U.S. International Trade Commission

Publication 4470 June 2013

Washington, DC 20436

Light-Walled Rectangular Pipe and Tube 

from China, Korea, Mexico, and Turkey 

Investigation Nos. 701-TA-449 and 731-TA-1118-1121 (Review)
U.S. International Trade Commission

COMMISSIONERS 

 

Irving A. Williamson, Chairman 

Dean A. Pinkert 

David S. Johanson 

Meredith M. Broadbent 

F. Scott Kieff 

Rhonda K. Schmidtlein

Robert B. Koopman

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Director of Operations

Edward Petronzio, Investigator 

Mahnaz Khan, Industry Analyst 

Cindy Cohen, Economist 

Justin Jee, Accountant 

Lita David-Harris, Statistician 

Darlene Smith, Statistical Assistant 

Michael Haldenstein, Attorney 

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

Washington, DC 20436 

www.usitc.gov

Publication 4470 June 2013

Light-Walled Rectangular Pipe and Tube 

from China, Korea, Mexico, and Turkey 

Investigation Nos. 701-TA-449 and 731-TA-1118-1121 (Review)
 
  

CONTENTS

Page

i

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

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

        Additional and dissenting views of Commissioner Meredith M. Broadbent concerning

  subject imports from Mexico ...................................................................................................... 31

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

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

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

Previous investigations.............................................................................................................. I‐3

Summary data ........................................................................................................................... I‐4

Statutory criteria and organization of the report ................................................................. I‐8

Statutory criteria ................................................................................................................... I‐8

Organization of report........................................................................................................... I‐9

Commerce’s reviews............................................................................................................... I‐10

Administrative reviews........................................................................................................ I‐10

Changed circumstances reviews ......................................................................................... I‐11

Five‐year reviews................................................................................................................. I‐12

The subject merchandise ........................................................................................................ I‐14

Commerce’s scope .............................................................................................................. I‐14

Tariff treatment................................................................................................................... I‐15

The product............................................................................................................................. I‐15

Overview.............................................................................................................................. I‐15

Description and applications............................................................................................... I‐16

Manufacturing processes.................................................................................................... I‐17

Domestic like product ............................................................................................................. I‐19

U.S. market participants.......................................................................................................... I‐20

U.S. producers..................................................................................................................... I‐20

U.S. importers...................................................................................................................... I‐22

U.S. purchasers.................................................................................................................... I‐22
  

CONTENTS

Page

ii

Part I: Introduction (continued) ............................................................................................. I‐1

Apparent U.S. consumption .................................................................................................... I‐23

U.S. market shares .................................................................................................................. I‐24

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

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

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

Geographic distribution ........................................................................................................... II‐1

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

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

U.S. demand ......................................................................................................................... II‐6

Substitutability issues............................................................................................................... II‐9

Lead times .......................................................................................................................... II‐10

Knowledge of country sources........................................................................................... II‐10

Factors affecting purchasing decisions............................................................................... II‐10

Comparisons of domestic products, subject imports, and nonsubject imports................ II‐13

Comparison of U.S.‐produced and imported LWR pipe and tube ..................................... II‐14

Elasticity estimates................................................................................................................. II‐18

U.S. supply elasticity........................................................................................................... II‐19

U.S. demand elasticity ........................................................................................................ II‐19

Substitution elasticity ......................................................................................................... II‐19

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

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

Changes experienced by the industry ................................................................................. III‐2

Anticipated changes in operations...................................................................................... III‐3

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

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

Alternative products............................................................................................................ III‐4

U.S. producers’ U.S. shipments and exports........................................................................... III‐6

U.S. producers’ inventories..................................................................................................... III‐7
  

CONTENTS

Page

iii

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

U.S. producers’ imports........................................................................................................... III‐8

U.S. employment, wages, and productivity ............................................................................ III‐8

    Financial experience of U.S. producers................................................................................... III‐9

Background.......................................................................................................................... III‐9

Operations on LWR pipe and tube ...................................................................................... III‐9

Capital expenditures and research and development expenses...................................... III‐15

Assets and return on assets............................................................................................... III‐15

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

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

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

Imports from subject and nonsubject countries.................................................................IV‐1

U.S. importers’ imports subsequent to December 31, 2013 ..................................................IV‐4

Cumulation considerations .....................................................................................................IV‐4

Presence in the market .......................................................................................................IV‐5

The industry in China...............................................................................................................IV‐5

Operations on LWR pipe and tube ......................................................................................IV‐5

The industry in Korea ..............................................................................................................IV‐8

Operations on LWR pipe and tube ......................................................................................IV‐8

The industry in Mexico..........................................................................................................IV‐11

Overview............................................................................................................................IV‐11

Operations on LWR pipe and tube ....................................................................................IV‐11

The industry in Turkey...........................................................................................................IV‐13

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

Operations on LWR pipe and tube ....................................................................................IV‐13

Global market........................................................................................................................IV‐14

Global Exports ...................................................................................................................IV‐14

Canada...............................................................................................................................IV‐15

Italy ....................................................................................................................................IV‐17
  

CONTENTS

Page

iv

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

Prices .................................................................................................................................IV‐17

Foreign demand.................................................................................................................IV‐17

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

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

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

Transportation costs to the U.S. market..............................................................................V‐1

U.S. inland transportation costs...........................................................................................V‐3

Pricing practices .......................................................................................................................V‐3

Pricing methods....................................................................................................................V‐3

Sales terms and discounts....................................................................................................V‐4

Price leadership ....................................................................................................................V‐4

Price data..................................................................................................................................V‐4

Price trends...........................................................................................................................V‐9

Price comparisons ..............................................................................................................V‐10

Appendixes

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

B. List of hearing witnesses  .................................................................................................. B‐1

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

D. Responses of U.S. producers and U.S. purchasers concerning the orders.......................D‐1

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

be published and therefore has been deleted.  Such deletions are indicated by asterisks.
UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation Nos. 701-TA-449 and 731-TA-1118-1121 (Review)

LIGHT-WALLED RECTANGULAR PIPE FROM CHINA, KOREA, MEXICO, AND TURKEY

DETERMINATIONS

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

International Trade Commission (Commission) determines,2 pursuant to section 751(c) of the 

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

light-walled rectangular pipe and tube from China and the antidumping duty orders on

light-walled rectangular pipe and tube from China, Korea, Mexico, and Turkey would be likely to 

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

reasonably foreseeable time.3

BACKGROUND

The Commission instituted these reviews on April 1, 2013 (78 F.R. 19526) and 

determined on July 5, 2013 that it would conduct full reviews (78 F.R. 42546, July 16, 2013). 

Notice of the scheduling of the Commission=s reviews and of a public hearing to be held in 

connection therewith was given by posting copies of the notice in the Office of the Secretary, 

U.S. International Trade Commission, Washington, DC, and by publishing the notice in the 

Federal Register on December 3, 2013 (78 F.R. 74161, December 10, 2013). The hearing was 

held in Washington, DC, on April 3, 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 K. Schmidtlein not participating. 

3 Commissioner Meredith M. Broadbent dissenting with respect to imports of light-walled 

rectangular pipe and tube from Mexico.

1

 
 
3

Views of the Commission

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

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

order on light‐walled rectangular (“LWR”) pipe and tube from China and the antidumping duty

orders on LWR pipe and tube from China, Korea, Mexico, and Turkey would likely lead to

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

reasonably foreseeable time.1 2

I. Background

In May and July 2008, the Commission unanimously determined that an industry in the

United States was materially injured by reason of subsidized imports of LWR pipe and tube

from China and less than fair value (LTFV) imports of LWR pipe and tube from China, Korea,

Mexico, and Turkey.3

  The antidumping orders and the countervailing duty order were issued in

May and August 2008.4

The Commission instituted the instant reviews on April 1, 2013.5

  The Commission

received joint responses to its notice of institution from nine U.S. producers of LWR pipe and

tube and two Mexican subject exporters of LWR pipe and tube.  It determined to conduct full

reviews of the orders on LWR pipe and tube from China, Korea, Mexico, and Turkey.6

                                                      

1 Commissioner Broadbent determines that revocation of the antidumping duty order on LWR

pipe and tube from Mexico would not be likely to lead to continuation or recurrence of material injury

to an industry in the United States within a reasonably foreseeable time.  See Additional and Dissenting

Views of Commissioner Meredith M. Broadbent.  She joins these views except as noted. 2 Commissioner Schmidtlein did not participate in these reviews.

3 The Commission’s original final determinations in 2008 were based on petitions filed on the

same day involving dumped and subsidized imports of LWR pipe and tube from the four subject

countries.  Because Commerce issued its final antidumping determination for Turkey earlier than it did

for the other investigations, the Commission’s final determinations were made at two separate times.  

In accordance with 19 U.S.C. § 1677(7)(G)(i) and (iii), the Commission made its determinations for all

investigations on the same record and cumulated dumped and subsidized imports from the four subject

countries.  See Light‐Walled Rectangular Pipe and Tube from Turkey, Inv. No. 731‐TA‐1121 (Final), USITC

Pub. 4001 (May 2008); Light‐Walled Rectangular Pipe and Tube from China, Korea, and Mexico, Inv. Nos.

701‐TA‐449 and 731‐TA‐1118‐1120 (Final), USITC Pub. 4024 (July 2008) (collectively referred to as

“Original Determinations”). 4 Light‐Walled Rectangular Pipe and Tube from Turkey: Antidumping Duty Order, 73 Fed. Reg.

31065 (May 30, 2008); Light‐Walled Rectangular Pipe and Tube from Mexico, the People's Republic of

China, and the Republic of Korea: Antidumping Duty Orders, 73 Fed. Reg. 45403 (Aug. 5, 2008); Light‐

Walled Rectangular Pipe and Tube from the People's Republic of China: Notice of Countervailing Duty

Order, 73 Fed. Reg. 45405 (Aug. 5, 2008). 5 78 Fed. Reg. 19526 (Apr. 1, 2013).

6 Light‐Walled Rectangular Pipe and Tube from China, Korea, Mexico, and Turkey: Notice of

Commission Determinations to Conduct Full Five‐Year Reviews, 78 Fed. Reg. 42546 (July 16, 2013).
4

The Commission received joint prehearing and posthearing submissions from nine

domestic producers that produce LWR pipe and tube and support continuation of the orders:  

Bull Moose Tube Company; California Steel and Tube; Hannibal Industries; JMC Steel Group;

Maruichi American Corporation; Searing Industries; Southland Tube; Vest, Inc.; and Western

Tube and Conduit (collectively referred to as “Domestic Producers”).  Representatives from

three of these domestic producers appeared at the Commission’s hearing.  No respondent

party filed briefs or appeared at the hearing.

U.S. industry data are based on the questionnaire responses of 18 U.S. producers of

LWR pipe and tube that are believed to account for the vast majority of U.S. production of LWR

pipe and tube during 2013.7  U.S. import data and related information are based on

questionnaire responses of 14 U.S. importers of LWR pipe and tube that accounted for

approximately two‐thirds of total U.S. imports of LWR pipe and tube during 2008‐2013 and ***

percent of subject imports during the same period.8

   

Foreign industry data and related information are based on the questionnaire responses

of nine producers and exporters of subject merchandise:  seven producers/exporters in Mexico,

accounting for the vast majority of total production of LWR pipe and tube in Mexico in 2013,

and two of the ten producers/exporters in Turkey, accounting for *** percent of LWR pipe and

tube production in Turkey in 2013.9

  No questionnaire responses were received from producers

of LWR pipe and tube in China or Korea.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

                                                      

7 Confidential Report (“CR”) at I‐24, Public Report (“PR”) at I‐20.

8 CR at I‐27, PR at I‐22.   9 CR at I‐11, PR at I‐10.

10 CR at IV‐7 and IV‐11, PR at IV‐5 and IV‐8. 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).
5

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

findings.13  

Commerce has defined the scope of the orders in these five‐year reviews as follows:

certain welded carbon quality light‐walled steel pipe and tube, of

rectangular (including square) cross section, having a wall

thickness of less than 4 mm.14

The scope definition is unchanged from that in the original investigations.  LWR pipe and tube is

a long‐rolled welded carbon steel product used in applications not involving the conveyance of

liquids or gas and not for bearing weight.15  Common applications for LWR pipe are ornamental

fencing, window guards, door security frames, metal furniture, cattle chutes, railings, furniture

components, athletic equipment, lawn and garden equipment, store display shelves, and

racks.16  

In its original determinations, the Commission defined the domestic like product as all

LWR pipe and tube products corresponding to Commerce’s scope definition.  There were no

arguments for any other definition.17  The record in these reviews indicates that the

characteristics and uses of LWR pipe and tube have not changed since the original

investigations.18  Further, those parties that have addressed the issue have not argued that the

Commission should define the domestic like product differently from the original

investigations.19  In light of this, we define a single domestic like product that is coextensive

with Commerce’s scope definition.  

                                                      

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‐TA‐

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

TA‐745 (Review), USITC Pub. 3577 at 4 (Feb. 2003). 14 Final Results of Expedited Sunset Reviews of Antidumping Duty Orders: Light‐Walled

Rectangular Pipe and Tube From Mexico, Turkey, the People's Republic of China, and the Republic of

Korea, 78 Fed. Reg. 47671 (Aug. 6, 2013); Light‐Walled Rectangular Pipe and Tube From the People's

Republic of China: Final Results of the Expedited First Sunset Review of the Countervailing Duty Order, 78

Fed. Reg. 48416 (Aug. 8, 2013).  Commerce indicated that the merchandise subject to the orders is

currently classifiable under items 7306.61.50.00 and 7306.61.70.60 of the Harmonized Tariff Schedule of  

the United States.  Id.  See also Issues and Decision Memorandum for the Final Results of the Expedited

Sunset Review of the Countervailing Duty Order on Light‐Walled Rectangular Pipe and Tube from the

People's Republic of China (July 30, 2013) (providing definition of “carbon‐quality steel”).

15 CR at I‐17, PR at I‐15.

16 CR at I‐17, PR at I‐15. 17 Original Determinations, USITC Pub. 4001 at 7.

18 See CR at I‐17 to I‐24, II‐27 n.13, PR at I‐15 to I‐19, II‐19 n.13.

19 Domestic Producers’ Prehearing Brief at 3.  The Mexican respondent, Regiomontana de

Perfiles y Tubos S.A. de C.V., indicated that it did not object to the definition in its response to the notice

of institution.  Regiomontana de Perfiles y Tubos S.A. de C.V. Response to Notice of Institution at 8 (May

1, 2013).
6

B. Domestic Industry  

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

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

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

the product.”20  In defining the domestic industry, the Commission’s general practice has been

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

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

In the original investigations, the Commission defined the domestic industry to be all

domestic producers of LWR pipe and tube.  The Commission found that two domestic

producers were related parties, but it determined that appropriate circumstances did not exist

to exclude either producer from the domestic industry under 19 U.S.C. § 1677(4)(B).21

In these reviews, we must determine whether any producer of the domestic like

product should be excluded from the domestic industry pursuant to section 771(4)(B) of the

Tariff Act.22  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.23  Exclusion of such a producer is

within the Commission’s discretion based upon the facts presented in each investigation.24

*** is a related party because it imported subject merchandise from Mexico during the

period of review and by virtue of its ownership ***, a Mexican exporter of the subject

merchandise.25  The record indicates that *** principal interest is in domestic production.  Its

ratio of imports to production since it became a domestic producer peaked at *** percent in

                                                      

20 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.

21 Original Determinations, USITC Pub. 4001 at 8‐9. 22 The Domestic Producers argue that the domestic industry encompasses all domestic

producers of LWR pipe and tube.  Tr. at 45 (Schagrin).

23 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).

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

circumstances exist to exclude a related party include the following:

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

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

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

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

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

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

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

25 CR at I‐26, Table I‐7, PR at I‐22.
7

2009 and has been under *** percent since 2011.26  It also commenced U.S. production during

the period of review.27  It accounted for *** percent of U.S. production from 2008‐2013.28

Although *** operating margins were *** than the industry average during the period,

it does not appear to have benefitted due to its imports of subject merchandise.  Its operating

margins were consistently higher than the other producers even when its imports were minimal

during 2011‐2013.29 30  Moreover, no party has argued that *** should be excluded from the

domestic industry.  We therefore determine that appropriate circumstances do not exist to

exclude *** from the domestic industry.31

Another domestic producer, ***, may also be considered a related party by virtue of its

*** with ***, a producer of subject merchandise in Mexico.32  Assuming arguendo that *** is a

related party, we find that appropriate circumstances do not exist to exclude it from the

domestic industry.33  *** accounted for a small share (***) of domestic production during 2008‐

2013.34  ***.35  However, there is no indication that it derives any benefit or operates in a

manner that is different from other domestic producers as a result of its affiliation with the ***.  

There also is no indication that *** affiliation with a subject producer of subject merchandise

has skewed its performance compared to other domestic producers during the period of

                                                      

26 CR/PR at Table III‐7.  Its imports from Mexico were *** short tons in 2008, *** short tons in

2009, *** short tons in 2010, *** short tons in 2011, *** short tons in 2012 and *** short tons in 2013.

27 CR/PR at Table III‐1.

28 CR/PR at Table I‐6.

29 CR/PR at Table III‐7 and Table III‐10.

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

are appropriate circumstances to exclude a related party from the domestic industry.  In his view, the

present record is not sufficient to link either producer’s financial performance with respect to its U.S.

operations to any specific benefit derived from its related party status.

31 Two U.S. producers, *** reported purchasing subject imports from Mexico imported by ***.  

CR at I‐27 n.38, PR at I‐22 n.38.  A purchaser of subject imports may be considered a related party if it

controlled an importer through purchases of subject imports.  This will occur when the domestic

producer was responsible for a predominant portion of an importer’s purchases and the importer's

purchases were substantial.  See, e.g., Electrolytic Manganese Dioxide from Australia and China, Inv.

Nos. 731‐TA‐1124‐1125 (Final), USITC Pub. 4036 (September 2008) at 6, n. 26.  The modest size of the

domestic producers’ purchases relative to volume of both subject imports from Mexico as a whole and

*** imports of subject merchandise indicate that they did not control large volumes of subject imports.  

See CR at I‐27 n.38, Table III‐7 and Table IV‐1, , PR at I‐22 n.38.  Moreover, the fact that *** is a domestic

producer as well as an importer militates against any conclusion that it was under the control of either

of these purchasers.  Therefore, we do not find that *** are related parties.   32 See CR at I‐26 n.37, PR at I‐22 n.37.  It reported that it is an *** of ***.

33 Related party status in these circumstances depends on whether “a third party directly or

indirectly controls the {U.S.} producer and the exporter or importer {of subject merchandise}.”  19 U.S.C.

§ 1677(4)(B)(ii)(III).  The record does not indicate either whether *** exports, or intends to export,

subject merchandise or the extent to which *** exercises direct or indirect control of ***.

34 CR/PR at Table I‐6.

35 CR/PR at Table I‐6.
8

review.36  We consequently do not exclude any related parties and define the domestic industry

as all U.S. producers of LWR pipe and tube.

III. Cumulation

A. Legal Standard

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

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

subject merchandise from all countries with respect to which reviews under

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

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

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

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

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

the domestic industry.37

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

which are governed by section 771(7)(G)(i) of the Tariff Act.38  The Commission may exercise its

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

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

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

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

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

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

In the original investigations, the Commission cumulated subject imports from all four

subject countries.  The parties did not dispute the appropriateness of cumulation.39  The

Commission found that there was general interchangeability between subject imports and

between subject imports and the domestic like product.  Subject imports from the four subject

countries were fungible with both the domestic like product and with each other.  Both

petitioners and respondents described LWR pipe and tube as a commodity product.40  With

                                                      

36 See CR/PR at Table III‐10.

37 19 U.S.C. § 1675a(a)(7).

38 19 U.S.C. § 1677(7)(G)(i); see also, e.g., Nucor Corp. v. United States, 601 F.3d 1291, 1293 (Fed.

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

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

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

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

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

Int’l Trade 2008).

39 Original Determinations, USITC Pub. 4001 at 12.

40 Original Determinations, USITC Pub. 4001 at 10‐11.
9

respect to channels of distribution, both domestic producers and importers sold the majority of

their LWR pipe and tube to distributors during the period of investigation.  There also was a

significant geographical overlap among imports from the subject countries and between such

imports and the domestic like product.41  Imports from each subject country were also present

in the U.S. market throughout the period of investigation.42

In these reviews, the statutory threshold for cumulation is satisfied because all reviews

were initiated on the same day, April 1, 2013.43  In addition, we consider the following issues in

deciding whether to exercise our discretion to cumulate the subject imports:  (1) whether

imports from either of the subject countries are precluded from cumulation because they are

likely to have no discernible adverse impact on the domestic industry; (2) whether there is a

likelihood of a reasonable overlap of competition among subject imports from the subject

countries and the domestic like product; and (3) whether subject imports are likely to compete

in the U.S. market under different conditions of competition.

B. Likelihood of No Discernible Adverse Impact

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

country are likely to have no discernible adverse impact on the domestic industry.44  Neither the

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

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

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

industry.45  With respect to this provision, the Commission generally considers the likely volume

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

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

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

subject imports in the original investigations.

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

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

the event of revocation.

China, Korea, and Turkey.  In the original investigations, subject imports from China,

Korea, and Turkey were present in the U.S. market in substantial quantities.46  After the

antidumping and countervailing duty orders were issued in 2008, subject imports from China,

Korea, and Turkey entered in greatly reduced volumes; with limited exceptions, the market

                                                      

41 Original Determinations, USITC Pub. 4001 at 11.

42 Original Determinations, USITC Pub. 4001 at 12.

43 78 Fed. Reg. 19526 (Apr. 1, 2013). 44 19 U.S.C. § 1675a(a)(7).

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

46 CR/PR at Table I‐2.
10

penetration of subject imports from China, Korea, and Turkey was no greater than *** percent

from 2008 to 2013.47

Only two subject producers in Turkey and no subject producers in China or Korea

reported information to the Commission on their LWR pipe and tube operations for the period

of review.48  Because of the limited information concerning the foreign industries, we have in

large part relied on public information concerning subject industries in China, Korea, and

Turkey.

Information from Simdex, a market research firm, indicates that the subject industries in

China, Korea, and Turkey are large.  There are 39 known producers in China and nine producers

in Korea of carbon‐welded pipes of rectangular cross section with wall thickness under 4 mm.49  

The two responding subject producers in Turkey are believed to account for only *** percent of

that country’s production of LWR pipe and tube.50  Moreover, the data the two firms reported

indicate that they operated at approximately *** percent capacity utilization from 2011 to

2013 and have significant excess capacity of almost *** short tons.51  

The subject industries in China, Korea, and Turkey are also export oriented.  Both China

and Korea are increasingly *** of LWR tubular products.52  The Chinese industry exported LWR

tubular products to 197 countries in 2013, and Korean producers exported to over 60 countries

between 2009 and 2013.53  According to Global Trade Atlas data, which we acknowledge

includes some products not within the scope of the orders under review, exports of LWR

tubular products from China increased over the period of review from 375,533 short tons in

2008 to 850,696 short tons in 2013.54  The Korean producers similarly increased their exports

from 73,038 short tons in 2008 to 116,733 short tons in 2013.55  The reporting subject

                                                      

47 Subject imports from Korea had a U.S. market penetration of *** percent in 2008.  Subject

imports from Turkey had U.S. market penetration of 1.0 percent and 0.3 percent in 2012 and 2013,

respectively. CR/PR at Table I‐2.

48 CR at IV‐7, PR at IV‐5.  In the original investigations, three Chinese producers responded to the

Commission’s questionnaires.  Id.

49 CR at IV‐7, IV‐13, PR at IV‐5, IV‐10.  The light‐walled rectangular tubular product on which

Simdex provides data is somewhat broader than the scope definition.  Korean producers include Ahshin

Pipe and Tube, Bookook Steel, Dongbu Steel, Histeel, Husteel, Hyundai HYSCO, Miju Steel MFG, Nexteel,

and SeAH Steel.  Id.

50 CR at I‐11.

51 CR/PR at Table IV‐11.  For comparison, apparent U.S. consumption was 674,043 short tons in

2013.  CR/PR at Table I‐1.  The pricing data indicate that LWR pipe and tube imported from Turkey was

priced below U.S.‐produced product in 29 of 34 instances during the period of review. CR at V‐16.

52 China’s net export balance of a product category that includes both LWR pipe and tube and

nonsubject products (which will be called “LWR tubular products”) increased from *** short tons in

2008 to *** short tons in 2013.  CR/PR at Table IV‐4.  Korea’s net export balance increased from 55,780

short tons in 2008 to 68,526 short tons in 2013. CR/PR at Table IV‐6.    53 CR at IV‐7, IV‐11, PR at IV‐5, IV‐8; CR/PR at Tables IV‐3, IV‐5.

