U.S. International Trade Commission

Publication 4457 March 2014

Washington, DC 20436

Laminated Woven Sacks From China

Investigation Nos. 701-TA-450 and 731-TA-1122 (Review)
U.S. International Trade Commission

COMMISSIONERS 

 

Irving A. Williamson, Chairman 

Shara L. Aranoff 

Dean A. Pinkert 

David S. Johanson 

Meredith M. Broadbent 

F. Scott Kieff

Robert B. Koopman

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Director of Operations

Michael Haberstroh, Investigator 

Jackie Jones, Industry Analyst 

Carolyn Holmes, Statistician 

Nataline Viray-Fung, Attorney 

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

Washington, DC 20436 

www.usitc.gov

Publication 4457 March 2014

Laminated Woven Sacks From China

Investigation Nos. 701-TA-450 and 731-TA-1122 (Review)

Table of Contents Page

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

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

INFORMATION OBTAINED IN THE REVIEW ........................................................................... I-2

Introduction............................................................................................................................... I-2

Background............................................................................................................................ I-2

The original investigations..................................................................................................... I-3

Commerce’s final results of expedited first five-year reviews.............................................. I-3

Commerce's administrative reviews.............................................................................................I-3

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

The Product............................................................................................................................... I-5

Commerce’s scope................................................................................................................. I-5

U.S. tariff treatment .............................................................................................................. I-6

Domestic like product and domestic industry....................................................................... I-7

Description and uses ............................................................................................................. I-7

Production process................................................................................................................ I-8

Interchangeability and customer and producer perceptions ............................................. I-11

Channels of distribution ...................................................................................................... I-11

Pricing and related information .......................................................................................... I-12

The Industry in the United States ........................................................................................... I-12

U.S. producers ..................................................................................................................... I-12

Related party issues............................................................................................................. I-13

U.S. producers’ trade and financial data............................................................................. I-13

U.S. Imports and Apparent Consumption............................................................................... I-14

U.S. imports......................................................................................................................... I-14

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

Apparent U.S. consumption and market shares ................................................................. I-16

The Industry in China .............................................................................................................. I-17

Background.......................................................................................................................... I-17

Capacity and production ..................................................................................................... I-18

Exports................................................................................................................................. I-18

Tariff or non-tariff barriers to trade .................................................................................... I-19

The Global Market................................................................................................................... I-19

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.

I-1
 

UNITED STATES INTERNATIONAL TRADE COMMISSION

 Investigation Nos. 701-TA-450 and 731-TA-1122 (Review) 

 LAMINATED WOVEN SACKS FROM CHINA 

DETERMINATION

On the basis of the record1

developed in the subject five-year reviews, the United States 

International Trade Commission (Commission) determines, pursuant to section 751(c) of the Tariff Act of 

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

laminated woven sacks from China would be likely to lead to continuation or recurrence of material injury 

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

BACKGROUND

The Commission instituted these reviews on July 1, 2013 (78 F.R. 39319) and determined on 

October 21, 2013, that it would conduct expedited reviews (78 F.R. 68473, November 14, 2013). 

 

 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 Kieff did not participate in these determinations. 

Views of the Commission

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

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

and countervailing duty orders on laminated woven sacks from China would likely lead to 

continuation or recurrence of material injury to an industry in the United States within a 

reasonably foreseeable time.1

I. Background

Original Investigations. The original investigations of laminated woven sacks from China 

were instituted in response to a petition that the Laminated Woven Sacks Committee (“the 

Committee” or “domestic producers”) filed on June 28, 2007.2

 At that time the Committee’s 

membership consisted of five domestic producers of laminated woven sacks: Bancroft Bag, 

Inc.; Coating Excellence International, LLC (“Coating Excellence”); Hood Packaging Corp. 

(“Hood”); Mid-America Packaging, LLC; and Polytex Fibers Corp. (“Polytex”).3

 

In July 2008, the Commission determined that an industry in the United States was 

materially injured by reason of imports of laminated woven sacks from China that the United 

States Department of Commerce (“Commerce”) found were subsidized and sold at less than fair 

value.4

 Commerce issued antidumping duty and countervailing duty orders on imports of 

laminated woven sacks from China on August 7, 2008.5

 

Current Reviews. The Commission instituted these reviews on July 1, 2013.

6

 The 

Commission received one substantive response to the notice of institution from the 

Committee.7 It did not receive a response from any respondent interested party. On October 

21, 2013, the Commission found the Committee’s response to the notice of institution 

individually adequate, the domestic interested party group response adequate, and the 

respondent interested party group response inadequate.8

 The Commission did not find any 

circumstances that would warrant conducting full reviews and determined that it would 

1 Commissioner Kieff did not participate in these reviews.

2 Confidential Report (“CR”) at I-3, Public Report (“PR”) at I-3.

3 CR at I-3, PR at I-3. 4 Laminated Woven Sacks from China, Inv. Nos. 701-TA-450 and 731-TA-1122 (Final), USITC Pub. 

4025 at 1 (Aug. 2008) (“Original Determination”). 5 Notice of Antidumping Duty Order: Laminated Woven Sacks from China, 73 Fed. Reg. 45941 

(Aug. 7, 2008); Laminated Woven Sacks from the People’s Republic of China, 73 Fed. Reg. 45955 (Aug. 7, 

2008) (countervailing duty order).

6 Laminated Woven Sacks from China, 78 Fed. Reg. 39319 (July 1, 2013) (institution of five-year 

reviews) (“Notice of Institution”). 7 Substantive Response to the Commission’s Notice of Institution, July 30, 2013 (“Response”). 

The Committee in these reviews consists of Coating Excellence, Exopack Holding Corp., Graphic 

Packaging International, Inc., Hood, Polytex, and SeaTac Packaging Manufacturing Corp.

8 Summary Voting Sheet, INV-13-531, EDIS Doc. 520120 (Oct. 21, 2013). 

3

 
conduct expedited reviews pursuant to section 751(c)(3) of the Tariff Act.9

 On February 12, 

2014, the Committee filed comments with the Commission.10

II. Domestic Like Product and Industry

A. Domestic Like Product

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

defines the “domestic like product” and the “industry.”11 The Tariff Act defines “domestic like 

product” as “a product which is like, or in the absence of like, most similar in characteristics and 

uses with, the article subject to an investigation under this subtitle.”12 The Commission’s 

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

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

findings.13

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

review as follows:

Laminated woven sacks are bags or sacks consisting of one or more plies 

of fabric consisting of woven polypropylene strip and/or woven 

polyethylene strip, regardless of the width of the strip; with or without an 

extrusion coating of polypropylene and/or polyethylene on one or both 

sides of the fabric; laminated by any method either to an exterior ply of 

plastic film such as biaxially-oriented polypropylene (“BOPP”) or to an 

exterior ply of paper that is suitable for high quality print 

graphics; printed with three colors or more in register; with or without 

lining; whether or not closed on one end; whether or not in roll form 

(including sheets, lay-flat tubing, and sleeves); with or without handles; 

9 See Explanation of Commission Determination on Adequacy, EDIS Doc. 520864 (Oct. 30, 2013).

10 Laminated Woven Sacks from China: Petitioners’ Comments on the Record (Feb. 12, 2014) 

(“Comments”). 11 19 U.S.C. § 1677(4)(A). 12 19 U.S.C. § 1677(10); see, e.g., Cleo Inc. v. United States, 501 F.3d 1291, 1299 (Fed. Cir. 2007); 

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

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

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

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

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

(Second Review), USITC Pub. 3831 at 8-9 (Dec. 2005); Crawfish Tail Meat from China, Inv. No. 731-TA752 (Review), USITC Pub. 3614 at 4 (July 2003); Steel Concrete Reinforcing Bar from Turkey, Inv. No. 731-

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

4

 
with or without special closing features; not exceeding one kilogram in 

weight.14

The scope definition set out above is unchanged from Commerce’s scope definition in 

the original investigations. 

Laminated woven sacks are used as packaging by manufacturers of pet food, bird seed, 

grass seed, fertilizer, and other consumer goods. The filled sacks typically weigh between 17 

and 55 pounds.15 They are made primarily from polypropylene woven fabric that is laminated 

either with plastic or paper.16 Laminated woven sacks are manufactured in several distinct 

stages, allowing producers to enter the production process at a number of different steps.

17

 Laminated woven sacks are made from plastic pellets that are melted, extruded into a 

sheet, and then cut into strips or tape.18 These strips are then woven into fabric, either in a 

tubular form, or as a flat woven sheet.19 Regardless of its shape, the sack fabric is next printed 

with graphics, laminated, and then cut into individual sizes.20 The sacks are finished by sewing 

the bottom and applying closure tape.21

In the original investigations, the Commission found a single domestic like product 

consisting of laminated woven sacks coextensive with the scope of the investigations.22 There 

is no new information obtained during these reviews that would suggest any reason to revisit 

the domestic like product definition and the responding domestic producers have requested 

that the Commission use the same domestic like product definition in these reviews that it did 

in the original investigations.23 Accordingly, we define the domestic like product in accordance 

with Commerce’s scope description as laminated woven sacks.

B. Domestic Industry 

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

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

14 Laminated Woven Sacks from the People’s Republic of China: Final Results of Expedited First 

Sunset Review of the Antidumping Duty Order, 78 Fed. Reg. 64472 (Oct. 29, 2013) (“Commerce 

Expedited AD Review”) and accompanying Issues and Decision Memorandum; Laminated Woven Sacks 

from the People’s Republic of China: Final Results of Expedited First Sunset Review of the Countervailing 

Duty Order, 78 Fed. Reg. 69369 (Nov. 19, 2013) (“Commerce Expedited CVD Review”) and 

accompanying Issues and Decision Memorandum. 15 CR at I-8, PR at I-7.

