 

essentially were stable during the POI. As discussed above, the U.S. producers’ share of the 

U.S. market initially declined slightly from *** percent in 2011 to *** percent in 2012 but 

subsequently increased to *** percent in 2013.

145 The domestic industry’s production 

increased steadily by *** percent overall between 2011 and 2013, starting at *** pounds in 

2011 and then increasing to *** pounds in 2012 and *** pounds in 2013.

146 The domestic 

industry’s U.S. shipments increased from *** pounds in 2011 to *** pounds in 2012 and ***

pounds in 2013, representing an overall increase of *** percent, although the domestic 

industry’s end-of-period inventories increased both on an absolute basis and relative to 

production and shipments from 2011 to 2013.147 Net sales by quantity and value increased by 

*** and *** percent, respectively, during the POI.

148 The domestic industry’s production 

capacity increased *** percent overall from 2011 to 2013, while capacity utilization increased 

by *** percentage points, from *** percent in 2011 to *** percent in 2012 and *** percent in 

2013.

149 The number of production workers decreased slightly, while hours worked, wages 

paid and productivity increased overall.150 

Although the domestic industry reported operating losses during the POI, its financial 

condition improved from 2011 to 2013. Notwithstanding increasing volumes of subject 

imports, the industry’s net sales quantities and revenues both increased. Because of the 

subject imports’ lack of significant price effects, per unit sales values and COGS moved in 

144 19 U.S.C. § 1677(7)(C)(iii); see also SAA at 851 and 885 (“In material injury determinations, 

the Commission considers, in addition to imports, other factors that may be contributing to overall 

injury. While these factors, in some cases, may account for the injury to the domestic industry, they also 

may demonstrate that an industry is facing difficulties from a variety of sources and is vulnerable to 

dumped or subsidized imports.”). 145 CR/PR at Table C-1. 

146 CR/PR at Tables III-2 & C-1. 147 CR/PR at Tables III-3, III-4 & C-1. 

148 CR/PR at Table C-1. Net sales, by quantity, increased from *** pounds in 2011 to *** pounds 

in 2012 and *** pounds in 2013. CR/PR at Table VI-1. Net sales, by value, increased from $*** in 2011 

to $*** in 2012 and $*** in 2013. Id. 149 CR/PR at Tables III-2 & C-1. The domestic industry’s production capacity was *** pounds in 

2011, *** pounds in 2012, and *** pounds in 2012. Id. 150 CR/PR at Table III-6. The number of production workers was *** in 2011, *** in 2012, and 

*** in 2013. Id. The total hours worked were *** in 2011, *** in 2012, and *** in 2013. Id. Wages 

paid were $*** in 2011, $*** in 2012, and $*** in 2013. Id. Productivity was *** short tons per 1,000 

hours in 2011, *** short tons per 1,000 hours in 2012, and *** short tons per 1,000 hours in 2013. 

CR/PR at Table C-1.

24

 
 

tandem from 2011 to 2013.

151 The domestic industry was able to improve its financial 

performance due to increased sales quantities and revenues that increased at a greater rate 

than COGS and selling, general, and administrative (“SG&A”) expenses combined.

152 The 

domestic industry’s aggregate operating income improved from operating losses in 2011 and 

2012 of $*** and $***, respectively, to an operating loss of only $*** in 2013.

153 The domestic 

industry’s ratio of operating income to net sales increased by *** percentage points from 2011 

to 2013, with operating margins declining from negative *** percent in 2011 to negative ***

percent in 2011 before improving to negative *** percent in 2013.

154 The domestic industry’s 

aggregate capital expenditures increased from $*** in 2011 to $*** in 2012 and $*** in 

2013.155 

The record indicates that some of the domestic industry’s performance indicators have 

not improved. We further acknowledge, as noted above, that the domestic industry 

experienced operating losses throughout the POI. Nevertheless, the record fails to show a 

meaningful correlation between subject imports and the domestic industry’s condition. As 

discussed above, the domestic industry increased production from 2011 to 2013 when 

apparent consumption was also increasing and the market was continuing to recover from the 

recession.

156 In addition, the domestic industry did not lose significant market share from 2011 

to 2013; rather, subject imports’ increase in market share came overwhelmingly at the expense 

of nonsubject imports. The domestic industry’s production, shipments, capacity utilization, and 

financial performance improved in 2013 when the volume of cumulated subject imports, based 

on official import statistics, was at its highest level during the POI.

157 

151 Per unit net sales values were $*** in 2011, $*** in 2012, and $*** in 2013. CR/PR at Table 

VI-1. Per unit COGS was $*** in 2011, $*** in 2012, and $*** in 2013. Id. 152 CR/PR at Table C-1. COGS increased *** percent overall, from $*** in 2011 to $*** in 2012 

and $*** in 2013. Id. SG&A expenses increased *** percent overall, decreasing from $*** in 2011 to 

$*** in 2012 before increasing to $*** in 2013. Id. 153 CR/PR at Table VI-1. 154 CR/PR at Tables VI-1 & C-1. 155 CR/PR at Table VI-3. No firms reported research and development expenses. CR at VI-6; PR 

at VI-2. 

156 CR at II-11 – II-12; PR at II-8 – II-9. 157 CR/PR at Table C-1. In asserting that there is a correlation between the domestic industry’s 

performance and subject imports, petitioners rely on data from questionnaire responses during the 

preliminary phase investigations rather than official import statistics. Petitioners’ Final Comments at 3-4 

& Exhibit 1. These data would indicate that the volume of subject imports increased more than is 

reported in official statistics for 2012 and then declined in 2013, rather than increasing each year of the 

POI as official import statistics show. Id. Compare also CR/PR at Table C-1 with CR/PR at Table C-2. 

Petitioners argue that this demonstrates a causal relationship between subject imports and the 

domestic industry’s condition because subject imports were highest in 2012 when the domestic industry 

experienced the highest level of operating losses. Petitioners’ Final Comments at pp. 3-4 & Exhibit 1. 

However, setting aside the data for 2012, which petitioners claim is aberrational, we observe that a 

comparison of the data for 2011 and 2013 does not show a correlation between subject imports and the 

domestic industry’s financial performance. The domestic industry’s operating losses were greater in 

2011 than in 2013, but the volume of cumulated subject imports was higher in the latter year. CR/PR at 

25

 

(Continued...)
 

Moreover, we do not find that the record supports petitioners’ assertion that the 

domestic industry’s improvement can be explained by the exit of subject imports from the 

market following the petition.158 As discussed above, although subject imports from Thailand 

decreased in October 2013 and left the U.S. market in November and December 2013, this did 

not result in a noticeable overall decline in the volume of cumulated subject imports during 

2013. Thus, we do not find that the pendency of these investigations explains the improvement 

in the domestic industry’s condition.

Based on the foregoing reasons, we find that cumulated subject imports have not had a 

significant impact on the domestic industry. Thus, we conclude that, notwithstanding the 

domestic industry’s operating losses during the POI, the industry is not materially injured by 

reason of cumulated subject imports. 

VI. No Threat of Material Injury by Reason of Subject Imports

A. Legal Standard

Section 771(7)(F) of the Tariff Act directs the Commission to determine whether the U.S. 

industry is threatened with material injury by reason of the subject imports by analyzing 

whether “further dumped or subsidized imports are imminent and whether material injury by 

reason of imports would occur unless an order is issued or a suspension agreement is 

accepted.”159 The Commission may not make such a determination “on the basis of mere 

conjecture or supposition,” and considers the threat factors “as a whole” in making its 

determination whether dumped or subsidized imports are imminent and whether material 

injury by reason of subject imports would occur unless an order is issued.160 In making our 

determination, we consider all statutory threat factors that are relevant.161

Table C-1. Accordingly, even if we were to rely on the import trends shown in the preliminary phase 

questionnaire data rather than official import statistics, it would not materially alter our conclusion. 

158 Petitioners’ Final Comments at 3-4. 

159 19 U.S.C. § 1677(7)(F)(ii).

160 19 U.S.C. § 1677(7)(F)(ii).

161 These factors are as follows:

(I) if a countervailable subsidy is involved, such information as may be presented to it by the 

administering authority as to the nature of the subsidy (particularly as to whether the countervailable 

subsidy is a subsidy described in Article 3 or 6.1 of the Subsidies Agreement) and whether imports of the 

subject merchandise are likely to increase,

(II) any existing unused production capacity or imminent, substantial increase in production 

capacity in the exporting country indicating the likelihood of substantially increased imports of the 

subject merchandise into the United States, taking into account the availability of other export markets 

to absorb any additional exports,

(III) a significant rate of increase of the volume or market penetration of imports of the subject 

merchandise indicating the likelihood of substantially increased imports,

26

 

(...Continued)

(Continued...)
 

B. Cumulation for Threat

Under section 771(7)(H) of the Tariff Act, the Commission may “to the extent 

practicable” cumulatively assess the volume and price effects of subject imports from all 

countries as to which petitions were filed on the same day if the requirements for cumulation in 

the material injury context are satisfied.

162 Petitioners argue that the Commission should 

exercise its discretion to cumulate subject imports from India and Thailand in assessing threat 

of material injury.163 

As discussed in section IV above, the record indicates that there is a reasonable overlap 

of competition between and among the domestic like product and subject imports from India 

and Thailand, and the record does not contain any evidence that this overlap is likely to change 

in the future. We have also considered whether subject imports from India and Thailand 

exhibited similar volume and price trends during the POI that would justify exercising our 

discretion to cumulate these imports for our threat analysis. There are some variations in these 

trends, but on this record we do not find them to be sufficient to indicate that subject imports 

from India and Thailand would compete in the U.S. market under different conditions of 

competition in the imminent future. Accordingly, we exercise our discretion to cumulate 

subject imports from India and Thailand in assessing threat of material injury. 

(IV) whether imports of the subject merchandise are entering at prices that are likely to have a 

significant depressing or suppressing effect on domestic prices and are likely to increase demand for 

further imports,

(V) inventories of the subject merchandise,

(VI) the potential for product-shifting if production facilities in the foreign country, which can be 

used to produce the subject merchandise, are currently being used to produce other products,

... 

(VIII) the actual and potential negative effects on the existing development and production 

efforts of the domestic industry, including efforts to develop a derivative or more advanced version of 

the domestic like product, and

(IX) any other demonstrable adverse trends that indicate the probability that there is likely to be 

material injury by reason of imports (or sale for importation) of the subject merchandise (whether or 

not it is actually being imported at the time). 

19 U.S.C. § 1677(7)(F)(i). To organize our analysis, we discuss the applicable statutory threat factors 

using the same volume/price/impact framework that applies to our material injury analysis. Statutory 

threat factors (I), (II), (III), (V), and (VI) are discussed in the analysis of subject import volume. Statutory 

threat factor (IV) is discussed in the analysis of subject import price effects. Statutory factors (VIII) and 

(IX) are discussed in the analysis of impact. Statutory factor (VII) concerning agricultural products is 

inapplicable to this determination. 

162 19 U.S.C. § 1677(7)(H).

163 Petitioners’ Posthearing Brief at 8-9, Responses to Commission’s Questions at 4-7 & 

Attachment A; Petitioners’ Final Comments at 11-12.

27

 

(...Continued)
 

C. Analysis of Threat of Material Injury by Reason of Subject Imports

As discussed above, although it continued to experience operating losses each year, the 

domestic industry’s performance generally improved during the POI, and we have found that 

the cumulated subject imports have not had significant adverse effects on the condition of the 

domestic industry. As discussed below, we likewise find that the domestic industry is not 

threatened with material injury by reason of cumulated subject imports. 

Likely Subject Import Volume164

We find that the increase in cumulated subject imports and market share during the POI 

does not indicate a likelihood of substantially increased imports in the imminent future. As 

detailed above, although cumulated subject imports increased over the POI, the rate of 

increase slowed considerably in 2013.165 Moreover, subject imports increased their share of 

the U.S. market primarily at the expense of nonsubject imports. By contrast, the domestic 

industry increased its market share in 2013 to roughly the level of its market share in 2011. 

Moreover, the industry increased its production and U.S. shipments throughout the period as 

apparent consumption increased. There is no evidence that these factors will change in the 

imminent future.166 167 

We also find that excess capacity in the subject countries, although significant, does not 

indicate the likelihood of substantially increased imports of the subject merchandise. 

Responding foreign producers from India reported that their production capacity increased 

each year and was nearly 9.0 million pounds – or 28.1 percent – higher in 2013 than in 2011.168 

Reported Indian excess capacity during the POI increased from 4.7 million pounds in 2011 to 

164 In its preliminary affirmative countervailing duty determinations on STR from India, 

Commerce found five subsidy programs to be countervailable: pre- and post-shipment export financing, 

a duty draw back program, an export promotion of capital goods scheme, a focus product scheme, and a 

status holder incentive scrip scheme. Steel Threaded Rod from India: Preliminary Affirmative 

Countervailing Duty Determination and Alignment of Final Determination with Final Antidumping 

Determination, 78 Fed. Reg. 76815 (Dec. 19, 2013) and accompanying Issues and Decisions 

Memorandum at 11-18. 

165 CR/PR at C-1. 

166 At the hearing, two representatives appearing on behalf of petitioners indicated that 

commercial construction, which is the principal end use for STR, is expected in increase in the imminent 

future. Tr. at 40 (McGrath), 81 (Logan). 

167 Petitioners’ assertion that the volume of subject imports from India in 2012 based on official 

import statistics is understated does not change our analysis. If we were to rely on data from the 

preliminary phase questionnaire responses, they show that cumulated subject imports actually declined 

from 2012 to 2013 rather than increased at a slower rate than that observed from 2011 to 2012. CR/PR 

at Table C-2. See also Petitioners’ Final Comments at Exhibit 1. This would further support our 

conclusion that subject imports are not likely to increase substantially in the imminent future and that 

any increase in subject imports is not likely to be at the expense of the domestic industry. 

168 CR/PR at VII-3. We also note, however, that over *** of the increase in capacity was 

attributed to a single firm, which was one of the few firms that did not export the majority of its STR to 

the United States and projected exports to the U.S. market to drop to zero in 2014-2015. CR/PR at VII-3 

– VII-4. By contrast, ***, reported stable capacity of *** pounds throughout the POI. CR/PR at VII-3 n.5. 

28

 
 

10.4 million pounds in 2012 before decreasing to 8.4 million pounds in 2013.169 Although no 

Thai producer responded to the Commission’s questionnaires, the largest STR producer in 

Thailand, Tycoons Worldwide Group (“Tycoons”), has publicly reported an annual threaded rod 

capacity of 39.7 million pounds,170 which is almost twice the quantity of U.S. imports of STR 

from Thailand in 2012.171 Notwithstanding subject producers’ substantial excess capacity 

throughout the POI, and a significant increase in capacity during the period, the rate at which 

subject merchandise entered the United States slowed considerably in 2013, and the domestic 

industry increased its market share that year.

172 We also observe that the majority of STR is 

sold from inventory and that the domestic industry maintained inventory levels throughout the 

POI that were comparable to the cumulated U.S. inventories of STR from subject countries in 

2012 and 2013.173 

We acknowledge that foreign producers in India and Thailand were export oriented and 

were substantially focused on supplying the U.S. market during the POI. Although responding 

Indian producers reported that their exports to the United States declined overall during the 

POI in absolute terms as well as relative to their overall shipments, the vast majority of 

shipments of STR from India during the POI were exported to the United States.174 Again, 

although no Thai producer responded to the Commission’s questionnaires, Tycoons has publicly 

reported that exports accounted for 59 percent of its total sales, including threaded rod, in 

2010 and 2011 and 52 percent in 2012.175 Notwithstanding this focus on the U.S. market, 

however, cumulated subject imports to the United States did not increase rapidly in 2013, and 

there is nothing to indicate that they would increase to levels sufficient to have adverse effects 

on the domestic industry in the imminent future. 

169 CR/PR at Table VII-1.

170 CR at VII-5; PR at VII-4 – VII-5. 171 CR at Table C-1. Imports of STR from Thailand were 20.6 million pounds in 2012. Id. 172 Petitioners again claim that the capacity figures are understated because they are based on 

data from only the six Indian producers that responded to the Commission’s questionnaires in the final 

phase investigation. Petitioners’ Prehearing Brief at 27-29. According to petitioners, the more complete 

coverage from the preliminary phase investigation shows that the Indian STR industry is *** to *** 

percent larger than reported in the final phase questionnaire responses and, therefore, the industry’s 

unused capacity is much greater than the above data indicate. Id., Petitioners’ Posthearing Brief at 10. 

Regardless of whether we rely upon the data from the preliminary phase investigations, however, we 

have acknowledged that Indian excess capacity is significant. Nevertheless, the existence of excess

capacity is unlikely to result in substantially increased volumes of subject imports in light of the subject 

import volume trends during the latter portion of the POI. CR/PR at Table C-1. We also find that, 

although there is some reported potential for product shifting, CR at II-9 – II-10; PR at II-7, it is unlikely 

due to the substantial excess capacity to produce STR. 173 CR at II-16 – II-17; PR at II-11; CR/PR at Table C-1. 174 CR at VII-3 – VII-4; CR/PR at Table VII-1. Shipments of STR exported to the United States were 

21.7 million pounds in 2011, 21.8 million pounds in 2012, and 20.6 million pounds in 2013. Id. As a 

share of Indian producers’ total shipments, exports of STR to the United States accounted for 82.6 

percent in 2011, 76.6 percent in 2012, and 64.4 percent in 2013. Id. 175 CR/PR at VII-5. 

29

 
 

We recognize that U.S. importers’ end-of-period inventories increased between 2011 

and 2013, increasing steadily from *** pounds in 2011 to *** pounds in 2013.176 Even if the 

increased inventory levels make some increase in subject imports likely, the record does not 

indicate that any such increase would be sufficient to have any significant likely impact on the 

domestic industry. We note that U.S. inventories of subject imports also increased substantially 

from 2011 to 2012,

177 but this did not result in a rapid increase in cumulated subject import 

volumes in 2013, a year in which the domestic industry increased its production, shipments, 

and market share and showed improved financial performance.

178 

In sum, we find that, notwithstanding subject producers’ excess capacity, inventory

levels of subject STR in the U.S. market, and subject producers’ export orientation, there was 

not a rapid increase in cumulated subject imports in 2013, and one is not likely in the imminent 

future. To the extent that subject imports may increase in the imminent future, any such 

increase is likely to be commensurate with increases in apparent consumption. As this occurs, 

the domestic industry is likely to continue to maintain its market share and increase its output, 

as it did during the POI.179

Likely Price Effects

We find that imports of subject merchandise are not likely to enter the U.S. market at 

prices that are likely to have significant depressing or suppressing effects on domestic prices or 

that are likely to increase demand for further imports. As detailed above, we have found that, 

during the POI, subject imports neither depressed nor suppressed prices for the domestic like 

product to a significant degree and that there was not significant underselling by subject 

imports. Because we have found that there is not a likelihood of substantially increased 

imports, and the record fails to demonstrate imminent changes in pricing trends in the U.S. 

market, the absence of significant price effects observed during the POI would likely continue in 

the imminent future. 

Likely Impact 

We have found above that, notwithstanding the significant and increased volume of 

subject imports, several domestic industry financial and trade indicators improved during the 

POI. Moreover, the domestic industry’s financial performance improved as demand recovered 

from recession levels, concluding the period at *** levels. Continued improving demand 

appears likely in the imminent future. Nothing in the record of these investigations gives us 

reason to believe that subject imports, which caused no material injury during the POI, would

176 CR/PR at Table C-1. In particular, we observe that inventories of STR from Thailand increased 

from *** pounds in 2011 to *** pounds in 2013. CR/PR at Table C-1. In addition, STR producers in India 

reported end-of-period inventories of 4.3 million pounds in 2011, 3.3 million pounds in 2012, and 3.5 

million pounds in 2013. CR/PR at Table VII-1. 177 CR/PR at Table C-1. 

178 CR/PR at Table C-1.

179 No responding producer, importer, or foreign producer reported antidumping duty orders on 

STR from India or Thailand in any third-country market. CR at VII-7; PR at VII-5. 

30

 
 

likely have a significant adverse impact on the condition of the domestic industry in the 

imminent future.180 

In light of the foregoing, we conclude that an industry in the United States is not 

threatened with material injury by reason of cumulated subject imports. 