54 CR/PR at Table IV‐4. 55 CR/PR at Table IV‐5 (Global Trade Atlas data).
11

producers in Turkey indicated that they exported between *** and *** percent of their LWR

pipe and tube shipments during the period of review.56

In light of the foregoing, we do not find that subject imports from China, Korea, or

Turkey would likely have no discernible adverse impact on the domestic industry if the orders

were revoked.

Mexico.

57  In the original investigations, subject imports from Mexico were significant

but declined from 156,263 short tons in 2005 to 140,937 short tons in 2007.58  Subject imports

from Mexico continued to have a substantial presence in the U.S. market during the period of

review despite the antidumping duty order, fluctuating between a low of 60,925 short tons in

2011 and a high of 115,179 short tons in 2008.59  Their share of the quantity of apparent U.S.

consumption ranged from 10.6 percent in 2012 to 18.5 percent in 2008.60

Seven Mexican producers, which account for the vast majority of LWR pipe and tube

production in Mexico, reported data to the Commission for the period of review.61  Their

capacity for production of LWR pipe and tube increased from *** short tons in 2008 to ***

short tons in 2013.  Their production also increased from *** short tons in 2008 to *** short

tons in 2013.62  In addition, the reporting Mexican producers reported excess capacity of almost

*** short tons in 2013.63

The United States was the largest export market for Mexican exports of LWR pipe and

tube in 2013.64  Total exports of LWR pipe and tube from Mexico fluctuated year to year, but

increased overall from *** short tons in 2008 to *** short tons in 2013.65  Based on the record,

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

impact on the domestic industry if the order were revoked.

C. Likelihood of a Reasonable Overlap of Competition

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

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

product.66  Only a “reasonable overlap” of competition is required.67  In five‐year reviews, the

                                                      

56 CR/PR at Table IV‐11. 57 Commissioner Broadbent does not join this section of the opinion.

58 CR/PR at Table I‐2.

59 CR/PR at Tables I‐2 and IV‐4.

60 CR/PR at Table I‐2.

61 CR at IV‐14, PR at IV‐11.

62 CR/PR at Table IV‐7.

63 CR/PR at Table IV‐7.

64 CR/PR at Table IV‐7.

65 CR/PR at Table IV‐7.  We also note that LWR pipe and tube imported from Mexico was priced

below domestically produced product in 72 of 83 instances. CR at V‐16, PR at V‐11.

66 The four factors generally considered by the Commission in assessing whether imports

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

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

(Continued...)
12

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

because the subject imports are absent from the U.S. market.68

Fungibility.  In the original investigations, the Commission found that there was general

interchangeability between subject imports and between subject imports and the domestic like

product.  Subject imports from the four subject countries were fungible with both the domestic

like product and with each other.  Both petitioners and respondents described LWR pipe and

tube as a commodity product. 69

The record in these reviews again indicates that domestically produced and imported

LWR pipe and tube can be used in the same applications.70  Subject imports and the domestic

like product share the same essential chemical and physical properties.  LWR pipe and tube is

generally manufactured to one of two ASTM standards, ASTM A‐500 (ornamental tubing) or

ASTM A‐513 (mechanical tubing).71  Moreover, the vast majority of responding U.S. producers, a

majority of importers, and majorities or pluralities of purchasers reported that the domestic like

product and imports from each subject source and nonsubject imports are always or frequently

interchangeable.72

Channels of Distribution.  In the original investigations, both the domestic producers and

importers sold the majority of their LWR pipe and tube to distributors during the period of

investigation.73  During the period of review, both the domestic like product and imports were

                                                                                                                                                                              

(...Continued)

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

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

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

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

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

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

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

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

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

however, that there have been investigations where the Commission has found an insufficient overlap in

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

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

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

Trade 1999); Static Random Access Memory Semiconductors from the Republic of Korea and Taiwan, Inv.

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

68 See generally, Chefline Corp. v. United States, 219 F. Supp. 2d 1313, 1314 (Ct. Int’l Trade 2002).

69 Original Determinations, USITC Pub. 4001 at 10‐11.

70 CR at II‐14, PR at II‐10. 71 CR at I‐19, PR at I‐17.

72 CR/PR at Table II‐9.  Half of the purchasers indicated that subject imports from China are

sometimes interchangeable with LWR pipe and tube from domestic sources.  The other half of

responding purchasers indicated that subject imports from China were frequently interchangeable.  Id.

73 Original Determinations, USITC Pub. 4001 at 11.
13

sold predominantly to distributors, although domestic producers sold a greater proportion of

products directly to end users than during the original investigations.74

Geographic Overlap.  In the original investigations, there was a significant geographical

overlap among the subject merchandise from each subject country and the domestic like

product.75  In the current reviews, U.S. producers reported nationwide sales.76  Subject imports

from Mexico, which were present in the market throughout the period of review, and subject

imports from Turkey were sold to multiple regions of the United States.77  Subject imports

(when present) and domestic product thus have been sold in the same geographic markets.   

Simultaneous Presence in Market.  In the original investigations, the Commission found

that imports from each of the subject countries were also present in the U.S. market

throughout the period of investigation.78  In the current reviews, subject imports from China,

Korea, and Turkey were not present in all years, and even when they were present, the levels

were relatively low.79

Conclusion.  The record indicates that domestically produced LWR pipe and tube and

subject imports from all sources generally are fungible.  Although subject imports from some

countries generally were at low volumes during the period of review, we found above that

subject imports would likely enter the U.S. market at levels sufficient to have a discernible

adverse impact on the domestic industry if the orders are revoked.  Therefore, based on the

record, including evidence from the original investigations, and the absence of contrary

argument, we find that upon revocation the domestic like product and the subject imports

likely would have similar channels of distribution, geographic overlaps in sales, and

simultaneous presence in the U.S. market.  Consequently, we find that there likely will be a

reasonable overlap in competition between the domestic like product and subject imports from

each country as well as among subject imports from each country upon revocation.  

D. Likely Conditions of Competition80

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

assess whether subject imports from China, Korea, Mexico, and Turkey likely would compete

under similar or different conditions in the U.S. market if the orders were revoked.81  

                                                      

74 See CR/PR at Table II‐1 (selling over 30 percent of shipments to end users during the period of

review).  Information on channels of distribution from 2008 to 2013 is available for subject imports from

Mexico and Turkey.  No data were reported for subject imports from China or Korea.  Id. 75 Original Determinations, USITC Pub. 4001 at 11.

76 CR at II‐2, PR at II‐1. 77 CR at II‐2, PR at II‐1. Importers reported selling subject imports from Mexico to all regions in

the continental United States except the Northeast and reported selling subject imports from Turkey in

four regions, ***.  Id.

78 Original Determinations, USITC Pub. 4001 at 12.

79 CR/PR at Tables I‐2 and IV‐2.

80 Commissioner Broadbent does not join this section of the opinion.

81 USITC Pub. 4029 at 13‐14 and 23‐25.
14

The record in these reviews does not indicate that there would likely be any significant

difference in the conditions of competition between subject imports from the subject countries

if the orders were revoked.  Given the commodity nature of LWR pipe and tube and the fact

that the industry in each of the subject countries supplied the U.S. market with LWR pipe and

tube meeting ASTM standards in the original investigations,82 we find that LWR pipe and tube

from each subject country would likely compete directly with one another and the domestic

like product in the event of revocation.  Competition in the U.S. market also is likely to be highly

price‐based.  Accordingly, we exercise our discretion to cumulate subject imports from China,

Korea, Mexico, and Turkey.

IV. 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.”83  

The SAA states that “under the likelihood standard, the Commission will engage in a

counterfactual analysis; it must decide the likely impact in the reasonably foreseeable future of

an important change in the status quo – the revocation or termination of a proceeding and the

elimination of its restraining effects on volumes and prices of imports.”84  Thus, the likelihood

standard is prospective in nature.85  The U.S. Court of International Trade has found that

“likely,” as used in the five‐year review provisions of the Act, means “probable,” and the

Commission applies that standard in five‐year reviews.86  

                                                      

82 See Original Determinations, USITC Pub. 4001 at 14.

83 19 U.S.C. § 1675a(a).

84 SAA at 883‐84.  The SAA states that “{t}he likelihood of injury standard applies regardless of

the nature of the Commission’s original determination (material injury, threat of material injury, or

material retardation of an industry).  Likewise, the standard applies to suspended investigations that

were never completed.”  Id. at 883.

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

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

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

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

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

86 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)

(Continued...)
15

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.”87  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.”88

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.”89  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).90  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.91

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

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

to consider whether the likely volume of imports would be significant either in absolute terms

or relative to production or consumption in the United States.92  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

                                                                                                                                                                              

(...Continued)

(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’”).

87 19 U.S.C. § 1675a(a)(5).

88 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. 89 19 U.S.C. § 1675a(a)(1).

90 19 U.S.C. § 1675a(a)(1). Commerce has not made any duty absorption findings with respect to

the orders under review.   91 19 U.S.C. § 1675a(a)(5).  Although the Commission must consider all factors, no one factor is

necessarily dispositive.  SAA at 886.

92 19 U.S.C. § 1675a(a)(2).
16

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.93

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.94

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.95  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.96

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.”97  The following conditions of competition inform our determinations.

                                                      

93 19 U.S.C. § 1675a(a)(2)(A‐D).

94 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.

95 19 U.S.C. § 1675a(a)(4).

96 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.

97 19 U.S.C. § 1675a(a)(4).
17

Demand Conditions.  In its original determinations, the Commission found that LWR

pipe and tube is an intermediate product with many end use applications, including fences,

gates, hand rails, furniture, sports equipment, and automotive equipment.98  Overall demand

for LWR pipe and tube was closely linked to demand for those end products.  As measured by

apparent U.S. consumption, U.S. LWR pipe and tube demand increased from 962,225 short tons

in 2005 to 1.03 million short tons in 2006, and then declined to 894,973 short tons in 2007, for

an overall period decline of 7.0 percent.99

In these reviews, the record indicates that the housing industry and uses related to

home improvement continue to account for much of the demand for LWR pipe and tube.100  

These applications include use in lawn mowers, lawn furniture, window guards, and fencing, all

of which are commonly purchased when homes are built.101 There have not been significant

changes in end uses or substitutes for LWR pipe and tube since the original investigations.102

The record indicates that demand for LWR pipe and tube during the period of review

was below the levels observed in the original investigations because the housing market and

U.S. home construction have not fully recovered from the 2008‐2009 decline in that market.103  

Reflecting this weakness, apparent U.S. consumption initially fell sharply from 622,369 short

tons in 2008 to 465,200 short tons in 2009.104  Apparent U.S. consumption then recovered,

rising to 532,363 short tons in 2010 and 674,043 short tons in 2013.105  The 2013 figure is well

below the lowest annual apparent U.S. consumption during the original investigations.106  

Supply Conditions.  In the original investigations, the Commission observed that there

had been some recent consolidation within the domestic industry.  The industry’s capacity and

production declined during the period of investigation, which encompassed years 2005 through

2007, by 6.5 percent and 7.2 percent, respectively.107

                                                      

98 Original Determinations, USITC Pub. 4001 at 13.

99 Original Determinations, USITC Pub. 4001 at 13.

100 Domestic Producers’ Prehearing Brief at 7.  In the original investigations, it accounted for 60

to 70 percent of total demand. CR at II‐10, PR at II‐7.

101 CR at II‐10, PR at II‐7.

102 CR at II‐27 n.13, PR at II‐19 n.13.

103 Domestic Producers’ Prehearing Brief at 7.

104 CR/PR at Table I‐2.

105 CR/PR at Table I‐2.

106 CR/PR at Table I‐2.

107 Original Determinations, USITC Pub. 4001 at 13.  The Commission also made findings

concerning nonsubject  imports.  In the determination concerning subject imports from Turkey, the

Commission found that the U.S. market share held by nonsubject imports, an overwhelming majority of

which were imported from either Canada or from Prolamsa of Mexico, which received a preliminary de

minimis dumping margin, declined steadily during the period of investigation.  Original Determinations,

USITC Pub. 4001 at 14.  In its final determination on subject imports from Mexico, Commerce calculated

a 5.73 percent dumping margin for Prolamsa, and accordingly, Prolamsa became a subject exporter for

purposes of the Commission’s final determinations on subject imports from China, Korea, and Mexico.  

Original Determinations, USITC Pub. 4024 at 3‐4.  In the latter determinations, the Commission observed

(Continued...)
18

During the period of review, the domestic industry added to its production capacity.  

The industry’s capacity increased from 1.11 million short tons in 2008 to 1.13 million short tons

in 2013.108 There were seven production curtailments or shutdowns during the period.109  Five

firms added capacity during the period, while four firms reduced capacity.110 Additionally,

Prolamsa Laredo became a domestic producer, opening a plant in Laredo, Texas in 2009 with

*** short tons of capacity.111

The record indicates that the domestic industry’s share of apparent U.S. consumption

was higher in 2013, at 76.8 percent, than it was in 2008, when it was 72.1 percent.112  The share

of apparent U.S. consumption held by cumulated subject imports was *** percent in 2008 and

12.6 percent in 2013, while nonsubject imports held *** percent of the U.S. market in 2008 and

10.6 percent in 2013.113  The largest supplier of nonsubject imports of LWR pipe and tube since

issuance of the orders has been Canada, which accounted for 36.7 percent of total imports and

80 percent of nonsubject imports in 2013.114   

Substitutability and Other Conditions.  The Commission found in the original

investigations that because manufacturing processes and technologies are similar throughout

the world, LWR pipe and tube from different sources was generally viewed as interchangeable

across a range of applications.  It indicated that LWR pipe and tube is manufactured to meet

common ASTM specifications (such as A‐513 or A‐500) regarding materials, dimensions, and

testing.115  The great majority of market participants reported that domestically produced LWR

pipe and tube was always or frequently interchangeable with subject LWR pipe and tube.116

In these reviews, there is no information in the record to suggest that these conditions

have changed since the original investigations.  The vast majority of responding U.S. producers,

a majority of importers, and majorities or pluralities of purchasers reported that the domestic

like product and imports from each subject source and nonsubject imports are always or

frequently interchangeable.117  Among the 15 reported purchase factors, purchasers most

frequently cited price as a “very important” factor.118  The majority of purchasers reported that

                                                                                                                                                                              

(...Continued)

that Prolamsa’s status as a subject producer changed the relative share of subject and nonsubject

imports but did not otherwise modify its findings on conditions of competition.  Id. at 7.

108 CR/PR at Table III‐3.

109 CR/PR at Table III‐2.

110 CR at III‐5, PR at III‐3. 111 CR/PR at Table III‐2; Prolamsa Laredo’s Producer Questionnaire at II‐5. 112 CR/PR at Table I‐2.

113 CR/PR at Table I‐2. 114 CR/PR at II‐1 and IV‐1.

115 Original Determinations, USITC Pub. 4001 at 14.

116 Original Determinations, USITC Pub. 4001 at 14. 117 CR/PR at Table II‐9.  Half of the purchasers indicated that subject imports from China are

sometimes interchangeable with LWR pipe and tube from domestic sources.  The other half of

responding purchasers indicated that subject imports from China were frequently interchangeable.  Id.

118  CR/PR at Table II‐6.
19

they always or usually purchase LWR pipe and tube that is the lowest priced available.119  

Accordingly, we find that the domestic like product and subject LWR pipe and tube are

generally substitutable and that price is an important factor in purchasing decisions.  

C. Likely Volume of Subject Imports

Original Investigations.  The Commission in its original determinations found that

cumulated subject import volume increased from 2005 to 2007, notwithstanding a decline from

2006 to 2007.120  The ratio of subject imports to U.S. production increased over the period.  The

total market share held by subject imports increased from 2005 to 2006, before declining in

2007.  The Commission also observed that the market share held by nonsubject imports

declined throughout the period. 121

The Commission found that increasing subject import volumes took market share from

both the domestic industry and nonsubject imports over the period of investigation.  

Furthermore, the decline in apparent U.S. consumption of 7.0 percent over the period

exacerbated the effects of the increasing subject imports.122

Current Reviews.

123  In these reviews, the record indicates that the orders have had a

disciplining effect on the volume of subject imports from China, Korea, and Turkey, which

decreased significantly since the imposition of the orders in 2008.  Subject imports from Mexico

remained in the U.S. market, albeit at reduced quantities since 2008.124  Cumulated subject

imports fell from *** short tons in 2007 to *** short tons in 2008 and declined each year from

2008 to 2011 before increasing in 2012 and 2013.125  In 2013, cumulated subject imports were

84,937 short tons.126  Subject imports from Mexico accounted for *** percent of subject

imports and over half of total imports during the period of review.127   

                                                      

119 CR at II‐17, PR at II‐11.

120 Original Determinations, USITC Pub. 4001 at 14. 121 Original Determinations, USITC Pub. 4001 at 15. 122 Original Determinations, USITC Pub. 4001 at 15.  As noted, the data in the determinations

concerning subject imports from China, Korea, and Mexico differed from the data in the determination

concerning subject imports from Turkey because Prolamsa was a subject producer only for the former

set of determinations.  This did not, however, require the Commission to modify its analysis. Original

Determinations, USITC Pub. 4024 at 8.

123 Commissioner Broadbent joins the following discussion on likely volume of subject imports

insofar as it concerns China, Korea, and Turkey. Cumulated subject imports from China, Korea, and

Turkey fell from *** short tons in 2007 to *** short tons in 2008, and remained between *** short tons

and *** short tons throughout the remainder of the period of review.  CR/PR at Table I‐2. She finds that

upon revocation, the volume of subject imports from those sources would likely return to significant

levels because of the removal of the disciplining effect of the orders and the large size, substantial

excess capacity, and export orientation of the three industries.   124 CR/PR at Table I‐2.

125 CR/PR at Table I‐2.

126 CR/PR at Table I‐2.

127 CR/PR at IV‐1, Table I‐2.
20

As previously stated, the Commission has relatively complete information concerning

the subject industry in Mexico, but no foreign producer or exporter of subject merchandise

from China or Korea and only two of ten subject producers in Turkey provided information to

the Commission.  The lack of participation has prevented the Commission from assembling a

comprehensive set of production and capacity data for producers for the four subject countries.  

Nonetheless, the record demonstrates that the subject industries have significant and

increasing production capacity, have significant unused capacity, and exported substantial and

increasing volumes of LWR pipe and tube during the period of review.

The record indicates that there are large subject industries in China, Korea, Mexico, and

Turkey.  There are reportedly 39 subject producers in China, nine subject producers in Korea,

ten subject producers in Turkey, and seven subject producers in Mexico.128  Subject producers

in Mexico and Turkey reported that they increased their capacity for the production of LWR

pipe and tube over the period of review.129  During the period, Chinese producers of LWR pipe

and tube also increased capacity by opening new manufacturing plants and were often the

subject of acquisitions by larger Chinese steel companies.130  

The record further indicates that there is significant excess capacity for the production

of LWR pipe and tube in Mexico and Turkey.  The two reporting producers in Turkey reported

approximately *** short tons of unused capacity in 2013.131  The seven producers in Mexico

reported approximately *** short tons of unused capacity in 2013.132  By comparison, apparent

U.S. consumption was 674,043 short tons in 2013.  Thus, in these two countries alone, there is

significant excess capacity relative to the size of the U.S. market.

The subject industries in China, Korea, and Turkey are also export oriented and, despite

being largely absent from the U.S. market during the period of review, would likely reenter the

market without the restraining effect of the orders.  Global Trade Atlas data indicate that

subject producers in China have significantly increased their exports of LWR tubular products

over the period of review.133  The subject industry in China exports to 197 countries and has

demonstrated the ability to shift and rapidly increase exports of LWR tubular products to

several countries. 134  Subject imports from China would likely reenter the U.S. market in the

absence of the discipline of the orders.  Likewise, the subject industry in Korea exports to 60

countries and increased its exports of LWR tubular products to the United States during the

                                                      

128 CR at IV‐7, IV‐11, IV‐14, and IV‐21, PR at IV‐5, IV‐8, IV‐11, and IV‐13.

129 CR/PR at Tables IV‐7, IV‐11.

130 CR at IV‐9, PR at IV‐7.

131 CR/PR at Table IV‐11.

132 CR/PR at Table IV‐7.

133 CR/PR at Table IV‐4 and IV‐6.  As previously stated, the Global Trade Atlas data include some

nonsubject merchandise.  Exports of LWR tubular products from China increased over the period of

review, from 375,533 short tons in 2008 to 850,696 short tons in 2013. CR/PR at Table IV‐3.

134 See CR at IV‐7, PR at IV‐5; CR/PR at Table IV‐3.
21

period of review, indicating the U.S market remains attractive to exporters in Korea.135  Subject

imports from Korea would likely reenter the U.S. market in the absence of the order.   

Although the subject industry in Turkey remains export oriented, the reporting subject

producers in Turkey indicated that their exports to their principal market, the European Union,

have declined, indicating an incentive to focus on alternative markets such as the United

States.136  The record also indicates that the Turkish economy is faltering, further suggesting an

incentive to shift shipments from the home market to export markets such as the United

States.137  Indeed, subject imports from Turkey reentered the U.S. market toward the end of the

period of review, indicating a renewed interest in this market.  Finally, exports of LWR pipe and

tube from Turkey ***.138

Subject producers in Mexico have continued to rely on the U.S. market as their primary

export market during the period of review.139 140  Although the Mexican industry’s home market

shipments have increased during the period of review, the United States accounted for ***

percent of the industry’s total shipments during 2013, even with the antidumping duty order in

place.141  Moreover, one subject producer in Mexico projected exporting an additional *** short

tons per year of subject merchandise to the United States if the antidumping duty order were

revoked.142  Thus, the U.S. market remains an attractive market for subject producers in Mexico,

and we find it likely that there will be increased shipments of subject merchandise from Mexico

if the antidumping duty order were revoked.143 144

In light of these factors, we find that the subject producers are likely, absent the

restraining effects of the orders, to direct significant volumes of LWR pipe and tube to the U.S.

                                                      

135 See CR/PR at Table IV‐5.  The Global Trade Atlas data for exports of LWR tubular products

from Korea include both out‐of‐scope products and in‐scope merchandise exported by a producer not

subject to the antidumping duty order.  Global Trade Atlas data indicate that exports from Korea of LWR

tubular products increased each year from 2009, when they were 8,242 short tons, to 2013, when they

were at a period high of 39,780 short tons.  CR/PR at Table IV‐5.    136 CR/PR at Table IV‐11.

137 See Domestic Producers’ Prehearing Brief at 12.   138 CR at IV‐24 n.22, PR at IV‐14 n.22.  The record does not indicate that subject producers in

China, Korea, or Mexico face barriers to their exports in third‐country markets.  See CR at IV‐19 n.19, PR

at IV‐12 n.19.

139 CR/PR at Table IV‐7.

140 Commissioner Broadbent does not join this paragraph except as it pertains to product

shifting and inventories of Turkish producers. 141 CR/PR at Table IV‐7.

142 CR at IV‐20, PR at IV‐13.

143 We have also considered the potential for product shifting by subject producers.  The

majority of the reporting subject producers in Mexico and Turkey indicated that ***.  CR at IV‐18, IV‐24,

PR at IV‐12, IV‐14. 144 Information concerning inventories in Mexico indicates that inventories as a ratio to

shipments *** from *** percent in 2008 to *** percent in 2013.  CR/PR at Table IV‐7.  The two reporting

Turkish producers reported that their inventories as a ratio to shipments *** from *** percent in 2008

to *** percent in 2013. CR/PR at Table IV‐11.
22

market, as they did during the period of investigation.  We 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.