16 CR at I-8-10, PR at I-8-11. 17 CR at I-9, PR at I-8-11. 18 CR at I-9-10, PR at I-8.

19 CR at I-10-11, PR at I-8-10.

20 CR at I-9-12, PR at I-10-11. 21 CR at I-13, PR at I-11. 22 Original Determination, USITC Pub. 4025 at 6.

23 See generally CR at I-8-12, PR at I-12-13; Response at 30.

5

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

the product.”24 In defining the domestic industry, the Commission’s general practice has been 

to include in the industry producers of all domestic production of the like product, whether tollproduced, captively consumed, or sold in the domestic merchant market. 

In its original investigations, the Commission defined the domestic industry as consisting 

of all responding domestic producers of the domestic like product.25 In these reviews, domestic 

producers have stated that they agree with this definition of the domestic industry.

26 There is 

no information on the record showing that any of the domestic producers imported subject 

merchandise from China during the review period or that otherwise presents domestic industry

issues. Accordingly, in light of the definition of the domestic like product, we define the 

domestic industry as all U.S. producers of laminated woven sacks.

III. Revocation of the Antidumping and Countervailing Duty Orders Would 

Likely Lead to Continuation or Recurrence of Material Injury Within a 

Reasonably Foreseeable Time 

A. Legal Standards

In a five-year review conducted under section 751(c) of the Tariff Act, Commerce will 

revoke an antidumping or countervailing duty order unless: (1) it makes a determination that 

dumping or subsidization is likely to continue or recur and (2) the Commission makes a 

determination that revocation of the antidumping or countervailing duty order “would be likely 

to lead to continuation or recurrence of material injury within a reasonably foreseeable time.”27 

The Uruguay Round Agreements Act Statement of Administrative Action (“SAA”) states that 

“under the likelihood standard, the Commission will engage in a counterfactual analysis; it must 

decide the likely impact in the reasonably foreseeable future of an important change in the 

status quo – the revocation or termination of a proceeding and the elimination of its restraining 

effects on volumes and prices of imports.”28 Thus, the likelihood standard is prospective in 

nature.29 The U.S. Court of International Trade has found that “likely,” as used in the five-year 

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

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

U.S.C. § 1677.

25 Original Determination, USITC Pub. 4025 at 13. 

26 Response at 23. 27 19 U.S.C. § 1675a(a).

28 SAA, H.R. Rep. 103-316, vol. I at 883-84 (1994). The SAA states that “{t}he likelihood of injury 

standard applies regardless of the nature of the Commission’s original determination (material injury, 

threat of material injury, or material retardation of an industry). Likewise, the standard applies to 

suspended investigations that were never completed.” Id. at 883.

29 While the SAA states that “a separate determination regarding current material injury is not 

necessary,” it indicates that “the Commission may consider relevant factors such as current and likely 

continued depressed shipment levels and current and likely continued {sic} prices for the domestic like 

6

 

(Continued...)
review provisions of the Act, means “probable,” and the Commission applies that standard in 

five-year reviews.30

The statute states that “the Commission shall consider that the effects of revocation or 

termination may not be imminent, but may manifest themselves only over a longer period of 

time.”31 According to the SAA, a “‘reasonably foreseeable time’ will vary from case-to-case, but 

normally will exceed the ‘imminent’ timeframe applicable in a threat of injury analysis in 

original investigations.”32

Although the standard in a five-year review is not the same as the standard applied in an 

original investigation, it contains some of the same fundamental elements. The statute 

provides that the Commission is to “consider the likely volume, price effect, and impact of 

imports of the subject merchandise on the industry if the orders are revoked or the suspended 

investigation is terminated.”33 It directs the Commission to take into account its prior injury 

determination, whether any improvement in the state of the industry is related to the order or 

the suspension agreement under review, whether the industry is vulnerable to material injury if 

the orders are revoked or a suspension agreement is terminated, and any findings by 

Commerce regarding duty absorption pursuant to 19 U.S.C. § 1675(a)(4).34 The statute further 

provides that the presence or absence of any factor that the Commission is required to consider 

shall not necessarily give decisive guidance with respect to the Commission’s determination.35

In evaluating the likely volume of imports of subject merchandise if the orders under 

review are revoked and/or a suspended investigation is terminated, the Commission is directed 

product in the U.S. market in making its determination of the likelihood of continuation or recurrence of 

material injury if the order is revoked.” SAA at 884.

30 See NMB Singapore Ltd. v. United States, 288 F. Supp. 2d 1306, 1352 (Ct. Int’l Trade 2003) 

(“‘likely’ means probable within the context of 19 U.S.C. § 1675(c) and 19 U.S.C. § 1675a(a)”), aff’d 

mem., 140 Fed. Appx. 268 (Fed. Cir. 2005); Nippon Steel Corp. v. United States, 26 CIT 1416, 1419 (2002) 

(same); Usinor Industeel, S.A. v. United States, 26 CIT 1402, 1404 nn.3, 6 (2002) (“more likely than not” 

standard is “consistent with the court’s opinion;” “the court has not interpreted ‘likely’ to imply any 

particular degree of ‘certainty’”); Indorama Chemicals (Thailand) Ltd. v. United States, 26 CIT 1059, 1070 

(2002) (“standard is based on a likelihood of continuation or recurrence of injury, not a certainty”); 

Usinor v. United States, 26 CIT 767, 794 (2002) (“‘likely’ is tantamount to ‘probable,’ not merely 

‘possible’”).

31 19 U.S.C. § 1675a(a)(5).

32 SAA at 887. Among the factors that the Commission should consider in this regard are “the 

fungibility or differentiation within the product in question, the level of substitutability between the 

imported and domestic products, the channels of distribution used, the methods of contracting (such as 

spot sales or long-term contracts), and lead times for delivery of goods, as well as other factors that may 

only manifest themselves in the longer term, such as planned investment and the shifting of production 

facilities.” Id. 33 19 U.S.C. § 1675a(a)(1).

34 19 U.S.C. § 1675a(a)(1). Commerce has not made any duty absorption findings with respect to 

the orders currently under review. CR at I-4, PR at I-4.

35 19 U.S.C. § 1675a(a)(5). Although the Commission must consider all factors, no one factor is 

necessarily dispositive. SAA at 886.

7

 

(...Continued)
to consider whether the likely volume of imports would be significant either in absolute terms

or relative to production or consumption in the United States.36 In doing so, the Commission 

must consider “all relevant economic factors,” including four enumerated factors: (1) any likely 

increase in production capacity or existing unused production capacity in the exporting country; 

(2) existing inventories of the subject merchandise, or likely increases in inventories; (3) the 

existence of barriers to the importation of the subject merchandise into countries other than 

the United States; and (4) the potential for product shifting if production facilities in the foreign 

country, which can be used to produce the subject merchandise, are currently being used to 

produce other products.37

In evaluating the likely price effects of subject imports if the orders under review are 

revoked and/or a suspended investigation is terminated, the Commission is directed to 

consider whether there is likely to be significant underselling by the subject imports as 

compared to the domestic like product and whether the subject imports are likely to enter the 

United States at prices that otherwise would have a significant depressing or suppressing effect 

on the price of the domestic like product.38

In evaluating the likely impact of imports of subject merchandise if the orders under 

review are revoked and/or a suspended investigation is terminated, the Commission is directed 

to consider all relevant economic factors that are likely to have a bearing on the state of the 

industry in the United States, including but not limited to the following: (1) likely declines in 

output, sales, market share, profits, productivity, return on investments, and utilization of 

capacity; (2) likely negative effects on cash flow, inventories, employment, wages, growth, 

ability to raise capital, and investment; and (3) likely negative effects on the existing 

development and production efforts of the industry, including efforts to develop a derivative or 

more advanced version of the domestic like product.39 All relevant economic factors are to be 

considered within the context of the business cycle and the conditions of competition that are 

distinctive to the industry. As instructed by the statute, we have considered the extent to 

which any improvement in the state of the domestic industry is related to the orders under 

review and whether the industry is vulnerable to material injury upon revocation.40

No respondent interested party participated in these expedited reviews. The record, 

therefore, contains limited new information with respect to the laminated woven sack industry

36 19 U.S.C. § 1675a(a)(2).

37 19 U.S.C. § 1675a(a)(2)(A-D).

38 See 19 U.S.C. § 1675a(a)(3). The SAA states that “{c}onsistent with its practice in 

investigations, in considering the likely price effects of imports in the event of revocation and 

termination, the Commission may rely on circumstantial, as well as direct, evidence of the adverse 

effects of unfairly traded imports on domestic prices.” SAA at 886.

39 19 U.S.C. § 1675a(a)(4).

40 The SAA states that in assessing whether the domestic industry is vulnerable to injury if the 

order is revoked, the Commission “considers, in addition to imports, other factors that may be 

contributing to overall injury. While these factors, in some cases, may account for the injury to the 

domestic industry, they may also demonstrate that an industry is facing difficulties from a variety of 

sources and is vulnerable to dumped or subsidized imports.” SAA at 885.

8

 
in China. There also is limited information on the laminated woven sack market in the United 

States during the period of review. Accordingly, for our determination, we rely as appropriate 

on the facts available from the original investigations, data submitted in the response to the 

notice of institution, and other public data.

B. Conditions of Competition and the Business Cycle

In evaluating the likely impact of the subject imports on the domestic industry if an 

order is revoked, the statute directs the Commission to consider all relevant economic factors 

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

the affected industry.”41 The following conditions of competition inform our determinations.