VII. Conclusion

For the reasons stated above, we determine that an industry in the United States is not 

materially injured or threatened with material injury by reason of subject imports of STR from 

Thailand that are sold in the United States at less than fair value.

180 Petitioners did not argue that subject imports had a significant actual or potential negative 

effect on the existing development and production efforts of the domestic industry. Indeed, no 

domestic firm reported research and development expenses. CR at VI-6; PR at VI-2. 

31

 

PART I: INTRODUCTION

BACKGROUND

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

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

America Threaded Products, Inc., Denver, CO (“All America”), Bay Standard Manufacturing, Inc., 

Brentwood, CA, (“Bay Standard”) and Vulcan Threaded Products, Inc., Pelham, AL (“Vulcan”), on 

June 27, 2013, alleging that an industry in the United States is materially injured and threatened 

with material injury by reason of subsidized and less-than-fair-value (“LTFV”) imports of certain 

steel threaded rod (“threaded rod”) 1 from India and LTFV imports for threaded rod from 

Thailand. The following tabulation provides information relating to the background of these 

investigations.

2 3

Effective date Action

June 27, 2013 Petitions filed with Commerce and the Commission; 

institution of the Commission investigations (78 FR 

40170, July 3, 2013)

July 24 Commerce’s notice of initiation (78 FR 44526 and 78 FR 

44532, antidumping duty and countervailing duty, 

respectively)

November 5 Commission’s preliminary determination (78 FR 66382)

December 19 Commerce’s preliminary CVD determination on India (78 

FR 76815)

December 31 Commerce’s preliminary AD determination on Thailand 

(78 FR 79670); scheduling of final phase of the 

Commission’s investigation (79 FR 3245, January 17, 

2014)

February 18, 2014 Commerce’s preliminary AD determination on India (78 

FR 79670)

March 14 Commerce’s final AD determination on Thailand 79 FR 

14476)

March 20 Commission’s hearing

April 17 Scheduled date for the Commission’s vote (Thailand)

May 1 Scheduled date for Commission’s views (Thailand)

May 29 Scheduled date for the Commission’s vote (India)

June 12, 2014 Scheduled date for Commission’s views (India)

1 See the section entitled “The Subject Merchandise” in Part I of this report for a complete 

description of the merchandise subject to these investigations. 2 Pertinent Federal Register notices are referenced in app. A, and may be found at the Commission’s 

website (www.usitc.gov).

3 Appendix B presents the list of witnesses who appeared at the Commission’s hearing.

I-1

 
STATUTORY CRITERIA AND ORGANIZATION OF THE REPORT

Statutory criteria

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

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

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

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

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

merchandise on domestic producers of domestic like products, but only in 

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

may consider such other economic factors as are relevant to the 

determination regarding whether there is material injury by reason of 

imports.

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

In evaluating the volume of imports of merchandise, the Commission shall 

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

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

or consumption in the United States is significant.

. . .

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

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

underselling by the imported merchandise as compared with the price of 

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

of such merchandise otherwise depresses prices to a significant degree or 

prevents price increases, which otherwise would have occurred, to a 

significant degree.

. . .

In examining the impact required to be considered under subparagraph 

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

business cycle and conditions of competition that are distinctive to the 

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

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

. . . (I) actual and potential decline in output, sales, market share, profits, 

productivity, return on investments, and utilization of capacity, (II) factors 

affecting domestic prices, (III) actual and potential negative effects on 

cash flow, inventories, employment, wages, growth, ability to raise 

capital, and investment, (IV) actual and potential negative effects on the 

existing development and production efforts of the domestic industry, 

including efforts to develop a derivative or more advanced version of the 

I-2
domestic like product, and (V) in {an antidumping investigation}, the 

magnitude of the margin of dumping.

Organization of report

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

dumping margins, and domestic like product. Part II of this report presents information on 

conditions of competition and other relevant economic factors. Part III presents information on 

the condition of the U.S. industry, including data on capacity, production, shipments, 

inventories, and employment. Parts IV and V present the volume of subject imports and pricing 

of domestic and imported products, respectively. Part VI presents information on the financial 

experience of U.S. producers. Part VII presents the statutory requirements and information 

obtained for use in the Commission’s consideration of the question of threat of material injury 

as well as information regarding nonsubject countries.

MARKET SUMMARY

Threaded rod is generally used in commercial construction to suspend electrical conduit, 

pipes for plumbing, HVAC ductwork, and sprinkler systems. The leading U.S. producers of 

threaded rod are Vulcan and All America, while leading responding producers of threaded rod 

outside the United States include Maharaja International, Mangal Steel Enterprises Limited

(“Mangal”), Meeras International (“Meeras”), and Sunil Industries (“Sunil”) of India. No 

responses were received from threaded rod producers in Thailand.4 The leading U.S. importers 

of threaded rod from India are Elite Components and Fastenal Company (“Fastenal”), while the 

leading importers of threaded rod from Thailand are Brighton-Best International, Inc. and 

Porteous Fastener Company (“Porteous”). Leading importers of threaded rod from nonsubject 

countries (primarily China and Taiwan) include Fastenal, Itochu Building Products Inc. Co. 

(“Itochu”), and Porteous. The main U.S. purchasers are distributors who resell threaded rod 

along with many other fastening products. These distributors/purchasers tend to focus on 

specific industry segments, such as electrical, plumbing, general construction, etc. The end 

users to whom these distributors of threaded rod sell constitute a wide variety of firms in the 

commercial construction industry. For example, end-user purchasers of threaded rod are firms 

that install sprinkler systems, hang pipes for plumbing or electrical conduit, install HVAC 

ductwork, install structural tie-downs, and provide basic industrial installation and repair 

services.

Apparent U.S. consumption of threaded rod totaled approximately *** million pounds 

($*** million) in 2013. Currently, six firms are known to produce threaded rod in the United 

4 Petitioners reported that Tycoons Worldwide Group is by far the largest producer in Thailand. 

Hearing transcript, p.89 (Waite) and conference transcript, p. 79 (Waite) and p. 90 (Logan); and 

Petitioners’ postconference brief, Exh. 1, p. 1.

I-3

 
States. U.S. producers’ U.S. shipments of threaded rod totaled *** million ($*** million) in 

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

percent by value. U.S. imports from subject sources totaled *** million ($*** million) in 2013

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

value. U.S. imports from nonsubject sources totaled *** million ($*** million) in 2013 and 

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

SUMMARY DATA AND DATA SOURCES

A summary of data collected in these investigations is presented in appendix C, table C1. Except as noted, U.S. industry data are based on questionnaire responses of five firms that 

accounted nearly all of U.S. production of threaded rod during 2013. U.S. imports are based on 

official statistics as there are several larger importers that did not provide questionnaire 

responses.

5

PREVIOUS AND RELATED INVESTIGATIONS

Threaded rod has been the subject of one prior antidumping duty investigation in the 

United States. On March 5, 2008, Vulcan filed an antidumping duty petition against imports of 

threaded rod from China. Following an affirmative determination by Commerce, on February 

27, 2009, the Commission determined that the U.S. threaded rod industry was materially 

injured by reason of imports of threaded rod from China.6 Commerce issued an antidumping 

duty order on Chinese imports of threaded rod in October 2008, with margins ranging from 

55.16 percent to 206.00 percent. The final results of the first administrative review were 

published on November 4, 2011, with margins of 0.37 percent for one company (RMB Fasteners 

Ltd.), 55.16 percent for seven companies, and 206.00 percent for the China-wide rate. On 

November 9, 2012, the final results of the second administrative review were published, with 

margins of 19.68 percent for one company (RMB Fasteners Ltd.) and 206.00 percent for the 

China-wide rate. On November 5, 2013, the final results of the third administrative review were 

published, with a margin of 19.54 percent for two companies (RMB/IFI Group and Zhejiang New 

Oriental Fastener Co., Ltd), and 206.00 percent for the China-wide rate.7

5 Petitioners reported that the majority of imports of threaded rod covered under the scope of these 

investigations are imported under 7318.15.5056 of the 2013 U.S. harmonized tariff schedule (“HTS”) and 

that the majority of merchandise entered under this provision is covered merchandise. Hearing 

transcript, p. 78 (Waite) and conference transcript, pp. 38 (Magrath) and 39-41 (Waite). 6 Certain Steel Threaded Rod from China, Inv. No. 731-TA-1145 (Final), USTIC Publication 4070, April 

2009, p. 3. 7 Certain Steel Threaded Rod from the People’s Republic of China: Notice of Antidumping Duty Order, 

70 FR 17154, April 14, 2009. Certain Steel Threaded Rod from the People’s Republic of China: Final 

Results and Final Partial Rescission of Antidumping Duty Administrative Review, 76 FR 68400, November 

I-4

 

(continued...)
NATURE AND EXTENT OF SUBSIDIES AND SALES AT LTFV

Subsidies

On December 19, 2013, Commerce published a notice in the Federal Register of its 

preliminary determination of countervailable subsidies for producers and exporters of threaded 

rod from India.

8 Table I-1 presents Commerce’s findings of subsidization of threaded rod in 

India.

Table I-1

Threaded rod: Commerce’s preliminary subsidy determination with respect to imports from India

Entity

Preliminary countervailable subsidy 

margin (percent)

Mangal Steel Enterprises Ltd. 8.13

Babu Exports 38.98

All others 8.13

Source: 78 FR 76815, December 19, 2013.

Sales at LTFV

On March 14, 2014, Commerce published a notice in the Federal Register of its final

determination of sales at LTFV with respect to imports from Thailand.

9 Table I-2 presents

Commerce’s dumping margins with respect to imports of product from Thailand.

Table I-2

Threaded rod: Commerce’s final weighted-average LTFV margins with respect to imports from 

Thailand

Producer/Exporter

Final dumping margin 

(percent)

Tycoons Worldwide Group (Thailand) Public Co., Ltd. 74.90

All others 68.41

Source: 79 FR 14476, March 14, 2014.

4, 2011. Certain Steel Threaded Rod from the People’s Republic of China: Final Results and Final Partial 

Rescission of Antidumping Duty Administrative Review; 2010–2011, 77 FR 67332, November 9, 2012. 

Certain Steel Threaded Rod From the People’s Republic of China; Final Results of Third Antidumping Duty 

Administrative Review; 2011–2012, 78 FR 66330, November 5, 2013.

8 Steel Threaded Rod From India: Preliminary Affirmative Countervailing Duty Determination and 

Alignment of Final Determination With Final Antidumping Determination, 78 FR 76815, December 19, 

2013

9 Steel Threaded Rod from Thailand: Final Determination of Sales at Less Than Fair Value and 

Affirmative Final Determination of Critical Circumstances, 79 FR 14476, March 14, 2014.

I-5

 

(...continued)
On February 18, 2014, Commerce published a notice in the Federal Register of its 

preliminary determination of sales at LTFV with respect to imports from India.

10 Table I-3

presents Commerce’s dumping margins with respect to imports of product from India.

Table I-3

Threaded rod: Commerce’s preliminary weighted-average LTFV margins with respect to imports 

from India

Producer/Exporter

Preliminary dumping margin 

(percent)

Mangal Steel Enterprises., Ltd. 8.63

Babu Exports 119.87

All others 8.63

Source: 79 FR 9164, February 18, 2014.

THE SUBJECT MERCHANDISE

Commerce’s scope

Commerce has defined the scope of this investigation as follows:11

Certain threaded rod, bar, or studs, of carbon quality steel, having a solid, 

circular cross section, of any diameter, in any straight length, that have 

been forged, turned, cold-drawn, cold-rolled, machine straightened, or 

otherwise cold-finished, and into which threaded grooves have been 

applied. In addition, the steel threaded rod, bar, or studs subject to this 

investigation are nonheaded and threaded along greater than 25 percent 

of their total length. A variety of finishes or coatings, such as plain oil 

finish as a temporary rust protectant, zinc coating (i.e., galvanized, 

whether by electroplating or hot-dipping), paint, and other similar finishes 

and coatings, may be applied to the merchandise. Included in the scope of 

this investigation are steel threaded rod, bar, or studs, in which: (1) iron 

predominates, by weight, over each of the other contained elements; (2) 

the carbon content is 2 percent or less, by weight; and (3) none of the 

elements listed below exceeds the quantity, by weight, respectively

indicated:

10 Steel Threaded Rod from India: Preliminary Determination of Sales at Less Than Fair Value, 

Affirmative Preliminary Determination of Critical Circumstances, in Part, and Postponement of Final 

Determination, 79 FR 9164, February 18, 2014. 11 Steel Threaded Rod From Thailand: Final Determination of Sales at Less Than Fair Value and 

Affirmative Final Determination of Critical Circumstances, 79 FR 14476, March 14, 2014.

I-6

 
• 1.80 percent of manganese, or

• 1.50 percent of silicon, or

• percent of copper, or

• 0.50 percent of aluminum, or

• 1.25 percent of chromium, or

• 0.30 percent of cobalt, or

• 0.40 percent of lead, or

• 1.25 percent of nickel, or

• 0.30 percent of tungsten, or

• 0.012 percent of boron, or

• 0.10 percent of molybdenum, or

• 0.10 percent of niobium, or

• 0.41 percent of titanium, or

• 0.15 percent of vanadium, or

• 0.15 percent of zirconium.

Tariff treatment

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

to the Commission indicates that the merchandise subject to these investigations is classifiable 

in subheading 7318.15.50, a provision for threaded steel studs, and primarily imported under 

statistical reporting number 7318.15.5056 of the 2013 HTS.12

THE PRODUCT

Description and applications13

The subject product is carbon steel rod threaded along greater than 25 percent of its 

length (figure I-1). This product is primarily used in commercial construction applications to 

suspend support systems for electrical conduit, pipes for plumbing, HVAC ductwork, sprinkler 

systems, etc. Normally, one end of the threaded rod is fastened to the ceiling and the other end 

is fastened to the support that is holding the pipes or ductwork or sprinkler system (figure I-2). 

12 Threaded rod may also be imported under statistical reporting numbers 7318.15.5051, 

7318.15.5090, and 7318.15.2095 depending on constituent materials and whether it is continuously 

threaded; subheading 7318.15.20 covers bolts and bolts imported with their nuts and washers.

13 Unless otherwise indicated, information in this section is taken from the conference transcript, pp. 

16-18 (Logan) and the hearing transcript, pp. 14-18 (Logan).

I-7

 
Figure I-1

Threaded rods

Source: All America Threaded Products, http://www.aatprod.com/, accessed March 25, 2014. 

Figure I-2.

Threaded rod in a piping support system

Source: American Fire Sprinkler Association, Sprinkler Age magazine, cover photograph, June 2013, 

http://www.firesprinkler.org/sprinkleragesite/archives.htm , accessed March 25, 2014. The arrows 

superimposed on the photograph indicate a threaded rod.

I-8
Other applications include structural tie-downs in earthquake and hurricane restraint 

systems for roofing, headless screws and general fasteners, and bolts to join pipe joints in the 

waterworks industry. The product is also used for basic industrial repairs. Often, the threaded 

rod is cut on site to the required length. 

The great majority of threaded rod is made from low carbon steel14 and threaded along 

its entire length. Rod threaded along its entire length is a versatile product as it can be cut to 

the needed length on site. A small share of the U.S. threaded rod market is accounted for by 

threaded rod which is threaded only on one end or both ends, but not in the middle. Such 

products are usually ordered for specific applications where the customer knows the exact 

length that is required. Although threaded rod is produced in various diameters and lengths, 

about 60 percent of the U.S. market for low carbon steel threaded rod is accounted for by rod 

three-eighths inches in diameter. The great majority of threaded rod in the U.S. market is of rod 

with diameters of three-eighths inches and greater; Vulcan estimates that threaded rod with 

diameter less than three-eighths inches accounts for less than 10 percent of the U.S. market.15

Standard threaded rod lengths are two feet, three feet, six feet, 10 feet, and 12 feet. 

Manufacturing processes16

The primary raw material used in the production of the subject product is low carbon 

steel wire rod or low carbon steel bar for larger diameters.17 The production process is the 

same for either raw material.

14 Low-carbon steel is defined by the petitioners as carbon steel with a carbon level at or below that 

specified in grade SAE 1018, i.e. 0.18 percent carbon or less. Threaded rod made of medium- and highcarbon steel reportedly accounts for less than 3 percent of U.S. threaded rod production and are 

included in the threaded rod product scope. Petitioners’ postconference brief, exh. 1, p. 11. Low-carbon 

steel is easier to cut than carbon steel with higher levels of carbon. Threaded rod made from alloy or 

stainless steel is outside the scope of these investigations and is used in applications demanding heat 

resistance, high strength, or corrosion resistance, such as for the automotive, aerospace, and oil and gas 

industries. Carbon steel threaded rod cannot be used in these applications. Petitioners’ prehearing 

brief, p. 4. 15 Hearing transcript, p. 38 (Logan).

16 Unless otherwise indicated, information in this section is from the conference transcript, pp. 14-16, 

(Logan) and the hearing transcript, pp. 14-16 (Logan). Although this section describes Vulcan’s 

manufacturing process, the manufacturing process is similar for all producers worldwide. Conference 

transcript, pp. 47-48 (Logan). 17 During the preliminary phase of these investigations, Porteous , a U.S. importer, stated that U.S. 

producers do not make threaded rod in sizes below 3/8 inches in diameter. Porteous’ postconference 

brief, p. 5. In the final phase of these investigations, U.S. producers testified that they produce threaded 

rod in sizes below 3/8 inches in diameter. Hearing transcript, p. 14 (Logan) and p. 22 (Broderick). Also, 

U.S. producers reported sales of domestically-produced 1⁄4 inch diameter threaded rod (product 5) 

throughout the 2011-13 period. See Part V of the report. Porteous has not participated in the final 

phase of these investigations.

I-9

 
The production process begins with the removal of surface scale18 from the wire rod or 

bar which is then cold drawn, straightened, and cut to length. Cold drawing and straightening 

the wire rod ensures that it is round and properly sized in terms of the desired diameter. Next, 

the wire rod is fed through a threading machine, which forms the threaded grooves along the 

rod’s length by a process known as thread rolling, which pushes the steel out of the valleys and 

into peaks, forming the threaded grooves. Finally, the threaded rod is either coated with a plain 

oil finish in the threading process or is galvanized using either zinc plating or a hot-dip 

galvanizing process. In the U.S. market, most threaded rod is zinc plated and the coating does 

not blend into the underlying material. In the hot dip process, the steel is dipped into molten 

zinc and the zinc actually bonds chemically with the steel. In other words, the zinc penetrates 

the steel and this physical bond between the zinc and the steel provides greater corrosion 

resistance than the zinc plating process. Hot-dipped galvanized threaded rod accounts for a 5-

10 percent share of the U.S. market.19

DOMESTIC LIKE PRODUCT ISSUES

No issues with respect to domestic like product have been raised in these investigations. 

For the purposes of its determinations in the preliminary phase of these investigations, the 

Commission found “a single domestic like product, coextensive with the scope.”20 21 Petitioners 

argue, as they did in the preliminary phase of these investigations, that the Commission should 

define the domestic like product to be coextensive with the definition of the scope of the 

subject merchandise.

22 Respondent Porteous, for the purposes of the preliminary phase

investigations, did not dispute the Petitioners’ proposed definition of the domestic like 

product.23 Respondents have not provided any comments on the definition of domestic like 

product in these final phase investigations.

18 Scale is the oxide of iron that forms on the surface of steel after heating and occurs, unless 

preventative measures are taken, after the wire rod manufacturing process. 

19 Hearing transcript, p. 21 (Broderick).

20 Certain Steel Threaded Rod from India and Thailand, Inv. No. 701-TA-498 and 731-TA-1213-1214 

(Preliminary), USTIC Publication 4420, August 2013, p. 9. 21In the earlier investigation of steel threaded rod from China, the Commission also found a single 

domestic like product coextensive with the scope of the investigation. Certain Steel Threaded Rod from 

China, Inv. No. 731-TA-1145 (Final), USTIC Publication 4070, April 2009, p. 6. 22 Petition p. I-14 and Petitioners’ postconference brief, p. 5. Petitioners did not comment on 

domestic like product in the comments on the draft questionnaires.

23 Porteous’ postconference brief, p. 2. Respondents did not provide comments on the draft 

questionnaires.