D. Likely Price Effects  

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

pipe and tube is largely a commodity product that is commonly produced to ASTM

specifications, and a high degree of fungibility exists between the domestic like product and

subject imports.  The vast majority of purchasers stated that price was very important to their

purchasing decisions.145

The Commission observed that cumulated subject imports undersold the domestic

product in over 80 percent of quarterly comparisons by an average margin over the POI of

approximately 15 percent.146  It further found that the persistent underselling by subject

imports depressed prices to a significant degree during the POI, leading the domestic producers

to institute pricing programs in which they offered product to customers at greatly reduced

prices to remain competitive with imported product and maintain market share.147

The Commission also found that lower‐priced subject imports suppressed domestic

prices to a significant degree.  Domestic producers were unable to raise their prices sufficiently

to cover costs due to significant volumes of lower‐priced subject imports entering the U.S.

market.148  In sum, the Commission found that the record indicated significant underselling by

subject imports during the period of investigation, and that subject imports depressed and/or

suppressed domestic prices to a significant degree. 149

Current Reviews.  As discussed above, we find that subject imports from all four

countries are substitutable for LWR pipe and tube manufactured in the United States and that

price is an important factor in purchasing decisions.  Thus, sustained underselling by even a

relatively moderate amount of subject imports is likely to have significant price‐suppressing or

price‐depressing effects.150

                                                      

145 Original Determinations, USITC Pub. 4001 at 15‐16.

146 Original Determinations, USITC Pub. 4001 at 16.  There were slight differences between the

determinations in underselling frequency and margins due to the changed status of Prolamsa.  See

Original Determinations, USITC Pub. 4024 at 9‐10. 147 Original Determinations, USITC Pub. 4001 at 16.

148 Original Determinations, USITC Pub. 4001 at 17.

149 Original Determinations, USITC Pub. 4001 at 18.

150 Commissioner Broadbent joins the following discussion on likely price effects of subject

imports insofar as it concerns China, Korea, and Turkey.  She finds that price is an important factor in

purchasing decisions.  In light of the finding that subject producers from these countries would be likely

to direct significant volumes of LWR pipe and tube to the U.S. market upon revocation, imports from

these sources would likely undersell the domestic like product to a significant degree in order to regain

U.S. market share.  She finds that a rapid increase in low‐priced subject imports from China, Korea, and

(Continued...)
23

The Commission collected pricing data on sales of four products in these reviews.151  

Sixteen U.S. producers provided usable pricing data, which represented *** percent of U.S.

commercial market shipments of U.S. produced LWR pipe and tube.152  Six importers provided

usable pricing data, which represented *** percent of imported product from Mexico and ***

percent of imported product from Turkey.153  There were no pricing data for sales of subject

imports from China or Korea.154

Subject imports from Mexico and Turkey undersold the domestic product in 101 of 117

pricing comparisons by an average underselling margin of 9.8 percent.155  This consistent

underselling occurred despite the disciplining effects of the antidumping duty orders.  Given the

predominant underselling during the period of review and the significant underselling in the

original investigations, as well as our finding that subject imports would likely increase upon

revocation, we find that the significant underselling would likely recur if the antidumping and

countervailing duty orders were revoked.  Because of the importance of price in purchasing

decisions, this underselling in turn would likely cause the domestic industry to consider either

reducing its prices or foregoing price increases to maintain market share, as was the case in the

original investigations.

We therefore conclude that the likely significant volume of cumulated imports of LWR

pipe and tube from China, Korea, Mexico, and Turkey would likely undersell the domestic like

product to a significant degree to gain market share and would also have likely significant price

depressing or suppressing effects.

                                                                                                                                                                              

(...Continued)

Turkey would likely have significant price‐suppressing or price‐depressing effects or would cause the

domestic industry to lose market share, as occurred during the original investigations.   151 CR at V‐6, PR at V‐5.   152 CR at V‐6, PR at V‐5.

153 CR at V‐6, PR at V‐5.

154 CR/PR at Tables V‐3 to V‐6.

155 CR/PR at Table V‐8.  Eighty‐three of the comparisons concerned subject imports from Mexico.

Thirty‐four of the comparisons concerned subject imports from Turkey.  Id.
24

E. Likely Impact156 157

                                                      

156 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 a five‐year review as “the

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

title.”  19 U.S.C. § 1677(35)(C)(iv); see also SAA at 887.  Commerce expedited its determinations in all of

its reviews and made affirmative determinations.  With regard to the antidumping review on subject

imports from China, Commerce found a likely dumping margin of 247.90 for Kunshan Lets Win Steel

Machinery Co., Ltd.; Wuxi Baishun Steel Pipe Co., Ltd.; Guangdong Walsall Steel Pipe Industrial Co., Ltd.;

Wuxi Worldunion Trading Co., Ltd.; Weifang East Steel Pipe Co., Ltd.; and Jiangyin Jianye Metal Products

Co., Ltd. and 255.07 percent for Zhangjiangang Zhongyuan Pipe Making Co., Ltd. and all other entities.  

CR/PR at Table I‐5;  Final Results of Expedited Sunset Reviews of Antidumping Duty Orders: Light‐Walled

Rectangular Pipe and Tube From Mexico, Turkey, the  People's Republic of China, and the Republic of

Korea, 78 Fed. Reg. 47671 (Aug. 6, 2013).   

With respect to subject imports from Korea, Commerce found a likely dumping margin of 30.66

percent for Dong‐A Steel Pipe Co. Ltd.; HiSteel Co. Ltd.; Jinbang Steel Co. Ltd.; Joong Won; Miju Steel

Mfg. Co., Ltd.; Yujin Steel Industry Co.; Ahshin Pipe & Tube; Han Gyu Rae Steel Co., Ltd.; Kukje Steel Co.,

Ltd.; and a rate of 15.79 percent for SeAH Steel Corporation, Ltd. and all other entities.  One Korean

producer, Nexteel Co., is not subject to the antidumping duty order.  Id.  As to subject imports from

Mexico, Commerce found a likely dumping margin of 2.40 percent for Maquilacero S.A. de C.V.; a rate of

5.12 percent for Productos Laminados de Monterrey S.A. de C.V.; a rate of 11.50 percent for Industrias

Monterrey S.A. de C.V.; Nacional de Acero S.A. de C.V.; PEASA‐Productos Especializados de Acero;

Tuberias Aspe; and Tuberias y Derivados S.A. de C.V.; and a rate of 3.76 percent for Arco Metal S.A. de

C.V.; Hylsa S.A. de C.V.; Internacional de Aceros S.A. de C.V.; Perfiles y Herrajes LM, S.A. de C.V ;

Regiomontana de Perfiles y Tubos; Talleres Acero Rey S.A. de C.V. and Tuberia Laguna, S.A. de C.V.; and

all other entities.  Finally, with respect to subject imports from Turkey, Commerce found a likely

dumping margin of 41.71 percent for Guven Boru Profil Sanayii ve Ticaret Limited Sirketi; MMZ Onur

Boru Profil Uretim San. ve Tic. A.S.; Anadolu Boru; Ayata Metal Industry; Goktas Tube/Gotkas Metal;

Kalibre Boru Sanayi ve Ticaret A.S.; Kerim Celik Mamulleri Imalat ve Ticaret; Ozgur Boru; Ozmak Makina

ve Elektrik Sanayi; Seamless Steel Tube and Pipe Co.; Umran Steel Pipe Inc.; and Yusan Industries, Ltd.  

Id.  Commerce also found a likely dumping margin of 27.04 percent for Borusan Mannesmann Boru;

Erbosan Erciyas Boru Sanayii ve Ticaret A.S.; Noksel Steel Pipe Co.; Ozborsan Boru San. ve Tic. A.S;

Ozdemir Boru Sanayi ve Ticaret Ltd. Sti.; Toscelik Profil ve Sac End. A.S.; Yucel Boru ve Profil Endustrisi

A.S.; and all other entities. Id.  In the China countervailing duty review, Commerce found a likely subsidy

rate of 2.20 percent for Kunshan Lets Win Steel Machinery Co., a likely subsidy rate of 200.58 percent

for Qingdao Xiangxing Steel Pipe Co., Ltd., and a likely subsidy rate of 15.28 percent for Zhangjiagang

Zhongyuan Pipe‐making Co., Ltd. and all other entities. Light‐Walled Rectangular Pipe and Tube From

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

Duty Order, 78 Fed. Reg. 48416 (Aug. 8, 2013).

157 In addition, the statute provides that “if a countervailable subsidy is involved, the

Commission shall consider information regarding the nature of the countervailable subsidy and whether

the subsidy is a subsidy described in Article 3 or 6.1 of the Subsidies Agreement.”  19 U.S.C. § 1675a(6).  

In its unpublished Issues and Decision Memorandum issued in the review of the countervailing duty

order with respect to China, Commerce found that no programs fell under Article 3.1. of the WTO

(Continued...)
25

Original Investigations.  The Commission in its original determinations found that the

record reflected declining trends for the domestic industry from 2005 to 2007, with significant

declines in most indicators occurring in 2007.158  The Commission found that the domestic

industry’s financial indicators, including operating income and operating margins, improved

from 2005 to 2006, but then fell to their lowest levels of the period in 2007.159  The industry’s

ratio of operating income to net sales grew from 9.9 percent in 2005 to 11.4 percent in 2006,

before declining to 6.4 percent in 2007.160  

The Commission found that the drop in apparent U.S. consumption from 2006 to 2007

likely had a negative impact on the domestic industry in 2007, but that impact was exacerbated

by significant volumes of low‐priced subject imports entering the market.  It noted that

although apparent consumption dropped from 2006 to 2007, subject imports were still entering

the market at rates that exceeded the volumes for 2006 until the filing of the petitions in late

June 2007.161

Current Reviews.

162 During the period of review, the condition of the domestic industry

was affected by the U.S. economic downturn, which resulted in reduced demand and declines

in virtually every indicator in 2009 relative to 2008.163  As apparent U.S. consumption improved

after 2009, the domestic industry’s condition improved despite apparent U.S. consumption

remaining well below the levels of the original investigations.  Neither sales volumes nor

profitability returned to the levels reached in the original investigations.164  Further, during the

final two years of the period of review, there has been some deterioration in the performance

of the industry despite increases in apparent U.S. consumption.165

                                                                                                                                                                              

(...Continued)

Subsidies Agreement.  Commerce also stated that it had insufficient evidence to determine whether the

following three Chinese programs fell within the meaning of Article 6.1 of the WTO Subsidies

Agreement:  (1) Provision of Inputs for Less than Adequate Remuneration‐Hot‐Rolled Steel; (2) Land for

Less than Adequate Remuneration (ZZPC Land Discount); and (3) Income Tax Subsidies for Foreign

Invested Enterprises‐Reduced Income Tax Rates for FIEs Based on Location.  Issues and Decision

Memorandum for the Final Results of the Expedited Sunset Review of the Countervailing Duty Order on

Light‐Walled Rectangular Pipe and Tube from the People's Republic of China (July 30, 2013).   158 Original Determinations, USITC Pub. 4001 at 19.

159 Original Determinations, USITC Pub. 4001 at 19.

160 Original Determinations, USITC Pub. 4001 at 19.

161 Original Determinations, USITC Pub. 4001 at 20.  See also Original Determinations, USITC Pub.

4001 at 14.

162 Commissioner Broadbent joins the following discussion on the condition of the U.S. industry

as well as the discussion on likely impact insofar as it concerns cumulated subject imports from China,

Korea, and Turkey.  She finds that upon revocation, imports from these sources would have a significant

impact on the domestic industry.

163 See CR/PR at Table I‐2.

164 See CR/PR at Table I‐2.

165 See CR/PR at Table I‐2 (net sales unit values and operating income declined in 2011 and

2012).
26

Average production capacity remained relatively stable between 2008 and 2013.166

Production levels declined substantially in 2009 relative to 2008, before subsequently

increasing, but remained lower in 2013 than in 2007 (during the original investigations).167  

Capacity utilization also declined initially before recovering later in the period of review.168  

Trends in the domestic industry’s U.S. shipments mirrored those for production.169  End‐of‐

period inventories relative to production and shipments increased overall and remained

relatively high.170

Notwithstanding the increase in nonsubject imports during this period, the domestic

industry was able to increase its share of the U.S. market.  Subject imports declined when the

antidumping and countervailing duty orders were issued and declined overall during the period

of review.171  Thus, the domestic industry has benefitted from the antidumping and

countervailing duty orders as its share of apparent U.S. consumption generally increased over

the period of review.172 173

                                                      

166 The domestic industry’s average capacity was 1,110,314 short tons in 2008, 1,081,371 short

tons in 2009, 1,089,411 short tons in 2010, 1,141,536 short tons in 2011, 1,109,604 short tons in 2012,

and 1,131,083 short tons in 2013.  CR/PR at Table III‐3.

167 The domestic industry’s production was 470,375 short tons in 2008, 367,451 short tons in

2009, 448,691 short tons in 2010, 472,564 short tons in 2011, 502,426 short tons in 2012 and 540,664

short tons in 2013.  CR/PR at Table III‐3.  Its net sales by quantity followed a similar trend, falling from

480,053 short tons in 2008 to 369,862 short tons in 2009, and then increasing to 426,764 short tons in

2010, 453,226 short tons in 2011, 501,480 short tons in 2012 and 546,511 short tons in 2013.  CR/PR at

Table III‐3.

168 The domestic industry’s capacity utilization was 42.4 percent in 2008, 34.0 percent in 2009,

41.2 percent in 2010, 41.4 percent in 2011, 45.3 percent in 2012, and 47.8 percent in 2013.  CR/PR at

Table III‐3.  The domestic industry does produce other pipe and tube products using the same

employees and production and related equipment as LWR pipe and tube. The portion of the domestic

industry’s total capacity to manufacture LWR pipe and tube increased over the period, from 16.6

percent in 2008 to 19.3 percent in 2013.  CR/PR at Table III‐4.

169 The domestic industry’s U.S. shipments were 448,481 short tons in 2008, 350,966 short tons

in 2009, 411,632 short tons in 2010, 435,122 short tons in 2011, 480,782 short tons in 2012 and 517,350

short tons in 2013.  CR/PR at Table III‐5.

170 The ratio of the domestic industry’s end‐of‐period inventories to total shipments was 15.3

percent in 2008, 19.5 percent in 2009, 20.6 percent in 2010, 22.5 percent in 2011, 18.8 percent in 2012

and 16.5 percent in 2013.  CR/PR at Table III‐6.  Exports were a small portion of the domestic industry’s

total shipments.  CR/PR at Table III‐5. 171 CR/PR at Table I‐2.

172 The domestic industry’s market share was 72.1 percent in 2008, 75.4 percent in 2009, 77.3

percent in 2010, 78.7 percent in 2011, 78.6 percent in 2012, and 76.8 percent in 2013.  CR/PR at Table I‐

2.

173 Commissioner Broadbent finds that imports from Mexico declined for reasons other than the

antidumping duty order, and therefore does not attribute the increase in the domestic industry’s market

share to the antidumping duty order from Mexico.  See Additional and Dissenting Views of

Commissioner Meredith M. Broadbent.
27

The number of production and related workers, total hours worked, and hours worked

per worker increased overall from 2008 to 2012.174  Hourly wages increased overall, whereas

productivity in short tons per 1,000 hours increased slightly overall.175

The domestic industry’s profitability fluctuated but declined overall from 2008 to

2013.176  The domestic industry’s net sales by value and operating income declined overall

despite increases from 2010 to 2012.177  Between 2008 and 2013, the domestic industry made

annual capital expenditures that ranged from a low of $8.1 million in 2013 to a high of $13.6

million in 2010.178

Although certain aspects of the domestic industry’s performance have improved, the

industry’s current performance indicators and overall demand are less than robust.179  

However, given the industry’s performance since 2009, we do not find the domestic industry to

be vulnerable.  The industry, nevertheless, is not in such a strong condition, nor are likely

demand conditions sufficiently positive, that the industry could withstand significantly

increased low‐priced subject imports without likely sustaining significant adverse effects.

As explained above, we find that cumulated subject imports would likely be significant

in the reasonably foreseeable future if the orders under review were revoked.  The domestic

industry supplies the majority of the U.S. market, and because subject imports are good

substitutes for the domestic like product, any increase in cumulated subject imports would

likely lead to declines in the domestic industry’s production, shipments, market share, and

employment.

We have further found that these additional volumes of cumulated subject imports

would be priced in a manner that would likely undersell the domestic like product to a

                                                      

174 There were 876 production and related workers in 2008, 779 in 2009, 800 in 2010, 857 in

2011, 879 in 2012, and 976 in 2013.  Hours worked were 1.9 million in 2008, 1.6 million in 2009, 1.7

million in 2010, 1.9 million in 2011, 2.0 million in 2012, and 2.2 million in 2013.  Wages paid were $62.8

million in 2008, $57.2 million in 2009, $59.3 million in 2010, $63.8 million in 2011, $67.0 million in 2012,

and $72.5 million in 2013.  CR/PR at Table III‐8.

175 Hourly wages were $32.67 in 2008, $35.62 in 2009, $34.04 in 2010, $33.05 in 2011, $33.57 in

2012, and $32.97 in 2013.  Productivity in short tons per 1,000 hours was 244.6 in 2008, 228.9 in 2009,

257.7 in 2010, 244.7 in 2011, 251.6 in 2012, and 246.0 in 2013.  CR/PR at Table III‐8.

176 The domestic industry’s operating income as a ratio of net sales was 10.2 percent in 2008,

negative 2.5 percent in 2009, 3.8 percent in 2010, 10.9 percent in 2011, 7.4 percent in 2012, and 6.4

percent in 2013.  CR/PR at Table III‐10. 177 Total net sales by value were $546.6 million in 2008, $321.2 million in 2009, $399.4 million in

2010, $488.9 million in 2011, $516.6 million in 2012, and $533.6 million in 2013.  CR/PR at Table III‐10.

Operating income was $55.8 million in 2008, negative $8.1 million in 2009, $15.1 million in 2010, $53.1

million in 2011, $38.1 million in 2012, and $34.1 million in 2013.  CR/PR at Table III‐10.

178 CR/PR at Table III‐13.  The domestic industry made only limited research and development

expenditures during the period of review.  Id. 179 We note that purchasers, producers, and importers offered mixed assessments of likely

demand.  See CR/PR at Table II‐3. We anticipate that demand will likely continue to improve but remain

weak relative to that experienced during the original investigations.
28

significant degree and have significant depressing or suppressing effects on prices of the

domestic like product.  Consequently, to compete with the likely additional volumes of subject

imports, the domestic industry would need to cut prices, forego needed price increases, or lose

sales, as it did in the original investigations.  The resulting loss of revenues would likely cause

further deterioration in the financial performance of the domestic industry which would result

in likely reductions in employment and, ultimately, likely losses in output and market share.  

Therefore, we find that revocation of the orders under review would likely have a significant

impact on the domestic industry.

We have also considered the role of factors other than subject imports so as not to

attribute likely injury from other factors to the subject imports.  Given the high substitutability

of LWR pipe and tube from all sources, if the orders on subject imports were revoked, the likely

significant volume of cumulated subject imports would likely compete with both the domestic

like product and nonsubject imports.  As was the case in the original investigations, the

continued presence of nonsubject imports in the U.S. market would not preclude subject

imports from taking market share from the domestic industry or forcing the domestic industry

to lower prices in order to compete.180

We further note that the market share of imports from nonsubject countries is less than

that of the domestic industry and subject imports.  Nonsubject imports’ share of the market

fluctuated but increased from a period low of *** percent in 2008 to a period high of 10.6

percent in 2013.181  Moreover, a comparison of average unit values (AUVs) of subject countries’

exports and nonsubject countries’ exports suggests that the subject imports were lower priced

than nonsubject imports during the period of review.  The AUVs of nonsubject imports were

consistently higher than AUVs of subject imports.182  

We also have considered the likely role of demand in the reasonably foreseeable future.  

Overall, demand, as measured by apparent U.S. consumption, increased from 2008 to 2013.183  

It remains well below the levels of the original investigations, however, and it is expected to

increase only modestly, reflecting the weakness in the housing industry.184  The moderate level

of increased demand likely in the reasonably foreseeable future, while likely to affect the

domestic industry’s condition positively, would not preclude the domestic industry from

incurring an adverse impact due to the likely significant volume and price effects of the

cumulated subject imports.

                                                      

180 Commissioner Broadbent has reached a negative determination on subject imports from

Mexico.  She has also considered these imports in her consideration of the role of factors other than

cumulated subject imports from China, Korea, and Turkey.

181 CR/PR at Table I‐2.

182 See CR/PR at Table I‐2.  We are mindful that the use of AUVs for establishing price trends or

comparisons may present product mix issues in that divergent values may reflect different merchandise

rather than differences in price.  Accord Allegheny Ludlum Corp. v. United States, 287 F.3d 1365, 1373‐74

(Fed. Cir. 2002).

183 CR/PR at Table I‐2.

184 CR at II‐12.
29

Accordingly, we conclude that, if the antidumping and countervailing duty orders were

revoked, cumulated subject imports from China, Korea, Mexico and Turkey would likely have a

significant impact on the domestic industry within a reasonably foreseeable time.

V. Conclusion

For the above reasons, we determine that revocation of the countervailing duty order

on LWR pipe and tube from China and the antidumping duty orders on LWR pipe and tube from

China, Korea, Mexico, and Turkey would likely lead to continuation or recurrence of material

injury to an industry in the United States within a reasonably foreseeable time.185

                                                      

185 Commissioner Broadbent determines that revocation of the antidumping duty order on LWR

pipe and tube from Mexico would not be likely to lead to continuation or recurrence of material injury

to an industry in the United States within a reasonably foreseeable time.
31

ADDITIONAL AND DISSENTING VIEWS OF COMMISSIONER MEREDITH M. BROADBENT

CONCERNING SUBJECT IMPORTS FROM MEXICO

Based on the record in this five‐year review, I determine under section 751(c) of the

Tariff Act of 1930, as amended, that revocation of the antidumping duty order on light‐walled

rectangular (“LWR”) pipe and tube from Mexico would not be likely to lead to continuation or

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

foreseeable time.

Except as otherwise noted, I join the Views of the Commission concerning domestic like

product, domestic industry, the legal standard concerning five‐year reviews, conditions of

competition, cumulation with regard to all subject countries except Mexico, and the affirmative

determination on cumulated subject imports from China, Korea, and Turkey.

I. Introduction

As discussed below, the Mexican industry is focused on serving its home market and has

exported a small and shrinking proportion of its shipments to regional markets. The Mexican

industry has had an established, gradually declining presence in the largest of these regional

markets — the United States — since the original period of investigation. This status quo is

unlikely to change in the reasonably foreseeable future, whether or not imports enter under

the discipline of the antidumping duty order. I have not found that a correlation existed

between the presence of low‐priced imports from Mexico and any adverse price effects

experienced by the domestic industry during the current period of review. For these reasons, I

find that, upon revocation, the existence of subject imports from Mexico would not be likely to

have a significant adverse effect on domestic producers’ prices or otherwise have a significant

adverse impact on the domestic industry. In contrast, the subject imports from China, Korea,

and Turkey have been virtually absent since the orders were imposed in 2008. These industries,

which are heavily focused on exports, are likely to compete more aggressively for their lost U.S.

market share if the orders on these countries were revoked.
32

II. Cumulation1

Based on my review of the record, I find that subject imports from Mexico would be

likely to compete under different conditions of competition than the subject imports from the

other subject countries, China, Korea, and Turkey. Subject imports from China, Korea, and

Turkey were heavily restrained by the orders after they were imposed in 2008, and have been

at near zero levels since that time.2 The evidence on the record does not indicate that

conditions of competition in these industries would prevent a reversal of the orders’ effect on

the volume of subject imports from China, Korea, and Turkey.  In contrast, imports from Mexico

have remained present in the U.S. market, while the market share held by these imports fell

steadily from 16.2 percent in 2005 to 12.3 percent in 2013, as Mexican home market shipments

increased.3 The continued presence of subject imports from Mexico is evidence of the

continued importance of the U.S. market to the Mexican industry, but as discussed below, this

importance has waned for reasons other than the antidumping duty order. I consequently

decline to exercise my discretion to cumulate subject imports from Mexico with imports from

the other subject countries.

During the original period of investigation, the Commission received foreign producer

questionnaire responses from eight Mexican producers accounting for *** percent of U.S.

imports from Mexico.4 In these reviews, the Commission received questionnaire responses

from seven Mexican producers that are believed to account for the vast majority of Mexican

LWR pipe and tube production in 2013.5 Therefore, the Commission has nearly complete

                                                            

1 See Views of the Commission, Section III.A, regarding the legal standard for cumulation.  

In the original investigations, subject imports from Mexico declined from 156,263 short tons in

2005 to 140,937 short tons in 2007. Subject imports from Mexico continued to have a presence in the

U.S. market during the period of review, falling from 115,179 short tons in 2008 to 82,710 short tons in

2013. CR/PR at Table I‐2. Subject imports from Mexico accounted for 12.3 percent of apparent U.S.

consumption in 2013, larger than any other source of imports. CR/PR at Table C‐1. Despite the sustained

decline in subject imports from Mexico that has continued since 2005, it is likely that subject imports

from Mexico will remain present in the U.S. market for the reasonably foreseeable future. Accordingly, I

do not find that subject imports from Mexico would likely have no discernible adverse impact on the

domestic industry if the order were revoked.  