Demand Conditions. In the original investigations, the Commission found that demand 

for laminated woven sacks was derived from demand for the consumer products packaged in 

such sacks, such as pet food, bird seed, animal feed, and grass seed.42 It observed that 

producers from Thailand and China began introducing laminated woven sacks to domestic 

packagers around 2003 as an alternative to multi-wall paper sacks.

43 From 2003 to 2008, 

demand for laminated woven sacks grew as domestic packagers increasingly used them. 

Furthermore, mass-merchant retailers such as Wal-Mart, Dollar General, Petco, and PetSmart 

began to use laminated woven sacks because they were sturdier and cheaper to produce than 

multi-wall paper bags. The Commission found that laminated woven sacks were used primarily 

for pet food and bird seed, and also by other manufacturers of consumer goods such as pet 

litter, animal feed products, grass seed, and fertilizer.44 

In these reviews, the information available indicates that the conditions of competition 

that influence demand for laminated woven sacks have not changed significantly since the 

original investigations. Apparent U.S. consumption of laminated woven sacks in 2012, based 

on data from responding domestic producers, was *** sacks, which is higher than any level 

during the original January 2005-December 2007 period of investigation (“POI”).

45 In the 

original investigations, apparent U.S. consumption of laminated woven sacks increased from 

*** sacks in 2005 to *** sacks in 2006 and then to *** sacks in 2007.46

Supply Conditions. In the original investigations, the Commission found that domestic 

producers, which were relatively new to the market, began production operations with 

differing production experiences and at different stages of production.47 Domestic production 

of laminated woven sacks grew over the POI. The quantity of nonsubject imports grew during 

the POI, but remained *** smaller than the quantity of subject imports.48

41 19 U.S.C. § 1675a(a)(4). 42 Original Determination, USITC Pub. 4025 at 32.

43 Original Determination, USITC Pub. 4025 at 32. 44 Original Determination, USITC Pub. 4025 at 32. 45 CR/PR at Table I-6.

46 Confidential Original Determination, EDIS Doc. 516687 at 55. 47 Original Determination, USITC Pub. 4025 at 34.

48 Confidential Original Determination, EDIS Doc. 516687 at 57.

9

 
 Subject imports increased during the POI, from 112.3 million sacks in 2005 to 153.2 

million sacks in 2006 and then to 234.4 million sacks in 2007.49 However, because apparent 

U.S. consumption increased during the same time period, subject imports’ share of the U.S. 

market decreased from *** percent in 2005 to *** percent in 2006 and *** percent in 2007.50

Nonsubject imports’ share of the U.S. market increased from *** percent in 2005 to ***

percent in 2006 and then to *** percent in 2007.51 

The Committee reported that there were ten domestic producers of laminated woven 

sacks in 2012, as opposed to the seven domestic producers identified in the original 

investigations.52 The capacity of reporting domestic producers in 2012, *** sacks, was higher 

and *** reported capacity in 2007. 53 The record further shows that the domestic industry held 

a *** share of apparent U.S. consumption in 2012 than during the original investigations, and is 

now the largest supplier of laminated woven sacks to the U.S. market. U.S. producers held ***

percent of apparent U.S. consumption in 2012, compared with *** percent in 2005, ***

percent in 2006, and *** percent in 2007.54 

By contrast, in 2012, subject imports held *** percent of apparent U.S. consumption, a 

much smaller share than during the original investigations.

55 Nonsubject imports continue to 

be in the U.S. market, and they have increased since the original investigations, both in 

absolute volume and market share; they held *** percent of apparent U.S. consumption in 

2012.

56 

Substitutability. The Commission found in the original investigations that domestic and 

subject laminated woven sacks were highly substitutable when made with the same print 

design and to the same specifications.57 Laminated woven sacks were generally sold on a spot 

basis, with pricing determined on a transaction-by-transaction basis, rather than based on price 

lists.58 Domestic producers and U.S. importers sold primarily to end users.59 In the original 

investigations, the parties agreed that laminated woven sacks were not a commodity product 

because they were always made to customer order with regard to criteria such as dimension, 

strength, closure, color, design, and handles.60 Many purchasers reported purchasing 

laminated woven sacks from one source although a comparable product was available from 

49 Original Determination, USITC Pub. 4025 at 37.

50 Confidential Original Determination, EDIS Doc. 516687 at 63. 51 Confidential Original Determination, EDIS Doc. 516687 at 57.

52 CR at I-16-17, PR at I-12-13.

53 CR/PR, Table I-2. 54 CR/PR at Table I-6. 55 CR/PR at Table I-6.

56 CR/PR at Tables I-3 and I-5-6. 57 Original Determination, USITC Pub. 4025 at 36.

58 Original Determination, USITC Pub. 4025 at 34-35.

59 Original Determination, USITC Pub. 4025 at 35.

60 Original Determination, USITC Pub. 4025 at 35.

10

 
another source for a lower price due to reasons other than price. Purchasers as a group, 

however, agreed that price was an important factor in purchasing decisions.61

In these reviews, there is no new information on the record to suggest that the 

substitutability of laminated woven sacks from domestic and subject sources has changed since 

the original investigations. The domestic producers assert that price continues to play an 

important role in purchasing decisions.62 Accordingly, we again find that the domestic like 

product and subject laminated woven sacks are highly substitutable and that price continues to 

be an important factor in purchasing decisions.

C. Likely Volume of Subject Imports

Original Investigations. In the original investigations, the Commission found that 

subject import volume increased from 112.3 million sacks in 2005 to 153.2 million sacks in 2006 

and then to 234.4 million sacks in 2007.63 Subject imports lost market share during the POI, 

decreasing from *** percent of U.S. apparent consumption in 2005 to *** percent in 2006 and 

then to *** percent in 2007.64 The Commission did not put great weight on the decrease in 

market share held by subject imports because it found that the domestic industry was very 

young at the beginning of the POI with a correspondingly low baseline of operations and that 

apparent U.S. consumption showed strong increases over the POI.65 Accordingly, the 

Commission found the volume of subject imports to be significant, both in absolute terms and 

relative to consumption and production in the United States.66 

Current Reviews. The information available in these reviews shows that subject imports

have declined since the imposition of the orders but remain in the U.S. market in appreciable 

quantities. The quantity of subject imports was 234.4 million sacks in 2007.67 It declined to 

51.6 million sacks in 2008 and fluctuated at lower levels thereafter. In 2012, subject import 

volume was at a period low of 30.6 million sacks and subject imports accounted for *** percent 

of apparent U.S. consumption. 68

The record does not contain any current data specific to laminated woven sack

production or capacity in China because subject producers declined to participate or furnish 

information in these reviews.69 Nonetheless, the information available in these reviews, which 

61 Original Determination, USITC Pub. 4025 at 36.

62 Comments at 3.

63 Original Determination, USITC Pub. 4025 at 37.

64 Confidential Original Determination, EDIS Doc. 516687 at 63.

65 Original Determination, USITC Pub. 4025 at 37-38.

66 Original Determination, USITC Pub. 4025 at 38.

67 CR/PR, Table I-5.

68 CR/PR, Tables I-3 and I-6.

69 The record also does not contain any current information about inventories of the subject 

merchandise or subject producers’ ability to shift production between products. The record does 

indicate that there are no outstanding antidumping or countervailing duty orders in other markets 

11

 

(Continued...)
the domestic industry has provided, indicates that both capacity and production of the 

laminated woven sacks industry in China are large and increasing. The available evidence 

suggests that Chinese producers of laminated woven sacks have increased their capacity by 

approximately 3.9 billion sacks per year since the original investigations.

70 The available data 

further indicate that Chinese producers increased production by 19.3 percent between 2010 

and 2011, and 12.1 percent between 2011 and 2012.71 These data indicate that the Chinese 

industry has the ability to significantly increase its exports of subject imports absent the 

discipline of the orders.

The record also contains global data for exports of sacks and bags.72 The data on record 

show that China has been the largest global exporter of sacks and bags from 2008 to 2012 and 

has increased its exports every year since 2009.

73 Exports of Chinese sacks were valued at $804 

million in 2008, $712 million in 2009, $818 million in 2010, $970 million in 2011, and $988 

million in 2012.74 Furthermore, notwithstanding the declines in the volume of subject 

merchandise since imposition of the orders, the U.S. market was the second largest market for 

exports of sacks and bags from China.75 China exported $104 million worth of sacks to the 

United States in 2012.76 These data indicate that the industry in China is export oriented and 

views the U.S. market as attractive – a proposition confirmed by the continued presence of 

subject imports in the U.S. market even after imposition of the orders.

We therefore find that, in light of the increasing amounts of exports from China and the 

United States’s position as a leading importer of sacks and bags, the laminated woven sack 

industry in China is likely to use its increased capacity and production to increase exports of 

subject merchandise to the United States to significant levels upon revocation of the orders, as 

it did during the original investigations.

77 We consequently find that the likely volume of 

subject imports, both in absolute terms and relative to consumption in the United States, would 

be significant if the orders were revoked. 

concerning laminated woven sacks from China other than the ones subject to these reviews. CR at I-25, 

PR at I-19.

70 Comments at 7; see CR/PR, Table I-6. 71 Response at 15. 72 See CR/PR at Tables I-7-9. The data available in these reviews cover a broader scope of sacks 

and bags than those in the scope of the antidumping and countervailing duty orders. 

73 CR/PR at Table I-8. 74 CR/PR at Table I-8. The second largest exporter of sacks, Turkey, exported $101 million worth 

of sacks and bags in 2012. Id. 75 CR/PR at Table I-7. 