I-10

 
II‐1

PART II: SUPPLY AND DEMAND INFORMATION

U.S. MARKET CHARACTERISTICS

Although threaded rod has a variety of applications and uses, its primary uses are in

commercial construction, where it is cut to different lengths, depending on the application.

Threaded rod has many uses—to support electrical conduit, pipes for plumbing, HVAC

ductwork, and sprinkler pipes for fire protection systems; as structural tie downs in

earthquakes and hurricane restraints for roofing; as headless screws in general fastener

applications; for bolting together pipe joints in the waterworks industry; for basic industrial

repairs; and for joint restraint systems for underground piping.1

Threaded rod is manufactured in various diameters and lengths, and can have several

different finishes applied.2 According to Petitioners, most of the threaded rod in the U.S.

market is zinc plated, with hot‐dipped galvanized threaded rod accounting for about 7 to 10

percent of the market.3 Most responding producers and importers indicated that there had

been no significant changes in product range, product mix, or marketing since January 2011.4  

U.S. PURCHASERS  

The Commission sent purchasers’ questionnaires to 131 companies believed to have

purchased threaded rod since 2011. Questionnaire responses were received from 34

purchasers, with 33 reporting that they had purchased threaded rod since 2011. Thirty

responding purchasers reported that they were distributors, three characterized themselves as

end users, and three reported being a “manufacturer” of some type (some firms provided more

than one response). Of the responding firms, the two largest U.S. purchasers of threaded rod in

terms of quantity in 2013 were ***.

 

1 Petition, p. I‐9. 2 Certain Steel Threaded Rod from China, Inv. No. 731‐TA‐1145 (Final), USTIC Publication 4070, April

2009, p. II‐1.

3 Hearing transcript, p. 15 (Logan) and conference transcript, pp. 15, 57 (Logan). 4 One producer (***) reported changes, adding that since it ***.” Three importers indicated changes

and one added that it ***, and another that dumping duties and exchange rates had altered its

purchasing patterns.
II‐2

CHANNELS OF DISTRIBUTION

The large majority of U.S. producers’ and importers’ U.S. shipments of threaded rod are

sold to distributors (table II‐1).5  Petitioners also stated that threaded rod is sold almost

exclusively sold through distributors.6 Petitioners explained that threaded rod is initially

purchased primarily by distributors of threaded rod, who are reselling threaded rod as one of

many other fastening products. In addition, Petitioners explained that starting in the late 1960s

and 1970s, “master distributors” emerged that will buy mass quantities from manufacturers to

sell to smaller distributors, which tend to focus on specific industry segments, such as electrical,

plumbing, general construction, etc.7 End users to whom the distributors of threaded rod sell

constitute a wide variety of firms in the commercial construction industry. For example, end‐

user purchasers of threaded rod are firms that install sprinkler systems, hang pipes for

plumbing or electrical conduit, install HVAC ductwork, install structural tie‐downs, and provide

basic industrial installation and repair services.8 According to importer Porteous, “threaded rod

with coil threads is a relatively new product that is sold to the concrete distribution trade and

not through normal threaded rod distribution channels.”9

Table II-1 

Threaded rod: U.S. producers’ and importers’ U.S. shipments, by sources and channels of 

distribution, 2011-13 

* * * * * * *

 

5 Importer ***.

6 Petition, pp. I‐13, I‐14. According to Petitioners, a substantial amount of imported subject

merchandise is imported through master distributors. Hearing transcript, p. 19 (Logan), pp. 22 ‐23

(Broderick), and conference transcript, p. 54 (Logan). 7 Conference transcript, pp. 51‐53 (Logan).

8 Petitioners add that “carbon steel threaded rod cannot be used in critical applications which have

more demanding performance requirements. For example, carbon steel threaded rod cannot be used in

applications that require heat resistance, high‐strength, or corrosion resistance, such as for the

automotive, aerospace, and oil and gas industries.” Petitioners’ postconference brief, p. 4.

9 Porteous postconference brief, p. 5.
II‐3

GEOGRAPHIC DISTRIBUTION

Most of the responding U.S. producers reported selling threaded rod to all regions of

the contiguous United States (table II‐2). Most responding importers of threaded rod from India

reported selling to at least three regions, with seven selling to all regions of the contiguous

United States. About half of the responding importers of threaded rod from Thailand reported

selling to three or more regions of the United States.

Three U.S. producers shipped more than 75 percent of their sales between 101 and

1,000 miles of their production facility, while one shipped more than 80 percent of its sales

within 100 miles. Most importers reported shipping threaded rod from their storage facilities.  

Most responding importers reported shipping at least 50 percent of their product within 100

miles of their U.S. point of shipment with many of these reporting shipping at least 75 percent

within 100 miles of their U.S. point of shipment. A number of responding importers reported

selling most of their product between 101 and 1,000 miles; and none reported shipping at least

50 percent of their product over 1,000 miles of their U.S. point of shipment.

Table II-2 

Threaded rod: Geographic market areas in the United States served by U.S. producers and 

importers, by number of responding firms 

Region U.S. producers 

U.S. importers 

from India 

U.S. importers 

from Thailand 

Northeast 4 12 4

Midwest 4 12 4

Southeast 4 15 5

Central Southwest 3 14 5

Mountains 4 10 7

Pacific Coast 5 12 8

Other1 3 7 3

 

Present in all continental regions (except 

other) 3 7 3

Responding Firms 5 24 9

 1 All other U.S. markets, including AK, HI, PR, and VI, among others. 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐4

SUPPLY AND DEMAND CONSIDERATIONS

U.S. supply

Domestic production

Based on available information, U.S. producers of threaded rod have the ability to

respond to changes in demand with moderate‐to‐large changes in the quantity of shipments of

U.S.‐produced threaded rod to the U.S. market. The main contributing factors to the moderate‐

to‐high degree of responsiveness of supply are the availability of unused capacity and the

existence of some inventories.

Petitioners identified six U.S. producers: All American, All‐Ohio, Bay Standard, Conklin &

Conklin, Interstate, and Vulcan. Vulcan is the largest domestic producer.10  

Industry capacity

Domestic capacity utilization increased slightly from *** percent in 2011 to *** percent

in 2013, driven by small and similar increases in both production and capacity. This relatively

low level of capacity utilization suggests that U.S. producers may have substantial capacity to

increase production of threaded rod in response to an increase in prices. Petitioners reported

that the “U.S. industry alone has more than enough capacity to satisfy domestic demand.”11

According to respondent Porteous, “the U.S. industry does not produce hot‐dipped galvanized

threaded rod in sufficient quantities to satisfy demand.”12 Porteous also added that “domestic

producers do not produce threaded rod in sizes below 3/8 inches in diameter.”13

Alternative markets

U.S. producers *** suggesting that U.S. producers have ***, ability to shift shipments

between the U.S. market and other markets in response to price changes.  

 

10 Petition, p. I‐2, I‐4. The Commission received questionnaire responses from five of the six identified

U.S. producers. See Part III for more information. 11 Petitioners’ postconference brief, p. 13. 12 Porteous postconference brief, p. 4.

13 Porteous postconference brief, p. 5. Vulcan representatives reported that the firm produces

“diameters under one‐quarter of an inch, which are called machine screw sizes, and up to two and a half

inches in diameter.” In addition, All America representatives reported that “All America produces and

sells the full range of threaded rod and stud products in terms of diameter, length, finish in metallurgy,

including high volumes of low carbon steel.” Hearing transcript, p. 38 (Logan) and conference transcript,

p. 14 (Logan) and p. 23 (Broderick).
II‐5

Inventory levels

U.S. producers’ inventories, as a ratio to total shipments, increased slightly from ***

percent in 2011 to *** percent in 2013. These inventory levels suggest that U.S. producers have

an ability to respond to changes in demand with changes in the quantity shipped from

inventories.  

Production alternatives

Some U.S. producers stated that they could switch production from other products to

threaded rod, although some producers indicated that product shifting is limited. Other

products that producers reportedly can produce on the same equipment as threaded rod

include alloy steel, stainless steel and double and single end threaded rod, anchor bolt and stab

bolts, threaded rod manufactured in other grades, and threaded rod “not covered in the

scope.” U.S. producers identified several factors affecting their ability to shift production

between alternate products, including qualified workers, “product sales and market size,”

physical size of the facilities, and overall production capacity.

Supply constraints

U.S. producers did not report any supply constraints.

Subject imports

According to Petitioners, production capacity of producers in India and Thailand has

increased “significantly” during the POI, and “there are more than 70 producers/exporters of

{threaded rod} in India and Thailand.”14 Petitioners also argued that “Imports from India and

Thailand are focused on the high volume products, what we would call our bread and butter

products.”15

 

14 Petition, p. I‐26. Petitioners also estimated that in 2010, imports of threaded rod from India and

Thailand were 27.3 million pounds, and had increased by 57 percent to 42.8 million pounds in 2012.

Petition, p. I‐12.

15 Hearing transcript, p. 27 (Iverson), p. 45 (Waite), and conference transcript, p. 25 (Broderick).
II‐6

Subject imports from India16

Based on available information, producers of threaded rod from India have the ability to

respond to changes in demand with moderate‐to‐large changes in the quantity of shipments of

threaded rod to the U.S. market. The main contributing factor to the moderate‐to‐high degree

of responsiveness of supply is the availability of unused capacity.

Industry capacity

Capacity utilization for responding Indian producers decreased slightly from 85.4

percent in 2011 to 79.5 percent in 2013, and is projected to decrease to 76.9 and 79.1 percent

in 2014 and 2015, respectively. This moderate level of capacity utilization suggests that Indian

producers may have some capacity to increase production of threaded rod in response to an

increase in prices. According to Porteous, the “market for {hot‐dipped galvanized threaded rod}

is serviced by subject countries, particularly India, and is sold to different customers in the

United States, particularly customers that want threaded rod for use in high corrosion

environments such as marine markets, at higher prices.”17

Alternative markets

Indian producers exported between *** percent and *** percent of total shipments to

the U.S. market, and from *** to *** percent to non‐U.S. markets, and less than 1 percent to

their domestic market. About 12 to 18 percent of their shipments were internal

consumption/transfers.  These data indicate that Indian producers have some ability to shift

shipments of threaded rod between the U.S. market and other markets.

Inventory levels

For Indian producers of threaded rod, inventories as a ratio to total shipments

decreased from approximately 16.3 percent in 2011 to 10.9 percent in 2013. These inventory

levels suggest that Indian producers have an ability to respond to changes in demand with

changes in the quantity shipped from inventories.

 

16 Petitioners’ economist identified 69 Indian producers and exporters of threaded rod. Conference

transcript, p. 35 (Magrath). They estimated that 10 to 12 of these producers account for the vast

majority of exports to the United States. They also stated that Indian producers export all types of

threaded rod, but generally do not produce the larger diameter sizes. Conference transcript, pp. 46, 59,

90 (Logan). The Commission received responses from 14 Indian producers of threaded rod in the

preliminary phase and nine producers in the final phase of these investigations.  The nine producers in

the final phase of the investigations represented at least 80 percent of reported imports of steel

threaded rod from India during the period of investigation. 17 Porteous postconference brief, p. 4.
II‐7

Production alternatives

Almost all responding Indian producers indicated that they did not produce any other

products on the same machinery or equipment. One Indian producer (***) reported that it also

produced stainless steel and alloy steel threaded rod on the same machinery or equipment as

threaded rod and indicated the ability to shift production between stainless steel and alloy steel

threaded rod (as well as metric‐sized rods) and threaded rod in response to a change in price.18

Supply constraints

Almost all importers of threaded rod from India reported no supply constraints. Two

importers identified antidumping duty laws as a supply constraint.  

Subject imports from Thailand19

The Commission did not receive any questionnaire responses from Thai producers of

threaded rod.  

Industry capacity

Petitioners stated that Tycoons Worldwide Group, a Thai manufacturer of steel wire

rod, “has reported publically that its capacity to produce threaded rod is 40 million pounds

annually.”20

Supply constraints

None of the importers of threaded rod from Thailand reported any supply constraints.

Nonsubject imports

The largest sources of nonsubject imports during 2011‐13 were China and Taiwan.

Combined, these countries accounted for approximately 36 percent (by quantity) of total

 

18  In the preliminary phase, two Indian producers indicated the ability to shift production between

threaded rod and double ended rods. One firm (***) also indicated that it had not yet manufactured this

product.

19 Petitioners’ economist stated that they had identified 18 Thai producers and exporters of threaded

rod. Conference transcript, p. 35 (Magrath). Petitioners added that one of these producers accounts for

the vast majority of exports to the United States. They also stated that Thai producers export only plain

and zinc plated threaded rod, and while their product range covers a majority of the market, they do not

produce steel threaded rod with a diameter greater than 1 1/8 inches in diameter. Hearing transcript,

pp. 26‐27 (Iverson) and conference transcript, pp. 46, 59, 90 (Logan).

20 Petitioners’ postconference brief, p. 31. They added that this capacity represents twice the volume

of U.S. imports of threaded rod from Thailand in 2012. Petitioners’ postconference brief, Ex. 1, p. 10.
II‐8

imports in 2013, although imports from Taiwan declined from approximately 17 percent of total

imports (by quantity) in 2011 to about 12 percent of total imports (by quantity) in 2013.  

U.S. demand

Based on available information, the overall demand for threaded rod is likely to change

relatively little in response to changes in price. The main contributing factors are the very

limited substitutes and the relatively small cost share of threaded rod in the most common end‐

use products, though this varies considerably across end‐use and definition of end product

(e.g., sprinkler system vs. commercial building).

Petitioners identified commercial construction as the primary use for threaded rod.21

They also stated that “In general, total demand for threaded rod has increased solidly over the

period as the industry recovered from the deep recession.”22

End uses

U.S. demand for threaded rod depends on the demand for U.S.‐produced downstream

products. Reported end uses include commercial construction; hanging of pipe, sprinkler

systems, conduit, electrical, lights, struts, and HVAC units; tie downs and fastening; concrete

anchors; aluminum door and window manufacturing; embeds and extenders; and general

framing and anchoring.

Business cycles

Four of five responding U.S. producers (including ***) and almost one‐third of

responding importers and purchasers indicated that the market was subject to business cycles

or conditions of competition. U.S. producers indicated that the threaded rod demand generally

follows the general economic business cycle and the business cycle of the commercial

construction industry. One producer noted that activity was slowest in November and

December. Two U.S. producers reported changes in business cycles or conditions of

competition; changes include lower prices driven by increased competition and overseas

supply, and improvement in the economy since the recession. U.S. importers and purchasers

also identified seasonal business cycles associated with the construction market and general

economic conditions.23 Some of these responding importers and purchasers also reported

changes in the business cycles or conditions of competition, including improvements in the

construction industry, a decrease in price from competitors, increased price and margin

 

21 Petition, p. I‐9 and hearing transcript, p. 17 (Logan). 22 Conference transcript, p. 28 (Magrath).

23 In general, U.S. importers reported increased demand in the spring and summer months, and

decreased demand in fall and winter months. One importer added that the market was “highly

competitive,” and another added that threaded rod was a “worldwide commodity” influenced by “labor,

steel prices and currency fluctuations.”
II‐9

pressure from U.S. producers, “strong Indian currency,” China not being a viable source due to

the antidumping order, and less overall business driving down prices.   

Demand trends

Overall demand for threaded rod depends on the demand for its end uses, of which

most are connected to nonresidential/commercial construction activity. Private nonresidential

construction spending increased by almost 40 percent between January 2011 and December

2013 (see figure II‐1).

Most producers, importers, and purchasers indicated that demand either fluctuated or

did not change since January 1, 2011 and about an equal number indicated that demand

increased or decreased (see table II‐3). Most firms cited changes in the economy or the

construction market and several indicated that demand is unstable or difficult to predict. The

one U.S. producer (***) that indicated that demand had increased characterized the change in

demand as a “slight increase.” Most firms indicated that demand outside the United States had

not changed during this period. Most purchasers indicated that final demand for their products

had not changed since January 1, 2011.

Petitioners noted that demand for threaded rod increased as activity in the

nonresidential sector improved.  They indicate that the 15 percent increase in annual private

nonresidential construction between 2011 and 2013 parallels the increase in apparent

consumption.  Petitioners also cited inelastic demand of threaded rod as reason why changes in

supply, including the price of inputs such as steel wire rod would have little or no effect on

demand for threaded rod.24

Substitute products

Three of five responding U.S. producers and almost all U.S. importers and purchasers

indicated that there were no substitutes for threaded rod. Substitute products cited by a few

importers and purchasers were speed link/tie wire, double end machine rods, wire hanger,

rebar, heat treaded carbon rods, bolts, stainless steel wire rods, concrete anchors, and “DE

stud” for hanging pipe. The purchaser reporting double end machine rods as a substitute

indicated that changes in the price of double end machine rods affects the price for threaded

rod.  No other firm indicated that changes in the price of these substitutes affected the price of

threaded rod. According to Petitioners, there is “little interchangeability between {the subject

steel threaded rod} and other types of threaded rod due to engineering and design

requirements, end‐user preferences, and pricing differences.”25  

 

24 Petitioners’ posthearing brief, Exhibit 1, Posthearing responses to questions from the Commission

on behalf of the Petitioners, p. 2.

25 Petition, p. I‐14.
II‐10

Figure II-1 

Private, nonresidential construction: Private, nonresidential construction spending (seasonallyadjusted, annual rate, reported monthly), January 2011—December 2013

Source: U.S. Census Bureau at http://www.census.gov/construction/c30/c30index.html, retrieved July 6, 

2013. 

Table II-3 

Threaded rod: Firms’ perceptions regarding changes in U.S. demand since January 1, 2011, by 

number of responding firms 

Item 

Number of firms reporting 

Increase No change Decrease Fluctuate 

Demand inside the United States: 

 U.S. producers 1 1 0 3

Importers 4 4 5 10

Purchasers 6 11 5 9

Demand outside the United States: 

 U.S. producers 0 2 0 0

Importers 1 7 1 2

Purchasers 1 7 1 3

Demand for purchasers' final 

products: 

 Purchasers 2 5 0 0

 Source: Compiled from data submitted in response to Commission questionnaires.
II‐11

Cost share

Most responding firms did not identify cost shares with associated end uses, with some

noting that the information was “unknown” or that they were distributors/wholesalers. Of the

identified end uses, threaded rod accounted for a highly variable share of the cost of the end‐

use products in which it is used. Some reported end uses and cost shares were as follows:

commercial construction, pipe hanging, and electrical (1 to 20 percent); cable spools (2

percent), hanging lights, pipes, struts, HVAC units (10 to 20 percent), concrete anchors (10

percent), galvanized, zinc plated, and plain studs (60 percent), embeds (85 percent), concrete

ties (95 percent), and general framing and anchoring (80 percent).

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported threaded 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 data, staff believes

that there is high degree of substitutability between domestically produced threaded rod and

threaded rod imported from subject sources.  

Lead times

Most responding U.S. producers ship at least 80 percent of threaded rod from inventory

(including ***), with lead times ranging from 2 to 7 days; lead times for product that is

produced to order ranged from 5 to 30 days.26 Most U.S. responding producers typically

arranged for transportation.  

The vast majority of importers sold at least 90 percent of sales from inventory at lead

times ranging from 1 to 7 days27 (with most 5 days or less); several importers sold 100 percent

of product that is produced to order with almost all reporting lead times ranging from 75 to 128

days; and only a few importers indicated that 100 percent of subject product was sold from the

foreign manufacturers’ inventory with lead times ranging from 90 to 120 days.28 Most

importers generally arrange for transportation.

 

26 ***.

27 One firm indicated a lead time of 90 days.

28 One importer selling with a “7 day” lead time produced to order and one reported selling from

foreign inventory with a 2 day lead time.
II‐12

Knowledge of country sources

As shown in table II‐4, most purchasers and their customers at most “sometimes” make

purchasing decisions based on the producer or country of origin. Of the four purchasers that

reported that they “always” make decisions based on the producer, firms cited consistent

source of supply, quality, and delivery performance.

Table II-4 

Threaded rod: Purchasing decisions based on producer and country of origin 

Decision Always Usually Sometimes Never 

Purchases based on producer: 

 Purchaser's decision 4 2 9 16

Purchaser's customer's decision 1 1 8 22

Purchases based on country of 

origin: 

 Purchaser's decision 5 2 12 12

Purchaser's customer's decision 0 2 15 14

 Source: Compiled from data submitted in response to Commission questionnaires. 