I also join the discussion within the Views of the Commission regarding the likelihood of a

reasonable overlap of competition, Section III.C. I find that there likely would be a reasonable overlap in

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

subject imports from each country upon revocation. 2 CR/PR at Table I‐2. Subject imports from China entered in amounts of less than 1,000 short tons in

each year during the period of review, compared to 88,879 short tons in 2007. Subject imports from

Korea (excluding the firm Nexteel) were *** short tons in 2008,  *** short tons in 2009, *** short tons

in 2010, and zero in 2011, 2012, and 2013. Subject imports from Turkey entered in amounts of less than

1,000 short tons in each year between 2008 and 2011, and were 5,920 short tons in 2012 and 2,101

short tons in 2013.

3 CR/PR at Table I‐2; CR/PR at Table IV‐7. 4 Derived from Tables VII‐7 and VII‐23 in INV‐FF‐049. 5 CR at IV‐14, PR at IV‐11.
33

coverage of the Mexican industry extending back to 2005. The Mexican industry has

experienced periods of growth, but this growth has been sustained with consistently high

capacity utilization rates of between *** percent and *** percent.6 Evidence on the record

therefore indicates that as the industry has grown, it has been effective in managing production

to avoid high levels of overcapacity.  

Since 2005, the Mexican industry has had an apparent strategy of focusing primarily on

its home market, with secondary sales serving regional export markets, including the United

States. Throughout the original period of investigation and extending into 2013, the Mexican

industry has increased its concentration on sales to non‐U.S. markets, particularly its home

market. Home market shipments and internal consumption/transfers increased from 72.5

percent of the Mexican industry’s shipments in 2005 to 78.3 percent in 2007.7 During the

current period of review, this share has increased from *** percent in 2008 to *** percent in

2013.8 Mexican exports to other export markets (primarily Central and South America)

accounted for an additional *** percent of Mexican shipments in 2013, with shipments to the

United States accounting for the remaining *** percent.9

As the Mexican industry has become more focused on its home market and other

regional markets, U.S. imports from Mexico have decreased for reasons other than the

imposition of the antidumping duty order. This decline was due, in part, to a fall in U.S. demand

that affected U.S. shipments from all sources. Apparent U.S. consumption fell by 30.5 percent

from 2007 to 2008 and by 25.3 percent from 2008 to 2009, while imports from Mexico dropped

by 18.3 percent and 40.7 percent, respectively.10 In addition, Prolamsa, the importer and

Mexican producer ***, opened a U.S. manufacturing facility in Laredo, Texas in 2009, and ***.11

***.12 Subject imports from Mexico have remained at 82,710 short tons or lower since 2009,

compared to 115,179 short tons in 2008.13 Therefore, even though U.S. demand has begun to

recover since 2009, subject imports from Mexico have not resumed entering the U.S. market at

pre‐recession levels because Prolamsa has shifted toward serving the U.S. market using U.S.‐

based production.  

Unlike the industry in Mexico, evidence on the record with respect to the industries in

China, Korea, and Turkey indicates that the presence of the orders is the only restraining factor

on subject imports from these countries. No foreign producer from China or Korea responded

to the Commission’s foreign producer questionnaire, but public trade data indicates that these

industries remain highly export‐oriented and ship significant volumes all over the world.  

Exports from China of light‐walled rectangular tubular products (a product category that

includes subject LWR pipe and tube) more than doubled from 375,533 short tons in 2008 to

850,696 short tons in 2013, with no single country accounting for 10 percent or more of

                                                            

6 Derived from Table VII‐8 and Table VII‐23 in INV‐FF‐049; CR/PR at Table IV‐7. 7 Derived from Table VII‐8 and Table VII‐23 in INV‐FF‐049.

8 CR/PR at Table IV‐7.

9 CR/PR at Table IV‐7, CR at IV‐19, PR at IV‐12.

10 CR/PR at Table I‐2. 11 CR/PR at Table III‐1, Table III‐7, and Table IV‐10. 12 Derived from CR/PR Table III‐7 and III‐3, III‐10, and Prolamsa’s Producer Questionnaire response.

13 CR/PR at Table C‐1.
34

Chinese exports over this time period.14 Exports from Korea of the same product category

increased from 73,038 short tons in 2008 to 116,733 short tons in 2013, and were shipped to

countries all over the world.15  

The two responding Turkish producers exported between *** and *** percent of their

LWR pipe and tube shipments during the period of review, indicating a focus on exports.16

Despite accounting for *** percent of total Turkish production in 2013,17 the responding

Turkish producers together had combined excess capacity of *** short tons, indicating that the

Turkish industry has substantial excess capacity with which it can increase exports.18 In

addition, no producer in China, Korea, or Turkey had an investment in U.S. production facilities

during the period of review, indicating that they do not have the ability to serve the U.S. market

using means other than exports.19

Consequently, I find that the current conditions of competition are sufficiently different

for subject imports from Mexico and for those from other subject countries. Subject imports

from Mexico remained present after the orders went into effect, but continued to decline at a

steady pace between the original period of investigation and the current period of review in

line with shifts in production and a greater focus on home market sales. In contrast, imports

from the other subject industries experienced sharp declines as a result of the orders going into

effect that could easily be reversed given the export orientation of these industries. I therefore

determine that, in the event of revocation, imports from Mexico would respond differently

from other subject imports. Accordingly, I do not exercise my discretion to cumulate subject

imports from Mexico with other subject imports.

III. Revocation of the Antidumping Duty Order on Subject Imports from Mexico Is Not

Likely to Lead to Continuation or Recurrence of Material Injury to the Domestic Industry

A. Likely Volume of Subject Imports

Since 2005, the first year in which this market was analyzed by the Commission, subject

imports from Mexico have been in steady decline. Subject imports from Mexico fell from

156,263 short tons in 2005 to 140,937 short tons in 2007, or by 9.8 percent. The imposition of

the orders in 2008 coincided with a sharp decline in apparent U.S. consumption, which fell by

30.5 percent in that year. While subject imports from China, Korea, and Turkey each fell by ***

to *** percent in 2008 as a result of the orders, subject imports from Mexico declined by 18.3

                                                            

14 CR/PR at Table IV‐3.

15 CR/PR at Table IV‐5.

16 CR/PR at Table IV‐11. 17 CR at I‐11, PR at I‐10.

18 CR/PR at Table IV‐11. For comparison, apparent U.S. consumption was 674,043 short tons in 2013,

meaning that reported Turkish excess capacity was equivalent to *** percent of the U.S. market in that

year.

19 CR/PR at Table I‐6.
35

percent, in line with the decrease in overall demand. In 2008, subject imports from Mexico

totaled 115,179 short tons, accounting for 18.5 percent of U.S. market.20

In 2009, Mexican producer Prolamsa, ***,21 opened a U.S. manufacturing facility in

Laredo, Texas.22 ***.23 With this shift in Prolamsa’s supply strategy toward the United States,

subject imports from Mexico fell to 68,311 short tons in 2009, and remained between 60,925

short tons and 82,710 short tons (or between 10.6 percent and 12.7 percent of the U.S. market)

from 2010 to 2013.24 Therefore, subject imports from Mexico have trended downward since

the first year of the original period of investigation, and have done so in line with lower U.S.

demand and a greater focus on serving the U.S. market using ***.  

The record does not support the conclusion that subject imports from Mexico would

likely exceed the volumes observed during the period of review if the order were revoked.

While the Mexican industry increased its capacity during the current period of review, its

capacity utilization also increased and remained high.25 In 2013, the Mexican industry’s capacity

utilization rate of *** percent was the highest it had been at any time since ***.26 Given that

U.S. imports from Mexico declined during the original period of investigation when capacity

utilization rates were lower and the quantity of excess capacity was higher, it is unlikely that

current excess capacity would be used to increase shipments to the United States if the order

were revoked.

In addition, the Mexican industry’s shipments have increasingly been focused on its own

home market and other nearby regional markets. Shipments to the United States have

decreased as a result.27 Mexican exports to the United States as a share of the Mexican

industry’s total shipments continued to decline steadily from 27.5 percent in 2005 to 21.6

                                                            

20 CR/PR at Table I‐2. 21 See INV‐FF‐049 at Table IV‐1 (showing that *** of imports from Mexico between 2005 and 2007).

*** of subject imports from Mexico was shipped to the Central Southwest region in 2007, a

region that accounted for only 8.9 percent of domestic producers’ U.S. shipments in 2007. INV‐FF‐049 at

Table III‐6 and Table IV‐6. *** of its LWR pipe and tube imports from Mexico to the Central Southwest

region in 2007, with *** percent shipped to the Midwest and *** percent shipped to the Southeast.

INV‐FF‐049 at Table IV‐6. The Midwest and the Southeast were the destinations for 61.9 percent of

domestic producers’ U.S. shipments in 2007. INV‐FF‐049 at Figure III‐1 and Table III‐6. Therefore, the

***.

22 CR/PR at Table III‐1.

23 CR/PR at Table III‐7, Table IV‐8, Table IV‐10. ***. CR/PR at Table III‐7.

24 CR/PR at Table I‐2.

25 During the current period of review, Mexican capacity grew by *** percent and production increased

by *** percent, while capacity utilization increased from *** percent in 2008 to *** percent in 2013.

CR/PR at Table IV‐7.

26 Derived from Table VII‐8 and Table VII‐23 in INV‐FF‐049; CR/PR at Table IV‐7. The Mexican industry’s

excess capacity was *** short tons in 2013. This volume is lower than excess capacity during the original

period of investigation, which was between *** short tons and *** short tons. Id.

27 During the original period of investigation, Mexican exports to the United States decreased by 16.0

percent, while home market shipments and internal consumption/transfers increased by 15.7 percent.

Derived from Table VII‐8 and Table VII‐23 in INV‐FF‐049. Similarly, during the current period of review,

Mexican exports to the United States decreased by *** percent, while home market shipments and

internal consumption/transfers increased by *** percent. CR/PR at Table IV‐7.
36

percent in 2007 during the original period of investigation,28 and from *** percent in 2008 to

*** percent in 2013 during the current period of review.29 *** of the remaining shipments

went to the Mexican home market. The exception was 2013, in which *** percent of Mexican

shipments were exports to third‐country markets primarily in nearby Central and South

America.30 Evidence on the record does not indicate that U.S. price levels are higher than the

prices that Mexican producers receive in alternative markets.31 Therefore, Mexican producers

are not likely to divert growing shipments from home or other regional export markets to the

United States if the order were revoked.  

Mexico has remained the largest source of imports in the United States since 2005, and I

therefore conclude that the volume of subject imports from Mexico would likely remain

significant if the order were revoked.32 However, the importance of the United States as a

secondary market for Mexican producers has lessened over time. This decline has been

reinforced by strong Mexican home market sales, a fall in U.S. demand, and Prolamsa’s status

as a U.S. domestic producer. I therefore conclude that subject imports from Mexico would not

likely rise to the volume levels experienced during the original period of investigation, and

would not change appreciably from the considerably lower volume levels of the current period

of review. As discussed below, I find that the significant volume of subject imports from Mexico

would not be likely to have a significant adverse effect on domestic producers’ prices or

otherwise have a significant adverse impact on the domestic industry.

B. Likely Price of Subject Imports

Price is generally an important factor in purchasing decisions in the U.S. LWR pipe and

tube market.33 In these reviews, sixteen U.S. producers and four importers from Mexico

provided usable price data for comparison of quarterly prices for the domestic like product and

subject imports from Mexico.  Reported pricing data accounted for *** percent of U.S.

shipments of U.S. produced LWR pipe and tube and *** percent of U.S. imports from Mexico.34  

During the period of review, subject imports from Mexico undersold the domestic like product

in 72 of 83 comparisons at an average margin of 9.2 percent.35 This pattern of underselling is

                                                            

28 Derived from Table VII‐8 and Table VII‐23 in INV‐FF‐049.

29 CR/PR at Table IV‐7.

30 CR/PR at Table IV‐7 and CR at IV‐19 and PR at IV‐12.   31 The average unit value of Mexican exports to the United States in 2013 was $*** per short ton,

compared to $*** per short ton for home market shipments and $*** per short ton for exports to third‐

country markets. CR/PR at Table IV‐7.

32 I have also considered the potential for product shifting by Mexican producers, the role of existing

inventories, and the existence of barriers to the importation of subject imports from Mexico in third‐

country markets. The majority of the reporting subject producers in Mexico indicated that ***. CR at IV‐

18, PR at IV‐12. Inventories in Mexico as a ratio to Mexican shipments *** from *** percent in 2008 to

*** percent in 2013. CR/PR at Table IV‐7.  The record does not indicate that subject producers in Mexico

face barriers to their exports in third‐country markets. See CR at IV‐19 n. 19, PR at IV‐12 n. 19.

33 CR/PR at Table II‐6.    34 CR at V‐6, PR at V‐5.

35 CR/PR at Table V‐8.
37

similar to that during the original period of investigation, when subject imports from Mexico

undersold the domestic like product in 41 out of 53 quarterly price comparisons, at an average

underselling margin of 11.7 percent.36  

Prices for the domestic like product increased over the period of review for all four

products, even as prices for subject imports from Mexico decreased over the period of

review.37  These product‐specific price increases occurred even as the per short ton value of

cost of goods sold (COGS) and raw materials fell over the period of review.38 While the

industry’s average unit value of net sales declined over the period of review, the industry’s

COGS to net sales ratio remained relatively stable.39 Therefore, despite the fact that subject

imports from Mexico undersold the domestic like product throughout the period of review,

there is no evidence that this pricing behavior correlated with any U.S. price depression, nor

was there any evidence that subject imports prevented U.S. price increases which otherwise

would have occurred.

I do not anticipate that the pricing patterns of subject imports from Mexico would likely

change appreciably upon revocation of the order.  Fairly priced subject imports from Mexico

during the current period of review undersold with a similar frequency and at similar margins to

unfairly priced imports during the original period of investigation. Moreover, as I have

previously found, the volume of subject imports from Mexico is not likely to increase

appreciably from the levels observed during the period of review.  Accordingly, exporters of the

subject merchandise from Mexico would have no incentive to reduce prices upon revocation; at

the likely prevailing volumes, reduced prices would only serve to reduce the exporters’

revenues.  Because these pricing patterns did not cause significant adverse price effects during

the five‐year period of review, they are unlikely to do so in the reasonably foreseeable future if

the order were revoked.  Hence, I conclude that the likely volume of subject imports from

Mexico would not be likely to have significant price‐depressing or price‐suppressing effects if

the order were revoked.   

C. Likely Impact of Subject Imports

I incorporate by reference the discussion within the Views of the Commission regarding

the condition of the domestic industry in section VI‐E.  For the reasons stated there, I find that

the domestic industry is not in a vulnerable condition. I note the steady improvement of the

industry since its low point in 2009, as indicated by growth in production, shipments, net sales,

operating income, and the number of production workers employed by the industry between

2009 and 2013.40

                                                            

36 Derived from Tables V‐1 to V‐5 and Tables D‐1 to D‐4 in INV‐FF‐049.

37 CR/PR at Table V‐7. U.S. prices increased by between 3.9 and 21.3 percent, while Mexican prices

declined by between 2.1 and 24.9 percent.

38 CR/PR at Table III‐11. The U.S. industry’s per‐unit raw material costs fell from $794 per short ton in

2008 to $695 per short ton in 2013, while the U.S. industry’s per‐unit COGS fell from $948 per short ton

in 2008 to $849 per short ton in 2013.

39 CR/PR at Table C‐1. The U.S. industry’s COGS/net sales ratio was 83.2 percent in 2008, 95.1 percent in

2009, 89.4 percent in 2010, 82.9 percent in 2011, 86.0 percent in 2012, and 86.9 percent in 2013.

40 CR/PR at C‐1.
38

In view of my findings regarding the likely volume and price effects of subject imports

from Mexico and the current lack of vulnerability of the domestic industry, I conclude that

subject imports from Mexico would not be likely to have a significant adverse impact on the

domestic industry’s output, sales, market share, profits, or return on investments if the order

were revoked.  The volumes of subject imports from Mexico likely upon revocation would be

insufficient to have likely price effects and therefore would not be likely to cause any significant

declines in the domestic industry’s revenues or financial performance.  Accordingly, I determine

that revocation of the antidumping duty order on subject imports from Mexico would not be

likely to lead to the continuation or recurrence of material injury to the domestic industry

within a reasonably foreseeable time.

IV. Conclusion

For the reasons stated above, I determine that revocation of the antidumping duty

order on imports of LWR pipe and tube from Mexico would not be likely to lead to continuation

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

foreseeable time.

I‐1

PART I: INTRODUCTION

BACKGROUND

On	April	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	countervailing	

duty	order	on	light‐walled	rectangular	pipe	and	tube	(“LWR	pipe	and	tube”)	from	China	

and	the	antidumping	duty	orders	on	LWR	pipe	and	tube	from	China,	Korea,	Mexico,	and	

Turkey	would	likely	lead	to	the	continuation	or	recurrence	of	material	injury	to	a	domestic	

industry.2 3	On	July	5,	2013,	the	Commission	determined	that	it	would	conduct	full	reviews	

pursuant	to	section	751(c)(5)	of	the	Act.	4		

The	following	tabulation	presents	information	relating	to	the	background	and	

schedule	of	this	proceeding:5		

                                                            

1 19 U.S.C. 1675(c). 2 Light‐Walled Rectangular Pipe and Tube from China, Korea, Mexico, and Turkey; Institution of Five‐

Year Reviews, 78 FR 19526, April 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 19647, April 2, 2013. 4 Light‐Walled Rectangular Pipe and Tube from China, Korea, Mexico, and Turkey: Notice of

Commission Determinations to Conduct Full Five‐Year Reviews, 78 FR 42546, July 16, 2013. The

Commission determined that the domestic interested party group responses were adequate and that

the respondent interested party group response to its notice of institution with respect to Mexico was

adequate, and decided to conduct a full review of the antidumping duty order on LWR pipe and tube

from Mexico. Although the Commission received a response to its notice of institution from the

Government of Turkey, the Commission found that the respondent interested party group responses

with respect to China, Korea, and Turkey were inadequate. However, the Commission determined to

conduct full reviews concerning the orders on LWR pipe and tube from China, Korea, and Turkey to

promote administrative efficiency in light of its decision to conduct a full review with respect to Mexico.   5 The Commission’s notice of institution, notice to conduct full reviews, scheduling notice, and

statement on adequacy are referenced in appendix A and may also be found at the Commission’s web

site (internet address www.usitc.gov). Commissioners’ votes on whether to conduct expedited or full

reviews may also be found at the web site. Appendix B contains a list of the witnesses that appeared at

the Commission’s hearing.
I‐2

Effective date Action

May 30, 2008 

Commerce’s antidumping duty order on LWR pipe and tube from Turkey (73 

FR 31065) 

August 5, 2008 

Commerce’s antidumping duty order on LWR pipe and tube from Mexico, 

China, and Korea (73 FR 45403) 

August 5, 2008 

Commerce’s countervailing duty order on LWR pipe and tube from China (73 

FR 45405) 

April 1, 2013 Commission’s institution of five-year reviews (78 FR 19526) 

April 1, 2013 Commerce’s initiation of five-year reviews (78 FR 19647, April 2, 2013) 

July 5, 2013 

Commission’s determinations to conduct full five-year reviews (78 FR 42546, 

July 16, 2013) 

August 6, 2013 

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

duty orders (78 FR 47671) 

August 8, 2013 

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

duty order (78 FR 48416) 

December 3, 2013 Commission’s scheduling of the reviews (78 FR 74161, December 10, 2013) 

April 3, 2013 Commission’s hearing 

May 23, 2013 Commission’s vote 

June 9, 2014 Commission’s determinations and views 

The original investigations

The	original	investigations	resulted	from	petitions	field	by	Allied	Tube	and	Conduit,	

(“Allied”);	Atlas	Tube	(“Atlas	Chicago”),	California	Steel	&	Tube	(“California”),	EXL	Tube	

(“EXL	Tube”);	Hannibal	Industries,	Inc.	(“Hannibal”),	Leavitt	Tube	Company	(“Leavitt”);	

Maruichi	American	Corp.	(“Maruichi”);	Searing	Industries	(“Searing”),	Southland	Tube,	Inc.	

(“Southland”),	Vest,	Inc.	(“Vest”),Welded	Tube;	and	Western	Tube	&	Conduit	Corp.	

(“Western”),	alleging	that	an	industry	in	the	United	States	is	materially	injured	and	

threatened	with	material	injury	by	reason	of	subsidized	imports	of	LWR	pipe	and	tube	

from	China	and	less‐than‐fair‐value	(“LTFV”)	imports	of	LWR	pipe	and	tube	from	China,	

Korea,	Mexico,	and	Turkey.6	Following	notification	of	a	final	determination	by	Commerce	

that	imports	of	LWR	pipe	and	tube	from	China	were	being	subsidized	and	imports	of	LWR	

pipe	and	tube	from	China,	Korea,	Mexico,	and	Turkey	were	sold	at	LTFV,	the	Commission	

determined	that	a	domestic	industry	was	materially	injured	by	reason	of	subsidized	

imports	of	LWR	pipe	and	tube	from	China	and	LTFV	imports	of	LWR	pipe	and	tube	from	

China,	Korea,	Mexico,	and	Turkey.7	Commerce	published	the	antidumping	duty	order	on	

                                                            

6 Bull Moose Tube, Inc. (“Bull Moose”) joined the original 12 petitioning firms over the course of the

investigations.   7 Light‐Walled Rectangular Pipe and Tube from Turkey, Inv. No. 731‐TA‐1121 (Final), USITC

Publication 4001 (May 2008); Light‐Walled Rectangular Pipe and Tube from China, Korea, and Mexico,

Inv. Nos. 731‐TA‐118‐1120 (Final), USITC Publication 4024 (July 2008). By decision and order dated

November 26, 2010, a NAFTA Chapter 19 Binational Panel affirmed in part and remanded in part the

Commission’s unanimous final affirmative determination with regard to LWR pipe and tube from

(continued...)
I‐3

subject	imports	of	LWR	pipe	and	tube	from	Turkey	on	May	30,	2008.8	Commerce	published	

the	antidumping	duty	orders	on	LWR	pipe	and	tube	from	China,	Mexico,	and	Korea	and	the	

countervailing	duty	order	on	China	on	August	5,	2008.9		

PREVIOUS INVESTIGATIONS

The	Commission	has	investigated	LWR	pipe	and	tube	several	times	both	in	import‐

injury	investigations	and	in	studies	associated	with	steel	safeguard	measures.10	Table	I‐1	

presents	data	on	previous	import	injury	investigations	and	reviews	concerning	LWR	pipe	

and	tube.		

Table I-1 

LWR pipe and tube: Previous import injury investigations 

Source Inv. No. 

USITC Publication 

Number Date Result 

Korea 731-TA-138 (Final) USITC 1519 April 1984 Affirmative; revoked October 

1985 VRA 

Spain 731-TA-198 (Preliminary) USITC 1569 August 1984 Terminated after preliminary; 

petition withdrawn 

Taiwan 731-TA-211 (Final) USITC 1799 January 1986 Negative 

Singapore 731-TA-296 (Final) USITC 1907 November 1986 Affirmative 

731-TA-296 (Review) USITC 3316 July 2000 Revoked following ITC 

negative 

Table continued on next page.

                                                            

(...continued)

Mexico. Upon consideration of the remand order, the Commission again found that an industry in the

United States was materially injured by reason of imports of LWR pipe and tube from Mexico that have

been found by the Department of Commerce to be sold in the United States at less than fair value. Light‐

Walled Rectangular Pipe and Tube from Mexico, Inv. 731‐TA‐1120 (Remand), USITC Publication 4272

(February 2011).   8 Notice of Antidumping Duty Order:  Light‐Walled Rectangular Pipe and Tube from Turkey, 73 FR

31065, May 30, 2008.

9 Light‐Walled Rectangular Pipe and Tube from Mexico, the People's Republic of China, and the

Republic of Korea: Antidumping Duty Orders; Light‐Walled Rectangular Pipe and Tube from the Republic

of Korea: Notice of Amended Final Determination of Sales at Less Than Fair Value, 73 FR 45403, August

5, 2008. Light‐Walled Rectangular Pipe and Tube from the People's Republic of China: Notice of

Countervailing Duty Order, 73 FR 45405, August 5, 2008.