76 CR/PR at Table I-7. 77 There are no antidumping or countervailing duty orders on subject imports in effect in any 

third countries.

12

 

(...Continued)
D. Likely Price Effects 

Original Investigations. In the original investigations, the Commission found that 

subject laminated woven sacks significantly undersold the domestic like product and 

suppressed prices of the domestic like product. Because laminated woven sacks were sold on a 

spot basis, with pricing determined on a transaction-by-transaction basis, the Commission 

found that price was an important factor in purchasing decisions. The subject imports 

undersold the domestic product in each of the 31 quarterly comparisons, involving three pricing 

products, by margins ranging from 18.9 percent to 57.9 percent.78 Furthermore, the record in 

the original investigations showed that the domestic industry’s costs increased over the POI, 

but that the domestic industry was unable to raise its prices to compensate due to persistent 

underselling by the subject merchandise. The Commission concluded that consistent and 

significant price underselling of the domestic like product by subject imports led to significant 

price suppression of the domestic product.79

Current Reviews. There is no new product-specific pricing information on the record of 

these expedited reviews. As noted above, we find that the domestic like product and the 

subject imports are highly substitutable and that price continues to be an important factor in 

purchasing decisions. Because price is an important factor in purchasing decisions, subject 

imports would likely increase their sales in the U.S. market by underselling the domestic like

product at high margins, as they did in the in the original investigations. We consequently find 

that if the antidumping and countervailing duty orders were revoked, there is likely to be 

significant price underselling by imports of the subject merchandise as compared to the 

domestic like product. This in turn would likely cause the domestic producers to cut prices or 

restrain price increases to avoid losing sales. 

Accordingly, given the likely significant volume of subject imports, we conclude that 

significant underselling of the domestic like product by subject imports to gain market share is 

likely and that the significant volume of low-priced subject imports would likely have significant 

depressing or suppressing effects on the price of the domestic like product if the antidumping 

and countervailing duty orders were revoked.

78 Original Determination, USITC Pub. 4025 at 39.

79 Original Determination, USITC Pub. 4025 at 41.

13

 
E. Likely Impact80

Original Investigations. In its original investigations, the Commission acknowledged 

that the record showed apparent improvements in the domestic industry’s production, 

shipments, and market share, but concluded that these improvements were offset by the 

domestic industry’s low level of capacity utilization.81 The Commission found that the levels of 

capacity utilization, despite increasing from 2005 to 2007, continued to be low throughout the 

POI notwithstanding significant increases in demand.82 Additionally, the Commission found 

that even though the parties reported that laminated woven sacks were produced to order, the 

domestic industry’s inventories increased over the POI.83

The Commission found that the average number of production-related workers, hours 

worked, wages paid, and hourly wages were all higher in 2007 than in 2005.84 Unit labor costs 

and productivity were mixed, largely due to the addition of new domestic producers during the 

POI.85 

The record in the original investigations showed that although net sales measured by 

quantity and net sales values increased over the POI, net sales unit values did not keep pace 

with increasing costs.86 The Commission observed that the cost of goods sold (“COGS”) was 

89.7 percent of sales in 2005, 102.1 percent of sales in 2006, and 94.4 percent of sales in 

2007.87 This led to operating losses in each year of the POI.88 Operating losses increased from 

80 Under the statute, “the Commission may consider the magnitude of the margin of dumping” 

in making its determination in a five-year review. 19 U.S.C. § 1675a(a)(6). The statute defines the 

“magnitude of the margin of dumping” to be used by the Commission in five-year reviews as “the 

dumping margin or margins determined by the administering authority under section 1675a(c)(3) of this 

title.” 19 U.S.C. § 1677(35)(C)(iv); see also SAA at 887.

Commerce expedited its antidumping duty review determination and found that revocation of 

the antidumping duty order would likely lead to continuation or recurrence of dumping at the following 

margins: 47.64 percent as the China-wide rate and 20.19 percent for the individually investigated 

exporters and producers. Laminated Woven Sacks From the People’s Republic of China: Final Results of 

Expedited First Sunset Review of the Antidumping Duty Order, 78 Fed. Reg. 64472 (Oct, 29, 2013) (listing 

each individually investigated exporter and/or producer).

Commerce also expedited its countervailing duty review determination and found that 

revocation of the order would likely lead to continuation or recurrence of a countervailable subsidy at 

rates between 83.34 and 406.62 percent for individually investigated exporters and producers, and 

280.65 percent as the China-wide rate. Laminated Woven Sacks From the People’s Republic of China: 

Final Results of the Expedited Sunset Review of the Countervailing Duty Order, 78 Fed. Reg. 69369 (Nov.

19, 2013).

81 Original Determination, USITC Pub. 4025 at 43-44.

82 Original Determination, USITC Pub. 4025 at 43.

83 Original Determination, USITC Pub. 4025 at 43.

84 Original Determination, USITC Pub. 4025 at 44.

85 Original Determination, USITC Pub. 4025 at 44.

86 Original Determination, USITC Pub. 4025 at 44.

87 Original Determination, USITC Pub. 4025 at 44.

14

 
2005 to 2006, but improved in 2007.89 Capital expenditures fluctuated over the POI, and 

research and development expenditures increased each year of the POI.90

The Commission concluded that subject imports had an adverse impact on the condition 

of the domestic industry during the POI. It found that the absolute and relative volumes of 

subject imports were significant, and that the large and increasing volume of subject imports 

dominated the U.S. market. The subject imports suppressed prices to a significant degree, and 

caused a young domestic industry to operate at very low levels of capacity utilization, which 

resulted in the inability of the domestic industry to cover its costs and expenses during a period 

of increased demand.91

Current Reviews. The information available concerning the domestic industry’s 

condition in these reviews consists of the data that the domestic producers provided in 

response to the notice of institution. The limited record is insufficient for us to make a finding 

on whether the domestic industry is vulnerable to the continuation or recurrence of material 

injury in the event of revocation of the orders.

92

In 2012, the capacity of the reporting domestic producers of laminated woven sacks was 

*** sacks, production was *** sacks, and capacity utilization was *** percent.93 U.S. shipments 

were *** sacks, and domestic producers reported an operating income of $*** from sales of 

$***, resulting in an operating income margin of *** percent in 2012.94 

Based on the information on the record, we find that should the orders be revoked, the 

likely significant volume and adverse price effects of the subject imports would likely have a 

significant adverse impact on the production, shipments, sales, market share, and revenues of 

the domestic industry. This impact would likely cause declines in the domestic industry’s 

financial performance.

We have also considered the role of factors other than subject imports, including the 

presence of nonsubject imports, so as not to attribute injury from other factors to the subject 

imports. Nonsubject imports have been present in the U.S. market since the original orders 

were imposed in 2008,95 but the condition of the domestic industry has improved during this 

period. We find that the presence of nonsubject imports is not likely to sever the causal nexus 

88 Original Determination, USITC Pub. 4025 at 44.

89 Original Determination, USITC Pub. 4025 at 44.

90 Original Determination, USITC Pub. 4025 at 45.

91 Original Determination, USITC Pub. 4025 at 45.

92 Based on the limited record of this review, Commissioner Pinkert finds the evidence mixed 

with respect to vulnerability. The domestic industry has substantial unused capacity, with a capacity 

utilization rate of only *** percent in 2012. Although the industry’s production, shipments, and 

aggregate net sales value improved from 2007 to 2012, the industry enjoyed an operating margin of 

only *** percent in 2012. Finally, apparent U.S. consumption rose from 2007 to 2012. CR/PR at Table I-2 

and Table I-6.

93 CR/PR at Table I-2.

94 CR/PR at Table I-2.

95 CR/PR at Tables I-4-6. Nonsubject imports as a share of the U.S. market were *** percent in 

2012.

15

 

(...Continued)
between subject imports and their likely significant adverse impact on the domestic industry if 

the orders were revoked. 

Accordingly, we conclude that if the orders were revoked, subject imports would likely 

have a significant adverse impact on the domestic industry within a reasonably foreseeable 

time.

IV. Conclusion

For the above reasons, we determine that revocation of the antidumping and 

countervailing duty orders on laminated woven sacks from China would likely lead to 

continuation or recurrence of material injury to an industry in the United States within a 

reasonably foreseeable time.

16
INFORMATION OBTAINED IN THE REVIEW

INTRODUCTION

Background

Effective July 1, 2013, the U.S. International Trade Commission (“Commission” or 

“USITC”) gave notice, pursuant to section 751(c) of the Tariff Act of 1930, as amended (“the 

Act”),1 that it had instituted reviews to determine whether revocation of the antidumping and 

countervailing duty orders on laminated woven sacks from China would be likely to lead to the 

continuation or recurrence of material injury to a domestic industry within a reasonably 

foreseeable time.

2 3 On October 21, 2013, the Commission determined that it would conduct 

expedited reviews pursuant to section 751(c)(3) of the Act.4 The following tabulation presents 

information relating to the background and schedule of this proceeding:

Effective date Action

August 7, 2008

Commerce’s antidumping and countervailing duty orders on laminated woven sacks 

from China

73 FR 45941 and 73 FR 45955

July 1, 2013

Commission’s institution of first five-year reviews

78 FR 39319

July 1, 2013

Commerce’s initiation of first five-year reviews

78 FR 39256

October 21, 2013

Commission’s scheduling of expedited five-year reviews 

(78 FR 68473, November 14, 2013)

1 19 U.S.C. 1675(c). 2 Laminated Woven Sacks From China; Institution of Five-Year Reviews, 78 FR 39319, July 1, 2013. All 

interested parties were requested to respond to this notice by submitting the information requested by 

the Commission.