Factors affecting purchasing decisions

Available information indicates that purchasers consider a variety of factors when

purchasing threaded rod. While price, quality, and availability were cited most frequently as

being top factors in their purchase decisions, other factors such as product consistency, and

reliability of supply were cited just as often as being very important purchasing factors.  

Price was most frequently cited by purchasers as their top factor in purchasing threaded rod

with 18 of 33 responding purchasers indicating that price was the most important factor in

considering a purchase and 30 of 33 purchasers indicating that price was one of the three most

important purchasing factors (see table II‐5). All but four responding purchasers indicated that

price is a very important factor in purchasing threaded rod (see table II‐6). Twenty‐six of 32

responding purchasers indicated that they either “sometimes” or “usually” purchase the lowest

price threaded rod.

Seven of 33 purchasers indicated that quality was the most important factor used in

purchasing decisions and 22 of 33 purchasers indicated that it was one of the three most

important factors. Twenty‐seven of 33 responding purchasers indicated that quality meeting

industry standards was a very important factor in their purchases. Twenty‐five of 31 purchasers

indicated that quality exceeding industry standards was at least a somewhat important

purchasing factor. U.S. purchasers identified various principal factors they considered in

determining the quality of threaded rod including: quality of threads and finish; appearance;

packaging; meeting specifications; coating available and consistency; threading quality,

consistency, integrity, gauge, precision and pitch; lack of rust; straightness; properly formed

ends; quality of hot dipped galvanized; lack of galling; and meeting standards.
II‐13

Table II-5 

Threaded rod: Ranking of factors used in purchasing decisions as reported by U.S. purchasers, 

by number of reporting firms 

Factor First Second Third Total 

Availability 2 14 5 21

Customer care 0 0 1 1

Delivery 0 3 1 4

Extension of credit 0 0 1 1

Payment terms 0 1 1 2

Price 18 4 8 30

Quality 7 8 7 22

Range of product line 0 0 1 1

Service 0 1 0 1

Traditional suppliers 3 0 0 3

Other1 3 2 5 10

1 Other factors include: “stock in Dallas, TX,” “manufactured in the United States,” “contract in place,” 

“overall stock growth,” “quality, availability,” freight costs,” “operational efficiency,” “packaging,” “what tube 

looks like-packaging,” and “supplier.” 

Source: Compiled from data submitted in response to Commission questionnaires. 

Table II-6 

Threaded rod: Importance of purchase factors, as reported by U.S. purchasers, by number of 

responding firms 

Factor 

Number of firms reporting 

Very Important 

Somewhat 

important Not important 

Availability 28 4 0

Delivery terms 21 11 0

Delivery time 24 8 0

Diameter less than 3/8 inch 4 10 17

Discounts offered 12 12 8

Extension of credit 12 8 11

Minimum qty requirements 9 13 10

Packaging 12 14 6

Price 28 4 0

Product consistency 29 1 1

Product range 12 18 1

Quality exceeds industry standards 7 18 6

Quality meets industry standards 27 6 0

Reliability of supply 26 6 0

Technical support/service 10 14 8

Threading type 15 13 4

Type of finish 22 10 0

U.S. transportation costs 16 12 4

 Source: Compiled from data submitted in response to Commission questionnaires. 
II‐14

Supplier certification

More than one‐half of responding purchasers indicated that they require that their

suppliers be certified for at least some of their purchases. Certification procedures vary by

purchaser with some purchasers testing samples, administering supplier surveys, and visiting

and auditing vendors. Most suppliers reported that certification takes from one week up to 2

months, although some purchasers report shorter certification periods or certification taking up

to 160 days. No purchasers reported that a supplier failed in its attempt to be certified to

supply threaded rod since 2011.

Importance of purchasing domestic product

Most responding purchasers reported that purchasing U.S.‐produced product was not

required for their purchasing decisions.  One purchaser (***) reported that all of its purchases

were required by law to be produced in the United States and 10 purchasers reported that 25

percent or less of their purchases were required by law to be produced in the United States.  

Many purchasers reported that they were not able to determine the country of origin of the

threaded rod that they purchase.

Comparison of U.S.‐produced and imported threaded rod

At least one‐half of responding purchasers reported that U.S. and imported product

were comparable in terms of all characteristics (table II‐7). As shown in table II‐8, all responding

U.S. producers indicated that product from all country sources was “always” or “frequently”

interchangeable with that from all other country sources. One producer (***) noted that the

“only reason it would not be interchangeable is if it was being used in a U.S. government job

that required that it be domestic product.”29

Almost all responding importers and two‐thirds of purchasers indicated that U.S.‐

produced and Indian‐produced, and U.S.‐produced and Thai‐produced threaded rod can

“always” or “frequently” be used in the same applications. A few responding importers

indicated that interchangeability was affected if domestic product was required. One importer

(***) indicated that U.S. and Thai product were “sometimes” interchangeable, noting that

Thailand has limited or no capability to produce hot dipped galvanized (“HDG”) rod, which

limits its ability to participate in market applications where HDG is required. One importer

noted that “low carbon steel rods are the same no matter where in the world they are

produced.”  The purchasers that indicated that U.S. and Indian and U.S. and Thai product are

“sometimes” interchangeable cited customer preferences, quality, and availability.

 

29 Petitioners also noted that “such Buy America requirements protect very little of our product.”

Hearing transcript, p. 88 (Upton) and conference transcript, p. 25 (Broderick).
II‐15

Table II-7 

Threaded rod: Purchasers’ comparisons between U.S.-produced and imported product

Factor 

Number of firms reporting 

U.S. vs. India U.S. vs. Thailand US vs. Nonsubject 

S C I S C I S C I 

Availability 7 11 1 2 9 2 5 11 1

Delivery terms 6 13 0 1 11 1 4 12 1

Delivery time 8 10 1 3 9 1 8 9 0

Diameter less than 3/8 inch 2 15 1 2 10 1 3 13 1

Discounts offered 2 14 2 1 11 1 2 14 1

Extension of credit 0 17 0 0 12 0 1 15 0

Minimum qty requirements 6 12 0 2 11 0 5 12 0

Packaging 2 16 1 1 11 1 2 14 1

Price1 0 12 7 2 7 4 1 8 8

Product consistency 3 16 0 1 12 0 3 14 0

Product range 3 15 1 2 11 0 3 14 0

Quality exceeds industry standards 2 18 0 1 12 0 3 14 0

Quality meets industry standards 3 16 0 1 12 0 2 15 0

Reliability of supply 5 13 1 3 10 0 5 12 0

Technical support/service 4 14 1 1 10 2 4 12 1

Threading type 2 17 0 1 12 0 3 14 0

Type of finish 4 15 0 1 11 1 2 14 1

U.S. transportation costs 4 14 1 2 11 0 4 12 1

 1A 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. 
II‐16

Table II-8 

Threaded rod: Perceived interchangeability between threaded rod produced in the United States 

and in other countries, by country pairs 

Country pair 

U.S. producers U.S. importers U.S. purchasers 

A F S N A F S N A F S N 

United States vs. India 2 3 0 0 13 8 0 0 10 6 4 0

United States vs. Thailand 1 2 0 0 4 5 1 0 7 3 4 0

India vs. Thailand 2 1 0 0 7 2 0 0 9 2 2 0

United States vs. China 2 2 0 0 7 4 0 0 8 4 4 1

United States vs. Taiwan 1 2 0 0 5 5 1 0 8 5 3 1

United States vs. Other 1 0 0 0 3 2 0 0 4 3 3 0

India vs. China 3 1 0 0 8 2 0 0 10 3 2 1

India vs. Taiwan 2 1 0 0 7 4 0 0 10 3 2 1

India vs. Other 1 0 0 0 3 2 0 0 6 2 1 0

Thailand vs. China 2 1 0 0 7 2 0 0 9 2 4 1

Thailand vs. Taiwan 2 1 0 0 7 3 0 0 10 3 3 1

Thailand vs. Other 1 0 0 0 4 1 0 0 6 2 2 0

China vs. Taiwan 2 1 0 0 5 4 1 0 9 2 4 1

China vs. Other 1 0 0 0 4 1 0 0 6 1 3 0

Taiwan vs. Other 1 0 0 0 4 1 0 0 6 2 2 0

 Note.—A=Always, F=Frequently, S=Sometimes, N=Never.

Source: Compiled from data submitted in response to Commission questionnaires. 

All responding importers and most responding purchasers indicated that Indian and Thai

product are “always” or “frequently” interchangeable. Almost all importers indicated that U.S.

threaded rod and product from nonsubject countries can “always” or “frequently” be used in

the same applications. One importer (***) reported that U.S. and Taiwan product were only

“sometimes” interchangeable, noting that Taiwan has limited or no capability to produce HDG

rod, which limits its ability to participate in market applications where HDG is required.  

As shown in table II‐9, all responding U.S. producers and most importers and purchasers

indicated that differences other than price were “sometimes” or “never” a significant factor in

comparing U.S. product to either Indian or Thai product. One U.S. producer commented that

lead times and quality matter to some customers, and another noted that it could manufacture

to ASTM F 1554 specifications and “test to compliance with lot certifications as requested.”  

Importers’ and purchasers’ reported differences other than price included that lead

times and quality matter to some customers; that “Indian manufacturers tend to have slower

deliveries {and it preferred} to purchase from non‐Indian manufacturers;” that “quality,

reliability, lead time for India are all poor;” that Thailand has limited HDG capability and limited

capability to meet A36 specification requirements; that no domestic producer supplies specialty

rod to its region; that freight costs and inventory are factors; that with the extension of the  
II‐17

Table II-9 

Threaded rod: Significance of differences other than price between threaded rod produced in the 

United States and in other countries, by country pairs 

Country pair 

U.S. producers U.S. importers U.S. purchasers 

A F S N A F S N A F S N 

United States vs. India 0 0 3 2 4 1 6 10 5 2 6 4

United States vs. Thailand 0 0 2 1 0 0 3 7 1 2 3 4

India vs. Thailand 0 0 2 1 0 1 1 7 1 2 2 4

United States vs. China 0 0 2 1 0 0 2 9 1 2 6 5

United States vs. Taiwan 0 0 2 1 0 0 2 9 1 2 5 5

United States vs. Other 0 0 0 1 0 0 0 4 1 1 4 2

India vs. China 0 0 2 1 0 1 1 7 1 2 4 4

India vs. Taiwan 0 0 2 1 0 1 2 8 1 2 3 5

India vs. Other 0 0 0 1 0 0 0 4 1 1 2 2

Thailand vs. China 0 0 2 1 0 0 1 8 1 2 3 5

Thailand vs. Taiwan 0 0 2 1 0 0 1 8 1 2 3 5

Thailand vs. Other 0 0 0 1 0 0 0 4 1 1 3 2

China vs. Taiwan 0 0 2 1 0 0 3 7 1 2 3 5

China vs. Other 0 0 0 1 0 0 0 4 1 1 3 2

Taiwan vs. Other 0 0 0 1 0 0 0 4 1 1 3 2

 Note.--A = Always, F = Frequently, S = Sometimes, N = Never. 

Source: Compiled from data submitted in response to Commission questionnaires. 

supply chain there is more risk introduced; and that U.S. producers do not provide private label,

have lower quality paper tube, and use flatbed trucks instead of pallets.

Only three of 29 responding purchasers indicated that certain grades, types, or sized of

threaded rod are available from a single source. These three purchasers cited higher grade and  

tensile strengths are sometimes only available from one source and that certain “exotic”

materials are only available from one or two sources.  No responding purchaser indicated it was

unable to procure any grades, types, or sizes of U.S.‐produced threaded since January 1, 2011.

In comparing U.S., Indian and Thai product to nonsubject country product, all

responding producers and most responding importers and purchasers indicated that

differences other than price were “sometimes” or “never’ significant.  

Petitioners stated that “threaded rod is sold primarily on the basis of price, and there

are no significant quality differences between threaded rod made by one manufacturer versus

another;”30 and that threaded rod is a “commodity type product, and price is the primary factor

that customers consider making in their purchasing decisions.”31 They added availability and

“prompt delivery” are relevant non‐price factors.32

 

30 Hearing transcript, p. 7 (Waite), p. 66 (Logan), and conference transcript, p. 6 (Waite).

31 Petitioners’ postconference brief, p. 9.

32 Conference transcript, p. 95 (Broderick).
II‐18

More than 75 percent of responding purchasers reported that domestically‐produced

product “always” met minimum quality specifications and all responding purchasers indicated

that it at least “usually” met minimum quality specifications. Just over one‐half of purchasers

indicated that threaded rod imported from India and Thailand “always” met minimum quality

specifications and the rest of the purchasers indicated that it at least “usually” met minimum

quality specification.   

ELASTICITY ESTIMATES  

This section discusses elasticity estimates; parties provided no comments on the

elasticities in the prehearing staff report.

U.S. supply elasticity

The domestic supply elasticity33 for threaded rod measures the sensitivity of the

quantity supplied by U.S. producers to changes in the U.S. market price of threaded 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 threaded rod. Analysis of these factors earlier indicates that the U.S. industry is likely

to be able to somewhat increase or decrease shipments to the U.S. market; an estimate in the

range of 3 to 5 is suggested.  

U.S. demand elasticity

The U.S. demand elasticity for threaded rod measures the sensitivity of the overall

quantity demanded to a change in the U.S. market price of threaded 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 threaded rod in the production of

any downstream products. Based on the available information, the aggregate demand for

threaded rod is likely to be inelastic; a range of ‐0.25 to ‐0.50 is suggested.  

Substitution elasticity

The elasticity of substitution depends upon the extent of product differentiation

between the domestic and imported products.34  Product differentiation, in turn, depends upon

 

33 A supply function is not defined in the case of a non‐competitive market.

34 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.
II‐19

such factors as quality (e.g., chemistry, appearance, et cetera) and conditions of sale (e.g.,

availability, sales terms/ discounts/ promotions, et cetera). Based on this information, the

elasticity of substitution between U.S.‐produced threaded rod and imported threaded rod is

likely to be in the range of 4 to 6.

PART III: U.S. PRODUCERS’ PRODUCTION, SHIPMENTS, AND 

EMPLOYMENT

The Commission analyzes a number of factors in making injury determinations (see 19 

U.S.C. §§ 1677(7)(B) and 1677(7)(C)). Information on the subsidies was presented in Part I of 

this report and information on the volume and pricing of imports of the subject merchandise is 

presented in Part IV and Part V. Information on the other factors specified is presented in this 

section and/or Part VI and (except as noted) is based on the questionnaire responses of five

firms that accounted for the vast majority of U.S. production of threaded rod during 2013.

U.S. PRODUCERS

The Commission sent U.S. producer questionnaires to six firms based on information 

contained in the petition. Five firms provided useable data on their productive operations.1

Staff believes that these responses represent the nearly all of U.S. production of threaded rod.

Table III-1 lists U.S. producers of threaded rod, positions on the petition, production 

locations, and shares of total production during the period examined. 

Table III-1

Threaded rod: U.S. producers’ ownership, related and/or affiliated firms, and share of total 

production, 2011-13

Firm

Position on 

petition

Production 

location(s)

Share of 

production 

(percent)

All America Threaded Products Support

Denver CO;

Indianapolis IN;

Lancaster PA ***

All Ohio *** Cleveland, OH ***

Bay Standard Manufacturing, Inc. Support Brentwood, CA ***

Interstate Threaded Products *** Dallas, TX ***

Vulcan Threaded Products Inc. Support Pelham, AL ***

Total 100.0

 Source: Compiled from data submitted in response to Commission questionnaires.

No U.S. producers are related to foreign producers of the subject merchandise in India 

or Thailand. As discussed in greater detail below, three U.S. producers directly imported the 

subject merchandise and two purchased threaded rod from other U.S. firms.

1 The remaining U.S. producer listed in petition *** is believed to be a small manufacturer with 

limited threaded rod production. Petition, Exh.I-1, declaration regarding production of steel threaded 

rod by the U.S. industry, p. 5

III-1

 
U.S. PRODUCTION, CAPACITY, AND CAPACITY UTILIZATION

Table III-2 and figure III-1 present U.S. producers’ production, capacity, and capacity 

utilization. U.S. capacity for threaded rod increased *** percent from 2011 to 2013. One firm, 

*** reported increases in capacity and one firm *** reported decreases in capacity during 

2011-13. *** increased capacity in ***, due to ***.

2 ***, which accounted for *** of the 2013 

decline in capacity, ***.

3

U.S. production of threaded rod increased *** percent from 2011 to 2013. All but ***

reported increased production in each year from 2011 to 2013. Similarly, capacity utilization for 

all but *** increased in each year over the same period.

Table III-2

Threaded rod: U.S. producers’ production, capacity, and capacity utilization, 2011-13

* * * * * * *

Figure III-1

Threaded rod: U.S. producers’ production, capacity, and capacity utilization, 2011-13

* * * * * * *

Reported constraints in the manufacturing process for the U.S. producers include ***.

All producers except *** reported production of other products (***) on the same 

equipment and machinery used to produce threaded rod. The volume of these products was

generally comparatively smaller than subject threaded rod, accounting for between ***

percent and *** percent of total quantity of production. ***.

4 Vulcan reported that shifting 

from threaded rod to a threaded product not covered by the scope is mostly a matter of 

changing the type of dies used in the production process.5 Bay Standard reported that it ***.

6

U.S. PRODUCERS’ U.S. SHIPMENTS AND EXPORTS

Table III-3 presents U.S. producers’ U.S. shipments, export shipments, and total 

shipments. Domestic commercial shipments accounted for *** of U.S. producers’ shipments of 

threaded rod during the period of investigation. The quantity of U.S. producers’ commercial 

shipments increased *** percent, by quantity and *** percent by value from 2011 to 2013. U.S. 

2 Email from ***, February 20, 2014.

3 Email from ***, February 19, 2014. 4 ***. 5 Conference transcript, pp. 49-50 (Logan).

6 Email from ***, February 20, 2014.

III-2

 
shipments for all firms but *** increased each year between 2011 and 2013. No firm reported 

internal consumption, transfers to related firms, or export shipments during the period of 

investigation.

Table III-3

Threaded rod: U.S. producers’ U.S. shipments, exports shipments, and total shipments, 2011-13

* * * * * * *

U.S. PRODUCERS’ INVENTORIES

Table III-4 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 over the period 

examined. U.S. producers’ inventories increased by *** percent between 2011 and 2013.

Inventories for all U.S. producers except *** increased each year during the period of 

investigation. The ratio of inventories to production and to shipments was relatively stable over 

the period of investigation for ***, although *** had one of the lowest ratios while *** had one 

of the highest ratios.

7

Table III-4

Threaded rod: U.S. producers’ inventories, 2011-13

* * * * * * *

U.S. PRODUCERS’ IMPORTS AND PURCHASES

U.S. producers’ imports and purchases of threaded rod are presented in table III-5. All 

U.S. producers except *** directly imported threaded rod from subject countries and three

firms *** purchased threaded rod from domestic firms.8 9 10 Subject imports by ***.

11 Of the 

three firms that purchased threaded rod from domestic producers, only *** reported total 

purchases equivalent to greater than *** percent of their production, and neither of these 

firms relied on a single firm for its purchases.

7 ***. 8 ***. 9 ***. 10 ***. 11 ***.

III-3

 
Table III-5

Threaded rod: U.S. producers’ U.S. production, imports and purchases, 2011-13

* * * * * * *

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

Table III-6 shows U.S. producers’ employment-related data during the period of 

investigation. In the aggregate, U.S. producers reported a small decline in the number of 

production and related workers (“PRWs”) and unit labor costs during 2011-2013, while other 

employment categories showed increases over the period.

12

Table III-6

Threaded rod: Average number of production and related workers, hours worked, wages paid to 

such employees, hourly wages, productivity, and unit labor costs, 2011-13

* * * * * * *

12 ***.