10 President George W. Bush issued a proclamation in 2002, imposing temporary import relief for a

period not to exceed three years and one day. Import relief, which did not apply to Mexico or Turkey,

consisted of an additional tariff of 15 percent ad valorem on imports in the first year, 12 percent in the

second year, and 9 percent in the third year. The steel safeguard tariffs were terminated on December

4, 2003. Presidential Proclamation 7741 of December 4, 2003 (68 FR 68483, December 8, 2003).
I‐4

Table I-1--Continued

LWR pipe and tube: Previous import injury investigations 

Source Inv. No. 

USITC Publication 

Number Date Result 

Taiwan 731-TA-349 (Final) USITC 1994 July 1987 Negative 

Argentina 731-TA-409 (Final) USITC 2187 May 1989 Affirmative 

731-TA-409 (Review) USITC 3316 July 2000 Order continued 

731-TA-409 (Second 

Review) 

USITC 3867 July 2006 Revoked following ITC 

negative 

Taiwan 731-TA-410 (Final) USITC 2169 March 1989 Affirmative 

731-TA-410 (Review) USITC 3316 July 2000 Order continued 

731-TA-410 (Second 

Review) 

USITC 3867 July 2006 Order continued 

Mexico 731-TA-730 (Preliminary) USITC 2892 May 1995 ITC Negative 

Mexico 731-TA-1054 (Final) USITC 3728 October 2004 ITC Negative 

Turkey 731-TA-1055 (Final) USITC 3728 October 2004 ITC Negative 

Turkey 731-TA-1121 (Final) USITC 4001 May 2008 Affirmative 

China 701-TA-449 (Final) USITC 4024 July 2008 Affirmative 

731-TA-1118 (Final) USITC 4024 July 2008 Affirmative 

Korea 731-TA-1119 (Final) USITC 4024 July 2008 Affirmative 

Mexico 731-TA-1120 (Final) USITC 4024 July 2008 Affirmative 

Source: Cited Commission publications. 

SUMMARY DATA

Table	I‐2	presents	a	summary	of	data	from	the	original	investigations	and	the	

current	full	five‐year	reviews.	During	the	original	investigations,	Commerce	issued	its	final	

LTFV	determination	with	respect	to	LWR	pipe	and	tube	from	Turkey	earlier	than	it	did	in	

its	investigations	with	respect	to	China,	Korea,	and	Mexico.	As	a	result,	the	Commission	

issued	its	determination	with	respect	to	LWR	pipe	and	tube	from	Turkey	earlier	than	

China,	Korea,	and	Mexico.11	In	Commerce’s	preliminary	determination	concerning	Mexico,	

producer	Prolamsa	received	a	zero	percent	dumping	margin;	therefore,	for	the	

Commission’s	determination	with	respect	to	LWR	pipe	and	tube	from	Turkey,	data	relating	

to	Prolamsa	were	classified	as	nonsubject.	In	its	final	determination,	however,	Commerce	

calculated	a	dumping	margin	for	Prolamsa,	and	accordingly,	Prolamsa	was	reclassified	as	

subject	exporter	for	purposes	of	the	Commission’s	final	determinations	on	China,	Korea,	

and	Mexico.12	Prolamsa	remains	subject	to	the	antidumping	duty	order	on	LWR	pipe	and	

tube	from	Mexico,	while	Korean	producer	Nexteel	remains	excluded	from	the	antidumping	

duty	order	on	LWR	pipe	and	tube	from	Korea.	

                                                            

11 Light‐Walled Rectangular Pipe and Tube from Turkey, Inv. No. 731‐TA‐1121 (Final), USITC

Publication 4001 (May 2008). 12 Light‐Walled Rectangular Pipe and Tube from China, Korea, and Mexico, Inv. Nos. 731‐TA‐118‐1120

(Final), USITC Publication 4024 (July 2008).
Table I-2 

LWR pipe and tube: Comparative data from the original investigations and current review, 2005-13 

Item 2005 2006 2007 2008 2009 2010 2011 

U.S. consumption quantity: Amount 962,225 1,025,684 894,973 622,369 465,200 532,363 553,03U.S. producers’ share 65.1 60.8 64.8 72.1 75.4 77.3 78U.S. importers’ share  China 4.2 8.0 9.9 0.1 0.0 0.0 0 Korea (subject) *** *** *** *** *** *** 0 Mexico 16.2 14.1 15.7 18.5 14.7 12.7 11 Turkey 3.2 5.5 1.6 0.0 0.0 0.0 0 Subtotal, subject *** *** *** *** *** *** 11 All other sources *** *** *** *** *** *** 10 Total imports 34.9 39.2 35.2 27.9 24.6 22.7 21U.S. consumption value: Amount 834,193 869,323 730,480 714,394 378,733 494,233 598,98U.S. producers’ share 68.2 66.1 69.0 74.3 78.2 79.0 79U.S. importers’ share  China 3.2 5.5 7.2 0.1 0.0 0.0 0 Korea (subject) *** *** *** *** *** *** 0 Mexico 14.6 13.1 14.1 16.2 11.8 10.7 9 Turkey 2.8 4.1 1.3 0.0 0.0 0.0 0 Subtotal, subject *** *** *** *** *** *** 9 All other sources *** *** *** *** *** *** 10 Total imports 31.8 33.9 31.0 25.7 21.8 21.0 20Table continued on next page. 

I‐5
Table I-2--Continued

LWR pipe and tube: Comparative data from the original investigations and current review, 2005-13 

Item 2005 2006 2007 2008 2009 2010 2011 

U.S. imports from: China:  Quantity 39,945 81,657 88,879 687 31 109 277  Value 27,040 47,605 52,939 627 74 235 438  Average unit value $677 $583 $596 $912 $2,369 $2,161 $1,583 Korea (subject):  Quantity *** *** *** *** *** *** 0  Value *** *** *** *** *** *** 0  Average unit value $*** $*** $*** $*** $*** $*** $0 Mexico  Quantity 156,263 144,925 140,937 115,179 68,311 67,692 60,925  Value 122,203 113,714 102,714 115,638 44,664 52,906 57,051  Average unit value $782 $785 $729 $1,004 $654 $782 $936 Turkey  Quantity 30,517 55,952 14,511 0 36 0 564  Value 23,264 39,584 9,192 0 24 0 507  Average unit value $762 636 633 $0 $650 $0 $899 Subtotal, subject  Quantity *** *** *** *** *** *** 61,766  Value *** *** *** *** *** *** 57,997  Average unit value $*** $*** $*** $*** $*** $*** $939 All other sources  Quantity *** *** *** *** *** *** 56,148  Value *** *** *** *** *** *** 62,823  Average unit value $*** $*** $*** $*** $*** $*** $1,119 All countries:  Quantity 336,258 402,295 315,412 173,888 114,234 120,731 117,914  Value 264,904 294,805 226,400 183,896 82,603 103,553 120,820  Average unit value $788 $733 $718 $1,058 $723 $858 $1,025 Table continued on next page. 

I‐6
Table I-2--Continued

LWR pipe and tube: Comparative data from the original investigations and current review, 2005-13 

Item 2005 2006 2007 2008 2009 2010 2011 

U.S. producers’: 

Capacity quantity 964,957 947,858 902,385 1,110,314 1,081,371 1,089,411 1,141,53Production quantity 625,933 631,842 580,847 470,375 367,451 448,691 472,56

Capacity utilization 64.9 66.7 64.4 42.4 34.0 41.2 41

U.S. shipments: 

Quantity 625,967 623,389 579,559 448,481 350,966 411,632 435,12Value 569,288 574,517 504,081 530,498 296,130 390,680 478,16Unit value $909 $922 $870 $1,183 $844 $949 $1,09

Ending inventory 64,764 65,118 56,366 68,574 68,290 84,699 97,74Inventory/total shipments 10.3 10.3 9.6 14.5 18.7 19.6 21Production workers 1,114 1,023 973 876 779 800 85Hours worked (1,000) 1,993 1,822 1,682 1,923 1,605 1,741 1,93Wages paid (1,000 dollars) 33,854 33,343 31,485 62,827 57,173 59,255 63,82Hourly wages $16.99 $18.30 $18.71 $32.67 $35.62 $34.04 $33.0Productivity (short tons per hour) 314.1 346.9 345.3 244.6 228.9 257.7 244

Net sales: 

Quantity 591,721 586,896 549,260 480,053 369,862 426,764 453,22Value 539,809 542,437 481,378 546,642 321,192 399,436 488,90Unit value $912 $924 $876 $1,138.71 $868.41 $935.96 $1,078.7

Cost of goods sold 452,240 444,888 418,199 454,994 305,308 357,052 405,07Gross profit or (loss) 87,569 97,549 63,179 91,648 15,884 42,384 83,83SG&A 33,990 35,853 32,310 35,851 23,953 27,305 30,73Operating income or (loss) 53,579 61,696 30,869 55,797 -8,069 15,079 53,09Unit cost of goods sold $764 $758 $761 $947.80 $825.46 $836.65 $893.7Unit operating income or (loss) $91 $105 $56 $116.23 -$21.82 $35.33 $117.1Cost of goods sold/sales (percent) 83.8 82.0 86.9 83.2 95.1 89.4 82Operating income or (loss)/sales 9.9 11.4 6.4 10.2 -2.5 3.8 10Source: Compiled from data submitted in response to Commission questionnaires and from official import statistics of the Commerce adjusted to exclude Nexteel of Korea. 

I‐7
I‐8

Statutory criteria and organization of the report

Statutory criteria

Section	751(c)	of	the	Act	requires	Commerce	and	the	Commission	to	conduct	a	

review	no	later	than	five	years	after	the	issuance	of	an	antidumping	or	countervailing	duty	

order	or	the	suspension	of	an	investigation	to	determine	whether	revocation	of	the	order	

or	termination	of	the	suspended	investigation	“would	be	likely	to	lead	to	continuation	or	

recurrence	of	dumping	or	a	countervailable	subsidy	(as	the	case	may	be)	and	of	material	

injury.”	

Section	752(a)	of	the	Act	provides	that	in	making	its	determination	of	likelihood	of	

continuation	or	recurrence	of	material	injury‐‐	

(1) IN GENERAL.‐‐ . . . the Commission shall determine whether revocation of an

order, or termination of a suspended investigation, would be likely to lead to

continuation or recurrence of material injury within a reasonably foreseeable

time. The Commission shall consider the likely volume, price effect, and impact

of imports of the subject merchandise on the industry if the order is revoked or

the suspended investigation is terminated. The Commission shall take into

account‐‐ 

(A) its prior injury determinations, including the volume, price

effect, and impact of imports of the subject merchandise on the industry

before the order was issued or the suspension agreement was accepted,

(B) whether any improvement in the state of the industry is

related to the order or the suspension agreement,

(C) whether the industry is vulnerable to material injury if the

order is revoked or the suspension agreement is terminated, and  

(D) in an antidumping proceeding . . ., (Commerce’s findings)

regarding duty absorption . . ..

(2) VOLUME.‐‐In evaluating the likely volume of imports of the subject  

merchandise if the order is revoked or the suspended investigation is terminated,

the Commission shall consider whether the likely volume of imports of the

subject merchandise would be significant if the order is revoked or the

suspended investigation is terminated, either in absolute terms or relative to

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

shall consider all relevant economic factors, including‐‐ 

(A) any likely increase in production capacity or existing unused

production capacity in the exporting country,  

(B) existing inventories of the subject merchandise, or likely

increases in inventories,  

(C) the existence of barriers to the importation of such

merchandise into countries other than the United States, and  
I‐9

(D) the potential for product‐shifting if production facilities in

the foreign country, which can be used to produce the subject

merchandise, are currently being used to produce other products.

(3) PRICE.‐‐In evaluating the likely price effects of imports of the subject

merchandise if the order is revoked or the suspended investigation is terminated,

the Commission shall consider whether‐‐ 

(A) there is likely to be significant price underselling by imports

of the subject merchandise as compared to domestic like products, and  

(B) imports of the subject merchandise are likely to enter the

United States at prices that otherwise would have a significant

depressing or suppressing effect on the price of domestic like products.

(4) IMPACT ON THE INDUSTRY.‐‐In evaluating the likely impact of imports of the

subject merchandise on the industry if the order is revoked or the suspended

investigation is terminated, the Commission shall consider all relevant economic

factors which are likely to have a bearing on the state of the industry in the

United States, including, but not limited to–

(A) likely declines in output, sales, market share, profits,

productivity, return on investments, and utilization of capacity,  

(B) likely negative effects on cash flow, inventories, employment,

wages, growth, ability to raise capital, and investment, and  

(C) likely negative effects on the existing development and

production efforts of the industry, including efforts to develop a

derivative or more advanced version of the domestic like product.

The Commission shall evaluate all such relevant economic factors . . . within the

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

distinctive to the affected industry.

Section	752(a)(6)	of	the	Act	states	further	that	in	making	its	determination,	“the	

Commission	may	consider	the	magnitude	of	the	margin	of	dumping	or	the	magnitude	of	the	

net	countervailable	subsidy.	If	a	countervailable	subsidy	is	involved,	the	Commission	shall	

consider	information	regarding	the	nature	of	the	countervailable	subsidy	and	whether	the	

subsidy	is	a	subsidy	described	in	Article	3	or	6.1	of	the	Subsidies	Agreement.”		

Organization of report

Information	obtained	during	the	course	of	the	reviews	that	relates	to	the	statutory	

criteria	is	presented	throughout	this	report.	A	summary	of	trade	and	financial	data	for	LWR	

pipe	and	tube	as	collected	in	the	reviews	is	presented	in	appendix	C.	U.S.	industry	data	are	
I‐10

based	on	the	questionnaire	responses	of	18	U.S.	producers	of	LWR	pipe	and	tube	that	are	

believed	to	have	accounted	for	the	vast	majority	of		domestic	production	of	LWR	pipe	and	

tube	in	2013.13	U.S.	import	data	and	related	information	are	based	on	Commerce’s	official	

import	statistics	and	the	questionnaire	responses	of	14	U.S.	importers	of	LWR	pipe	and	

tube	that	are	believed	to	have	accounted	for	***	percent	of	subject	U.S.	imports	of	LWR	pipe	

and	tube	during	2008‐2013.14	Foreign	industry	data	and	related	information	are	based	on	

the	questionnaire	responses	of	nine	producers	of	LWR	pipe	and	tube.	Seven	producers	in	

Mexico,	which	accounted	for	the	vast	majority	of	total	production	of	LWR	pipe	and	tube	in	

Mexico	and	two	producers	in	Turkey,	which	accounted	for	approximately	***	percent	of	

total	production	of	LWR	pipe	and	tube	in	Turkey,	submitted	questionnaire	responses.	The	

Commission	received	no	responses	from	producers	of	LWR	pipe	and	tube	from	China	or	

Korea.	Responses	by	firms	to	a	series	of	questions	concerning	the	significance	of	the	

existing	antidumping	and	countervailing	duty	orders	and	the	likely	effects	of	revocation	of	

such	orders	are	presented	in	appendix	D.		

COMMERCE’S REVIEWS

Administrative reviews

Table	I‐3	presents	the	final	results	of	Commerce’s	administrative	reviews	of	the	

antidumping	duty	orders	on	LWR	pipe	and	tube	from	China,	Mexico,	and	Turkey.	

Commerce	has	not	conducted	any	administrative	reviews	on	the	orders	on	LWR	pipe	and	

tube	from	Korea.	

                                                            

13 The Commission received also three responses from domestic producers *** that were either

incomplete or that contained trade and financial data that were not usable. 14 Official Commerce statistics have been adjusted to exclude Nexteel, a producer of LWR pipe and

tube, which is excluded from the antidumping duty order on Korea. Light‐Walled Rectangular Pipe and

Tube from Mexico, the People's Republic of China, and the Republic of Korea: Antidumping Duty Orders;

Light‐Walled Rectangular Pipe and Tube from the Republic of Korea: Notice of Amended Final

Determination of Sales at Less Than Fair Value, 73 FR 45403, August 5, 2008.
I‐11

Table I-3 

LWR pipe and tube: Final results of Commerce’s administrative reviews, by country 

Country Period of review Producer or exporter 

Firmspecific 

rate 

(percent) 

China 1/20/2008-7/31/2009 

(75 FR 57456, September 21, 2010) The Sun Group 27.12

Turkey 1/30/2008-4/30/2009 

(75 FR 61127, October 4, 2010) Toscelik Profil Ve Sac Endustri A.S. 0.00

Mexico 1/30/2008-7/31/2009 

(76 FR 9547, February 18, 2011) 

Maquilacero S.A. de C.V. 3.11

Regiomontana de Perfiles y Tubos 

S.A. de C.V. 9.15

Galvak S.A. de C.V. 6.13

Hylsa S.A. de C.V. 6.13

Industrias Monterrey S.A. de C.V. 6.13

Nacional de Acero S.A. de C.V. 6.13

Perfiles y Herrajes LM S.A. de C.V. 6.13

Productos Laminados de Monterrey 

S.A. de C.V. 6.13

Ternium Mexico S.A. de C.V. 6.13

Turkey 5/1/2009-4/30/2010 

(76 FR 57953, September 19, 2011) Noksel Celik Boru Sanayi A.S. 0.00

Mexico 

8/1/2009-7/31/2010 

(77 FR 1915, January 12, 2012) 

Maquilacero S.A. de C.V. 0.80

Regiomontana de Perfiles y Tubos 

S.A. de C.V. 3.20

Turkey 5/1/2010-4/30/2011 

(78 FR 55455, September 10, 2012) Noksel Celik Boru Sanayi A.S. 0.00

Mexico 8/1/2010-7/31/2011 

(78 FR 1199, January 8, 2013) 

Maquilacero S.A. de C.V. 0.00

Regiomontana de Perfiles y Tubos 

S.A. de C.V. 0.00

Source: Cited Federal Register notices. 

Changed circumstances reviews

Commerce	has	conducted	one	changed	circumstances	review	with	respect	to	LWR	

pipe	and	tube	from	Mexico	and	determined	that	Ternium	is	the	successor‐in‐interest	to	
I‐12

Hysla	and,	as	a	result,	should	be	accorded	the	same	treatment	previously	accorded	to	Hysla	

in	regard	to	the	antidumping	duty	order	on	LWR	pipe	and	tube	from	Mexico	as	of	August	

19,	2009.15

Five‐year reviews

Commerce	has	issued	the	final	results	of	its	expedited	five	year	reviews	with	respect	

to	all	subject	countries.	Tables	I‐4	and	I‐5	present	the	countervailable	subsidy	rates	and	

antidumping	duty	margins	calculated	by	Commerce	in	its	original	investigations	and	first	

reviews,	respectively.16		

Table I-4 

LWR pipe and tube: Commerce’s original and subsequent five-year countervailable subsidy 

margins for producers/exporters in China 

Producer/exporter 

Original rate 

(percent) 

Five-year review 

rate (percent) 

Kunshan Lets Win Steel Machinery Co., Ltd. 2.17 2.20

Qingdao Xiangxing Steel Pipe Co., Ltd. 200.58 200.58

Zhangjiagang Zhongyuan Pipe-making Co., Ltd., 

Jiangsu Qiyuan Group Co., Ltd. 15.28 15.28

All others 15.28 15.28

Source: 73 FR 35642, June 24, 2008 and 78 FR 48416, August 8, 2013 

Table I-5 

LWR pipe and tube: Commerce’s original and subsequent five-year dumping margins for 

producers/exporters, by subject country 

Producer/exporter 

Original margin 

(percent) 

Five-year review 

margin (percent) 

China 

Zhangjiangang Zhongyuan Pipe Making Co., Ltd. 264.64 255.07

Kunshan Lets Win Steel Machinery Co., Ltd. 249.12 247.90

Wuxi Baishun Steel Pipe Co., Ltd. 249.12 247.90

Guangdong Walsall Steel Pipe Industrial Co., Ltd. 249.12 247.90

Table continued on next page. 

                                                            

15 Final Results of Antidumping Duty Changed Circumstances Review: Light‐Walled Rectangular Pipe

and Tube from Mexico, 74 FR 41680, August 18, 2009.   16 Final Results of Expedited Sunset Reviews of Antidumping Duty Orders: Light‐Walled Rectangular

Pipe and Tube from Mexico, Turkey, the People’s Republic of China, and the Republic of Korea, 78 FR

47671, August 6, 2013. Light‐Walled Rectangular Pipe and Tube from the People’s Republic of China:

Final Results of the Expedited First Sunset Review of the Countervailing Duty Order, 78 FR 48416, August

8, 2013.  
I‐13

Table I-5--Continued

LWR pipe and tube: Commerce’s original and subsequent five-year dumping margins for 

producers/exporters, by subject country 

Producer/exporter 

Original margin 

(percent) 

Five-year review 

margin (percent) 

China 

Wuxi Worldunion Trading Co., Ltd. 249.12 247.90

Weifang East Steel Pipe Co., Ltd. 249.12 247.90

Jiangyin Jianye Metal Products Co., Ltd. 249.12 247.90

All others 264.64 255.07

Korea 

Nexteel Co., Ltd. 0.92 (de minimus) (excluded)

Dong-A Steel Pipe Co. Ltd. 30.66 30.66

HiSteel Co. Ltd. 30.66 30.66

Jinbang Steel Co. Ltd. 30.66 30.66

Joong Won 30.66 30.66

Miju Steel Mfg. Co., Ltd. 30.66 30.66

Yujin Steel Industry Co. 30.66 30.66

Ahshin Pipe & Tube 30.66 30.66

Han Gyu Rae Steel Co., Ltd. 30.66 30.66

Kukje Steel Co., Ltd. 30.66 30.66

SeAH Steel Corporation, Ltd. 15.79 15.79

All others 15.79 15.79

Mexico 

Maquilacero S.A. de C.V. 2.40 2.40

Productos Laminados de Monterrey S.A. de C.V. 5.12 5.12

Arco Metal S.A. de C.V. 3.76 3.76

Hylsa S.A. de C.V. 3.76 3.76

Industrias Monterrey S.A. de C.V. 11.50 11.50

Internacional de Aceros, S.A. de C.V. 3.76 3.76

Nacional de Acero S.A. de C.V. 11.50 11.50

PEASA-Productos Especializados de Acero 11.50 11.50

Perfiles y Herrajes LM, S.A. de C.V. 3.76 3.76

Regiomontana de Perfiles y Tubos 3.76 3.76

Talleres Acero Rey S.A. de C.V. 3.76 3.76

Tuberias Aspe 11.50 11.50

Tuberia Laguna, S.A. de C.V. 3.76 3.76

Tuberias y Derivados S.A. de C.V. 11.50 11.50

All others 3.76 3.76

Table continued on next page. 
I‐14

Table I-5--Continued

LWR pipe and tube: Commerce’s original and subsequent five-year dumping margins for 

producers/exporters, by subject country 

Producer/exporter 

Original 

margin 

(percent) 

Five-year 

review margin 

(percent) 

Turkey 

Guven Boru Profil Sanayii ve Ticaret Limited Sirketi 41.71 41.71

MMZ Onur Boru Profil Uretim San. ve Tic. A.S. 41.71 41.71

Anadolu Boru 41.71 41.71

Ayata Metal Industry 41.71 41.71

Goktas Tube/Gotkas Metal 41.71 41.71

Kalibre Boru Sanayi ve Ticaret A.S. 41.71 41.71

Kerim Celik Mamulleri Imalat ve Ticaret 41.71 41.71

Ozgur Boru 41.71 41.71

Ozmak Makina ve Elektrik Sanayi 41.71 41.71

Seamless Steel Tube and Pipe Co. (“Celbor”) 41.71 41.71

Umran Steel Pipe Inc 41.71 41.71

Yusan Industries, Ltd. 41.71 41.71

Borusan Mannesmann Boru 27.04 27.04

Erbosan Erciyas Boru Sanayii ve Ticaret A.S 27.04 27.04

Noksel Steel Pipe Co. 27.04 27.04

Ozborsan Boru San. ve Tic. A.S 27.04 27.04

Ozdemir Boru Sanayi ve Ticaret Ltd. Sti. 27.04 27.04

Toscelik Profil ve Sac End. A.S. 27.04 27.04

Yucel Boru ve Profil Endustrisi A.S 27.04 27.04

All others 27.04 27.04

Source: 73 FR 45403, August 5, 2008 (Korea, Mexico, China); 73 FR 19814, April 11, 2008 (Turkey); 

78 FR 47671, August 6, 2013. 

THE SUBJECT MERCHANDISE

Commerce’s scope

Commerce	has	defined	the	scope	of	these	reviews	as	follows:	

The merchandise subject to the order is certain welded carbon quality

light‐walled steel pipe and tube, of rectangular (including square) cross

section, having a wall thickness of less than 4 mm.  