3 In accordance with section 751(c) of the Act, the U.S. Department of Commerce (“Commerce”) 

published a notice of initiation of five-year reviews of the subject antidumping and countervailing duty 

orders concurrently with the Commission’s notice of institution. Initiation of Five-Year (“Sunset”) 

Review, 78 FR 39256, July 1, 2013. 4 Laminated Woven Sacks From China; Scheduling of Five-Year Reviews Concerning the Countervailing 

Duty and Antidumping Duty Orders on Laminated Woven Sacks From China, 78 FR 68473, November 14, 

2013. The Commission received one response to its notice of institution filed by the Laminated Woven 

Sacks Committee, whose members account for substantially all domestic production of laminated 

woven sacks. The Commission did not receive any responses from producers in China or U.S. importers 

of the subject merchandise from China. The Commission determined that the domestic interested party 

group response to its notice of institution was adequate and that the respondent interested party group 

response was inadequate. In the absence of respondent interested party responses and any other 

circumstances that would warrant the conduct of full reviews, the Commission determined to conduct 

expedited reviews.

I-2

 
Effective date Action

The press release announcing the Commission’s determination concerning 

adequacy and the conduct of expedited reviews can be found at 

http://usitc.gov/press_room/news_release/2013/er1021ll4.htm

October 29, 2013

Commerce’s final results of expedited five-year reviews of the antidumping duty 

orders (78 FR 64472)

November 19, 2013

Commerce’s final results of expedited five-year reviews of the countervailing duty 

orders (78 FR 69369)

February 28, 2014 Commission’s vote

March 11, 2014 Commission’s determinations and views to Commerce

The original investigations

The original investigations resulted from petitions filed on June 28, 2007, by the 

Laminated Woven Sacks Committee (“the Committee”)5, alleging that an industry in the United 

States was materially injured and threatened with material injury by reason of subsidized and

less-than-fair-value (“LTFV”) imports of laminated woven sacks from China. On June 24, 2008,

Commerce determined that imports of laminated woven sacks from China were being 

subsidized6 and sold at LTFV.7 On July 30, 2008, the Commission determined that an industry in 

the United States was materially injured by reason of subsidized and LTFV imports of laminated 

woven sacks from China.8 Commerce issued antidumping and countervailing duty orders on

laminated woven sacks from China on August 7, 2008.9

Commerce’s final results of expedited first five-year reviews

On October 29, 2013, Commerce determined that revocation of the antidumping duty 

order on laminated woven sacks from China would likely lead to continuation or recurrence of 

dumping at the weighted-average margins of 20.19 percent for individually listed 

5 The Committee consisted of individual members: Bancroft Bag, Inc.; Coating Excellence 

International, LLC; Hood Packaging Corp.; Mid-America Packaging, LLC; and Polytex Fibers Corp.

6 Laminated Woven Sacks From the People’s Republic of China: Final Affirmative Countervailing Duty 

Determination and Final Affirmative Determination, in Part, of Critical Circumstances, 73 FR 35639, June 

24, 2008. 7 Laminated Woven Sacks From the People’s Republic of China: Final Determination of Sales at Less 

Than Fair Value and Partial Affirmative Determination of Critical Circumstances, 73 FR 35646, June 24, 

2008.

8 Laminated Woven Sacks From China; Determinations, 73 FR 45473, August 5, 2008.

9 Laminated Woven Sacks From China: Countervailing Duty Order, 73 FR 45955, August 7, 2008; and 

Notice of Antidumping Duty Order: Laminated Sacks From the People’s Republic of China, 73 FR 45941, 

August 7, 2008.

I-3

 
exporters/producers and 47.64 percent for the all other rate. 10 On November 19, 2013, 

Commerce determined that revocation of the countervailing duty order on laminated sacks 

from China would likely lead to continuation or recurrence of net countervailable subsidies at 

rates between 83.34 and 406.62 percent for individually listed exporters/producers, and 280.65 

percent for all others.11 

Commerce’s administrative reviews

Commerce has completed three administrative reviews of the antidumping duty order 

on laminated woven sacks from China. The results of the administrative reviews are shown in 

Table I-1. Commerce conducted one anti-circumvention inquiry, in which it found that 

laminated woven sacks produced with two ink colors printed in register and a screening process 

(“screening-process sacks”) were not circumventing the antidumping and countervailing duty 

orders on laminated woven sacks.

12

Table I-1

LW Sacks: Administrative reviews of the antidumping duty order

Date results 

published Period of review Producer or exporter

Weightedaverage margin 

(percent)

March 18, 2011

(76 FR 14906) 01/31/08 – 07/31/09

PRC-Wide (including Zibo Aifudi 

Plastic Packaging Co., Ltd.) 91.73

April 15, 2011

(76 FR 21333) 08/01/09 – 07/31/10

PRC-Wide (including Zibo Aifudi 

Plastic Packaging Co., Ltd.) 91.73

March 29, 2013

(78 FR 19209) 08/01/11 – 07/31/12

PRC-Wide (including Zibo Aifudi 

Plastic Packaging Co., Ltd.) 91.73

Source: Cited Federal Register notices.

Previous and related title VII investigations

Other than the original investigations, laminated woven sacks have not been the subject 

of antidumping or countervailing duty investigations in the United States. 

10 Laminated Woven Sacks From the People’s Republic of China: Final Results of Expedited First Sunset 

Review of the Antidumping Duty Order, 78 FR 64472, October 29, 2013. 11 Laminated Woven Sacks From the People’s Republic of China: Final Results of the Expedited Sunset 

Review of the Countervailing Duty Order, 78 FR 69369, November 19, 2013. 12 Laminated Woven Sacks From the People’s Republic of China: Negative Final Determination of 

Circumvention, 78 FR 12716, February 25, 2013.

I-4

 
THE PRODUCT

Commerce’s scope

In its final results of the expedited first five-year reviews of the antidumping and 

countervailing duty orders, Commerce defined the subject merchandise as:

13

The merchandise covered by the order is laminated woven sacks. 

Laminated woven sacks are bags or sacks consisting of one or more plies 

of fabric consisting of woven polypropylene strip and/or woven 

polyethylene strip, regardless of the width of the strip; with or without an 

extrusion coating of polypropylene and/or polyethylene on one or both 

sides of the fabric; laminated by any method either to an exterior ply of 

plastic film such as biaxially-oriented polypropylene ("BOPP") or to an 

exterior ply of paper that is suitable for high quality print graphics;14

printed with three colors or more in register; with or without lining; 

whether or not closed on one end; whether or not in roll form (including 

sheets, lay-flat tubing, and sleeves); with or without handles; with or 

without special closing features; not exceeding one kilogram in weight. 

Laminated woven sacks are typically used for retail packaging of 

consumer goods such as pet foods and bird seed. 

Effective July 1, 2007, laminated woven sacks are classifiable under 

Harmonized Tariff Schedule of the United States ("HTSUS") subheadings 

6305.33.0050 and 6305.33.0080. Laminated woven sacks were previously 

classifiable under HTSUS subheading 6305.33.0020. If entered with 

plastic coating on both sides of the fabric consisting of woven 

polypropylene strip and/or woven polyethylene strip, laminated woven 

sacks may be classifiable under HTSUS subheadings 3923.21.0080, 

3923.21.0095, and 3923.29.0000. If entered not closed on one end 

or in roll form (including sheets, lay-flat tubing, and sleeves), laminated 

woven sacks may be classifiable under other HTSUS subheadings 

including 3917.39.0050, 3921.90.1100, 3921.90.1500, and 5903.90.2500. 

If the polypropylene strips and/or polyethylene strips making up the 

fabric measure more than 5 millimeters in width, laminated woven sacks 

13 Issues and Decision Memorandum for the Final Results of Expedited First Sunset Review of the 

Antidumping Duty Order on Laminated Woven Sacks from the People’s Republic of China, from Christian 

Marsh, Deputy Assistant Secretary for Antidumping and Countervailing Duty Operations, to Paul 

Piquado, Assistant Secretary for Enforcement and Compliance, October 23, 2013. 14 “Paper suitable for high quality print graphics,” as used herein, means paper having an ISO 

brightness of 82 or higher and a Sheffield Smoothness of 250 or less. Coated free sheet is an example of 

a paper suitable for high quality print graphics. 

I-5

 
may be classifiable under other HTSUS subheadings including 

4601.99.0500, 4601.99.9000, and 4602.90.0000. Although HTSUS 

subheadings are provided for convenience and customs purposes, the 

written description of the scope of the order is dispositive.

Commerce has made several scope rulings since the original investigation. On August 

27, 2009, Commerce found Products A and Product B described as: (1) Made of a single ply of 

woven polypropylene strip; (2) laminated with biaxially-oriented polypropylene (‘‘BOPP’’) are 

within the scope of the antidumping and countervailing duty orders; (3) printed in three colors; 

and (4) of less than one kilogram in weight are within the scope of the antidumping duty order; 

Products C, D and F described as each having no lamination or coating of BOPP are outside the 

scope of the antidumping and countervailing duty orders; and Product E described as: (1) Made 

of a single ply of woven polypropylene strip; (2) laminated with BOPP; (3) printed in two colors; 

and (4) less than one kilogram in weight is outside the scope of the antidumping and 

countervailing duty orders. 

On March 24, 2010, Commerce determined that Shapiro Packaging’s three imported 

sacks are not merchandise covered by the scope of the orders.

On February 21, 2012, Commerce found that the laminated woven sacks produced by 

The Super Poly Partnership from imported woven fabric are not within the scope of the 

antidumping duty and countervailing duty orders.