III-4

 
PART IV: U.S. IMPORTS, APPARENT U.S. CONSUMPTION, AND MARKET 

SHARES

U.S. IMPORTERS

The Commission issued importer questionnaires to 35 firms believed to be importers of 

subject product, as well as to all U.S. producers of threaded rod.1 Usable questionnaire 

responses were received from 28 companies, representing *** percent of total imports from 

India and *** percent of total imports from Thailand between 2011 and 2013 under HTS 

subheading 7318.15.5056, a “basket” category that the petitioners estimate mostly correspond 

to the threaded rod covered by the scope of these investigations.2 Seven companies reported 

importing from China, representing *** percent of total imports from China between 2011 and 

2013 under HTS subheading 7318.15.5056. Seven companies reported importing from Taiwan, 

representing *** percent of total imports from Taiwan between 2011 and 2013 under HTS 

subheading 7318.15.5056. Table IV-1 lists all responding U.S. importers of threaded rod from 

India, Thailand, and other sources, their locations, and their shares of U.S. imports, during 

2011-13.

1 The Commission issued questionnaires to those firms identified in the petition, 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 from India or Thailand, or more than five percent 

of imports from all other sources under HTS statistical reporting numbers 7318.15.5056, 7318.15.5051, 

and 7318.15.5090, in 2011-13. 2 These firms also represent approximately 3.4 percent and 0.6 percent of total imports from India 

and Thailand, respectively, under statistical reporting numbers 7318.15.5051 and 7318.15.5090 under 

which threaded rod may also be imported.

IV-1

 
Table IV-1

Threaded rod: U.S. importers by source, 2011-13

Firm Headquarters

Share of imports by source (percent)

Subject Nonsubject

India Thailand China Taiwan

All 

Other

All America Threaded Products Denver, CO *** *** *** *** ***

All Ohio Threaded Rod Co Cleveland, OH *** *** *** *** ***

All Tools Inc San Juan, PR *** *** *** *** ***

B&F Fastener Supply Ramsey, MN *** *** *** *** ***

Bay Standard Manufacturing, Inc. Brentwood, CA *** *** *** *** ***

Bowie Bolt & Supply, Inc Bridgeville, DE *** *** *** *** ***

Brighton-Best International, Inc. Long Beach, CA *** *** *** *** ***

Building Material Distributors, Inc Galt, CA *** *** *** *** ***

Chun Yu Works (USA) Chino, CA *** *** *** *** ***

Ct Tech Corporation Pomona, CA *** *** *** *** ***

Dc International Inc Wilsonville, OR *** *** *** *** ***

Edwards & West Inc. T/A Divspec Kenilworth, NJ *** *** *** *** ***

Elite Components Sugarland, TX *** *** *** *** ***

Endries International Brillion, WI *** *** *** *** ***

Fastenal Company Winona, MN *** *** *** *** ***

Hardware Plus, Inc. Caguas, PR (

2

) *** *** *** ***

Industrial Products Company Lynchburg , VA *** *** *** *** ***

International Fasteners, Inc. Tampa, FL *** *** *** *** ***

Interstate Threaded Products Dallas, TX *** *** *** *** ***

Itochu Building Products Co Inc New York, NY *** *** *** *** ***

Kirkwood Industries, Inc. Woodinville, WA *** *** *** *** ***

Porteous Fastener Company

Santa Fe Springs, 

CA *** *** *** *** ***

Rapid Cool Trading USA Blacksburg, VA *** *** *** *** ***

San Juan Distributors, San Juan, PR *** *** *** *** ***

Timberline Fasteners

Commerce City, 

CO *** *** *** *** ***

Titan Fastener Products, Inc Brunswick, GA *** *** *** *** ***

U S Castings Waco, TX *** *** *** *** ***

Vertex Distribution Attleboro, MA *** *** *** *** ***

Total 100.0 100.0 100.0 100.0 100.0

1 Less than 0.05 percent.

2 Reported in pieces not pounds.

Source: Compiled from data submitted in response to Commission questionnaires.

IV-2
U.S. IMPORTS

Table IV-2 presents data for U.S. imports of threaded rod from India, Thailand, China, 

Taiwan, Malaysia, and all other sources based on official import statistics. The quantity of U.S. 

imports from India fluctuated during the period of investigation, but declined overall by less 

than 1 million pounds (2.5 percent). From 2011 to 2012, the quantity of U.S. imports from India 

decreased by 5.7 million pounds (21.6 percent).3 From 2012 to 2013, the quantity of U.S. 

imports from India increased by 5.1 million pounds (24.4 percent). The value of U.S. imports 

from India followed a similar trend, ending 3.4 percent lower in 2013 compared with 2011. The 

quantity of U.S. imports from Thailand increased 12.2 million pounds (145.6 percent) from 2011 

to 2013. The value of U.S. imports from Thailand followed a similar trend, ending 147.1 percent 

higher in 2013 compared with 2011. The volume of U.S. imports from nonsubject countries 

increased 6.7 percent from 2011 to 2013.

The share of U.S. imports, by quantity, accounted for by India declined 7.4 percentage 

points between 2011 and 2013, while Thailand’s share of U.S. imports increased by 12.9

percentage points over the same period. Imports from nonsubject sources were 5.5 percentage 

points lower.

The ratio of U.S. imports from India to U.S. production declined *** percentage points 

between 2011 and 2013. The ratio of U.S. imports from Thailand to U.S. production increased 

*** percentage points between 2011 and 2013.

3 Petitioners, in their posthearing brief, noted what they view as a “significant discrepancy” in the 

official Commerce statistics insofar as it concerns 2012 import quantities from India. Petitioners note 

that during the preliminary phase of these investigations 14 Indian producers reported 2012 total 

exports of 28,177,000 pounds of steel threaded rod while official Commerce statistics show imports of 

20,724,000 pounds of Indian threaded rod for the same period. Consequently, petitioners urge the 

Commission “to place greater weight on the data from the {foreign producer} questionnaire responses 

for shipments and entries from India in 2012.” Table C-2 presents summary data using the 2012 data 

from the 14 questionnaire responses for imports from India. Petitioners’ posthearing brief, Attachment 

A, pp. 1-3. 

IV-3

 
Table IV-2

Threaded rod: U.S. imports by source, 2011-13

Item

Calendar year

2011 2012 2013

Quantity (1,000 pounds)

U.S. imports from.--

 India 26,442 20,724 25,785

Thailand 8,401 22,087 20,630

 Subtotal, subject sources 34,844 42,810 46,415

China 13,819 19,510 20,081

Taiwan 11,550 10,712 9,631

 Malaysia 3,903 3,997 3,487

All other 3,674 2,621 1,946

Subtotal, nonsubject sources 32,945 36,840 35,146

Total U.S. imports 67,789 79,651 81,561

Value (1,000 dollars)

U.S. imports from.--

 India 14,690 12,166 14,193

Thailand 4,256 11,099 10,519

 Subtotal, subject sources 18,946 23,265 24,712

China 11,458 16,205 16,010

Taiwan 8,085 7,543 6,602

 Malaysia 2,727 3,232 3,616 

All other 5,042 5,030 3,379 

Subtotal, nonsubject sources 27,311 32,009 29,606

Total U.S. imports 46,257 55,275 54,318

Unit value (dollars per pound)

U.S. imports from.--

 India 0.56 0.59 0.55

Thailand 0.51 0.50 0.51

 Subtotal, subject sources 0.54 0.54 0.53

China 0.83 0.83 0.80

Taiwan 0.70 0.70 0.69

Malaysia 0.70 0.81 1.04

All other 1.37 1.92 1.74

Subtotal, nonsubject sources 0.83 0.87 0.84

Total U.S. imports 0.68 0.69 0.67

 Table continued on next page.

IV-4
Table IV-2—Continued

Threaded rod: U.S. imports by source, 2011-13

Item

Calendar year

2011 2012 2013

Share of quantity (percent)

U.S. imports from.--

 India 39.0 26.0 31.6

Thailand 12.4 27.7 25.3

 Subtotal, subject sources 51.4 53.7 56.9

China 20.4 24.5 24.6

Taiwan 17.0 13.4 11.8

Malaysia 5.8 5.0 4.3

All other 5.4 3.3 2.4

Subtotal, nonsubject sources 48.6 46.3 43.1

Total U.S. imports 100.0 100.0 100.0

Share of value (percent)

U.S. imports from.--

 India 31.8 22.0 26.1

Thailand 9.2 20.1 19.4

 Subtotal, subject sources 41.0 42.1 45.5

China 24.8 29.3 29.5

Taiwan 17.5 13.6 12.2

Malaysia 5.9 5.8 6.7

All other 10.9 9.1 6.2

Subtotal, nonsubject sources 59.0 57.9 54.5

Total U.S. imports 100.0 100.0 100.0

Ratio to U.S. production (percent)

U.S. imports from.--

 India *** *** ***

Thailand *** *** ***

 Subtotal, subject sources *** *** ***

China *** *** ***

Taiwan *** *** ***

Malaysia *** *** ***

All other *** *** ***

Subtotal, nonsubject sources *** *** ***

Total U.S. imports *** *** ***

 Note.—Because of rounding, figures may not add to the totals shown.

 Source: Compiled from official Commerce statistics.

IV-5
CRITICAL CIRCUMSTANCES

On February 18, 2014, Commerce issued a preliminary determination that “critical 

circumstances” exist with respect to imports from India of threaded rod in the countervailing 

duty investigation, with exception of imports from Mangal.

4 In this investigation, if both 

Commerce and the Commission make affirmative final critical circumstances determinations, 

certain subject imports from India may be subject to countervailing duties retroactive by 90 

days from February 18, 2014, the effective date of Commerce’s preliminary affirmative 

countervailing duty determination. Table IV-3 and figure IV-1 present U.S. imports from India, 

excluding Mangal, by month from January 2013 to December 2013. U.S. imports from India, 

excluding Mangal, were *** percent higher in the six month period (July 2013 to 

December2013) following the filing of the petition than in the preceding six month period 

(January 2013 to June2013).5

Table IV-3

Threaded rod: U.S. imports from India, excluding Mangal, by month, January 2013 to December 

2013

* * * * * * *

Figure IV-1

Threaded rod: U.S. imports from India, excluding Mangal, by month, January 2013 to December 

2013

* * * * * * *

4

79 FR 9162, February 18, 2014, referenced in appendix A. When petitioners file timely allegations of 

critical circumstances, Commerce examines whether there is a reasonable basis to believe or suspect 

that (1) either there is a history of dumping and material injury by reason of dumped imports in the 

United States or elsewhere of the subject merchandise, or the person by whom, or for whose account, 

the merchandise was imported knew or should have known that the exporter was selling the subject 

merchandise at LTFV and that there was likely to be material injury by reason of such sales; and (2) there 

have been massive imports of the subject merchandise over a relatively short period. 5 In the petitioners’ posthearing brief, petitioners suggest that pre- and post-petition periods of four 

to five months, rather than the six-month comparison periods, would be more appropriate due to 

Commerce not extending its preliminary determination. Petitioners’ posthearing brief, Exhibit 1, pp. 14-

16. Using proprietary Customs data, subject imports from India, excluding Mangal, increased by ***

percent during the four-month period (July 2013 to October 2013) following the filing of the petition 

compared to the four-month period (March 2013 to June 2013) previous to the petition being filed and 

by *** percent during the five-month period (July 2013 to November 2013) following the filing of the 

petition compared to the five-month period (February 2013 to June 2013) previous to the petition being 

filed. 

IV-6

 
On February 18, 2014, Commerce issued a preliminary determination that “critical 

circumstances” exist with respect to imports from India of threaded rod in the antidumping 

duty investigation, with exception of imports from Mangal and firms receiving the “All others” 

preliminary margin.

6 In this investigation, if both Commerce and the Commission make 

affirmative final critical circumstances determinations, certain subject imports from India may 

be subject to antidumping duties retroactive by 90 days from February 18, 2014, the effective 

date of Commerce’s preliminary affirmative antidumping determination. Table IV-4 and figure 

IV-2 present U.S. imports from India, excluding Mangal and firms receiving the “All others” rate, 

by month from January 2013 to December 2013. U.S. imports from India, excluding imports 

from Mangal and firms receiving the “All others” rate, were *** percent higher in the six month 

period (July 2013 to December 2013) following the filing of the petition than in the preceding 

six month period (January 2013 to June 2013).7

Table IV-4

Threaded rod: U.S. imports from India, excluding Mangal and firms receiving the “All Others” rate, 

by month, January 2013 to December 2013

* * * * * * *

Figure IV-2

Threaded rod: U.S. imports from India, excluding Mangal and firms receiving the “All Others” rate,

by month, January 2013 to December 2013

 * * * * * * *

On December 31, 2013, Commerce issued a preliminary determination that “critical 

circumstances” exist with respect to imports from Thailand of threaded rod in the antidumping 

duty investigation8 In this investigation, if both Commerce and the Commission make 

affirmative final critical circumstances determinations, subject imports may be subject to 

antidumping duties retroactive by 90 days from December 31, 2013, the effective date of 

Commerce’s preliminary affirmative antidumping determination. Table IV-5 and figure IV-3 

6

79 FR 9164, February 18, 2014, referenced in appendix A. 7

As noted previously, petitioners suggest that pre- and post-petition periods of four to five months, 

rather than the six-month comparison periods, would be more appropriate due to Commerce not 

extending its preliminary determination. Petitioners’ posthearing brief, Exhibit 1, pp. 14-16. Subject 

importer from India with exception of imports from Mangal and firms receiving the “All others” 

increased by *** percent during the four-month period (July 2013 to October 2013) following the filing 

of the petition compared to the four-month period (March 2013 to June 2013) previous to the petition 

being filed and by *** percent during the five-month period (July 2013 to November 2013) following the 

filing of the petition compared to the five-month period (February 2013 to June 2013) previous to the 

petition being filed. 

8

78 FR 79670, December 31, 2013, referenced in appendix A.

IV-7

 
present U.S. imports from Thailand, by month from January 2013 to December 2013. U.S. 

imports from Thailand were 15.8 percent lower in the six month period (July 2013 to December 

2013) following the filing of the petition than in the preceding six month period (January 2013 

to June 2013).9

Table IV-5

Threaded rod: U.S. imports from Thailand, by month, January 2013 to December 2013

Period

Imports from Thailand

Quantity (1,000 pounds) Landed Duty-Paid Value (1,000 dollars)

2013:

 Jan 2,081 1,065

Feb 1,897 919

Mar 1,471 714

Apr 2,291 1,211

May 1,466 735

Jun1 1,997 1,003

Jul 2,260 1,169

Aug 4,634 2,429

Sep 1,898 961

Oct 636 312

Nov 0 0

Dec 0 0

Total 20,630 10,519

 1 The petition in this investigation was filed on June 27, 2013.

Source: Compiled from official import statistics.

9 As noted previously, petitioners suggest that pre- and post-petition periods of four to five months, 

rather than the six-month comparison periods, would be more appropriate due to Commerce not 

extending its preliminary determination. Petitioners’ posthearing brief, Exhibit 1, pp 14-16. Using official 

statistics from Department of Commerce, subject imports from Thailand increased by 30.5 percent 

during the four-month period (July 2013 to October 2013) following the filing of the petition compared 

to the four-month period (March 2013 to June 2013) previous to the petition being filed and by 3.4 

percent during the five-month period (July 2013 to October 2013) following the filing of the petition 

compared to the five-month period (February 2013 to June 2013) previous to the petition being filed. 

IV-8

 
Figure IV-3

Threaded rod: U.S. imports from Thailand, by month, January 2013 to December 2013

Source: Compiled from official import statistics.

Table IV-6 shows the imports and end-of-period inventories from Tycoon using 

questionnaire responses from eight reporting firms. Imports from Tycoon peaked in *** with 

approximately *** pounds imported. End-of-period inventories from imports from Tycoon 

peaked in *** with approximately *** pounds.

Table IV-6

Threaded rod: U.S. imports and end of period inventories from Tycoon, by month, December 2012

to December 20131

* * * * * * *

NEGLIGIBILITY

The statute requires that an investigation be terminated without an injury 

determination if imports of the subject merchandise are found to be negligible.10 Negligible 

10 Sections 703(a)(1), 705(b)(1), 733(a)(1), and 735(b)(1) of the Act (19 U.S.C. §§ 1671b(a)(1), 

1671d(b)(1), 1673b(a)(1), and 1673d(b)(1)).

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

4,500

5,000

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2013

Quantity (1,000 pounds)

U.S. imports from Thailand

IV-9

 
imports are generally defined in the Tariff Act of 1930, as amended, as imports from a country 

of merchandise corresponding to a domestic like product where such imports account for less 

than 3 percent of the volume of all such merchandise imported into the United States in the 

most recent 12-month period for which data are available that precedes the filing of the 

petition or the initiation of the investigation. However, if there are imports of such merchandise 

from a number of countries subject to investigations initiated on the same day that individually 

account for less than 3 percent of the total volume of the subject merchandise, and if the 

imports from those countries collectively account for more than 7 percent of the volume of all 

such merchandise imported into the United States during the applicable 12-month period, then 

imports from such countries are deemed not to be negligible. Imports from India accounted for 

27.9 percent and imports from Thailand accounted for 28.9 percent of total imports of 

threaded rod by quantity during June 2012 – May 2013.

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. Issues concerning fugilibility and 

channels of distribution are addressed in Part II of this report. Additional information 

concerning geographical markets and simultaneous presence in the market is presented below. 

Presence in the market

With respect to simultaneous presence in the market, between January 2011 and 

December 2013, imports of threaded rod from India and Thailand entered the United States in 

every month, except in November and December 2013 when there were no imports from 

Thailand.

11 However, as shown in Figure IV-4, monthly volumes varied over time.

11 Department of Commerce’s official statistics (HTS 7318.15.5056).

IV-10

 
Figure IV-4

Threaded rod: U.S. imports, monthly entries into the United States, by sources, January 2011-

December 2013

Source: Compiled from official Commerce statistics (HTS 7318.15.5056).

Geographical markets

With respect to geographic markets, U.S. imports of threaded rod from India primarily 

entered the United States through the Customs districts of (1) Houston-Galveston, Texas; (2) 

Los Angeles, California; (3) New York, New York; and (4) Savannah, Georgia. U.S. imports of 

threaded rod from Thailand primarily entered the United States through the Customs districts 

of (1) Los Angeles, California; (2) Savannah, Georgia; (3) New York, New York; and (4) Seattle, 

Washington. U.S. imports of threaded rod from all other sources primarily entered the United 

States through the Customs districts of (1) Houston-Galveston, Texas; (2) Los Angeles, 

California; (3) Savannah, Georgia; (4) New York, New York; and (5) Chicago, Illinois.

APPARENT U.S. CONSUMPTION 

Table IV-7 and figure IV-5 presents data on apparent U.S. consumption and U.S. market 

shares for threaded rod over the period of investigation. Apparent U.S. consumption, by 

quantity, increased each year, ending *** percent higher than in 2011. 

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

4,500

5,000

2011 2012 2013

Quantity (1,000 pounds)

All Other Sources China India Taiwan Thailand

IV-11
Table IV-7

Threaded rod: U.S. shipments of domestic product, U.S. imports, and apparent U.S. consumption, 

2011-2013

Item

Calendar year

2011 2012 2013

Quantity (1,000 pounds)

U.S. producers' U.S. shipments *** *** ***

U.S. imports from.--

 India 26,442 20,724 25,785

Thailand 8,401 22,087 20,630

 Subtotal, subject sources 34,844 42,810 46,415

China 13,819 19,510 20,081

Malaysia 3,903 3,997 3,487

Taiwan 11,550 10,712 9,631

All other 3,674 2,621 1,946

Subtotal, nonsubject sources 32,945 36,840 35,146

Total U.S. imports 67,789 79,651 81,561

Apparent U.S. consumption *** *** ***

Value (1,000 dollars)

U.S. producers' U.S. shipments *** *** ***

U.S. imports from.--

 India 14,690 12,166 14,193

Thailand 4,256 11,099 10,519

 Subtotal, subject sources 18,946 23,265 24,712

China 11,458 16,205 16,010

Malaysia 2,727 3,232 3,616

Taiwan 8,085 7,543 6,602

All other 5,042 5,030 3,379

Subtotal, nonsubject sources 27,311 32,009 29,606

Total U.S. imports 46,257 55,275 54,318

Apparent U.S. consumption *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires and from official 

Commerce statistics.

Figure IV-5

Threaded rod: Apparent U.S. consumption, by sources, 2011-2013

* * * * * * *

U.S. MARKET SHARES 

U.S. market share data are presented in table IV-8. From 2011 to 2013, U.S. producers 

lost *** and *** percentage points of market share based on quantity and value, respectively.