The term carbon‐quality steel includes both carbon steel and alloy steel

which contains only small amounts of alloying elements. Specifically, the

term carbon‐quality includes products in which none of the elements

listed below exceeds the quantity by weight respectively indicated: 1.80

percent of manganese, or 2.25 percent of silicon, or 1.00 percent of
I‐15

copper, or 0.50 percent of aluminum, or 1.25 percent of chromium, or

0.30 percent of cobalt, or 0.40 percent of lead, or 1.25 percent of nickel,

or 0.30 percent of tungsten, or 0.10 percent of molybdenum, or 0.10

percent of niobium, or 0.15 percent vanadium, or 0.15 percent of

zirconium. The description of carbon‐quality is intended to identify

carbon‐quality products within the scope.17

Tariff treatment

LWR	pipe	and	tube	is	classifiable	in	the	Harmonized	Tariff	Schedule	of	the	United	

States	(HTS)	under	the	HTS	subheading	7306.61.50.18	This	subheading	specifically	covers	

other	tubes,	pipes	and	hollow	profiles	of	iron	and	steel	of	a	rectangular	or	square	cross	

section	having	a	wall	thickness	of	less	than	4	millimeters.	The	general	rate	of	duty	for	this	

subheading	is	free.	Additionally,	certain	LWR	pipe	and	tube	may	be	imported	under	HTS	

subheading	7306.61.70	(statistical	reporting	number	7306.61.7060,	which	specifically	

covers	other	tubes,	pipes,	and	hollow	profiles	of	iron	and	steel	of	a	square	of	rectangular	

cross‐section	of	other	alloy	steel	(not	including	stainless	steel)).	The	general	rate	of	duty	

for	this	subheading	is	free.	The	HTS	subheadings	are	provided	for	convenience	and	

Customs	purposes,	and	Commerce’s	scope	of	these	investigations	is	dispositive.		

THE PRODUCT  

Overview  

LWR	pipe	and	tube	is	a	long‐rolled	welded	carbon	steel	product	commonly	used	in	

applications	not	involving	the	conveyance	of	liquids	or	gases,	and	not	designed	to	bear	

weight.	The	most	common	applications	for	LWR	pipe	are	where	a	thinner	wall	may	be	

preferred,	such	as	ornamental	fencing,	window	guards,	door	security	frames,	metal	

furniture,	cattle	chutes,	railings,	furniture	components,	athletic	equipment,	lawn	and	

garden	equipment,	store	display	shelves,	racks,	and	other	similar	items.19	Figure	I‐1	is	a	

visual	depiction	of	LWR	pipe	and	tube.		

                                                            

17 Light‐Walled Rectangular Pipe and Tube From the People's Republic of China: Final Results of the

Expedited First Sunset Review of the Countervailing Duty Order, 78 FR 48416, August 8, 2013.

18 Effective February 3, 2007, HTS subheading 7306.60.50 was replaced by subheadings 7306.61.50

and 7306.69.50. Also effective February 3, 2007, HTS subheading 7306.60.70 was replaced by

subheadings 7306.61.70 and 7306.69.70. Imports classifiable under subheadings 7306.69.50 and

7306.69.70 are not included in this investigation.

19 Hearing transcript, pp. 15‐16 (Searing).  
I‐16

Figure I-1 

LWR Pipe and tube 

Source: http://www.diytrade.com 

Description and applications  

The	terms	“pipes,”	“tubes,”	and	“tubular	products”	are	interchangeable	in	common	

usage	and	in	the	HTSUS.	However,	tubular	product	manufacturers	typically	classify	“pipes”	

as	having	a	circular	cross‐section	in	a	few	standard	sizes,	whereas	“tubes”	may	have	any	

cross‐sections	including	circular,	square,	rectangular	or	others.	Pipes	are	specified	in	terms	

of	their	internal	nominal	diameter,	whereas	tubes	are	specified	in	terms	of	their	outside	

dimensions	and	wall	thickness.	Steel	pipes	and	tubes	can	be	further	subdivided	according	

to	their	manufacturing	method	(welded	or	seamless)	or	grades	of	steel	(carbon,	alloy	and	

stainless).20	Only	welded	carbon‐steel	tubular	products	are	subject	to	this	review.	

LWR	pipe	and	tube	sold	in	the	U.S.	market	is	generally	manufactured	to	conform	to	

standards	of	the	American	Society	for	Testing	and	Materials	(“ASTM”)	International21	or	

the	American	Society	of	Mechanical	Engineers	(“ASME”).	Chemical	requirements,	testing	

procedures,	and	permissible	variations	(tolerances)	are	specified	in	the	ASTM	or	ASME	

                                                            

20 Although carbon steel contains trace amounts of alloy elements, it is mainly composed of carbon

and iron.  Alloy steel is any type of steel to which one or more elements besides carbon have been

intentionally added to produce a desired physical property or characteristic. Common elements that are

added to make alloy steel are molybdenum, manganese, nickel, silicon, boron, chromium, and

vanadium. Stainless steel is an alloy steel composed of certain amounts of nickel and chromium, which

makes it corrosion‐resistant.   21 ASTM International (formerly called American Society for Testing and Materials) is not a product

testing or certification organization. Rather, manufacturers can voluntarily choose to indicate on the

label or packaging that their products have been tested according to ASTM standards.  
I‐17

specifications.22	Domestically	produced	and	subject	imported	LWR	pipe	and	tube	are	

typically	manufactured	to	meet	ASTM	A‐500	(ornamental	tubing)23	or	ASTM	A‐513	

(mechanical	tubing).24	In	the	U.S.	market,	LWR	pipe	and	tube	is	commonly	stocked	and	sold	

in	20	or	24	foot	straight	lengths	in	bundles.25			

LWR	pipe	and	tube	can	be	distinguished	by	its	coating	type	—	either	corrosion‐

resistant	or	black.	Corrosion‐resistant	LWR	pipe	and	tube	is	produced	from	hot‐rolled	or	

cold‐rolled	sheet	that	is	clad,	plated,	or	coated	with	corrosion	resistant	metals	such	as	zinc,	

aluminum,	zinc‐aluminum,	nickel	or	iron‐based	alloys	and	may	be	painted,	varnished,	or	

coated	with	other	non‐metallic	substances	in	addition	to	the	metallic	coating.	Black	LWR	

tubing	is	blackened,	pickled	or	coated	with	a	thin	layer	of	oil	or	lacquer	for	weather	and	

rust	protection,	and	does	not	meet	the	specifications	for	corrosion‐resistant	products.	Both	

black	and	corrosion‐resistant	products	can	be	used	in	the	same	applications	depending	on	

customers’	specifications.	However,	galvanized	products	are	preferred	in	applications	

where	corrosion	resistance	is	an	important	service	requirement	such	as	carports,	air	

conditioning	equipment,	automotive	parts	and	outdoor	signs.	

Generally,	less	expensive	products	such	as	steel	angle,	bar,	rod,	and	channel	can	be	

utilized	in	place	of	LWR	pipe	and	tube	in	many	applications,	however,	their	inferior	

strength‐to‐weight	ratio	may	restrain	their	usage	in	many	instances.	Circular	light‐walled	

pipe	and	tube	could	serve	as	a	substitute	to	LWR	pipe	and	tube,	but	end‐user	specifications	

and	customer	preferences	limit	the	interchangeability	of	these	products.	LWR	pipe	and	

tube	frequently	is	produced	on	the	same	equipment	and	by	the	same	employees	as	circular	

and	other	non‐circular	tubing,	as	well	as	heavier‐walled	or	structural	tubing.	26	

Manufacturing processes

The	raw	material	input	for	manufacturing	LWR	is	hot‐rolled	or	cold‐rolled	steel	

strip,	depending	on	the	tube,	or	pipe	dimension	or	application.27	The	LWR	pipe	and	tube	

                                                            

22 Mohinder L. Nayyar, Piping Handbook: Sixth Edition, 1992.    23 ASTM A‐500 covers cold‐formed welded and seamless carbon steel round, square, rectangular, or

special shape structural tubing for welded, riveted, or bolted construction of bridges and buildings, and

for general structural purposes.

24 ASTM A‐513 covers the following: 1) electric‐resistance‐welded carbon and alloy steel tubing for

use as mechanical tubing, 2) mechanical tubing made from hot‐ or cold‐rolled steel, and 3) round,

square, rectangular, and special shape tubing.

25 The following U.S. manufacturers stated that they stock 20 foot and 24 foot LWR pipe and tube on

their respective websites: Bushwick Metals; Hannibal Industries; Searing Industries; Southland Tube,

Inc., and; Northwest Pipe.   26 Light‐Walled Rectangular Pipe and Tube from China, Korea, Mexico, and Turkey, Investigation Nos.

701‐TA‐449 and 731‐TA‐1118‐1121 (Final), May 1, 2008.

27 Light‐Walled Rectangular Pipe and Tube from China, Korea, Mexico, and Turkey, Investigation Nos.

701‐TA‐449 and 731‐TA‐1118‐1121 (Final), May 1, 2008.
I‐18

manufacturing	process	begins	by	heating	steel	strip	in	the	form	of	continuous	skelp.28	Then	

the	flat‐rolled	steel	strip	is	slit	into	strips	lengthwise	to	the	width	necessary	for	the	desired	

pipe	and	tube	dimensions.			

The	most	common	welding	method	for	U.S.	producers	of	LWR	pipe	and	tube	is	the	

longitudal	seam,	where	the	welded	seam	is	formed	parallel	to	the	tube	axis.29	U.S.	

producers	currently	employ	either	of	the	two	common	methods	of	manufacturing,	both	of	

which	use	the	electric	resistance	welding	process	(ERW).	The	first	method	is	the	ERW	

form‐square	weld‐square	process	whereby	the	steel	strip	is	formed	directly	into	a	square	

or	rectangular	shape	prior	to	welding.	The	second	method	is	the	ERW	weld‐round	form‐

square	process	where	the	steel	strip	is	fed	into	machinery	that	forms	it	into	a	round	form	

before	it	is	welded.30	Subsequently,	the	round	tube	is	passed	through	additional	forming	

rolls	to	shape	the	tube	into	rectangular	or	square	cross	sections.31	Generally,	the	edges	of	

formed	tube	are	pressed	together	and	heated	by	electrical	resistance	to	form	a	weld.	For	

both	ERW	methods,	a	saw	downstream	of	the	welding	location	cuts	the	tube	into	individual	

straight	lengths.	The	pipes	and	tubes	are	sent	to	the	finishing	department	for	further	

processing,	testing	and	inspection.	Figure	I‐2	depicts	the	general	pipe	and	tube	making	

process.		

Figure I-2 

LWR pipe and tube: General tube forming process 

Source: Good Luck Steel website, http://www.goodlucksteel.com/industries/manufacturing-process.html

                                                            

28 Skelp is an intermediate product used in the manufacture of pipes and tubes. It is an untrimmed

band of hot‐rolled or cold‐rolled sheet.   29 Simdex Steel Manufacturers Worldwide Guide 2013, retrieved on February 19, 2014.   30 Bull Moose Tube Company, “Hollow Structural Sections, Frequently Asked Questions,” available at

http://www.bullmoosetube.com/products/product‐range.aspx?gid=732a864d‐7512‐4718‐9979‐

b49b09051a8e, retrieved on February 19, 2014.   31 Light‐Walled Rectangular Pipe and Tube from China, Korea, Mexico, and Turkey, Investigation Nos.

701‐TA‐449 and 731‐TA‐1118‐1121 (Final), May 1, 2008.
I‐19

In	the	finishing	final	stages,	LWR	pipe	and	tube	may	be	subject	to	galvanizing,	the	

process	of	coating	steel	with	a	thin	film	of	zinc	to	protect	the	steel	from	corrosion.	The	most	

common	galvanizing	method	is	the	hot‐dip	process,	in	which	the	tubes	are	dipped	into	a	

molten	zinc	bath.	Figure	1‐3	depicts	the	in‐line	galvanizing	process	for	LWR	pipe	and	tube.	

Alternatively,	some	producers	manufacture	LWR	tubing	from	purchased	pre‐galvanized	

sheet	and	subsequently	re‐galvanize	the	weld	zone.	Generally,	the	physical	properties	of	

strength,	hardness	and	ductility,	and	the	mechanical	characteristics	of	black	and	corrosion‐

resistant	LWR	pipe	and	tube	are	not	affected	by	the	galvanizing	process.32		

Figure 1-3 

LWR pipe and tube: In-line galvanizing process 

Note.--This image does not demonstrate the additional step necessary for the production of square and 

rectangular shapes which would involve additional rollers following the welding step to shape the circular 

pipe into the appropriate shape. Note also that this image demonstrates the production of corrosionresistant pipe through a zinc bath. Black product would be cut following the rolling into squares or 

rectangles (black product as well as corrosion resistant product might also be painted, pickled, oil, et 

cetera). In terms of corrosion-resistant product, another production method is possible which would 

involve welding pre-galvanized or already corrosion-resistant sheet into pipe.

Source: Prolamsa, Inc. 

DOMESTIC LIKE PRODUCT  

In	its	original	determinations,	the	Commission	defined	a	single	domestic	like	

product	consisting	of	LWR	pipe	and	tube,	coextensive	with	the	scope	of	the	

investigations.33	Domestic	interested	parties	indicated	that	they	agree	with	the

Commission’s	previous	determination	that	there	is	a	single	domestic	like	product	

coextensive	with	the	scope	of	the	investigations.34	Of	the	respondent	interested	parties,	

                                                            

32 Light‐Walled Rectangular Pipe and Tube from China, Korea, Mexico, and Turkey, Investigation Nos.

701‐TA‐449 and 731‐TA‐1118‐1121 (Final), May 1, 2008.

33 Light‐Walled Rectangular Pipe and Tube from Turkey, Inv. Nos. 731‐TA‐1121 (Final), USITC

Publication 4001 (May 2008), p. 7.   34 Domestic interested parties’ prehearing brief, p. 3.  Domestic interested parties also agree with the

Commission’s definition of the domestic industry and argue that Prolamsa’s subsidiary that began

(continued...)
I‐20

Regiomontana	de	Perfiles	y	Tubos	S.A.	de	C.V.	(“Regiopytsa”),	a	producer	of	LWR	pipe	and	

tube	in	Mexico,	indicated	that	it	did	not	object	to	the	definitions	of	the	domestic	like	

product	and	the	domestic	industry.35		

U.S. MARKET PARTICIPANTS

U.S. producers

During	the	original	investigations,	22	firms	provided	the	Commission	with	usable	

data	concerning	their	U.S.	operations	with	respect	to	LWR	pipe	and	tube.	These	firms	

accounted	for	the	vast	majority	of	U.S.	production	of	LWR	pipe	and	tube.	

In	the	current	proceeding,	18	firms	provided	the	Commission	with	usable	data	

concerning	their	LWR	pipe	and	tube	operations.	These	firms	are	believed	to	account	for	the	

vast	majority	of	U.S.	production	of	LWR	pipe	and	tube	in	2013.	Presented	in	table	I‐6	is	a	

list	of	current	domestic	producers	of	LWR	pipe	and	tube,	each	company’s	position	on	the	

continuation	of	the	orders,	production	locations,	and	share	of	reported	production	of	LWR	

pipe	and	tube	during	2008‐13.36		

Table I-6 

LWR pipe and tube: U.S. producers, positions on orders, U.S. production locations, and shares of 

2008-13 reported U.S. production 

Firm Position on orders 

U.S. production 

locations 

Share of 

production 

(percent) 

AK Tube LLC 

(“AK Steel”) *** Walbridge, OH ***

Allied *** 

Harvey, IL 

Philadelphia, PA 

Phoenix, AZ 

De Pere, WI ***

Atlas (Chicago) *** 

Chicago, IL 

Plymouth, MI 

Blytheville, AR ***

Table continued on next page. 

                                                            

(...continued)

producing LWR pipe and tube in the United States in 2009 should be included in the domestic industry.

Domestic interested parties’ response to the notice of institution, p. 19. Hearing transcript, p. 45

(Schagrin).   35 Regiopytsa’s response to the notice of institution, p. 8.

36 Welded Tube of Canada ceased production of LWR pipe during the period. Domestic interested

parties response to the notice of institution, p. 17. One firm that responded to the Commission’s

questionnaire in the original investigations, Paragon Inc., did not provide a response in the current

reviews.   
I‐21

Table I-6--Continued

LWR pipe and tube: U.S. producers, positions on orders, U.S. production locations, and 

shares of 2008-13 reported U.S. production 

Firm Position on orders 

U.S. production 

locations 

Share of 

production 

(percent) 

Bull Moose *** 

Gerald, MO 

Chicago, IL 

Elkhart, IN 

Trenton, GA 

Masury, OH 

Casa Grande, AZ ***

California *** City of Industry, CA ***

Camrose Pipe 

Corporation 

(“Evraz Oregon”) *** Portland, OR ***

EXL Tube *** North Kansas City, MO ***

Hanna Steel 

Corporation 

(“Hanna”) *** 

Fairfield, AL 

Northport, AL 

Pekin, IL 

Hoover, AL ***

Hannibal *** Los Angeles, CA ***

Maruichi Leavitt 

Pipe and Tube, 

LLC 

(“Leavitt”) *** Chicago, IL ***

Parthenon Metal 

Works, a division 

of Leggett & Platt, 

Incorporated 

(“Leggett & Platt”) *** La Vergne, TN ***

Longhorn Tube 

(“Longhorn”) *** Dallas, TX ***

Maruichi *** Santa Fe Springs, CA ***

Mid-States Tube 

Corporation 

(“Mid-States”) *** Kenosha, WI ***

Northwest Tube *** Houston, TX ***

Prolamsa Inc. 

(“Prolamsa 

Laredo”) *** Laredo, TX ***

Searing *** Rancho Cucamonga, CA ***

Southeast Tube 

(“Southeast”) *** Cadiz, KY ***

Southland *** Birmingham, AL ***

Vest *** Vernon, CA ***

Western *** Long Beach, CA ***

Total 100.0

Source: Compiled from data submitted in response to Commission questionnaires. 
I‐22

As	detailed	in	table	I‐6,	***.	Five	U.S.	producers	***	indicated	that	they	are	related	to	

producers	of	LWR	pipe	and	tube	in	the	U.S.	and	other	countries.37	Two	U.S.	producers	

directly	import	LWR	pipe	and	tube,	including	***.		Two	U.S.	producers,	***	reported	

purchases	of	LWR	pipe	and	tube	from	U.S.	importers.38		

U.S. importers

In	the	original	investigations,	43	U.S.	importing	firms	supplied	the	Commission	with	

usable	information	on	their	operations	involving	the	importation	of	LWR	pipe	and	tube,	

accounting	for	82.5	percent	of	total	U.S.	imports	of	LWR	pipe	and	tube	between	2005	and	

2007.	Of	the	responding	U.S.	importers,	several	firms	were	also	domestic	producers.39

In	the	current	proceeding,	14	U.S.	importing	firms	supplied	the	Commission	with	

usable	information	on	their	operations	involving	the	importation	of	LWR	pipe	and	tube,	

and	are	believed	to	have	account	for	63.4	percent	of	total	U.S.	imports	during	2008‐2013,	

including	***	percent	of	subject	U.S.	imports	of	LWR	pipe	and	tube.	Table	I‐7	lists	all	

responding	U.S.	importers	of	LWR	pipe	and	tube,	the	location	of	their	headquarters,	and	

their	shares	of	U.S.	imports	by	source	during	2008‐13.	Of	the	responding	U.S.	importers,	

several	firms	***	were	also	domestic	producers;	several	firms	indicated	that	they	are	

related	to	foreign	producers	of	LWR	pipe	and	tube;	and	in	some	cases,	the	responding		

foreign	producer	indicated	that	they	also	act	as	the	importer	of	record	in	the	United	

States.40		

Table I-7 

LWR pipe and tube: U.S. importers, sources of imports, U.S. headquarters, and shares of imports, 

by source, 2008-13 

* * * * * * * 

 

U.S. purchasers

The	Commission	received	23	usable	questionnaire	responses	from	firms	that	bought	

LWR	pipe	and	tube	during	2008‐13.41	Twenty‐two	responding	purchasers	are	distributors	

and	one	is	an	end	user.	Responding	U.S.	purchasers	are	located	throughout	the	United	

                                                            

37 ***.

38 ***. ***.

39 ***.

40 ***. 41 Of the 23 responding purchasers, 20 purchased domestically produced LWRPT, 0 purchased

imports from China, 2 purchased imports from Korea, 9 purchased imports from Mexico, 1 purchased

imports from Turkey, and 5 purchased imports from other countries (Australia, Canada, Dubai,

Guatemala, India, Taiwan, Thailand, and Vietnam).
I‐23

States,	with	eight	in	California	and	three	in	Texas.	The	largest	responding	purchasers	of	

LWR	pipe	and	tube	are	***.	

APPARENT U.S. CONSUMPTION  

Data	concerning	apparent	U.S.	consumption	of	LWR	pipe	and	tube	are	shown	and	

depicted	in	table	I‐8	and	figure	I‐4.	Apparent	U.S.	consumption	decreased	between	2008‐

2009	before	increasing	every	year	between	2009	and	2013.	U.S.	producers’	U.S.	shipments	

followed	a	similar	trend,	falling	to	their	lowest	levels	in	2009	and	reaching	their	peak	levels	

in	2013.	Subject	U.S.	imports	decreased	between	2008	and	2011,	before	increasing	in	2012	

and	2013,	resulting	in	an	overall	decrease	of	***	percent	during	2008‐2013.	

Table I-8 

LWR pipe and tube: Apparent U.S. consumption, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

U.S. producers' U.S. shipments 448,481 350,966 411,632 435,122 480,782 517,350

U.S. imports from.-- 

 China 687 31 109 277 282 126

Korea *** *** *** 0 0 0

Mexico 115,179 68,311 67,692 60,925 64,684 82,710

Turkey 0 36 0 564 5,920 2,101

Subtotal, subject sources *** *** *** 61,766 70,885 84,937

All other sources *** *** *** 56,148 60,298 71,756

Total U.S. imports 173,888 114,234 120,731 117,914 131,183 156,693

Apparent U.S. consumption 622,369 465,200 532,363 553,036 611,965 674,043

 Value (1,000 dollars) 

U.S. producers' U.S. shipments 530,498 296,130 390,680 478,167 500,975 514,216

U.S. imports from.-- 

 China 627 74 235 438 350 144

Korea *** *** *** 0 0 0

Mexico 115,638 44,664 52,906 57,051 55,172 66,982

Turkey 0 24 0 507 4,831 1,836

Subtotal, subject sources *** *** *** 57,997 60,353 68,962

All other sources *** *** *** 62,823 64,025 70,782

Total U.S. imports 183,896 82,603 103,553 120,820 124,378 139,744

Apparent U.S. consumption 714,394 378,733 494,233 598,987 625,353 653,960

 

Source: Compiled from data submitted in response to Commission questionnaires and from official 

import statistics of the U.S. Department of Commerce adjusted to exclude Nexteel of Korea. 
I‐24

Figure I-4 

LWR pipe and tube: Apparent U.S. consumption, by quantity (short tons), 2008-13 

* * * * * * * 

U.S. MARKET SHARES

U.S.	market	share	data	are	presented	in	table	I‐9.	U.S.	producers’	share	of	apparent	

U.S.	consumption	increased	by	4.7	percentage	points	between	2008	and	2013,	while	the	

U.S.	market	share	for	subject	imports	(primarily	Mexico)	decreased	by	***	percentage	

points	over	the	same	period.	The	U.S.	market	share	for	nonsubject	imports	(primarily	

Canada)	increased	by	***	percentage	points	between	2008	and	2013.				