U.S. tariff treatment

During the original investigations, laminated woven sacks of polyethylene or 

polypropylene strip or the like, which are treated for tariff purposes as being “of textile 

materials,” were classified in the HTS under subheading 6305.33.00 (with initial import 

reporting under statistical reporting number 6305.33.0020), while subject goods not of textile 

materials were classified in other HTS chapters. Effective July 1, 2007, new statistical reporting 

provisions were established to cover such laminated woven sacks, with those weighing less 

than 1 kilogram and having outer laminated ply of plastics sheeting in statistical reporting 

number 6305.005015 and other such sacks reported under 6305.33.0080.16 17 

15 This statistical reporting number would include laminated woven sacks laminated with BOPP film, 

but not laminated woven sacks laminated with paper, and therefore, would not contain all types of 

products within the scope of these investigations. 

16 This HTS statistical reporting number, 6305.33.0080, is a residual or “basket” category for goods of 

polyethylene or polypropylene strip or the like that each weigh less than one kilogram. 17 Effective as of July 1, 2013, statistical reporting number 6305.33.0050 was subdivided to allow the 

gathering of data on goods printed with three or more colors (6305.33.0040) and other sacks weighing 

less than 1 kilogram (6305.33.0060). The column 1-general duty rate under subheading 6305.33.00 is 

8.4 percent ad valorem.

I-6

 
Domestic like product and domestic industry

In the final phase of the original investigations, the Commission found a single domestic 

like product comprised of all laminated woven sacks, regardless of their dimension, strength, 

closure, or design that corresponded to the scope of the investigations. No party advocated 

defining the domestic like product differently.

18 The Commission defined a single domestic 

industry producing the domestic like product.19

In its notice of institution for these reviews, the Commission solicited comments from 

interested parties regarding the appropriate domestic like product and domestic industry. In 

the Committee’s response to the Commission’s notice of institution, it indicated that it agrees 

with the Commission’s definition of the domestic like product and domestic industry as defined 

by the Commission in the original investigations.

20 The Commission did not receive any other 

responses to the notice of institution. 

Description and uses21

Laminated woven sacks are primarily made from polypropylene woven fabric. 

Laminated woven sacks have improved physical properties compared with multi-wall paper 

sacks because they weigh less, occupy less storage space, are more tear-resistant, and have 

greater tensile strength leading to less breakage. Compared to multi-wall paper sacks, 

laminated woven sacks are resistant to water, oil, and grease, resulting in less material 

breakdown and leakage and leading to cost savings for the consuming industry. The pet supply 

industry values the high quality print graphics on the laminated woven sacks, particularly those 

laminated with BOPP film, because the lamination helps to maintain the integrity of the 

graphics. Laminated woven sacks are generally used by pet food, bird seed, grass seed, 

fertilizer, and other manufacturers as flexible packaging for their consumer goods that typically 

weigh between 17 and 55 pounds. 

18 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), USITC 

Publication 4025, July 2008, p. 6.

19 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), USITC 

Publication 4025, July 2008, p. 13.

20 The Committee’s Response to the Commission’s Notice of Institution, July 30, 2013, p. 26. 21 Unless otherwise noted this information is based on the following publication: Laminated Woven 

Sacks from China, Inv. Nos. 701-TA-450 and 731-TA-1122 (Final), USITC Publication 4025, July 2008. The 

Committee reported that there have been no significant changes in uses and applications of laminated 

woven sacks since the original investigations and no other substitutes have entered the market. The 

Committee’s Response to the Notice of Institution, July 30, 2013, p. 26.

I-7

 
Production process22

The production of laminated woven sacks involves several separate staged operations, 

which allow for a producer to enter into the production scheme at a number of different steps, 

resulting in a variation of starting materials. The initial step for the most vertically integrated of 

the domestic producers (i.e., Polytex) involves the melting of PP (or PE) pellets and extrusion 

into a sheet of a specific thickness. The sheets are then cut into thin flat strips that are spooled 

onto a bobbin for weaving into the necessary fabric. Figure I-1 shows a schematic of the 

extrusion equipment used to produce the required polyethylene or polypropylene sheet for the 

laminated woven sacks. The dry PP pellets are loaded into a receptacle (hopper), and then fed 

into a grating chamber through the action of a revolving screw. At the end of the heating 

chamber, the molten plastic material is forced through a small opening, shaped in the form of 

the desired product, and is subsequently fed onto a conveyor belt on which it is cooled either 

by air blowers or by water.

Once sheets have been cut into strips (or tapes), the strips are fed through a hot air 

stretching oven and to a stretching unit to add strength and stability before being wound onto 

the bobbins. 

The second discrete step in laminated sacks production involves the weaving of the 

spooled PP strip into fabric (see figure I-2). Although eventually the laminated woven sacks can 

be made using either a tubular woven form or from a flat woven sheet, both are made from the 

same weaving process that initially produces the tubular woven form. The tubular woven 

material is used directly to produce the seamless laminated woven sacks; however, the tubular 

woven material is slit to produce the flat sheet form (which requires a heat-sealing step at a 

later stage of production) to produce “back seam LW sacks.” The equipment used in the 

weaving process can produce various widths of fabric for different size laminated woven sacks, 

by variation of the weaving ring.

The differences between the laminated woven sacks produced from the tubular woven 

material (“tubular sacks”) and that produced from a flat material (“vertical back seam sacks”), 

both in terms of the costs involved in the slightly different processes and the differences in 

functionality, were cited repeatedly by parties testifying at the conference during the 

preliminary phase of the investigations. Consequently, the domestic producers indicated in 

their responses to the questionnaire that in 2007, five of the six responding domestic producers 

of laminated woven sacks produced only vertical back seam sacks and only one producer 

produced the tubular sacks. 

22 Unless otherwise noted this information is based on the following publication: Laminated Woven 

Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), Staff Report, INV-FF-075, July 

2, 2008. The Committee reported that no major changes in production methods, development efforts, 

ability to increase production, or factors related to the ability to shift supply among different national 

markets; however, lamination technology used to produce laminated woven sacks has mature allowing 

Chinese producers to more easily and quickly establish operations then they could during the POI. The 

Committee’s Response to the Notice of Institution, July 30, 2013, p. 25.

I-8

 
Figure I-1

LW sacks: Extrusion line and slitter for producing polypropylene strips

Source: Laminated Woven Sacks from China, Inv. No. 701-TA-450 and 731-TA-1122 (Final),

USITC Publication 4025, July 2008, p. I-11.

Figure I-2

LW sacks: Weaving process

Source: Laminated Woven Sacks from China, Inv. No. 701-TA-450 and 731-TA-1122 (Final),

USITC Publication 4025, July 2008, p. I-12.

Also, the domestic producers responded to a question on the material that was being 

used to laminate the laminated woven sacks, indicating that in 2007 two producers laminated 

I-9
sacks exclusively with paper, three producers laminated exclusively with BOPP-film, and one 

U.S. producer reported that it produced sacks with both paper and BOPP-film. 

Printing onto the laminate prior to the lamination process provides another of the 

features that gives laminated woven sacks an advantage over previous packaging alternatives. 

Producers of laminated woven sacks reverse print onto the laminate material, a plastic film 

such as BOPP (or directly print onto an exterior ply of laminating paper). Both of these 

laminates are suitable for high quality print graphics, allowing for the application of high quality 

print graphics in multiple colors that serve as point-of-sale advertising for packaged consumer 

goods.

Once printed, the lamination step (see figure I-3) bonds the laminate material directly to 

the woven sack material. The process involves a “curtain of liquid PP” that is allowed to “flow 

between the film and the fabric, immediately forming a bonding center layer.” When bonding 

the laminate to the flat woven sheet format, only one side of the material is laminated. 

However, when bonding the laminate to the woven tube formatted material, the laminate is 

bonded to two sides (at the same time). The dual-sided process often results in the extra 

laminate extending along two sides of the resulting laminated woven sacks, referred to by the 

respondents as “fins.”

Figure I-3 

LW sacks: Lamination process

Source: Laminated Woven Sacks from China, Inv. No. 701-TA-450 and 731-TA-1122 (Final),

USITC Publication 4025, July 2008, p. I-13.

I-10
After lamination, in the case of the flat sheet laminated material, the rolls are sent to a 

tuber, where the fabric is formed into a continuous tube, gusseted, and cut into individual 

pieces. The individual tubes are then transferred to a sewing line where they are sewn and 

formed into individual sacks of the required dimensions. In the case of the already tubular 

formed laminate, there is no tubing or gusseting; the laminated tubular form is cut and sewn 

into the individual sacks. In both cases, the bags are finished by sewing the bottom and 

applying closure tape and the pull tape for easy opening. The bags are then inspected and 

packaged for shipment. 

Interchangeability and customer and producer perceptions

In the original investigations, both petitioners and respondents believed that laminated 

woven sacks were not a commodity product. A strong majority of questionnaire respondents (5

of 5 U.S. producers, 7 of 13 importers, and 23 of 28 purchasers) stated that domestically 

produced laminated woven sacks and subject imports from China were either “always” or

“frequently” interchangeable. The majority or a plurality of responding purchasers indicated 

that laminated woven sacks produced in the United States and those imported from China were 

comparable for all of the different purchasing factors polled except for lower price. For lower 

price, a majority of purchasers indicated that the domestically produced laminated woven sacks 

were higher priced than the Chinese product.23

Channels of distribution

U.S. producers and U.S. importers of laminated woven sacks sell primarily to end users. 

Typical end users include manufacturers of consumer goods such as pet foods, grass seed, and 

some other feed products. All U.S. producers of laminated woven sacks reported shipping at 

least 25 percent of their shipments over 100 miles from their storage or production facilities. 