From 2011 to 2013, U.S. imports from India lost *** percentage points of market share based 

on quantity and *** percentage points based on value. During the same period, U.S. imports 

IV-12
from Thailand gained *** percentage points based on quantity and *** percentage points 

based on value. 

Table IV-8

Threaded rod: U.S. consumption and market shares, 2011-2013

* * * * * * *

IV-13

PART V: PRICING DATA

FACTORS AFFECTING PRICES

Raw material costs

Threaded rod is made primarily from low-carbon steel wire rod or low-carbon steel bar.1

The main raw material used in the production of threaded rod is carbon steel wire rod; the wire 

rod is cold-drawn, straightened, cut to length, threaded, and then sometimes plated or

galvanized.2 Raw materials (including wire rod) accounted for approximately 65 percent of total 

cost of goods sold during 2011-13 (see Part VI for additional information). As seen in figure V-1, 

the price of carbon steel wire rod increased slightly during 2011, declined sharply in January 

2012, and then declined irregularly for the next two years. From January 2011 to January 2014, 

the price of low carbon steel wire rod declined by almost 18 percent.

Most U.S. producers and importers indicated that raw material costs have either 

fluctuated, been stable or slightly decreased since January 1, 2011, and that raw material costs 

have had little or no effect on their firm’s selling price during that period. Most firms anticipate 

at least a slight increase in raw material costs or are unable to predict a change in raw material 

costs. Several firms cited the antidumping investigation on wire rod imported from China as 

reason why prices may increase.

U.S. inland transportation costs

Most responding U.S. producers and importers reported that they typically arrange 

transportation to their customers. U.S. producers reported that their U.S. inland transportation 

costs ranged from 5 to 10 percent. Importer responses varied. Importers reported 

transportation costs ranging from 1 to 5 percent (9 importers), 6 to 10 percent (7 importers), 

and 10 to 20 percent (3 importers).3

 

1 Certain Steel Threaded Rod from China, Inv. No. 731-TA-1145 (Final), USTIC Publication 4070, April 

2009, p. II-1; hearing transcript, p. 14 (Logan) and conference transcript, p. 14 (Logan). 2 Certain Steel Threaded Rod from China, Inv. No. 731-TA-1145 (Final), USTIC Publication 4070, April 

2009, p. V-1; hearing transcript, pp. 14-15 (Logan) and conference transcript, pp. 14-15 (Logan).

3 A few importers reported higher transportation cost shares of 25 percent (1 firm) and more than 90 

percent (1 firm).

V-1 

 
Figure V-1 

Low carbon steel wire rod: Average monthly U.S. prices in dollars per hundredweight, January 

2011 to January 2014

Source: American Metal Market. 

PRICING PRACTICES

Pricing methods

U.S. producers and importers reported using transaction-by-transaction negotiations, 

contracts, set price lists, and other methods to set prices for threaded rod. As presented in 

table V-1, U.S. producers and importers sell primarily using transaction-by-transaction 

negotiations and contracts. Other pricing methods included cost plus, price match, or 

adjustment if “competitive situation dictates.” 

Most U.S. producers and importers reported selling the majority of threaded rod on the 

spot market (more than 60 percent of shipments for U.S. producers and more than 80 percent 

of shipments for importers) (table V-2). U.S. producers’ short-term contracts were for 3 to 12 

months, fixed price, and did not have meet-or-release provisions. Three of four producers did 

not allow for price renegotiation in their contracts. No U.S. producer reported using long-term 

contracts. While some importers sold threaded rod using short-term contracts, very few 

reported using long-term contracts. Importers’ short-term contracts were for 3 to 12 months, 

fixed quantity, and price or both. Only two of 13 importers reported having meet-or-release 

provisions. Six of 14 responding importers allow the price to be renegotiated in their short-term 

contracts.

V-2 
Table V-1 

Threaded rod: U.S. producers’ and importers’ reported price setting methods, by number of 

responding firms1 

Method U.S. producers U.S. importers

Transaction-by-transaction 4 23

Contract 3 10

Set price list 2 6

Other 1 3

 1 The sum of responses down will 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.

Table V-2 

Threaded rod: U.S. producers’ and importers’ shares of U.S. commercial shipments by type of 

sale, 2013

Type of sale

Share of commercial U.S. shipments (percent)

U.S. producers U.S. importers

Long-term contracts 0.0 0.2

Short-term contracts 34.0 13.4

Spot sales 66.0 86.3

 Note.--Because of rounding, figures may not add to the totals shown. 

Source: Compiled from data submitted in response to Commission questionnaires.

Sales terms and discounts

U.S. producers typically quote prices on a delivered and sometimes on an f.o.b. basis, 

with sales terms most often net 30 days. Although terms and discounts varied most U.S. 

producers offered quantity and/or annual volume discounts/rebates. Sixteen of 27 responding 

importers quote prices on a delivered basis, and the rest quote on an f.o.b. basis (one quotes 

on both an f.o.b. and delivered basis). Importers most often report sales terms most of net 30 

days, though several importers noted that terms vary by customer. Twenty of 27 responding 

importers offered no discount; the remaining importers offered a variety of discounts including, 

quantity (6 importers), annual volume (5 importers), and others (e.g., cost plus, price match, 

payment-terms discount, and transaction-by-transaction).

V-3 
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 threaded rod products shipped to unrelated 

U.S. customers during January 2011—December 2013. 

Product 1.-- Low-carbon steel fully threaded rod, electroplated with zinc, a 3⁄8 inch 

diameter (as measured from the top of the thread), in 10 foot lengths, in 

cardboard tubes.

Product 2.-- Low-carbon steel fully threaded rod, electroplated with zinc, a 3⁄8 inch 

diameter (as measured from the top of the thread), in 6 foot lengths, in 

cardboard tubes.

Product 3.-- Low-carbon steel fully threaded rod, electroplated, a 1⁄2-inch diameter (as 

measured from the top of the thread), in 10-foot lengths, in cardboard tubes.

Product 4.-- Low-carbon steel fully threaded rod, plain, 3⁄4 inch diameter (as measured 

from the top of the thread), 12 feet in length, in cardboard tubes.

Product 5.-- Low-carbon steel fully threaded rod, electroplated with zinc, 1⁄4 -inch 

diameter (as measured from the top of the thread), 10 feet in length, in 

cardboard tubes. 

Product 6.-- Low-carbon steel fully threaded rod, hot dipped galvanized, 5⁄8-inch 

diameter (as measured from the top of the thread), 12 feet in length, in 

cardboard tubes. 

Four U.S. producers and 22 importers4 provided usable pricing data for sales of the 

requested products, although not all firms reported pricing for all products for all quarters. 

Pricing data reported by these firms accounted for approximately *** percent of U.S. 

producers’ shipments of threaded rod, *** percent of subject imports from India, and *** 

percent of subject imports from Thailand overall during the period of investigation. Pricing data 

4 Price data provided by importers *** were not included in the following tables and charts. ***” 

Importer ***. Email from ***, July 19, 2013. ***. The majority (***) of Itochu imports were from ***

and a substantial amount *** of Fastenal imports were from ***. Price data reported by Itochu

accounted for about ***. Price data reported by Fastenal accounted for about ***. 

Price data for ***. 

V-4 

 
reported by importers of threaded rod from nonsubject countries accounted for approximately 

*** percent of imports from Taiwan and less than *** percent of imports from China overall 

during the period of investigation.

5

Price data for products 1-6 are presented in tables V-3 to V-8 and figure V-2. Nonsubject 

country prices are presented in Appendix D. Itochu and Fastenal price data are presented in 

Appendix E. 

Table V-3 

Threaded rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 11

and margins of underselling/(overselling), by quarters, January 2011-December 2013

* * * * * * *

Table V-4 

Threaded rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 21

and margins of underselling/(overselling), by quarters, January 2011-December 2013

Period

United States India Thailand

Price

($ per 

pound)

Quantity

(pounds)

Price

($ per 

pound)

Quantity

(pounds)

Margin

(percent)

Price

($ per 

pound)

Quantity

(pounds)

Margin

(percent)

2011:

Jan.-Mar. *** *** 0.60 524,867 *** *** *** ***

Apr.-June *** *** *** *** *** *** *** ***

July-Sept. *** *** *** *** *** *** *** ***

Oct.-Dec. *** *** *** *** *** *** *** ***

2012:

Jan.-Mar. *** *** 0.64 600,509 *** *** *** ***

Apr.-June *** *** 0.59 628,291 *** *** *** ***

July-Sept. *** *** 0.64 411,649 *** *** *** ***

Oct.-Dec. *** *** 0.64 441,773 *** *** *** ***

2013:

Jan.-Mar. *** *** 0.66 384,227 *** *** *** ***

Apr.-June *** *** 0.59 507,389 *** *** *** ***

July-Sept. *** *** 0.57 379,732 *** *** *** ***

Oct.-Dec. *** *** 0.51 522,967 *** *** *** *** 1 Product 2: Low-carbon steel fully threaded rod, electroplated with zinc, a 3⁄8 inch diameter (as measured 

from the top of the thread), in 6 foot lengths, in cardboard tubes.

Source: Compiled from data submitted in response to Commission questionnaires.

5 Vulcan accounted for *** percent of domestic pricing data. Importers Porteous and Elite ***. 

Importer Elite accounted for *** and importer Porteous accounted for ***. 

V-5 

 
Table V-5 

Threaded rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 31

and margins of underselling/(overselling), by quarters, January 2011-December 2013

Period

United States India Thailand

Price

($ per 

pound)

Quantity

(pounds)

Price

($ per 

pound)

Quantity

(pounds)

Margin

(percent)

Price

($ per 

pound)

Quantity

(pounds)

Margin

(percent)

2011:

Jan.-Mar. *** *** 0.60 364,540 *** *** *** ***

Apr.-June *** *** *** *** *** *** *** ***

July-Sept. *** *** *** *** *** *** *** ***

Oct.-Dec. *** *** *** *** *** *** *** ***

2012:

Jan.-Mar. *** *** 0.67 183,293 *** *** *** ***

Apr.-June *** *** 0.66 212,762 *** *** *** ***

July-Sept. *** *** 0.67 172,810 *** *** *** ***

Oct.-Dec. *** *** 0.68 129,853 *** 0.60 436,226 ***

2013:

Jan.-Mar. *** *** 0.64 253,708 *** *** *** ***

Apr.-June *** *** *** *** *** *** *** ***

July-Sept. *** *** 0.78 184,307 *** *** *** ***

Oct.-Dec. *** *** 0.72 178,793 *** *** *** *** 1 Product 3: Low-carbon steel fully threaded rod, electroplated, a 1⁄2-inch diameter (as measured from the 

top of the thread), in 10-foot lengths, in cardboard tubes.

Source: Compiled from data submitted in response to Commission questionnaires.

V-6 
Table V-6 

Threaded rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 41

and margins of underselling/(overselling), by quarters, January 2011-December 2013

Period

United States India Thailand

Price

($ per 

pound)

Quantity

(pounds)

Price

($ per 

pound)

Quantity

(pounds)

Margin

(percent)

Price

($ per 

pound)

Quantity

(pounds)

Margin

(percent)

2011:

Jan.-Mar. 0.58 238,578 *** *** *** *** *** ***

Apr.-June 0.59 247,716 *** *** *** *** *** ***

July-Sept. 0.61 272,962 *** *** *** *** *** ***

Oct.-Dec. 0.60 254,339 *** *** *** *** *** ***

2012:

Jan.-Mar. 0.62 222,494 *** *** *** *** *** ***

Apr.-June 0.63 333,650 0.95 8,682 (51.2) *** *** ***

July-Sept. 0.62 328,059 *** *** *** *** *** ***

Oct.-Dec. 0.61 248,005 *** *** *** *** *** ***

2013:

Jan.-Mar. 0.61 270,651 0.94 7,141 (53.3) *** *** ***

Apr.-June 0.61 234,338 *** *** *** *** *** ***

July-Sept. 0.59 285,025 *** *** *** *** *** ***

Oct.-Dec. 0.59 260,266 *** *** *** *** *** *** 1 Product 4: Low-carbon steel fully threaded rod, plain, 3⁄4 inch diameter (as measured from the top of the 

thread), 12 feet in length, in cardboard tubes.

Source: Compiled from data submitted in response to Commission questionnaires.

V-7 
Table V-7 

Threaded rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 51

and margins of underselling/(overselling), by quarters, January 2011-December 2013 

Period

United States India Thailand

Price

($ per 

pound)

Quantity

(pounds)

Price

($ per 

pound)

Quantity

(pounds)

Margin

(percent)

Price

($ per 

pound)

Quantity

(pounds)

Margin

(percent)

2011:

Jan.-Mar. *** *** *** *** *** *** *** ***

Apr.-June *** *** *** *** *** *** *** ***

July-Sept. *** *** *** *** *** *** *** ***

Oct.-Dec. *** *** *** *** *** *** *** ***

2012:

Jan.-Mar. *** *** 0.69 43,570 *** *** *** ***

Apr.-June *** *** 0.72 46,699 *** *** *** ***

July-Sept. *** *** 0.63 144,239 *** *** *** ***

Oct.-Dec. *** *** *** *** *** *** *** ***

2013:

Jan.-Mar. *** *** *** *** *** *** *** ***

Apr.-June *** *** *** *** *** 0.65 77,310 ***

July-Sept. *** *** 0.74 42,282 *** *** *** ***

Oct.-Dec. *** *** 0.68 51,247 *** *** *** *** 1 Product 5: Low-carbon steel fully threaded rod, electroplated with zinc, 1⁄4 -inch diameter (as measured 

from the top of the thread), 10 feet in length, in cardboard tubes.

Source: Compiled from data submitted in response to Commission questionnaires.

V-8 
Table V-8 

Threaded rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 61

and margins of underselling/(overselling), by quarters, January 2011-December 2013

* * * * * * *

Figure V-2 

Threaded rod: Weighted-average prices and quantities of domestic and imported product, by 

quarters, January 2011-December 2013

* * * * * * *

Price trends

In general, prices for threaded rod were mixed for domestic, Indian, and Thai product 

during January 2011-December 2013. Table V-9 summarizes the price trends, by country and by 

product. As shown in the table, changes in domestic prices were less than 5 percent, while 

changes in the prices of subject imports varied widely. 

Price comparisons

As shown in table V-10 and V-11, prices for threaded rod imported from India and 

Thailand were below those for U.S.-produced product in 58 of 142 instances; margins of 

underselling ranged from less than 1 percent to 39.2 percent. In the remaining 84 instances, 

prices for threaded rod from India and Thailand were between 0.1 and 220.9 percent above 

prices for the domestic product. Underselling is concentrated in product 5, the smallest

diameter of the six price products.

 

Petitioners argue that there are reporting errors and other anomalies in the pricing data 

reported by U.S. importers and indicate that these data are inconsistent with import AUVs and 

the lost sales and revenue data.6

 They contend that in some instances data was reported in 

incorrect units; data was provided for higher value products that aren’t price competitive; data 

was provided for products that importers indicate elsewhere that they don’t import; and that

importers that typically quote their prices on a delivered basis may have also reported their 

price data on a delivered basis.7

 If U.S. producers’ prices are compared to data provided by the 

two largest importers (***) prices for threaded rod imported from India and Thailand were 

below those for U.S.-produced product in 59 of 117 instances with margins of underselling 

ranging from less than 1 percent to 12.1 percent.

6 Petitioners’ posthearing brief, p. 6.

7 When asked to identify specific firms for which price data was problematic, petitioners indicated 

that ***. Staff interview with ***, counsel for petitioners, March 28, 2014. *** confirmed that their 

reported import price data is valued at f.o.b. their plant. Email from ***, March 31, 2014.

V-9 

 
Table V-9 

Threaded rod: Summary of weighted-average f.o.b. prices for products 1-4 from the United States, 

India and Thailand

Item

Number of 

quarters

Low price

(per unit)

High price

(per unit)

Change in 

price1 (percent)

Product 1

United States 12 0.59 0.63 (0.9)

India 12 0.57 0.63 3.7 

Thailand 12 0.58 0.64 1.3 

Product 2

United States 12 0.58 0.61 1.5 

India 12 0.51 0.66 (15.0)

Thailand 12 0.59 0.66 12.1 

Product 3

United States 12 0.61 0.66 (2.0)

India 12 0.60 0.78 19.4 

Thailand 12 0.59 0.67 0.2 

Product 4

United States 12 0.58 0.63 3.3 

India 12 0.67 1.06 15.4 

Thailand 12 0.56 0.79 (18.1)

Product 5

United States 12 0.74 0.78 (1.9)

India 12 0.63 0.81 3.3 

Thailand 12 0.46 0.74 ***

Product 6

United States 12 0.92 1.00 4.5 

India 10 0.71 1.24 (8.6)

Thailand 12 1.54 2.94 (47.6)

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.

V-10
Table V-10

Threaded rod: Instances of underselling/overselling and the range and average of margins, by 

country, January 2011-December 2013

Source

Underselling Overselling

Number of 

instances

Range 

(percent)

Average 

margin 

(percent)

Number of 

instances

Range 

(percent)

Average 

margin 

(percent)

India 25 0.2 to 28.7 6.5 45 0.2 to 77.8 15.5

Thailand 33 0.0 to 39.2 6.8 39 0.1 to 220.9 52.3

 Total 58 0.0 to 39.2 6.7 84 0.1 to 220.9 32.6

Source: Compiled from data submitted in response to Commission questionnaires.

Table V-11

Threaded rod: Instances of underselling/overselling and the range and average of margins, by 

product, January 2011-December 2013

Source

Underselling Overselling

Number of 

instances

Range 

(percent)

Average 

margin 

(percent)

Number of 

instances

Range 

(percent)

Average

margin 

(percent)

Product 1 9 0.3 to 4.7 2.0 15 0.1 to 5.6 2.2

Product 2 8 0.1 to 14.4 3.4 16 0.4 to 11.2 4.2

Product 3 9 0.7 to 7.2 4.0 15 0.2 to 28.8 6.3

Product 4 7 0.0 to 9.3 4.0 17 4.9 to 77.8 31.7

Product 5 21 0.2 to 39.2 10.4 3 3.1 to 7.3 5.5

Product 6 4 2.4 to 28.7 15.1 18 1.0 to 220.9 110.4

 Total 58 0.0 to 39.2 6.7 84 0.1 to 220.9 32.6

Source: Compiled from data submitted in response to Commission questionnaires.

Petitioners claim that any pricing analysis should begin with a review of the import 

average unit values (AUVs).8 They indicate that AUVs for imports from Thailand and India under 

HTS 7318.15.5056 are between 27 cents per pound and 30 cents per pounds below those of 

China and also significantly below the reported prices of U.S. industry in its questionnaire 

responses.9 Petitioners point out that U.S. importers have reported to the Commission that 

virtually all of their subject imports are classified under this HTS number during the period of 

investigation.

10

However, import AUVs understate sales prices of subject imports to some extent 

because they do not include the importers’ sales markup in U.S. market. For example, ***. 

***. 

Also, the variation in the price data reported by U.S. producers suggests that prices vary 

by type of product, making a comparison of AUVs problematic if there are differences in

8 Petitioners’ prehearing brief, pp. 18-19.

9

 Hearing transcript, (Waite), pp. 41-42.

10 Petitioners’ posthearing brief, p. 3. 

V-11

 
product mix between sources being compared. For example, U.S. producers’ prices for the hotdipped galvanized product 6 ranged from $0.92 to $1.00 per pound and the small diameter 

product 5 ranged in price from $0.74 to $0.78 per pound, compared to the $0.58 to $0.66 per 

pound price range reported for the first four products. Also, the AUV for all six U.S. pricing 

products range from $0.61 to $0.63 per pound during 2011 to 2013, which is lower than the 

AUV for all shipments of U.S.-produced threaded rod, which ranges from $0.68 to $0.70 per 

pound during the same time period. Since the price data represent about one-half of U.S. 

shipments, this implies that the domestic products not captured in the six price products have 

prices averaging about $0.75 to $0.78 per pound. 

The range of import competing prices reported by U.S. producers in the lost sales 

allegations also suggest variation in prices of threaded rod. For example, the alleged import 

competing prices ranged from $0.50 per pound to $3.08 per pound with a median price of 

$0.58 per pound and a weighted average price of $0.60 per pound. 