Table I-9 

LWR pipe and tube: Apparent U.S. consumption and market shares, 2008-2013 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

Apparent U.S. consumption 622,369 465,200 532,363 553,036 611,965 674,043

 Share of quantity (percent) 

U.S. producers' U.S. shipments 72.1 75.4 77.3 78.7 78.6 76.8

U.S. Imports from.-- 

 China 0.1 0.0 0.0 0.1 0.0 0.0

Korea *** *** *** 0.0 0.0 0.0

Mexico 18.5 14.7 12.7 11.0 10.6 12.3

Turkey 0.0 0.0 0.0 0.1 1.0 0.3

Subtotal, subject sources *** *** *** 11.2 11.6 12.6

All other sources *** *** *** 10.2 9.9 10.6

Total U.S. imports 27.9 24.6 22.7 21.3 21.4 23.2

 Value (1,000 dollars) 

Apparent U.S. consumption 714,394 378,733 494,233 598,987 625,353 653,960

 Share of value (percent) 

U.S. producers' U.S. shipments 74.3 78.2 79.0 79.8 80.1 78.6

U.S. Imports from.-- 

 China 0.1 0.0 0.0 0.1 0.1 0.0

Korea *** *** *** 0.0 0.0 0.0

Mexico 16.2 11.8 10.7 9.5 8.8 10.2

Turkey 0.0 0.0 0.0 0.1 0.8 0.3

Subtotal, subject sources *** *** *** 9.7 9.7 10.5

All other sources *** *** *** 10.5 10.2 10.8

Total U.S. imports 25.7 21.8 21.0 20.2 19.9 21.4

 

Source: Compiled from data submitted in response to Commission questionnaires and from official 

import statistics of the U.S. Department of Commerce adjusted to exclude Nexteel of Korea. 
PART II: CONDITIONS OF COMPETITION IN THE U.S. MARKET

U.S. MARKET CHARACTERISTICS

U.S. producers’ market share has increased since the original investigations, from just 

under two-thirds of the U.S. market during the original investigations to more than threequarters market share during most years of the review period. Mexico continued to supply the 

U.S. market during the review period, as did nonsubject country Canada. The quantity of 

imports from the other subject countries, China, Korea, and Turkey, were relatively small 

although all supplied the U.S. market during at least some years of the review period. Total U.S. 

production capacity remained fairly constant, although there were a number of plant openings 

and closures during the period of review. One plant opening was that of the Mexican producer 

Prolamsa which began producing LWR pipe and tube in the United States in 2009. 

LWR pipe and tube is used in a wide range of applications including shelving, racks, 

fences, gates, hand rails, trailers, metal building components, automotive equipment, furniture, 

and sports equipment. Over the period of review, there have been large changes in U.S. 

demand for LWR pipe and tube, reflecting ups and downs in the overall economy, and in 

construction and automotive demand in particular. Available information indicates that end 

uses have not changed significantly since the original investigation. LWR pipe and tube

continues to be sold mainly through distributors. 

CHANNELS OF DISTRIBUTION

U.S. producers and importers sold mainly to distributors during the review period (table 

II-1).

GEOGRAPHIC DISTRIBUTION

U.S. producers reported selling LWR pipe and tube to all regions in the United States

(table II-2). Importers reported selling LWR pipe and tube from Mexico to all regions in the 

contiguous United States except the Northeast and reported selling LWR pipe and tube from 

Turkey in four regions, ***. For U.S. producers, 19 percent of sales were within 100 miles of 

their production facility, 69 percent were between 101 and 1,000 miles, and 12 percent were 

over 1,000 miles. Importers of LWR pipe and tube from Mexico sold 52 percent within 100 

miles of their U.S. point of shipment and 48 percent between 101 and 1,000 miles. Importers of 

LWR pipe and tube from Turkey sold ***.

II-1
Table II-1 

LWR pipe and tube: U.S. producers’ and importers’ share of reported U.S. shipments (percent), by 

sources and channels of distribution, 2008-13

Item

Calendar year

2008 2009 2010 2011 2012 2013

Share of quantity (percent)

U.S. producers' U.S. shipments to:

 Distributors 63.1 69.5 69.3 69.7 69.3 68.4

End users 36.9 30.5 30.7 30.3 30.7 31.6

U.S. importers' U.S. shipments of 

imports from Mexico to:

 Distributors 91.7 95.7 95.8 95.6 95.7 95.6

End users 8.3 4.3 4.2 4.4 4.3 4.4

U.S. importers' U.S. shipments of 

imports from Turkey to:

 Distributors *** *** *** *** *** ***

End users *** *** *** *** *** ***

U.S. importers' U.S. shipments of 

imports from all other sources to:

 Distributors *** *** *** *** *** ***

End users *** *** *** *** *** ***

 Note: No data were reported for China or Korea.

Source: Compiled from data submitted in response to Commission questionnaires.

Table II-2

LWR pipe and tube: 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

Mexico Turkey

All other 

sources

Northeast 8 0 *** ***

Midwest 13 1 *** ***

Southeast 11 4 *** ***

Central Southwest 12 6 *** ***

Mountains 15 5 *** ***

Pacific Coast 16 3 *** ***

Other1 6 0 *** ***

All regions in the continental United 

States 8 0 *** ***

 1 All other U.S. markets, including AK, HI, PR, and VI, among others.

Source: Compiled from data submitted in response to Commission questionnaires.

II-2
II‐3

SUPPLY AND DEMAND CONSIDERATIONS

U.S. supply

Six of 19 U.S. producers noted changes in factors affecting U.S. supply since 2008,

including new suppliers (Solaris and the opening of the Prolamsa plant in Laredo, TX), capacity

added in 2012 (***) and 2013 (***), volatility in steel prices and a 30 percent increase in freight

expenses, reduced workforce, and overcapacity limiting price increases. Most U.S. producers

(15 of 19) do not anticipate any changes in the availability of U.S. supply. One producer noted

that Vietnam has begun exporting to the United States. No importers reported anticipating any

changes in import supply to the U.S. market.  

Domestic production

Based on available information, U.S. producers of LWR pipe and tube have the ability to

respond to changes in demand with large changes in the quantity of shipments of U.S.‐

produced LWR pipe and tube to the U.S. market. The main contributing factors to this degree of

responsiveness of supply are the availability of unused capacity, existence of inventories, and

the ability to produce alternate products.

Industry capacity

Domestic capacity utilization for LWR pipe and tube increased from 2008 to 2013 but

was less than 50 percent in every year. This relatively low level of capacity utilization suggests

that U.S. producers may have substantial capacity to increase production of LWR pipe and tube

in response to an increase in prices.

Alternative markets

U.S. producers’ exports comprised about five percent of their total shipments during the

period of review. U.S. producers stated that it would be difficult to shift their shipments to

other markets, with the exception in some cases of Canada. Firms cited high transportation

costs, inability to price competitively in other markets, the need to retool to produce metric

dimensions, lack of experience in exporting, and logistics as the major barriers to selling to

other markets. Most U.S. producers reported no tariff or nontariff barriers to trade in other

markets.  

Inventory levels

U.S. producers’ inventories increased from 14.5 percent of total shipments in 2008 to

21.3 percent in 2011 and then declined to 15.6 percent in 2013. These inventory levels suggest

that U.S. producers may have some ability to respond to changes in demand with changes in

the quantity shipped from inventories.
Production alternatives

U.S. producers produce circular mechanical tubing, other light-walled products, and 

heavy-walled products using the same equipment and/or workers used for LWR pipe and tube. 

In fact, LWR pipe and tube accounted for less than 20 percent of the quantity of products 

produced using the same equipment and workers (see part III of this report). Fifteen of 19 U.S. 

producers reported producing other products using the same equipment and/or workers as for 

LWR pipe and tube and more than half of responding U.S. producers stated that they could 

switch production from LWR pipe and tube to other products. 

Subject imports from China

Limited information is available on the Chinese industry; no firms provided foreign 

producer questionnaire responses. In the original investigations, staff concluded that it is likely 

that producers of LWR pipe and tube in China have the ability to respond to changes in demand 

with moderate changes in the quantity of shipments of LWR pipe and tube to the U.S. market. 

The main contributing factors to this degree of responsiveness of supply were the existence of 

alternate markets and inventories. Currently available information suggests that supply 

responsiveness is likely to be at least moderate. 

During 2008-10, Chinese LWR pipe and tube producers increased production by opening 

new manufacturing plants (see part IV of this report). China’s global exports of LWR pipe and 

tube more than doubled between 2008 and 2012.1 China exported LWR pipe and tube to nearly 

200 countries during the period of review; its top 10 export destinations in 2013 included 

countries in many regions including three countries in the Americas (Peru, Venezuela, and 

Panama). 

Subject imports from Korea

Limited information is available on the industry in Korea; no firms provided foreign 

producer questionnaire responses. In the original investigations, staff concluded that Korean 

producers have the capability to respond to changes in demand with relatively large changes in 

the quantity shipped to the U.S. market. The main contributing factors to this degree of 

responsiveness of supply were unused capacity and the existence of alternate markets. 

Currently available information suggests that supply responsiveness is likely to be at least 

moderate.

Korea’s global exports of LWR pipe and tube increased by 60 percent between 2008 and 

2013.2 Korea exported LWR pipe and tube to nearly 75 countries during the period of review; 

1 Based on export data reported for HS7306.61 (see part IV of this report). Note that this subheading 

includes products outside of the scope of the orders. 2 Based on export data reported for HS7306.61 (see part IV of this report). Note that this subheading 

includes products outside of the scope of the orders.

II-4

 
the United States and Mexico were the top two destinations, followed by Japan, UAE, and Saudi 

Arabia. 

Subject imports from Mexico

Seven firms reported information on their operations in Mexico; these firms are 

believed to account for the vast majority of Mexican production in 2013. Based on available 

information, LWR pipe and tube producers in Mexico have the ability to respond to changes in 

demand with moderate changes in the quantity of LWR pipe and tube shipments to the U.S. 

market. The main contributing factors to this degree of responsiveness of supply are some

availability of unused capacity, alternate markets and inventories, and the ability to produce 

alternate products.

Industry capacity

Capacity utilization increased from *** percent in 2008 to *** percent in 2013. This 

level of capacity utilization suggests that producers in Mexico may have some capacity to 

increase production of LWR pipe and tube in response to an increase in prices.

Alternative markets

Responding Mexican firms reported that about *** percent of their LWR pipe and tube

shipments were to their home market with most of the remainder to the U.S. market. 

Shipments to third country markets increased from *** in 2008 to *** percent of total 

shipments in 2013. ***. 

Inventory levels

The ratio of inventories to total shipments increased from *** percent in 2008 to ***

percent in 2013. These inventory levels suggest that Mexican producers may have some ability 

to respond to changes in demand with changes in the quantity shipped from inventories.

Production alternatives

Six of seven firms reported the ability to shift production between LWR pipe and tube

and other products. Slightly less than half of reporting Mexican firm’s production was products 

other than LWR pipe and tube.

Subject imports from Turkey 

Two firms reported information on their operations in Turkey; these firms are estimated 

to account for *** percent of production in Turkey. Based on available information, producers 

of LWR pipe and tube from Turkey have the ability to respond to changes in demand with 

moderate to large changes in the quantity of LWR pipe and tube shipments to the U.S. market. 

The main contributing factors to this degree of responsiveness of supply are the availability of 

unused capacity, existence of alternate markets, and the ability to produce alternate products.

II-5
Industry capacity

Capacity utilization decreased from *** percent in 2008 to *** percent in 2013. This 

level of capacity utilization suggests that responding producers in Turkey may have substantial 

capacity to increase production of LWR pipe and tube in response to an increase in prices.

Alternative markets

In 2013, more than *** of responding Turkish producers’ LWR pipe and tube shipments 

were to their home market, up from *** percent in 2008. Exports to the EU market, as a 

percentage of total shipments, decreased from ***percent in 2008 to ***percent in 2013.

Exports to other markets, including the U.S. market, accounted for ***percent of total 

shipments in 2013. 

Inventory levels

The ratio of inventories to total shipments ranged from *** percent during the period of 

review. These inventory levels suggest that responding producers in Turkey may have some 

ability to respond to changes in demand with changes in the quantity shipped from inventories.

Production alternatives

*** firms reported the ability to shift production between LWR pipe and tube and other 

products. Over the past 3 years, *** of production was products other than LWR pipe and tube, 

increasing from *** percent in 2008 to *** percent in 2013.

Nonsubject imports

Canada was by far the largest source of nonsubject imports of LWR pipe and tube during 

the period of review. It accounted for 80 percent of nonsubject imports in 2013.

New suppliers

Only 3 of 23 purchasers indicated that new suppliers entered the U.S. market since 

2008, and only five purchasers expect additional entrants. Purchasers reported the following 

new entrants since 2008: MX Trading, Tube One, Bobco Metals, Mega Steel, LP Tube, and the 

Prolamsa plant in Texas.

U.S. demand

Based on available information, the overall demand for LWR pipe and tube is likely to 

experience moderate changes in response to changes in price. The main contributing factors 

are the limited range of substitute products and the substantial cost share of LWR pipe and 

tube in the intermediate products in which it is used.

Since LWR pipe and tube is an intermediate product with many end-use applications, 

the overall demand for LWR pipe and tube is closely linked to the demand for those end use 

II-6
products. In the original investigations, Petitioners reported that 60 to 70 percent of LWR pipe 

and tube was used in residential construction (new homes) and in home improvement 

applications (e.g., lawn mowers, lawn furniture, hammocks, window guards, and fencing).3

End uses

U.S. demand for LWR pipe and tube depends on the demand for U.S.-produced 

downstream products. LWR pipe and tube is used in a wide variety of end use applications 

including shelving, racks, fences, gates, hand rails, trailers, metal building components, 

automotive equipment, furniture, and sports equipment. 

Most firms (15 of 18 U.S. producers, all 11 importers, and 17 of 20 purchasers) reported 

no changes in end uses since 2008. Similarly, very few firms (only 1 of 17 U.S. producers, no 

importers, and 1 of 18 purchasers) anticipated any changes in end uses. Two purchasers noted 

a drop in demand in certain end uses, particularly in construction (but reported that activity is 

expected to increase as construction recovers), transportation, and manufacturing. U.S. 

producers noted that original equipment manufacturers are sourcing more finished goods from 

overseas, an increase in the use of LWR pipe and tube in solar frameworks, and less residential 

construction. 

Business cycles

Most firms (15 of 19 U.S. producers, 8 of 11 importers, and 19 of 24 purchasers)

indicated that the LWR pipe and tube market was not subject to business cycles or other 

distinctive conditions of competition.

However, several firms noted that demand was seasonal. Among producers, one firm 

reported higher demand in spring and summer; and one firm reported strong sales early in the 

year, slow sales in summer, and then an increase again in the fall. Some importers also noted 

seasonal business, particularly in construction and agriculture but less so in the automotive

sector. One importer described high demand during January to August and slower demand 

from September to December. Four purchasers noted that demand was seasonal, including 

slower construction activity in the winter. 

Most firms (all producers, 4 of 6 importers, and 4 of 5 purchasers) reported no changes 

in business cycles or conditions of competition since 2008. However, one purchaser noted a 

dramatic slowing in the industry worldwide and one importer noted that prices have been up 

and down, by as much as $100 per ton.

Apparent consumption

Apparent U.S. consumption of LWR pipe and tube was slightly higher in 2013 than in 

2008. After a large decline from 2008 to 2009, apparent consumption increased in each year 

3 Light-Walled Rectangular Pipe and Tube from Turkey, Inv. Nos. 731-TA-1121 (Final), USITC 

Publication 4001 (May 2008), p. II-5.

II-7

 
during the review period. Overall, apparent U.S. consumption in 2013 was 8.3 percent higher 

than in 2008.

Demand trends

Firms had mixed responses regarding the change in U.S. demand for LWR pipe and tube

since 2008, likely reflecting the ups and downs of the market over the six-year period (table II3). U.S producers’ comments included the following: demand increased after the 2009 decline 

(which according to one producer was a 40 percent decline); homebuilding was “terrible” in 

2009-11 but was rebounding in 2013 into 2014; and demand mirrored the overall economy 

with an increase over the past few years. Importers mentioned the economic recovery and that

some end users relocated to China. Purchasers noted the rebound in the economy; a decline in 

home improvement with falling housing prices; a decline in the transportation and construction 

markets; the market crash in 2008-09, rebound in 2010-11, and that recently demand has 

fluctuated with no clear trend; and lackluster demand in manufacturing and construction.

Table II-3

LWR pipe and tube: Firms’ responses regarding U.S. demand, by number of responding firms

Item

Number of firms reporting

Increase No change Decrease Fluctuate

Demand inside the United States since 2008:

 U.S. producers 3 2 9 5

Importers 4 2 1 5

Purchasers 6 3 6 6

Foreign producers 4 1 2 1

Anticipated demand inside the United States:

 U.S. producers 8 3 2 6

Importers 5 3 0 4

Purchasers 5 10 0 7

Foreign producers 6 1 1 0

Demand for purchasers' final products since 2008:

 Purchasers 1 1 0 0

 Source: Compiled from data submitted in response to Commission questionnaires.

Firms generally expect demand to increase or stay the same. Among producers two 

expect small increases in short term demand, one reported that construction and homebuilding 

had improved but remained below 2007 levels, and one reported increased imports of finished 

assemblies. Importers reported that future demand for LWR pipe and tube depends on 

whether economic growth continues and also reported anticipating increased demand with the 

recovery in the automotive and home building sectors. Purchasers reported improvements in 

housing and in non-residential construction, but one firm reported that it doesn’t expect any 

real strength until 2015. Foreign producers also cited economic growth, including growth in 

automotive and in construction, as reasons for expecting U.S. demand to increase. 

U.S. demand in some of the sectors in which LWR pipe and tube is used is forecasted to 

grow over the next two years. Nonresidential construction is forecasted to grow by 5.8 percent 

II-8
in 2014 and by 8.0 percent in 2015.4 Housing starts are forecasted to increase by 18.6 percent 

in 2014 and by 38.7 percent in 2015.5 Homeowner remodeling spending is also expected to be 

strong, increasing by 9.9 to 14.7 percent in the first three quarters of 2014.6 U.S. motor vehicle 

production is forecasted to grow approximately 5.5 percent in 2014 and 0.9 percent in 2015.7

Substitute products

Substitutes for LWR pipe and tube are limited. Most U.S. producers (12 of 18), importers

(10 of 11), and purchasers (18 of 20) reported that there were no substitutes and no firms 

anticipated any future changes in substitutes.

8 Firms that reported substitutes listed the 

following: stamped material for automotive applications; chain link for fences; steel angles for 

fencing, shelving, trailers and racks; roll formed sections for racks and shelving; channels for 

trailers and racks; plastic pipe for conduit; block wall for fencing; wood for fencing; and 

seamless tube for railings.

Cost share

LWR pipe and tube typically accounts for a moderate to large share of the cost of the 

intermediate products in which it is used. Responding firms reported limited cost share 

information, with cost shares ranging from 20 to 80 percent. Firms reported the following end 

uses (and cost shares): fencing (20-70 percent), solar frameworks (80 percent), cranes (25

percent), automotive racks (80 percent), and warehouse structures (80 percent). 

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported LWR pipe and tube 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 

4 American Institute of Architects, Consensus Construction Forecast, 

http://info.aia.org/aiarchitect/2014/charts/jan2014/ccs_012414.html, retrieved March 9, 2014. 5 National Association of Home Builders, Total Housing Starts, Housing and Interest Rate Forecast

(February 28, 2014), http://www.nahb.org, retrieved March 9, 2014.

6 Harvard University, Leading Indicator of Remodeling Activity, 

http://www.jchs.harvard.edu/sites/jchs.harvard.edu/files/lira_2013_q4_fullsize.png, retrieved March 9, 

2014. 7 Center for Automotive Research, “CAR’s U.S. Vehicle Sales, Production, and Employment Outlook 

First Quarter - January 2014,” p. 4, http://www.cargroup.org/assets/files/forecasts/2014_-

_q1_forecast.pdf, retrieved March 9, 2014.

8 For the few firms that reported substitutes, about half of their responses indicated that changes in 

the prices of the substitutes they listed affected the prices of LWR pipe and tube.

II-9

 
that there is moderate to high degree of substitutability between domestically produced LWR 

pipe and tube and LWR pipe and tube imported from subject sources. 

Lead times

LWR pipe and tube is sold both produced-to-order and from inventory. U.S. producers 

reported that half of their commercial shipments were produced-to-order and half were from 

inventories. Most firms reported that lead times for produced-to-order product were 15 to 45

days and that lead times from inventories were 1 to 7 days. Importers reported that 57 percent 

of imports of LWR pipe and tube from Mexico were produced to order and that the remaining 

43 percent were sold from foreign inventories. Lead times for Mexican product were similar to 

that for domestic product, 3 to 10 days for product in inventories and 15 to 45 days for product 

produced to order. Most imports from Turkey *** were sold from U.S. inventories with a lead 

time of *** days, with the remainder produced to order with a lead time of *** days. One U.S. 

producer reported that because of the longer lead times for foreign product (typically 2 to 3 

months), customers typically won’t purchase imported product “until the spread approaches 

$150 per ton.”

Knowledge of country sources

Twenty-one purchasers indicated they had marketing/pricing knowledge of domestic 

product, four of Korean product, eight of Mexican product, one of nonsubject countries, and no 

purchaser indicated that they had knowledge of product from China or Turkey.

As shown in table II-4, most purchasers and their customers sometimes or never make 

purchasing decisions based on the producer or country of origin. The purchasers that reported 

that they always or usually make decisions based on the manufacturer cited the following 

reasons: quality, availability, a preference for domestic product, and not purchasing Chinese 

product because of quality issues.

Table II-4

LWR pipe and tube: Purchasing decisions based on producer and country of origin, by number of 

reporting firms

Decision Always Usually Sometimes Never

Purchaser makes decision based on producer 4 6 9 4

Purchaser’s customers make decision based on 

producer 1 1 13 7

Purchaser makes decision based on country 3 6 7 7

Purchaser’s customers make decision based on 

country 3 2 9 8

 Source: Compiled from data submitted in response to Commission questionnaires.

Factors affecting purchasing decisions

The most often cited top three factors firms consider in their purchasing decisions for 

LWR pipe and tube were price (20 firms), quality (17 firms), and availability (11 firms) as shown

II-10
in table II-5. Quality was the most frequently cited first most important factor (cited by 9 firms), 

followed by price (8 firms); availability was the most frequently reported second most 

important factor (8 firms); and price was the most frequently reported third most important 

factor (7 firms). 

Table II-5 

LWR pipe and tube: Ranking of factors used in purchasing decisions as reported by U.S. 

purchasers, by number of reporting firms

Factor First Second Third Total

Price 8 5 7 20

Quality 9 4 4 17

Availability 2 8 1 11

Delivery costs and/or time 1 1 3 5

Service and reliability 1 2 2 5

Product range 1 0 2 3

Other1 3 3 4 10

1 Other factors include traditional supplier, domestic mills, contracts, extension of credit, logistics, 

inventory, credit, terms, and support of special customer contracts.

Note: Some firms listed more than one factor for first, second, or third.

Source: Compiled from data submitted in response to Commission questionnaires.

The majority of purchasers (17 of 24) reported that they usually or always purchase LWR 

pipe and tube that is offered at the lowest price. When asked if they purchased LWR pipe and 

tube from one source although a comparable product was available at a lower price from 

another source, 18 purchasers reported reasons including reliability of supply, availability, 

location, lead times, inventories, and minimum order size, with a number of these firms noting 

that they prefer domestic product. Only 3 of 22 purchasers reported that certain types of 

product were only available from a single source.9

Importance of specified purchase factors

Purchasers were asked to rate the importance of 15 factors in their purchasing decisions 

(table II-6). The factors rated as “very important” by more than half of responding purchasers 

were price (22 purchasers); availability, product consistency, and reliability of supply (21 each), 

quality meets industry standards (18), delivery time (16), and U.S. transportation costs (15).

9 One purchaser reported primed tubing offered by Mexican producers, one reported ornamental 

tube from domestic producers, and one stated that certain metric sizes, gauges and grades are not 

currently available domestically. 

II-11

 
Table II-6

LWR pipe and tube: 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 21 2 0

Delivery terms 10 9 4

Delivery time 16 6 1

Discounts offered 7 14 2

Extension of credit 5 9 9

Minimum quantity requirements 3 13 7

Packaging 8 11 4

Price 22 1 0

Product consistency 21 2 0

Product range 11 10 2

Quality exceeds industry standards 10 11 2

Quality meets industry standards 18 4 0

Reliability of supply 21 2 0

Technical support/service 3 16 4

U.S. transportation costs 15 6 2

Source: Compiled from data submitted in response to Commission questionnaires.

Supplier certification

About half of responding purchasers (11 of 23) require that their suppliers be certified. 

Such certification may include a vendor quality survey, mill test reports, adherence to ASTM or 

ASME specifications, ISO certification, financial stability, reliability of supply, and conflict-free 

mineral compliance. Purchasers reported that the time to qualify a new supplier ranged from 1

to 180 days with most firms reporting a month or less.

10 Only two of 22 purchasers reported 

that a supplier had failed in its attempt to qualify product; specifically these firms listed “all 

Chinese tube mills” and MX Enterprises.

Changes in purchasing patterns

Firms were asked about their purchases before and after the orders. Sixteen of 23 

purchasers bought LWR pipe and tube from subject sources before 2008 including six from 

China, six from Korea, 9 from Mexico and 4 from Turkey. Of these 23 purchasers, 7 indicated 

that their purchasing pattern was unchanged, 4 discontinued purchasing subject product 

because of the orders, and 6 changed their purchases from subject sources for other reasons. 