Six U.S. importers reported selling at least one-half of their shipments within 100 miles of their 

storage facilities; five U.S. importers reported making at least one-half of their shipments 

between 101 and 1,000 miles of their storage facilities; and the remaining six U.S. importers 

reported making at least one-half of their shipments over 1,000 miles from their storage 

facilities.24

23 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), Staff 

Report, INV-FF-075, July 2, 2008, p. II-10. 24 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), Staff 

Report, INV-FF-075, July 2, 2008, p. II-1.

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Pricing and related information

In the original investigations, the Commission collected price data for three products. In 

all 31 quarterly price comparisons between U.S. produced and imported Chinese products, 

prices for the Chinese products were lower than those for their U.S. counterparts. The margins 

of underselling ranged from 18.9 percent to 57.9 percent.

25 Respondents claimed these 

comparisons are not evidence of price differences because U.S. producers earn a premium for 

their lead time advantage and that U.S. producers sell a significantly greater share of tubular 

sacks than Chinese importers’ vertical back seam laminated woven sacks which packagers do 

not regard as fully interchangeable with vertical back seam laminated woven sacks on their 

equipment. Respondents also indicate that the tubular laminated woven sacks are sold to 

different customers than vertical-back seam laminated woven sacks.26

Raw materials costs as a share of COGS increased from 55.2 percent in 2005 to 62.0 

percent in 2007. The primary raw material used in the production of laminated woven sacks is 

polypropylene (or polypropylene resin), making up approximately 60 to 70 percent of the cost 

of production according to respondents.

27

During the original investigations, demand for laminated woven sacks increased as 

customers began to switch from multi-wall paper sacks because of greater durability, improved 

print graphics, and price competitiveness. Demand was expected to increase as pet food 

producers, the largest section of the U.S. market, make the change to laminated woven sacks.28

The Committee reported that there have been no significant changes to demand conditions 

since 2008 and that none of these demand conditions are likely to change within a reasonably 

foreseeable time.29

THE INDUSTRY IN THE UNITED STATES

U.S. producers

In the original investigations, the Commission issued questionnaires to seven producers 

and received questionnaire responses with usable data from six firms accounting for virtually all 

25 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), Staff 

Report, INV-FF-075, July 2, 2008, pp. V-2. 

26 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), Staff 

Report, INV-FF-075, July 2, 2008, p. V-11. 27 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), Staff 

Report, INV-FF-075, July 2, 2008, p. V-1. 28 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final),

Commission Views, pp. 54-56. 29 The Committee’s Response to the Notice of Institution, July 30, 2013, p. 26.

I-12

 
of U.S. production of the domestic like product in 2007.30 The producers’ share of 2007 U.S. 

production for each firm were as follows: (1) Polytex (***percent), (2) Coating Excellence (***

percent), (3) SeaTac (*** percent), (4) Hood (*** percent), (5) Mid-America (*** percent), and 

(6) Bancroft (*** percent).

31

In its response to the Commission’s notice of institution, the Committee identified the 

following ten laminated woven sacks producers: Coating Excellence International, LLC; Exopack 

Holding Corporation; Graphic Packaging International, Inc.; Hood Packaging Corporation; 

Polytex Fibers Corporation; SeaTac Packaging Manufacturing Corporation; JohnPac, Inc.; Central 

Bag Company; Cady Bag Company, LLC; and Grief, Inc.

32 The Committee estimates that its share 

of domestic production in 2012 will exceed ***percent.

33

Related party issues

During the original investigation, four U.S. producers of laminated woven sacks (Coating 

Excellence, Hood, Mid-America, and Polytex) imported subject merchandise and qualified as 

“related parties” under 19 U.S.C. § 1677(4)(B). However, the Commission found that 

“appropriate circumstances” did not exist to exclude these firms from the domestic industry

mostly due to *** and because of the ***.

34 The Committee reported in its response to the 

notice of institution in these first five-year reviews that it did not import laminated woven sacks 

from China and are not affiliated with any Chinese producers or exporters of laminated woven

sacks.35

U.S. producers’ trade and financial data

The Commission requested that domestic interested parties provide trade and financial 

data in their response to the notice of institution of these five-year reviews of the subject 

orders. Table I-2 presents the data reported by responding U.S. producers from both the 

original investigation (2005-07) and the responses to the notice of institution (2012).

30 The Commission did not receive a final questionnaire response from U.S. producer La Pac. In the 

preliminary phase of the original investigations, La Pac reported that it accounted for *** percent of 

2006 U.S. production of laminated woven sacks.

31 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), Staff 

Report, INV-FF-075, July 2, 2008, p. III-4, table III-3.

32 The Committee’s Response to the Notice of Institution, July 30, 2013, exh. 7.

33 The Committee’s Response to the Notice of Institution, July 30, 2013, p. 25.

34 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122

(Final), USITC Publication 4025, July 2008, Views of the Commission, pp. 13-21

35 The Committee’s Response to the Notice of Institution, July 30, 2013, p. 25.

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Table I-2

LW Sacks: U.S. producers’ trade and financial data, 2005-07 and 2012

Item 2005 2006 2007 2012

Capacity (1,000 sacks) 111,301 172,783 232,953 ***

Production (1,000 sacks) 15,240 28,287 52,231 ***

Capacity utilization (percent) 13.7 16.4 22.4 ***

U.S. shipments

 Quantity (1,000 sacks) 14,190 26,075 51,411 ***

 Value ($1,000) 7,682 15,692 30,656 ***

 Unit value (dollars per sack) $0.54 $0.60 $0.60 ***

Net sales value ($1,000) 7,681 15,581 31,312 ***

Cost of goods sold (COGS) ($1,000) 6,889 15,915 29,559 ***

Gross profit or (loss) ($1,000) 792 (333) 1,753 ***

SG&A ($1,000) 1,093 2,560 3,357 ***

Operating income or (loss) ($1,000) (301) (2,893) (1,604) ***1

COGS/sales (percent) 89.7 102.1 94.4 ***

Operating income or (loss)/sales 

(percent) (3.9) (18.6) (5.1) *** 1 Staff calculates operating profit as ***. The difference between reported and calculated operating profit 

is due to the numbers reported by ***.

Source: Laminated Woven Sacks from China, Inv. No. 701-TA-450 and 731-TA-1122 (Final), USITC 

Publication 4025, July 2008, Tables III-3, III-6 and VI-1. The Committee’s Response to the Notice of 

Institution, July 30, 2013, exh. 4.

U.S. IMPORTS AND APPARENT CONSUMPTION

U.S. imports

In the original investigations, the Commission received usable U.S. importer 

questionnaires from 21 firms that imported laminated woven sacks from China and other 

nonsubject countries. In 2007, *** was the largest importer of laminated woven sacks, 

accounting for *** percent of reported U.S imports from China in 2007.36

In its response to the Commission’s notice of institution in these reviews, the 

Committee identified 21 current operating U.S. importers of laminated woven sacks.

37

Table I-3 presents U.S. import data by source, from 2008 to 2012. According to official 

Commerce import data, China was the second largest source of imported laminated woven 

sacks in 2012, representing 16.7 percent of U.S. imports, by quantity. The largest source of 

imported laminated woven sacks was Vietnam, representing 56.2 percent of total imports.

36 Laminated Woven Sacks from China, Inv. No. 701-TA-450 and 731-TA-1122 (Final), USITC 

Publication 4025, July 2008, p. IV-2 and table IV-1.

37 The Committee’s Response to the Notice of Institution, July 30, 2013, exh 8.

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Table I-3

LW Sacks: U.S. import data, by source, 2008-12

Item

Calendar year

2008 2009 2010 2011 2012

 Quantity (1,000 sacks)

China 51,597 36,946 46,718 38,694 30,580

All other sources 97,836 151,971 154,147 137,390 153,055

 Total imports 149,433 188,917 200,866 176,085 183,636

 Value ($1,000)

China 15,972 9,848 13,933 13,284 10,196

All other sources 41,810 60,441 59,422 55,286 59,500

 Total imports 57,782 70,289 73,355 68,570 69,696

 Unit value (dollars per sack)

China 0.31 0.27 0.30 0.34 0.33

All other sources 0.43 0.40 0.39 0.40 0.39

 Average 0.39 0.37 0.37 0.39 0.38

 Share of quantity (percent)

China 34.5 19.6 23.3 22.0 16.7 

All other sources 65.5 80.4 76.7 78.0 83.3 

 Total imports 100.0 100.0 100.0 100.0 100.0 

Share of value (percent)

China 27.6 14.0 19.0 19.4 14.6

All other sources 72.4 86.0 81.0 80.6 85.4

 Total imports 100.0 100.0 100.0 100.0 100.0 

Source: Data compiled from official Commerce statistics, HTS number 6305.33.0050, using the weight-tonumber of sacks conversion rate of 8,000 sacks to 1 short ton to 907 kilograms. 

Ratio of imports to U.S. production

The ratios of imports from China and nonsubject countries during 2005-07 and 2012 are 

shown in table I-4 below.

Table I-4

LW Sacks: Ratio of U.S. imports to U.S. production, 2005-07 and 2012

Item

Calendar year

2005 2006 2007 2012

Ratio of imports to U.S. production (percent)

China 736.6 541.5 448.7 ***

All other countries *** *** *** ***

Total imports *** *** *** ***

Source: Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final),

Staff Report, INV-FF-075, July 2, 2008, Table IV-7 and compiled from official Commerce statistics, 

HTSUS subheading 6305.33.0050 for 2012.