LOST SALES AND LOST REVENUE

The Commission requested U.S. producers of threaded rod to report any instances of 

lost sales or revenue they experienced due to competition from imports of threaded rod from 

India or Thailand since January 2010. Of the five responding U.S. producers, three reported that 

they had to reduce prices or roll back announced price increases, and three indicated that they 

had lost sales to imports from India or Thailand. One U.S. producer (***) indicated that it had 

not reduced prices or rolled back price increases to avoid losing sales to imports from India or 

Thailand. The 319 lost sales allegations totaled $*** million and involved about *** million 

pounds and almost *** pieces of threaded rod, and the 456 lost revenue allegations totaled 

approximately $*** in lost revenue and involved *** million pounds and almost *** pieces of 

threaded rod. Staff contacted almost all purchasers and a summary of the information obtained 

follows (see tables V-12 to V-15). 

Based on value, purchasers agreed with 36 percent of the lost sales allegations, 

disagreed with 20 percent of the allegations, neither agreed nor disagreed with 12 percent of 

the allegations, and did not respond to one-third of the lost sales allegations. Purchasers 

agreed with 29 percent of the value of lost revenue allegations, disagreed with 18 percent of 

the allegations, neither agreed nor disagreed with 4 percent of the allegations, and did not 

respond to 50 percent of the allegations. Based on the number of allegations, purchasers 

agreed with 132 of 319 lost sales allegations, disagreed with 73 allegations, neither agreed or 

disagreed with 38 of the allegations, and did not respond to 77 of the allegations. Regarding 

lost revenue allegations, purchasers agreed with 106 of the 456 allegations, disagreed with 54

of the allegations, neither agreed or disagreed with 26 of the allegations, and did not respond 

to 270 of the allegations.11

11 This is not based on a staff assessment of whether the purchaser comments agree or disagree; 

rather, it is only reporting whether the purchaser wrote agree or disagree and comments on the 

allegations.

V-12

 
 

Table V-12 

Threaded rod: U.S. producers’ lost sales allegations, quantity reported in pounds

* * * * * * *

Table V-13

Threaded rod: U.S. producers’ lost sales allegations, quantity reported in pieces

* * * * * * 

Table V-14

Threaded rod: U.S. producers’ lost revenue allegations, quantity reported in pounds

* * * * * * *

Table V-15

Threaded rod: U.S. producers’ lost revenue allegations, quantity reported in pieces

* * * * * * *

Petitioners stated that responding purchasers largely confirmed allegations of lost sales and 

revenues.12 They indicate that although two purchasers (***) who confirmed lost sales were 

unsure of the country of origin of the imported product, both agreed that they had bought 

cheaper imported products and that *** acknowledged that ***.” Petitioners indicate that the 

low AUVs for imports from India and Thailand make it reasonable to assume that these sales 

were lost to imports from India and/or Thailand. They also indicated that although purchaser 

*** noted that the reported quantities were overstated for lost sales that it confirmed, it does 

not diminish the significance of this purchaser’s confirmation that these were in fact lost 

sales.13 This purchaser (***) indicated that it only purchased 32,553 pounds of threaded rod 

imported from India in 3 years, far less the 1.8 million pounds named in these allegations. 

These 1.8 million pounds of lost sales allegations make up 23 percent of all lost sales alleged by 

U.S. producers. 

Petitioners also provided examples where they felt that some purchasers that disagreed 

with allegations indicate that they misunderstood the question being asked in the allegation. 

They noted examples of where one purchaser indicated in its narrative response that it

purchases from *** and other cases where purchasers indicated merely that they did not 

“import” threaded rod from India or Thailand, but that they could have purchased threaded rod

imported from these countries.14 In the preliminary phase, purchasers responding to the lost 

sales and lost revenue allegations also were asked whether they shifted their purchases of 

threaded rod from U.S. producers to suppliers of threaded rod from India or Thailand since 

12 Hearing transcript, p. 32 (McGrath).

13 Petitioners’ posthearing brief, Exhibit 1, Posthearing responses to questions from the Commission 

on behalf of the Petitioners, pp. 20-21. 14 Petitioners’ posthearing brief, Exhibit 1, Posthearing responses to questions from the Commission 

on behalf of the Petitioners, pp. 22-23.

V-13

 
 

2010. Six of the 25 responding purchasers reported that they had shifted purchases of threaded 

rod from U.S. producers to subject imports since 2010; six15 purchasers reported that price was 

the reason for the shift.16 

In addition, they were asked whether U.S. producers reduced their prices in order to 

compete with suppliers of threaded rod from India or Thailand. Eleven of 18 responding 

purchasers reported that the U.S. producers had reduced their prices in order to compete with 

the prices of subject imports since 2010.17 The following are additional comments on lost sales 

and lost revenue allegations:

***. 

15 These purchasers are not all the same as the preceding six purchasers as some purchasers 

responded to the second half of the question without answering the first half and vice versa. 

16 Additional substantive comments included (1) “Some items were purchased from importers so that 

we could get the sale, that we would have lost due to cost;” (2) “We hesitate to do direct importation of 

this product. If you look into our importation program, you will find that our imported volume on 

threaded rod product line is relatively small, compared with any other importers. The reason we do not 

prefer to do direct import of this product line is that we have to purchase at large volume in order to 

allow oversea manufacturers to process our order for us; that means, we have to put in much more 

capital on inventory of this product line. The reasons we import this product are following: (a) Domestic 

manufacturers cannot provide us with our own label, in other words, we cannot have our own brand on 

this product. (b) The packaging quality from overseas producers are much better, they use heavy duty 

tube, while domestic tubes are much thinner. (c) Oversea producers can palletize this product for us, 

while domestic manufacturers delivered from a flatbed truck, which will take much more space when 

stocking this item. In terms of pricing, it does not make that much difference between domestic offering 

and oversea pricing. This is due to large price increase in International ocean freight for the past couple 

years;” (3) “I can’t honestly say yes or no, but I assume foreign made goods drove down prices from 

American made goods. Our last direct purchase from India for all threaded product was on Sept. 30, 

2009. The quality was poor. I then directed we purchase from reputable U.S. suppliers. Most threaded 

rod we’ve purchase for the past several years has been produced domestically;” (4) “Other Asian nations 

were more expensive;” and (5) “Price is not the only reason, I can’t only depend on 2 or 3 factories.”

Responses to various lost sales and revenue allegations. 17 Additional substantive comments from responding and non-responding purchasers include (1) “All 

America has always been competitive;” (2) “I don’t know, like I said I have purchased threaded rod from 

overseas. Happy with product, material wrapping, palletizing, as well as time;” (3) “U.S. producers never 

reduce their pricing to offer our company and try to win more business;” (4) “Pricing has been kept quite 

low for a long while now, which is a little out of the ordinary from past experience;” (5) “Threaded rod 

pricing did not get reduced to us from a U.S. producer until August of 2012. Prices actually increased in 

August 2011 for approximately 12 months;” (6) “No apparent changes in price (up or down) since May 

2009.” Responses to various lost sales and revenue allegations; and (7) “After reviewing purchasing 

history, it appears our price from U.S. producers has decreased. As to whether this is in response to 

pressures from imports from India and Thailand I can’t say.”

V-14

 
PART VI: FINANCIAL EXPERIENCE OF U.S. PRODUCERS

INTRODUCTION

Five U.S. producers *** provided usable financial data on their operations on threaded 

rod. 1 These data are believed to account for nearly all U.S. production of threaded rod in 2013. 

No firms reported tolling operations, internal consumption, or transfers to related firms. ***.

OPERATIONS ON THREADED ROD

Income-and-loss data for U.S. producers of threaded rod are presented in table VI-1, 

while selected financial data, by firm, are presented in table VI-2. The reported financial 

condition of the U.S. industry *** from 2011 to 2012, and *** from 2012 to 2013, ***. The 

reported aggregate net sales quantity *** from 2011 to 2013, while the aggregate net sales 

value *** during this time. Collectively, the aggregate cost of goods sold (“COGS”) and selling, 

general, and administrative (“SG&A”) expenses *** during this time. As a result of the *** in 

revenue as compared to operating costs and expenses, aggregate operating income ***.

On a per-pound basis and as a ratio to net sales, steel costs *** from 2011 to 2012, 

then *** from 2012 to 2013. In comparison, plating costs/other raw material costs, direct 

labor, other factory costs, and SG&A expenses were *** on a per-pound basis and as a ratio to 

net sales.

2 3

 Steel costs accounted for an average *** percent of total COGS for the reporting 

period, and had ***. Although SG&A expenses were *** on a per-pound basis and as a ratio to 

net sales, they accounted for *** percent of overall operating costs and expenses during the 

period examined and *** of the industry.4

Table VI-1 

Threaded rod: Results of operations of U.S. producers, 2011-13

* * * * * * *

1 All America, a subsidiary of Acme Manufacturing, was formed in June 2010, and reflects the 

combined operations of acquisitions made in 2008 (Threaded Rod), 2009 (Lancaster Threaded Products 

and Watson Metal Products), and 2010 (Rods Indiana and J&D Industrial Products). Hearing transcript 

(Broderick), pp. 19-20. 2 ***. E-mail from ***, February 20, 2014. ***. 

3 ***. 

4 SG&A expenses consist primarily of ***. E-mail from ***, February 21, 2014, ***, February 20, 

2014, and ***, February 21, 2014. ***. 

VI-1

 
Table VI-2 

Threaded rod: Selected results of operations of U.S. producers, by firm, 2011-13

* * * * * * *

Capital expenditures and total assets

The responding firms’ aggregate data on capital expenditures and total assets are shown 

in table VI-3. No firms reported research and development (“R&D”) expenses. Aggregate 

capital expenditures *** from 2011 to 2013. The majority of reported capital expenditures, 

***, reflect the data reported by ***. According to ***.

5

 ***.

6

 ***.

7

 ***.

8

 The total assets 

utilized in the production, warehousing, and sales of threaded rod increased from $*** million 

in 2011 to $*** million in 2013.

Table VI-3

Threaded rod: Capital expenditures and total assets of U.S. producers, 2011-13

* * * * * * *

Capital and investment

The Commission requested U.S. producers of threaded rod to describe any actual or 

potential negative effects of imports of threaded rod from India or Thailand on their firms’ 

growth, investment, ability to raise capital, development and production efforts, or the scale of 

capital investments. Responses by U.S. producers follow.

Actual Negative Effects:

* * * * * * *

Potential Negative Effects:

* * * * * * *

5 Petitioners’ postconference brief, exhibit 1, p. 13. 

6 E-mail from ***, February 20, 2014. 7 E-mail from ***, February 21, 2014.

8 Petitioners’ postconference brief, exhibit 1, p. 13. 

VI-2

 
PART VII: THREAT CONSIDERATIONS AND INFORMATION ON 

NONSUBJECT COUNTRIES

Section 771(7)(F)(i) of the Act (19 U.S.C. § 1677(7)(F)(i)) provides that—

In determining whether an industry in the United States is threatened 

with material injury by reason of imports (or sales for importation) of the 

subject merchandise, the Commission shall consider, among other 

relevant economic factors1--

(I) if a countervailable subsidy is involved, such information as may 

be presented to it by the administering authority as to the nature 

of the subsidy (particularly as to whether the countervailable 

subsidy is a subsidy described in Article 3 or 6.1 of the Subsidies 

Agreement), and whether imports of the subject merchandise are 

likely to increase,

(II) any existing unused production capacity or imminent, substantial 

increase in production capacity in the exporting country indicating 

the likelihood of substantially increased imports of the subject 

merchandise into the United States, taking into account the 

availability of other export markets to absorb any additional 

exports,

(III) a significant rate of increase of the volume or market penetration 

of imports of the subject merchandise indicating the likelihood of 

substantially increased imports,

(IV) whether imports of the subject merchandise are entering at prices 

that are likely to have a significant depressing or suppressing 

effect on domestic prices, and are likely to increase demand for 

further imports,

(V) inventories of the subject merchandise,

1 Section 771(7)(F)(ii) of the Act (19 U.S.C. § 1677(7)(F)(ii)) provides that “The Commission shall 

consider {these factors} . . . as a whole in making a determination of whether further dumped or 

subsidized imports are imminent and whether material injury by reason of imports would occur unless 

an order is issued or a suspension agreement is accepted under this title. The presence or absence of 

any factor which the Commission is required to consider . . . shall not necessarily give decisive guidance 

with respect to the determination. Such a determination may not be made on the basis of mere 

conjecture or supposition.”

VII-1

 
(VI) the potential for product-shifting if production facilities in the 

foreign country, which can be used to produce the subject 

merchandise, are currently being used to produce other products,

(VII) in any investigation under this title which involves imports of both 

a raw agricultural product (within the meaning of paragraph 

(4)(E)(iv)) and any product processed from such raw agricultural 

product, the likelihood that there will be increased imports, by 

reason of product shifting, if there is an affirmative determination 

by the Commission under section 705(b)(1) or 735(b)(1) with 

respect to either the raw agricultural product or the processed 

agricultural product (but not both),

(VIII) the actual and potential negative effects on the existing 

development and production efforts of the domestic industry, 

including efforts to develop a derivative or more advanced version 

of the domestic like product, and

(IX) any other demonstrable adverse trends that indicate the 

probability that there is likely to be material injury by reason of 

imports (or sale for importation) of the subject merchandise 

(whether or not it is actually being imported at the time).2

Information on the nature of the alleged subsidies was presented earlier in this report; 

information on the volume and pricing of imports of the subject merchandise is presented in 

Parts IV and V; and information on the effects of imports of the subject merchandise on U.S. 

producers’ existing development and production efforts is presented in Part VI. Information on 

inventories of the subject merchandise; foreign producers’ operations, including the potential 

for “product-shifting;” any other threat indicators, if applicable; and any dumping in thirdcountry markets, follows. Also presented in this section of the report is information obtained 

for consideration by the Commission on nonsubject countries.

2 Section 771(7)(F)(iii) of the Act (19 U.S.C. § 1677(7)(F)(iii)) further provides that, in antidumping 

investigations, “. . . the Commission shall consider whether dumping in the markets of foreign countries 

(as evidenced by dumping findings or antidumping remedies in other WTO member markets against the 

same class or kind of merchandise manufactured or exported by the same party as under investigation) 

suggests a threat of material injury to the domestic industry.”

VII-2

 
THE INDUSTRY IN INDIA

The Commission issued foreign producers’ or exporters’ questionnaires to 69 firms 

believed to produce and/or export threaded rod from India.3 Useable responses to the 

Commission’s questionnaire were received from six firms: ***.

4 These firms’ exports to the 

United States accounted for 87.9 percent of U.S. imports of threaded rod from India over the 

period of investigation. According to estimates requested of the responding India producers, 

the production of threaded rod in India reported in this section of the report accounts for the 

majority of overall production of threaded rod in India. 

Production capacity increased in each year, ending nearly 9.0 million pounds higher 

(28.1 percent) in 2013 than in 2011. Five of the six responding firms increased production 

capacity during 2011-13.5 Over *** of the increase in capacity was attributed to ***. In 

addition, *** had the largest individual increase in production between 2011 and 2013, 

contributing to the 19.2 percent (5.2 million pounds) increase in aggregated Indian production. 

The vast majority of shipments of threaded rod for all but two (***) of the responding firms 

during 2011-13 were exported to the United States. However, exports of threaded rod to the 

United States decreased 4.7 percent (mostly driven by ***) between 2011 and 2013. Two firms, 

***, projected increased exports to the United States in 2014 and 2015 while *** projected 

2014-15 exports to the United States to drop to zero. Table VII-1 presents information on the

threaded rod operations of the responding producers and exporters in India. 

3 These firms were identified through a review of information submitted in the petition and 

contained in proprietary Customs records. 4 During the preliminary phase of these investigations 14 firms provided useable responses. The six 

firms responding in the final phase all provided responses in the preliminary phase. 5 *** reported stable capacity of *** pounds of capacity from 2011-2013.

VII-3

 
Table VII-1 

Threaded Rod: Data for producers in India, 2011-2013 and projections for 2014-2015

Item

Actual experience Projections

Calendar year

2011 2012 2013 2014 2015

Quantity (1,000 pounds)

Capacity 31,900 38,050 40,875 37,350 37,700

Production 27,240 27,640 32,478 28,728 29,832

End-of-period inventories 4,282 3,254 3,485 2,811 2,781

Shipments:

 Internal consumption/ transfers *** *** *** *** ***

Home market shipments *** *** *** *** ***

Export shipments to:

 United States 21,671 21,801 20,642 16,614 16,941

All other markets *** *** *** *** ***

Total exports *** *** *** *** ***

Total shipments 26,250 28,468 32,067 29,382 29,912

Ratios and shares (percent)

Capacity utilization 85.4 72.6 79.5 76.9 79.1

Inventories/production 15.7 11.8 10.7 9.8 9.3

Inventories/total shipments 16.3 11.4 10.9 9.6 9.3

Share of total shipments:

 Internal consumption/ transfers *** *** *** *** ***

Home market shipments *** *** *** *** ***

Export shipments to:

 United States 82.6 76.6 64.4 56.5 56.6

All other markets *** *** *** *** ***

Total exports *** *** *** *** ***

Total shipments 100.0 100.0 100.0 100.0 100.0

 Source: Compiled from data submitted in response to Commission questionnaires.

THE INDUSTRY IN THAILAND

The Commission issued foreign producers’/exporters’ questionnaires to 18 firms 

believed to produce and/or export threaded rod from Thailand.6 No responses were received. 

Petitioners reported that Tycoons Worldwide Group (“Tycoons”) is by far the largest producer 

in Thailand.7 Tycoons’ facility in Rayong, Thailand has an annual wire rod production capacity of 

7,936.6 million pounds (360,000 metric tons) and an annual threaded rod capacity of 396.8 

6 These firms were identified through a review of information submitted in the petition and 

contained in proprietary Customs records. 7 Hearing transcript, p. 89 (Waite) and Conference transcript, p. 79 (Waite) and p. 90 (Logan); and 

postconference brief, Exh. 1, p. 1.

VII-4

 
million pounds (1,500 metric tons per month).8 Exports accounted for 59 percent of Tycoons’ 

total sales including threaded rod in 2010 and 2011, and 52 percent in 2012.9

U.S. INVENTORIES OF IMPORTED MERCHANDISE

Table VII-2 presents data on U.S. importers’ reported inventories of threaded rod. 

Inventories of imports, as well as the ratio to U.S. imports and the ratio to U.S. shipments of 

imports from India increased overall during 2011-13. Inventories of imports and the ratio to 

U.S. imports from Thailand increased during the period of investigation, while the ratio of U.S. 

shipments of imports from Thailand fluctuated over the same period. *** accounted for 

roughly *** of the inventories of imports from India. *** accounted for the majority of the 

inventories of imports from Thailand.

Table VII-2 

Threaded Rod: U.S. importers’ inventories, 2011-2013

* * * * * * *

U.S. IMPORTERS’ OUTSTANDING ORDERS

The Commission requested importers to indicate whether they imported or arranged for 

the importation of threaded rod after January 1, 2014. Table VII-3 presents the quantity of 

orders by 11 U.S. importers which indicated that they had imported or arranged for the 

importation of threaded rod from India and other sources. No importer reported orders from 

Thailand subsequent to January 2014.

Table VII-3 

Threaded rod: U.S. importers’ orders for subsequent to January 1, 2014

* * * * * * *

ANTIDUMPING OR COUNTERVAILING DUTY ORDERS IN THIRD-COUNTRY MARKETS

No responding producer, importer, or foreign producer reported countervailing or 

antidumping duty orders on threaded rod from India or Thailand other than the antidumping 

order on U.S. imports from China (see Part I of this report for further details).

8 Petition, Exh. 16 and Tycoons Worldwide Group (Thailand) Public Co., Ltd, Annual report 2012, p. 3.

9 Tycoons Worldwide Group (Thailand) Public Co., Ltd, Annual report 2012, p. 5.

VII-5

 
INFORMATION ON NONSUBJECT COUNTRIES

In assessing whether the domestic industry is materially injured or threatened with 

material injury “by reason of subject imports,” the legislative history states “that the 

Commission must examine all relevant evidence, including any known factors, other than the 

dumped or subsidized imports, that may be injuring the domestic industry, and that the 

Commission must examine those other factors {including non-subject imports} ‘to ensure that it 

is not attributing injury from other sources to the subject imports.’”10

According to the petitioners, the major nonsubject threaded rod producers are China 

and Taiwan.