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Apparent U.S. consumption and market shares

Table I-5 shows U.S. shipments of domestic product, U.S. imports and apparent U.S. 

consumption in 2005-07 and 2012. Table I-6 shows U.S. market shares during 2005-07 and 

2012.

Table I-5

LW Sacks: U.S. shipments of domestic product, U.S. imports, and apparent U.S. consumption, 

2005-07 and 2012

Item

Calendar Year

2005 2006 2007 2012

Quantity (1,000 sacks)

U.S. producers’ U.S. shipments 14,190 26,075 51,411 ***

U.S. imports from--

 China 112,262 153,182 234,368 30,580

 All other sources *** *** *** 153,055

 Total imports *** *** *** 183,636

Apparent U.S. consumption *** *** *** ***

Value (1,000 dollars)

U.S. producers’ U.S. shipments 7,682 15,692 30,656 ***

U.S. imports from--

 China 26,746 39,025 58,147 10,196

 All other sources *** *** *** 59,500

 Total imports *** *** *** 69,696

Apparent U.S. consumption *** *** *** ***

Source: Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final),

Staff Report, INV-FF-075, July 2, 2008, Table IV-5 and compiled from official Commerce statistics, 

HTSUS subheading 6305.33.0050 for 2012.

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Table I-6

LW Sacks: U.S. market shares, 2005-07 and 2012

Item

Calendar Year

2005 2006 2007 2012

Quantity (1,000 sacks)

Apparent U.S. consumption *** *** *** ***

Value (1,000 dollars)

Apparent U.S. consumption *** *** *** ***

Share of quantity (percent)

U.S. producers’ U.S. shipments *** *** *** ***

U.S. imports from--

 China *** *** *** ***

 All other sources *** *** *** ***

 Total imports *** *** *** ***

Share of value (percent)

U.S. producers’ U.S. shipments *** *** *** ***

U.S. imports from—

 China *** *** *** ***

 All other sources *** *** *** ***

 Total imports *** *** *** ***

Source: Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final),

Staff Report, INV-FF-075, July 2, 2008, Table IV-6 and compiled from official Commerce statistics, 

HTSUS subheading 6305.33.0050 for 2012.

THE INDUSTRY IN CHINA

Background

During the original investigations, the Commission requested data from 40 Chinese 

firms which were listed in the petition and believed to produce laminated woven sacks during 

the period of investigation. The Commission sent questionnaires to these firms and received 

one response, from Shandong Shouguag Jianyuanchun Co., Ltd. (“Shandong”), which claimed to 

account for approximately *** percent of Chinese production of laminated woven sacks and ***

percent of exports to the United States in 2007.38

In its response to the notice of institution in the first five-year reviews, the Committee 

identified 87 firms as producers/exporters of laminated woven sacks in China.39 

38 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), Staff 

Report, INV-FF-075, July 2, 2008, pp. VII-2, 3.

39 The Committee’s Response to the Commission’s Notice of Institution, July 30, 2013, exh. 9.

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Capacity and production

During the original investigations, the Commission received only one response to its 

request for data from firms believed to produce laminated woven sacks in China during the 

period of investigation.40 The response, submitted by Shangdong, reported an increase in 

capacity from *** sacks in 2005 to *** sacks in 2006, but then a decrease to *** sacks in 2007. In 

2007, *** percent of Shandong’s total shipments of laminated woven sacks were exported to the 

United States.41

The Committee reported that China’s laminated woven sacks production capacity has 

expanded in recent years. Shandong Shouguang Jianyuanchun Co., Ltd./Shandong Longxing 

Plastic Products Co., Ltd. increased its capacity of plastic woven sacks from 38 million pieces 

annually in 2009 to 80 million pieces annually in 2012. WhoKing Group Ltd. increased its annual 

production capacity for plastic woven sacks by approximately 2.8 billion pieces from 2008 to 

2013. Guangyuan Chengda Plastic Weaving Co., Ltd. began production in December 2012 of a 

laminated woven sack facility with annual capacity of 800 million pieces. Heilongjiang Province 

Nanyang Plastic Products Co., Ltd. began production in 2009 and expanded its annual capacity 

to 180 million pieces of plastic woven sacks (including laminated woven sacks). Baotoou Qiselu 

Packaging Co., Ltd. began high-strength production of laminated plastic woven sacks in April 

2013 with a capacity of 50 million pieces. Hubei Ruixiang Plastic Industry Co., Ltd., established 

in January 2010, began production of color-printed laminated woven sacks in June 2013 with an 

annual capacity of 50 million pieces. Zheijiang Huatai Plastic Group began construction of a 

medium and high-grade plastic woven sacks project in 2012.42

Exports

Table I-7 presents data for the top ten markets for Chinese exports of laminated woven 

sacks from 2008 to 2012. Except for 2010, when the United States was China’s largest market, 

Japan was China’s largest market. Total Chinese exports of laminated woven sacks increased 

from 2008 to 2012, by 22.9 percent.

40 During the preliminary phase of these investigations, a witness testified at the staff conference 

that there may be 300 to 400 producers of laminated woven sacks in China, 95 percent of which he 

believed to be small private-owned businesses concentrated on the Chinese home market and not 

export-oriented. Conference transcript, pp. 207-208 (Zhu). 41 Laminated Woven Sacks from China, Investigation Nos. 701-TA-450 and 731-TA-1122 (Final), Staff 

Report, INV-FF-075, July 2, 2008, pp. Vll-2 through Vll -4 & table Vll-1. 42 The Committee’s Response to the Commission’s Notice of Institution, July 30, 2013, pp. 15-17.

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Table I-7

LW Sacks: Chinese exports, by country, 2008-12

Country

Calendar Year

2008 2009 2010 2011 2012

Value ($1,000)

United States 116,530 98,737 104,092 105,552 104,345

Russia 51,819 43,440 54,513 77,521 101,553

Japan 151,381 103,284 94,714 117,883 109,982

South Korea 69,357 49,080 43,562 56,361 51,534

Philippines 15,968 19,218 28,826 42,476 42,324

Kazakhstan 31,212 25,546 34,106 43,769 67,185

Hong Kong 6,123 10,746 18,054 23,404 41,483

Canada 25,988 29,961 21,448 22,165 21,497

Australia 23,584 18,579 21,258 26,217 25,965

Ukraine 18,388 12,390 20,618 28,262 22,830

All others 293,845 301,394 377,058 426,205 400,002

World 804,193 712,375 818,249 969,814 988,701

Source: Global Trade Information Service (“Global Trade Atlas”), HTS code 630533, sacks and bags, of a 

kind used for the packing of goods: Other of polyethylene or polypropylene strip of the like. This HTS 

code is over inclusive and contains sacks and bags outside of the scope of the subject laminated woven 

sacks.

Tariff or non-tariff barriers to trade

There are no outstanding antidumping and/or countervailing duty measures against 

laminated woven sacks produced in China in third country markets.

THE GLOBAL MARKET

Table I-8 shows the ten largest exporting countries of laminated woven sacks. Total 

world exports increased by 20.5 percent from 2008 to 2012. 

I-19
Table I-8

LW Sacks: Exports by reporting country, 2008-12

Country

Calendar Year

2008 2009 2010 2011 2012

Value ($1,000)

China 804,193 712,375 818,249 969,814 988,701

Turkey 57,321 56,452 72,135 102,649 100,597

Thailand 79,357 70,174 79,099 79,856 83,107

Indonesia 62,400 48,165 69,929 85,812 67,601

Mexico 23,604 20,288 28,939 38,028 39,943

Ecuador 14,901 13,100 19,351 31,422 26,718

USA 26,826 20,863 26,497 25,368 25,267

Cote d’Ivoire 15,246 13,121 19,198 21,664 25,201

Azerbaijan 11,779 8,914 12,465 19,825 16,476

Brazil 12,238 8,422 11,349 15,566 15,023

All others 211,452 154,654 228,998 264,132 200,586

World 1,319,317 1,126,529 1,386,207 1,654,137 1,589,220

Source: Global Trade Information Service (“Global Trade Atlas”), HTS code 630533, sacks and bags, of a 

kind used for the packing of goods: Other of polyethylene or polypropylene strip of the like. This HTS 

code is over inclusive and contains sacks and bags outside of the scope of the subject laminated woven 

sacks.

Table I-9 shows the ten largest importing countries of laminated woven sacks. Total 

world imports increased by 14.8 percent from 2008 to 2012.

I-20
Table I-9

LW Sacks: Imports by reporting country, 2008-12

Country

Calendar Year

2008 2009 2010 2011 2012

Value ($1,000)

United States 194,325 162,194 189,098 201,961 196,156

Russia 64,400 49,596 60,888 64,822 90,457

Japan 47,906 41,461 45,237 61,187 54,621

South Korea 33,676 31,204 34,913 40,399 40,375

Australia 28,904 25,955 30,933 34,303 36,902

Italy 38,228 27,801 31,419 41,284 31,022

Colombia 16,096 12,955 20,562 33,606 30,703

Belgium 19,753 17,182 21,524 30,035 27,516

Canada 23,968 19,143 25,468 26,878 26,513

Kazakhstan 18,071 9,644 11,280 13,342 25,627

All others 525,300 411,000 533,690 628,938 600,017

World 1,010,627 808,136 1,005,012 1,176,755 1,159,909

Source: Global Trade Information Service ((“Global Trade Atlas”), HTS code 630533, sacks and bags, of 

a kind used for the packing of goods: Other of polyethylene or polypropylene strip of the like. This HTS 

code is over inclusive and contains sacks and bags outside of the scope of the subject laminated woven 

sacks.

I-21