11 China has a very large capacity to produce threaded rod and its threaded rod 

industry is export-oriented. In 2009, an antidumping duty order was imposed on threaded rod 

imports from China.12 Taiwan is also a supplier of threaded rod to the U.S. market, but, the 

volume of imports from Taiwan has fallen over the past few years, the petitioners argue that 

this is probably the result of its relatively high costs compared with producers in India and 

Thailand.13 According to official Commerce import statistics during 2011-13, Malaysia is the 

fifth largest threaded rod import source and the third largest nonsubject source.14

Nonsubject imports accounted for a declining share of total U.S. imports during 2011-

13, 48.6 percent in 2011, 46.3 percent in 2012, and 43.1 percent in 2013 (table VII-4). According 

to official Commerce import statistics, China and Taiwan accounted for the great majority of 

imports from nonsubject countries; 84.5 percent in 2013 while Malaysia accounted for 11.7

percent of nonsubject imports in 2013. 

10 Mittal Steel Point Lisas Ltd. v. United States, 542 F.3d 866, 867 (Fed. Cir. 2008), quoting from 

Statement of Administrative Action on Uruguay Round Agreements Act, H.R. Rep. 103-316, Vol. I at 851-

52; see also Bratsk Aluminum Smelter v. United States, 444 F.3d 1369 (Fed. Cir. 2006). 11 Conference transcript, pp. 67-71, (Logan). 12 Hearing transcript, p. 7 (Waite) and petitioners’ postconference brief, exh. 1, p. 5.

13 Ibid. and petitioners’ posthearing brief, exh. 1, pp. 12-13. 14 During the preliminary phase of these investigations, petitioners alleged that U.S. imports from 

Malaysia are actually produced in China and transshipped through Malaysia. Conference transcript, pp. 

68-70 and Petitioners’ postconference brief, exh. 1, pp. 5-6. During the final phase of these 

investigations, Vulcan said that it visited a major threaded rod manufacturer in Malaysia whose 

manufacturing operations appeared too small to account for the quantity of U.S. imports from Malaysia. 

Hearing transcript, pp. 55-56 (Logan). 

VII-6

 
Table VII-4

Threaded rod: U.S. imports, by subject and major nonsubject supplier, 2011-13

Item

Calendar year

2011 2012 2013

Quantity (1,000 pounds)

U.S. imports from.--

 India 26,442 20,724 25,785

Thailand 8,401 22,087 20,630

 Subtotal, subject sources 34,844 42,810 46,415

China 13,819 19,510 20,081

Taiwan 11,550 10,712 9,631

Malaysia 3,903 3,997 3,487

All other 3,674 2,621 1,946

Subtotal, nonsubject sources 32,945 36,840 35,146

Total U.S. imports 67,789 79,651 81,561

Value (1,000 dollars)

U.S. imports from.--

 India 14,690 12,166 14,193

Thailand 4,256 11,099 10,519

 Subtotal, subject sources 18,946 23,265 24,712

China 11,458 16,205 16,010

Taiwan 8,085 7,543 6,602

Malaysia 2,727 3,232 3,616

All other 5,042 5,030 3,379 

Subtotal, nonsubject sources 27,311 32,009 29,606

Total U.S. imports 46,257 55,275 54,318

Unit value (dollars per pound)

U.S. imports from.--

 India 0.56 0.59 0.55

Thailand 0.51 0.50 0.51

 Subtotal, subject sources 0.54 0.54 0.53

China 0.83 0.83 0.80

Taiwan 0.70 0.70 0.69

Malaysia 0.70 0.81 1.04 

All other 1.37 1.92 1.74 

Subtotal, nonsubject sources 0.83 0.87 0.84

Total U.S. imports 0.68 0.69 0.67

 1 Landed, duty paid.

Note.—Because of rounding, figures may not add to the totals shown.

Source: Compiled from official Commerce statistics for imports covered by HTS statistical reporting number 

7318.15.5056.

VII-7
According to petitioners, the areas of highest demand for threaded rod are the United 

States and the European Union where China is the primary source of imports. Asia is not 

believed to be a major consumer of threaded rod.15. 

15 Hearing transcript, pp. 86-87 (Logan).

VII-8

 
APPENDIX A

FEDERAL REGISTER NOTICES 

A-1

The Commission makes available notices relevant to its investigations and reviews on its 

website, www.usitc.gov. In addition, the following tabulation presents, in chronological order, 

Federal Register notices issued by the Commission and Commerce during the current 

proceeding.

Citation Title Link

78 FR 40170

July 3, 2013

Certain Steel Threaded Rod From 

India and Thailand; Institution of 

Antidumping and Countervailing Duty 

Investigations and Scheduling of 

Preliminary Phase Investigations

http://www.gpo.gov/fdsys/pkg/FR2013-07-03/pdf/2013-15968.pdf

78 FR 44526

July 24, 2013

Steel Threaded Rod From India and 

Thailand: Initiation of Antidumping 

Duty Investigations

http://www.gpo.gov/fdsys/pkg/FR2013-07-24/pdf/2013-17794.pdf

78 FR 44532

July 24, 2013

Steel Threaded Rod From India: 

Initiation of Countervailing Duty 

Investigation

http://www.gpo.gov/fdsys/pkg/FR2013-07-24/pdf/2013-17795.pdf

78 FR 66382

November 5, 

2013

Certain Steel Threaded Rod From 

India and Thailand

http://www.gpo.gov/fdsys/pkg/FR2013-11-05/pdf/2013-26403.pdf

78 FR 56217

September 12, 

2013

Steel Threaded Rod from India:

Postponement of Preliminary 

Determination of Countervailing Duty 

Investigation

http://www.gpo.gov/fdsys/pkg/FR2013-09-12/pdf/2013-22225.pdf

78 FR 71565

November 29, 

2013

Steel Threaded Rod from India: 

Postponement of Preliminary 

Determination of Antidumping Duty 

Investigation 

http://www.gpo.gov/fdsys/pkg/FR2013-11-29/pdf/2013-28554.pdf

78 FR 76815

December 19, 

2013

Steel Threaded Rod From India: 

Preliminary Affirmative 

Countervailing Duty Determination 

and Alignment of Final Determination 

With Final Antidumping 

Determination 

http://www.gpo.gov/fdsys/pkg/FR2012-05-10/pdf/2012-11221.pdf

78 FR 79670

December 31, 

2013

Steel Threaded Rod From Thailand: 

Preliminary Determination of Sales at 

Less Than Fair Value and Affirmative 

Preliminary Determination of Critical 

Circumstances

http://www.gpo.gov/fdsys/pkg/FR2013-12-31/pdf/2013-31341.pdf

A-3
79 FR 3245

January 17, 2014

Certain Steel Threaded Rod From 

India and Thailand; Scheduling of the 

Final Phase of Countervailing Duty 

and Antidumping Investigations. 

http://www.gpo.gov/fdsys/pkg/FR2014-01-17/pdf/2014-00800.pdf

79 FR 9164

February 18, 

2014

Steel Threaded Rod from India: 

Preliminary Determination of Sales at 

Less Than Fair Value, Affirmative 

Preliminary Determination of Critical 

Circumstances, in Part, and 

Postponement of Final Determination

http://www.gpo.gov/fdsys/pkg/FR2014-02-18/pdf/2014-03483.pdf

79 FR 14476

March 14, 2014

Steel Threaded Rod From Thailand: 

Final Determination of Sales at Less 

Than Fair Value and Affirmative Final 

Determination of Critical 

Circumstances

http://www.gpo.gov/fdsys/pkg/FR2014-03-14/pdf/2014-05681.pdf

A-4
APPENDIX B

LIST OF HEARING WITNESSES

B-1
B-2
CALENDAR OF PUBLIC HEARING

Those listed below appeared as witnesses at the United States International Trade 

Commission’s hearing:

Subject: Certain Steel Threaded Rod from India and Thailand

Inv. Nos.: 701-TA-498 and 731-TA-1213-1214 (Final)

Date and Time: March 20, 2014 - 9:30 a.m.

A session was held in connection with these investigations in the Main Hearing Room 

(room 101), 500 E Street, S.W., Washington, D.C.

OPENING REMARKS:

Petitioners (Frederick P. Waite, Vorys, Sater, Seymour and Pease LLP)

In Support of the Imposition of 

Antidumping and Countervailing Duty Orders:

Vorys, Sater, Seymour and Pease LLP

Washington, DC

on behalf of

Vulcan Threaded Products Inc.

All America Threaded Products Inc.

Bay Standard Manufacturing Inc.

William D. Upton, Jr., President, Vulcan Threaded

Products Inc.

Alan D. Logan, Vice President, Operations, Vulcan

Threaded Products Inc.

Brent Jenkins, Sales and Marketing Analyst, Vulcan

Threaded Products Inc.

Timothy P. Broderick, Senior Vice President, All America

Threaded Products Inc.

Greg Iverson, President, Bay Standard Manufacturing Inc.

B-3
In Support of the Imposition of

 Antidumping and Countervailing Duty Orders (continued):

Robert Rodgers, National Account Sales Manager, Bay

Standard Manufacturing Inc.

Dr. Patrick Magrath, President, Magrath & Otis, LLC

Frederick P. Waite )

) – OF COUNSEL

Kimberly R. Young )

CLOSING REMARKS:

Petitioners (Frederick P. Waite, Vorys, Sater, Seymour and Pease LLP)

B-4
APPENDIX C

SUMMARY DATA

C-1

Table C-1 

Threaded Rod: Summary data concerning the U.S. market, 2011-13

2,010 2011 2012 2013 2011-13 2011-12 2012-13

U.S. consumption quantity:

Amount...................................................................... *** *** *** *** *** ***

Producers' share (1)................................................. *** *** *** *** *** ***

Importers' share (1):

India....................................................................... *** *** *** *** *** ***

Thailand................................................................. *** *** *** *** *** ***

 Subject, subtotal.................................................. *** *** *** *** *** ***

China...................................................................... *** *** *** *** *** ***

Malaysia...................................................... *** *** *** *** *** ***

Taiwan................................................................... *** *** *** *** *** ***

All others sources, nonsubject.............................. *** *** *** *** *** ***

 Nonsubject, subtotal............................................ *** *** *** *** *** ***

Total imports.................................................... *** *** *** *** *** ***

U.S. consumption value:

Amount...................................................................... *** *** *** *** *** ***

Producers' share (1)................................................. *** *** *** *** *** ***

Importers' share (1):

India....................................................................... *** *** *** *** *** ***

Thailand................................................................. *** *** *** *** *** ***

 Subject, subtotal.................................................. *** *** *** *** *** ***

China...................................................................... *** *** *** *** *** ***

Malaysia...................................................... *** *** *** *** *** ***

Taiwan................................................................... *** *** *** *** *** ***

All others sources, nonsubject.............................. *** *** *** *** *** ***

 Nonsubject, subtotal............................................ *** *** *** *** *** ***

Total imports.................................................... *** *** *** *** *** ***

U.S. imports from:

India: CDE

Census Quantity.................................................................. 26,442 20,724 25,785 9 (2.5) (21.6) 24.4

Census Value...................................................................... 14,690 12,166 14,193 33 (3.4) (17.2) 16.7

Census Unit value............................................................... $0.56 $0.59 $0.55 45 (0.9) 5.7 (6.2)

200 Ending inventory quantity....................................... 4,313 3,718 5,323 245 (2) (2) (2)

 Thailand:

Census Quantity.................................................................. 8,401 22,087 20,630 10 145.6 162.9 (6.6)

Census Value...................................................................... 4,256 11,099 10,519 34 147.1 160.8 (5.2)

Census Unit value............................................................... $0.51 $0.50 $0.51 46 0.6 (0.8) 1.5

200 Ending inventory quantity....................................... 2,870 7,864 10,794 300 (2) (2) (2)

Subtotal, Subject:

Census Quantity.................................................................. 34,844 42,810 46,415 11 33.2 22.9 8.4

Census Value...................................................................... 18,946 23,265 24,712 35 30.4 22.8 6.2

Census Unit value............................................................... $0.54 $0.54 $0.53 47 (2.1) (0.1) (2.0)

200 Ending inventory quantity....................................... 7,183 11,582 16,117 355 (2) (2) (2)

China:

Census Quantity.................................................................. 13,819 19,510 20,081 12 45.3 41.2 2.9

Census Value...................................................................... 11,458 16,205 16,010 36 39.7 41.4 (1.2)

Census Unit value............................................................... $0.83 $0.83 $0.80 48 (3.8) 0.2 (4.0)

200 Ending inventory quantity....................................... 3 38 210 410 (2) (2) (2)

Malaysia:

Census Quantity.................................................................. 11,550 10,712 9,631 13 (16.6) (7.3) (10.1)

Census Value...................................................................... 8,085 7,543 6,602 37 (18.3) (6.7) (12.5)

Census Unit value............................................................... 0.70 0.70 0.69 49 (2.1) 0.6 (2.7)

Ending inventory quantity....................................... (3) (3) (3) (3) (3) (3)

Taiwan:

Census Quantity.................................................................. 3,903 3,997 3,487 14 (10.6) 2.4 (12.7)

Census Value...................................................................... 2,727 3,232 3,616 38 32.6 18.5 11.9

Census Unit value............................................................... $0.70 $0.81 $1.04 50 48.4 15.8 28.2

200 Ending inventory quantity....................................... 4,860 5,638 4,617 465 (2) (2) (2)

All other sources:

Census Quantity.................................................................. 3,674 2,621 1,946 15 (47.0) (28.7) (25.8)

Census Value...................................................................... 5,042 5,030 3,379 39 (33.0) (0.2) (32.8)

Census Unit value............................................................... $1.37 $1.92 $1.74 51 26.5 39.8 (9.5)

200 Ending inventory quantity....................................... 1,770 1,600 1,540 520 (2) (2) (2)

Subtotal, Nonsubject sources

Census Quantity.................................................................. 32,945 36,840 35,146 16 6.7 11.8 (4.6)

Census Value...................................................................... 27,311 32,009 29,606 40 8.4 17.2 (7.5)

Census Unit value............................................................... $0.83 $0.87 $0.84 52 1.6 4.8 (3.0)

200 Ending inventory quantity....................................... 6,633 7,276 6,367 575 (2) (2) (2)

Total imports:

Census Quantity.................................................................. 67,789 79,651 81,561 17 20.3 17.5 2.4

Census Value...................................................................... 46,257 55,275 54,318 41 17.4 19.5 (1.7)

Census Unit value............................................................... $0.68 $0.69 $0.67 53 (2.4) 1.7 (4.0)

200 Ending inventory quantity....................................... 13,816 18,858 22,484 630 (2) (2) (2)

U.S. producers':

100 Average capacity quantity......................................... *** *** *** 191 *** *** ***

100 Production quantity................................................... *** *** *** 193 *** *** ***

100 Capacity utilization (1).............................................. *** *** *** 217 *** *** ***

U.S. shipments:

100 Quantity.................................................................. *** *** *** 227 *** *** ***

100 Value...................................................................... *** *** *** 228 *** *** ***

100 Unit value............................................................... *** *** *** 229 *** *** ***

Export shipments:

100 Quantity.................................................................. *** *** *** 200 *** *** ***

100 Value...................................................................... *** *** *** 201 *** *** ***

100 Unit value............................................................... *** *** *** 225 *** *** ***

100 Ending inventory quantity.......................................... *** *** *** 242 *** *** ***

100 Inventories/total shipments (1).................................. *** *** *** 245 *** *** ***

100 Production workers................................................... *** *** *** 205 *** *** ***

100 Hours worked (1,000s)............................................. *** *** *** 206 *** *** ***

100 Wages paid ($1,000)................................................ *** *** *** 207 *** *** ***

100 Productivity (short tons per 1,000 hours).................. *** *** *** 249 *** *** ***

100 Unit labor costs ($ per 1,000 pounds)...................... *** *** *** 251 *** *** ***

Net Sales:

100 Quantity.................................................................. *** *** *** 409 *** *** ***

100 Value...................................................................... *** *** *** 413 *** *** ***

100 Unit value............................................................... *** *** *** 446 *** *** ***

100 Cost of goods sold (COGS)...................................... *** *** *** 418 *** *** ***

100 Gross profit of (loss)................................................. *** *** *** 419 *** *** ***

100 SG&A expenses........................................................ *** *** *** 422 *** *** ***

100 Operating income or (loss)....................................... *** *** *** 423 *** *** ***

100 Capital expenditures................................................. *** *** *** 550 *** *** ***

100 Unit COGS................................................................ *** *** *** 480 *** *** ***

100 Unit SG&A expenses................................................ *** *** *** 484 *** *** ***

100 Unit operating income or (loss)................................ *** *** *** 485 *** *** ***

100 COGS/sales (1)........................................................ *** *** *** 460 *** *** ***

100 Operating income or (loss)/sales (1)........................ *** *** *** 465 *** *** ***

Notes:

(1).--Report data are in percent and period changes are in percentage points.

(2).--Undefined. 

(3)--Not available

Source: Compiled from data submitted in response to Commission questionnaires and from statistics of the U.S. Department of Commerce.

C-3

C-3

(Quantity=1,000 pounds; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per pound; Period changes=percent--exceptions noted)

Report data Period changes

Calendar year Calendar year
Table C-2 is confidential in its entirety.

C-4
D‐1

APPENDIX D

NONSUBJECT COUNTRY PRICE DATA

D‐3

Four importers reported price data for nonsubject countries China and Taiwan for

products 1‐6 in Part V of this report. Price data reported by these firms accounted for less than

*** percent of U.S. imports from China and *** percent of U.S. imports from Taiwan. These

data were collected on the same basis as those presented in tables V‐3 to V‐8. Price and

quantity data for China and Taiwan are shown in tables D‐1 to D‐6 and in figure D‐1 (with

domestic and subject sources).

In comparing nonsubject country pricing data with U.S. producer pricing data, prices for

product imported from China and Taiwan were lower than prices for U.S.‐produced product in

46 instances and higher in 35 instances. In comparing nonsubject country pricing data with

subject country pricing data, prices for product imported from nonsubject countries were lower

than prices for product imported from subject countries in 100 instances and higher in 60

instances.

Table D-1 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 11

, by quarters, 

January 2011-December 2013 

* * * * * * *

Table D-2 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 21

, by quarters, 

January 2011-December 2013 

* * * * * * *

Table D-3 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 31

, by quarters, 

January 2011-December 2013 

* * * * * * *

Table D-4 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 41

, by quarters, 

January 2011-December 2013 

* * * * * * *

Table D-5 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 51

, by quarters, 

January 2011-December 2013 

* * * * * * *

Table D-6 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 61

, by quarters, 

January 2011-December 2013 

* * * * * * *
D‐4

Figure D-1 

Threaded rod: Weighted-average f.o.b. prices and quantities of domestic and imported product 1, 

by quarters, January 2011-December 2013 

* * * * * * *
APPENDIX E

ITOCHU AND FASTENAL PRICE DATA

E-1 
E-2 
Table E-1 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 11 for 

Itochu/Prime Source, by quarters, January 2011-December 2013

* * * * * * *

Table E-2 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 21 for 

Itochu/Prime Source, by quarters, January 2011-December 2013

* * * * * * *

Table E-3 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 31 for 

Itochu/Prime Source, by quarters, January 2011-December 2013

* * * * * * *

Table E-4 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 41 for 

Itochu/Prime Source, by quarters, January 2011-December 2013

* * * * * * * 

Table E-5 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 51 for 

Itochu/Prime Source, by quarters, January 2011-December 2013

* * * * * * *

Table E-6 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 61 for 

Itochu/Prime Source, by quarters, January 2011-December 2013

* * * * * * *

Table E-7 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 11 for Fastenal, 

by quarters, January 2011-December 2013

* * * * * * *

E-3 
Table E-8 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 21 for Fastenal, 

by quarters, January 2011-December 2013

* * * * * * *

Table E-9 

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 31 for Fastenal, 

by quarters, January 2011-December 2013

* * * * * * *

Table E-10

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 41 for Fastenal, 

by quarters, January 2011-December 2013

* * * * * * *

Table E-11

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 51 for Fastenal, 

by quarters, January 2011-December 2013

* * * * * * *

Table E-12

Threaded rod: Weighted-average f.o.b. prices and quantities of imported product 61 for Fastenal, 

by quarters, January 2011-December 2013

* * * * * * *

E-4