10 Three of 10 purchasers reported longer times of 60 to 180 days.

II-12

 
Specifically, several firms stopped purchasing Chinese product because of quality concerns, one 

stopped purchasing Turkish product for quality concerns, and one stopped purchasing Turkish 

product because of price. In addition, firms also mentioned market conditions and availability 

as reasons for stopping purchasing product from subject countries. Most purchasers reported 

that they either did not purchase LWR pipe and tube from nonsubject countries before or after 

the orders or that their purchase pattern was unchanged; only two purchasers increased 

purchases from nonsubject countries and none decreased purchases from nonsubject 

countries.

Similarly, purchasers were asked about changes in their purchasing patterns from 

different sources since 2008 (table II-7). Most firms that reported changes in purchasing 

patterns reported increases in purchases of U.S. product. Only three purchasers reported that 

they had changed suppliers since 2008. Three purchasers reported new suppliers during the 

period of review, specifically MX Trading, Tube One, Bobco Metals, Mega Steel, LP Tube and 

Prolamsa (Texas). Five purchasers anticipate that new suppliers will enter the U.S. market

depending on demand in the U.S. market and in other markets (specifically falling demand in 

Asia), domestic pricing and supply.

Table II-7

LWR pipe and tube: Changes in purchase patterns from U.S., subject, and nonsubject countries

Source of purchases Did not 

purchase Decreased Increased Constant Fluctuated

United States 1 0 10 9 3

China 16 2 0 0 1

Korea 15 2 1 1 1

Mexico 9 2 2 5 1

Turkey 15 2 0 0 0

All other sources 11 2 1 2 0

Source: Compiled from data submitted in response to Commission questionnaires.

Importance of purchasing domestic product

Purchasers were asked to estimate the percentage of their 2013 LWR pipe and tube

purchases that required domestic product. They reported that they did not require domestic 

product for 72 percent of their 2013 purchases. For 16 percent of their purchases their 

customers required domestic product, and for the remaining 12 percent, purchases of domestic 

product were required by law or regulation.

Comparisons of domestic products, subject imports, and nonsubject imports

Purchasers were asked a number of questions comparing LWR pipe and tube produced 

in the United States, subject countries, and nonsubject countries. First, purchasers were asked 

II-13
for a country-by-country comparison on the same 15 factors (table II-8) for which they were 

asked to rate the importance.11

A majority or plurality of purchasers reported that U.S. product was superior to that 

from China on most of the 15 factors with the exceptions of discounts offered and price, for 

which most rated the imported product as superior; reliability of supply and technical 

support/service for which firms were evenly split between rating the Chinese product superior 

and inferior, and U.S. transportation costs for which firms were evenly split between superior, 

comparable and inferior. A majority or plurality of purchasers rated domestic and Mexican 

products as comparable with respect to 11 of the 15 factors. A plurality rated the U.S. product 

as superior with respect to availability, delivery time, reliability of supply, and technical 

support/service. A majority or plurality of purchasers rated domestic product as superior to the 

Turkish product with respect to 9 of the 15 factors. 

Comparison of U.S.-produced and imported LWR pipe and tube

In order to determine whether U.S.-produced LWR pipe and tube can generally be used 

in the same applications as imports, U.S. producers, importers, and purchasers were asked 

whether the products can “always,” “frequently,” “sometimes,” or “never” be used 

interchangeably. As shown in table II-9, the majority of firms reported that LWR pipe and tube 

from each country combination “always” or “frequently” can be used interchangeably, with the 

exception of purchasers comparing product from China to imports from other countries. Two of 

four purchasers reported that U.S. product and that from China were only “sometimes” 

interchangeable. 

One importer of Mexican product noted that Chinese quality is not acceptable for the 

U.S. market. Purchasers provided limited information with regard to interchangeability, with 

some firms explicitly noting that they were unfamiliar with imports from the subject sources. 

Two purchasers noted that quality differences were a factor with respect to China, and one 

mentioned different grades of steel and different gauge controls in place. 

As can be seen from table II-10, almost all responding purchasers reported that 

domestically-produced product “always” met minimum quality specifications. Most responding 

purchasers reported that the LWR pipe and tube from Korea, Mexico, and Turkey “usually” met 

minimum quality specifications. Only two of 5 responding purchasers reported that LWR pipe 

and tube from China usually met minimum quality specifications, with the other 3 reporting 

that it sometimes, rarely or never met minimum specifications. 

11 The table shows country combinations for which at least 3 purchasers responded.

II-14

 
Table II-8

LWR pipe and tube: Purchasers’ comparisons between U.S.-produced and imported product

Factor

Number of firms reporting

U.S. vs. China U.S. vs. Korea U.S. vs. Mexico

S C I S C I S C I

Availability 4 1 1 4 2 0 6 4 2

Delivery terms 4 1 1 4 2 0 4 7 1

Delivery time 4 0 2 4 1 1 6 4 2

Discounts offered 1 2 3 2 3 1 1 10 1

Extension of credit 3 2 1 2 4 0 1 11 0

Minimum quantity requirements 4 1 1 4 2 0 1 10 1

Packaging 3 2 1 3 2 1 1 9 2

Price1 1 1 3 2 1 3 3 5 4

Product consistency 4 0 2 3 3 0 3 8 1

Product range 3 1 2 2 4 0 4 7 1

Quality exceeds industry standards 4 0 2 3 3 0 4 7 1

Quality meets industry standards 3 1 2 2 4 0 1 10 1

Reliability of supply 3 0 3 2 2 2 5 3 4

Technical support/service 3 0 3 2 1 3 6 3 3

U.S. transportation costs1 2 2 2 2 3 1 2 7 3

Factor

Number of firms reporting

U.S. vs. Turkey China vs. Korea China vs. Mexico

S C I S C I S C I

Availability 3 1 1 1 2 2 1 1 3

Delivery terms 3 2 0 1 3 1 1 1 3

Delivery time 3 1 1 1 3 1 1 1 3

Discounts offered 0 4 1 1 3 1 2 1 2

Extension of credit 2 3 0 1 3 1 1 1 3

Minimum quantity requirements 3 2 0 1 3 1 1 1 3

Packaging 2 2 1 1 3 1 1 1 3

Price1 1 2 2 1 3 1 2 2 1

Product consistency 3 2 0 1 1 3 1 1 3

Product range 2 2 1 1 3 1 1 1 3

Quality exceeds industry standards 2 2 1 1 1 3 1 1 3

Quality meets industry standards 3 2 0 1 1 3 1 1 3

Reliability of supply 3 1 1 1 3 1 1 1 3

Technical support/service 3 1 1 1 2 2 1 1 3

U.S. transportation costs1 3 1 1 1 3 1 1 1 3 Table continued on next page.

II-15
Table II-8

LWR pipe and tube: Purchasers’ comparisons between U.S.-produced and imported product

Factor

Number of firms reporting

Mexico vs. Turkey

U.S. vs. All other 

sources

S C I S C I

Availability 3 1 0 2 0 2

Delivery terms 2 2 0 2 1 1

Delivery time 3 1 0 2 0 2

Discounts offered 1 2 1 1 2 1

Extension of credit 2 2 0 1 3 0

Minimum quantity requirements 2 2 0 1 2 1

Packaging 2 2 0 1 3 0

Price1 0 3 1 1 2 1

Product consistency 1 2 1 1 3 0

Product range 0 3 1 1 2 1

Quality exceeds industry standards 1 3 0 1 3 0

Quality meets industry standards 1 3 0 1 3 0

Reliability of supply 2 1 1 1 2 1

Technical support/service 2 1 1 2 0 2

U.S. transportation costs1 2 2 0 1 2 1

1 A rating of superior means that price/U.S. transportation costs is generally lower. For example, if a firm reported 

“U.S. superior,” it meant that the U.S. product was generally priced lower than the imported product.

Note: S=first listed country’s product is superior; C=both countries’ products are comparable; I=first listed country’s 

product is inferior. Comparisons are shown only for those country pairs for which at least 3 purchasers provided 

responses. 

Source: Compiled from data submitted in response to Commission questionnaires.

In addition, producers, importers, and purchasers were asked to assess how often 

differences other than price were significant in sales of LWR pipe and tube from the United 

States, subject, or nonsubject countries. As seen in table II-11, most firms reported that 

differences other than price between LWR pipe and tube from most country combinations were 

sometimes or never significant. The exception was in comparing U.S. LWR pipe and tube to that 

from China, in which 4 of 6 purchasers reported that differences other than price were “always” 

or “frequently” significant.

One U.S. producer noted that domestic product had the following advantages over 

imports: availability, transportation, product range, technical support, and customer service. 

Another producer noted that imports have higher transportation costs as well as uncertainty in 

delivery schedules, lack of quality and technical support and cannot be used in government 

contracts. One importer reported that other factors include length tolerances and rustpreventing chemicals and one reported that compared to domestic product the lead time on 

Mexican product is longer as it is produced-to-order.

II-16
Table II-9

LWR pipe and tube: Interchangeability between LWR pipe and tube 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. China 10 4 1 0 3 1 3 0 0 2 2 0

United States vs. Korea 10 4 1 0 3 2 2 0 3 5 0 0

United States vs. Mexico 11 4 0 0 6 4 0 0 3 9 0 0

United States vs. Turkey 10 5 0 0 5 3 1 0 1 5 0 0

United States vs. Other 10 4 1 0 5 1 1 0 1 4 0 0

China vs. Korea 7 1 1 0 3 1 2 0 0 1 0 1

China vs. Mexico 8 1 0 0 4 1 2 0 0 1 0 1

China vs. Turkey 7 2 0 0 3 2 1 0 0 1 0 1

China vs. Other 7 1 1 0 3 1 1 0 0 1 0 1

Korea vs. Mexico 7 1 1 0 3 2 1 0 0 1 0 0

Korea vs. Turkey 7 1 1 1 3 1 1 0 0 1 1 0

Korea vs. Other 7 1 1 1 3 1 1 0 0 1 0 0

Mexico vs. Turkey 8 1 0 0 5 3 0 0 0 2 1 0

Mexico vs. Other 8 1 0 0 5 1 0 0 0 3 0 0

Turkey vs. Other 7 1 1 0 4 2 0 0 0 1 0 0

China vs. Other 7 1 1 0 3 1 1 0 0 1 0 1

Korea vs. Other 7 1 1 1 3 1 1 0 0 1 0 0

Mexico vs. Other 8 1 0 0 5 1 0 0 0 3 0 0

Turkey vs. Other 7 1 1 0 4 2 0 0 0 1 0 0

 Note.—A=Always, F=Frequently, S=Sometimes, N=Never.

 Source: Compiled from data submitted in response to Commission questionnaires.

Table II-10

LWR pipe and tube: Ability to meet minimum quality specifications, by source and number of 

reporting firms1

Source Always Usually Sometimes Rarely or never

United States 16 3 0 0

China 0 2 2 1

Korea 1 4 0 0

Mexico 3 8 0 0

Turkey 0 4 0 0 1 Purchasers were asked how often domestically produced or imported LWR pipe and tube meets 

minimum quality specifications for their own or their customers’ uses.

Source: Compiled from data submitted in response to Commission questionnaires.

II-17
Table II-11

LWR pipe and tube: Significance of differences other than price between LWR pipe and tube

produced in the United States and in other countries, by country pair

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. China 1 2 4 8 2 0 2 3 2 2 0 2

United States vs. Korea 1 2 4 8 2 0 2 3 1 1 2 3

United States vs. Mexico 1 2 3 9 2 1 2 5 0 2 5 5

United States vs. Turkey 1 2 4 8 2 0 3 4 0 0 2 2

United States vs. Other 1 1 3 9 1 0 1 5 0 0 3 1

China vs. Korea 1 0 2 6 2 0 1 3 1 0 1 0

China vs. Mexico 1 0 2 6 2 0 2 3 0 0 0 0

China vs. Turkey 1 0 2 6 2 0 1 3 0 0 0 0

China vs. Other 1 0 2 6 1 0 1 3 0 0 0 0

Korea vs. Mexico 1 0 2 6 2 0 1 4 0 0 0 0

Korea vs. Turkey 1 0 2 6 2 0 0 4 0 0 0 0

Korea vs. Other 1 0 2 6 1 0 1 3 0 0 0 0

Mexico vs. Turkey 1 0 1 7 2 0 0 6 0 0 0 1

Mexico vs. Other 1 0 1 7 1 0 0 5 0 0 1 0

Turkey vs. Other 1 0 2 6 1 0 1 4 0 0 0 0

China vs. Other 1 0 2 6 1 0 1 3 0 0 0 0

Korea vs. Other 1 0 2 6 1 0 1 3 0 0 0 0

Mexico vs. Other 1 0 1 7 1 0 0 5 0 0 1 0

Turkey vs. Other 1 0 2 6 1 0 1 4 0 0 0 0

 Note.--A = Always, F = Frequently, S = Sometimes, N = Never.

Source: Compiled from data submitted in response to Commission questionnaires.

Three purchasers noted that the quality of Chinese product was lower than that of other 

sources. In addition, purchasers noted the following differences: location of inventory and 

delivery charges, Mexican suppliers offer lighter wall thicknesses resulting in lower price per 

foot; domestic is the best quality and most timely deliveries with Korea second, China’s quality 

suspect and delivery performance is not that good; lead time is a factor for imports from 

Mexico and other sources; domestic mills have better availability, shipping reliability, and 

quality reputation than Mexico.

ELASTICITY ESTIMATES

This section discusses elasticity estimates. Parties did not comment on the estimates.

II-18
U.S. supply elasticity

The domestic supply elasticity12 for LWR pipe and tube measures the sensitivity of the 

quantity supplied by U.S. producers to changes in the U.S. market price of LWR pipe and tube. 

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 LWR pipe and tube. Analysis of these factors earlier indicates that 

the U.S. industry is likely to be able to greatly increase or decrease shipments to the U.S. 

market; an estimate in the range of 5 to 10 is suggested. 

U.S. demand elasticity

The U.S. demand elasticity for LWR pipe and tube measures the sensitivity of the overall 

quantity demanded to a change in the U.S. market price of LWR pipe and tube. 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 LWR pipe and tube in the 

production of any downstream products. Based on the available information, the aggregate 

demand for LWR pipe and tube is likely to be inelastic; a range of -0.75 to -1.0 is suggested.13

Substitution elasticity

The elasticity of substitution depends upon the extent of product differentiation 

between the domestic and imported products.14 Product differentiation, in turn, depends upon 

such factors as quality (e.g., chemistry, appearance, etc.) and conditions of sale (e.g., 

availability, sales terms/ discounts/ promotions, etc.). In the original investigations, staff 

estimated that the elasticity of substitution between U.S.-produced LWR pipe and tube and 

imported LWR pipe and tube is likely to be in the range of 3 to 5 for all countries except China 

for which it estimated an elasticity of substitution of 2 to 4. Available information in the current 

reviews indicates that elasticities of substitution likely continue to be in the same ranges. 

12 A supply function is not defined in the case of a non-competitive market.

13 This is the range estimated in the original investigation. Available information suggests that there 

have been no major changes in end uses or substitutes since the original investigation. 14 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

 

PART III: CONDITION OF THE U.S. INDUSTRY

OVERVIEW

The information in this section of the report was compiled from responses to the 

Commission’s questionnaires and public sources. Eighteen firms, which are believed to account

for the vast majority of U.S. production of LWR pipe and tube during the period for which data 

were collected, supplied usable data on their operations in these reviews.

1

Since 2008, the domestic LWR pipe and tube industry has undergone a number of 

important changes, some directly impacting firm’s LWR operations. These changes are detailed 

in table III-1. 

Table III-1

LWR pipe and tube: Significant industry events, 2008-13

Year Company Event 

2008 Allied Closure/ Reorganization. Allied announced it will be closing its Pine 

Bluff, AR mill in phases from September 8, 2008 to December 31, 

2008. The production output will be relocated to existing facilities in 

Harvey, IL; Philadelphia, PA; and Phoenix, AZ. 

Atlas Decreased Capacity. Atlas reported temporarily ceasing production 

of their Blytheville, AR plant.

Hannibal Reduction. Hannibal reduced the number of employees and the 

number of hours worked at their manufacturing plants, which 

produces LWR pipe and tube used for ornamental tubing. 

Heartland Steel 

Products 

Acquisition. Heartland Steel Products acquired Eugene Welding 

Company, which manufactures structural shapes to ASTM A500 

specs in square sizes and rectangle with wall thicknesses of 2.1 to 

4.8 millimeters.

2009 Allied Closure. Allied reported a prolonged shutdown at its Phoenix, AZ 

manufacturing plant. 

Allied Capacity Increase. Allied planned to double the size of the facility in 

Harvey, IL at the estimated cost of $30 million. This will add another 

514,000 square feet to the current facility to increase capacity for 

secondary operations like coil slitting, roll forming and threading.

Prolamsa Laredo Opening. Prolamsa Laredo opened its new manufacturing facility in 

Laredo, TX. Initially, the two mills will produce light-walled, square 

and rectangular mechanical tubing. 

2010 Nucor 

Corporation 

Plant Opening. Nucor subsidiary, Skyline Steel, announced that they 

expect to open a new pipe facility in Longview, Washington to 

manufacture rolled and welded pipes. 

Table continued on the next page.

1 The Commission received incomplete and/or unusable responses from several firms, including ***. 

Northwest Tube and Welded Tube of Canada stopped producing LWR pipe and tube in the United States 

during the period for which data were collected. 

III-1

 
Table III-1--Continued

LWR pipe and tube: Significant industry events, 2008-13

Year Company Event 

2011 Kloeckner Metals Acquisition. California Steel and Tube was acquired by Kloeckner 

Metals, a producer of carbon welded and galvanized pipes and 

tubes.

Northwest Pipe Phase-Out. Northwest Pipe upgraded its production mill in Atchison, 

KS and will begin to phase out the production of light walled tubing to 

focus on energy tubular products.

Atlas Re-opening. Atlas announced a restart of the idled Blytheville, AR

facility and expects it to be fully operational by September 2011.

2012 Evraz Oregon Re-opening. Evraz Oregon announced that they will restart the tube 

mill in Oregon with a capacity of 200,000 tons of welded pipe 

annually in the first half of 2013. The mill was shut in 2009.

JMC Steel Group Shutdown. JMC Steel announced an agreement to buy the assets of 

the Atkore International facility in Morrisville, PA. The facility currently 

produces standard pipe and structural rounds and shapes. JMC 

intends to relocate the equipment to other JMC facilities for 

operation.

JMC Steel Group Acquisition. JMC Steel Group completed its $58.05 million purchase 

of Lakeside Steel, which produces carbon steel pipes in various 

shapes. 

Welded Tube of 

Canada 

Closure. Welded Tube of Canada planned to close their Berkeley, 

WV facility that currently produces standard pipe, and the structural 

tube mill in Huger, SC due to slow market conditions. 

Metal Matic Expansion. Metal Matic, a Minneapolis, MN based cold drawn 

mechanical tube producer, announced expansion into Middletown, 

OH with a 30-40,000 ton per year facility. 

Nova Steel Expansion. Nova Steel upgraded its Montreal tube mill with two new 

standard and structural lines valued at a combined $12.1 million, 

which is expected to open in late 2012 or early 2013. The mill will 

produce square pipes with a 0.375-inch wall thickness. It is expected 

to open in the first quarter of 2013. 

2013 Prolamsa Laredo Opening. Prolamsa Laredo confirmed it will build its new 300,000-

plus ton per year pipe and tube facility at Texas Triangle Park in 

Bryan, TX. The mill, at a cost of more than $120 million, is expected 

to begin operations by mid-2014 and will operate under a newly 

formed company, Axis Pipe and Tube, Inc.

Leggett & Platt Closure. Leggett and Platt closed its Blazon Tube operation in West 

Point, MS and consolidated them at its LaVergne, TN location.

Source: Preston Pipe and Tube Monthly Reports, American Metals Market and other Internet articles. 

Changes experienced by the industry 

Domestic producers were asked to indicate whether their firm had experienced any 

plant openings, relocations, expansions, acquisitions, consolidations, closures, or prolonged 

shutdowns because of strikes or equipment failure; curtailment of production because of 

shortages of materials or other reasons, including revision of labor agreements; or any other 

change in the character of their operations or organization relating to the production of LWR 

pipe and tube since January 1, 2008. A number of domestic producers that provided responses 

in these reviews indicated that they had experienced such changes; their responses are 

presented in table III-2.

III-2
Table III-2

LWR pipe and tube: Changes in the character of U.S. operations since January 1, 2008

* * * * * * *

Anticipated changes in operations

The Commission asked domestic producers to report anticipated changes in the 

character of their operations relating to the production of LWR pipe and tube. Three firms 

reported anticipated changes, including ***. 

U.S. PRODUCTION, CAPACITY, AND CAPACITY UTILIZATION

Over the review period, four firms *** reported a net decrease in capacity while five 

firms *** reported a net increase in capacity, resulting in an aggregate increase of 1.9 percent 

between 2008 and 2013.

2 U.S. production of LWR pipe and tube decreased between 2008 and 

2009 largely as a result of ***, before increasing every year between 2009 and 2013.Overall, 

U.S. production of LWR pipe and tube increased by 14.9 percent between 2008 and 2013 with 

capacity utilization levels increasing by 5.4 percentage points over the same period. Table III-3

and figure III-1 present and depict U.S. producers’ production, capacity, and capacity utilization.

Table III-3

LWR pipe and tube: U.S. producers’ production, capacity, and capacity utilization, 2008-13

Item

Calendar year

2008 2009 2010 2011 2012 2013

Quantity (short tons)

Capacity 1,110,314 1,081,371 1,089,411 1,141,536 1,109,604 1,131,083

Production 470,375 367,451 448,691 472,564 502,426 540,664

Ratio (percent)

Capacity utilization 42.4 34.0 41.2 41.4 45.3 47.8

 Source: Compiled from data submitted in response to Commission questionnaires.

2 ***. ***. ***. 

III-3

 
Figure III-1 

LWR pipe and tube: U.S. producers’ production, capacity, and capacity utilization, 2008-13

 

Source: Compiled from data submitted in response to Commission questionnaires.

Constraints on capacity

Domestic producers identified the following constraints in the manufacturing process

for LWR pipe and tube: availability of raw materials, mill speed, retooling/change over time, 

and limitations or restrictions on equipment and workforce. 

Alternative products

Nearly all domestic producers of LWR pipe and tube reported using the same equipment 

and/or employees to produce other products, the most common of which included: circular 

mechanical tubing, other light-walled products, and heavy-walled products. As detailed in table 

III-4 and depicted in figure III-2, products other than LWR pipe and tube accounted for no less 

than 80 percent of domestic producers’ overall product mix during the period. Heavy-walled 

products accounted for the largest share of these alternative products, representing more than 

half of 2013 total combined (LWR pipe and tube and non-LWR pipe and tube) production. 

III-4
Table III-4

LWR pipe and tube: U.S. producers’ overall capacity, production, and capacity utilization, 2008-13

Item

Calendar year

2008 2009 2010 2011 2012 2013

Quantity (short tons)

Overall capacity 4,887,582 4,065,631 4,093,397 4,601,757 4,553,736 4,467,944

Production:

 LWR pipe and tube 470,375 367,451 448,691 472,564 502,426 540,664

Other products 2,358,440 1,561,487 1,817,653 2,026,006 2,216,265 2,263,512

Total production 2,828,815 1,928,938 2,266,344 2,498,570 2,718,691 2,804,176

Ratio (percent)

Overall capacity utilization 57.9 47.4 55.4 54.3 59.7 62.8

Share of quantity (percent)

Share of production:

 LWR pipe and tube 16.6 19.0 19.8 18.9 18.5 19.3

Other products 83.4 81.0 80.2 81.1 81.5 80.7

Total production 100.0 100.0 100.0 100.0 100.0 100.0

 

Source: Compiled from data submitted in response to Commission questionnaires.

Figure III-2 

LWR pipe and tube: U.S. producers’ shifting of production, 2008-13

 

Source: Compiled from data submitted in response to Commission questionnaires.

III-5
U.S. PRODUCERS’ U.S. SHIPMENTS AND EXPORTS

Table III-5 presents U.S. producers’ U.S. shipments, export shipments, and total 

shipments of LWR pipe and tube. Commercial U.S. shipments, which accounted for the vast 

majority of total U.S. shipments, decreased between 2008 and 2009 before increasing every 

year between 2009 and 2013, resulting in an overall increase of *** percent between 2008 and 

2013. *** reported internal consumption of LWR pipe and tube and *** reported transfers of 

LWR pipe and tube to related firms.3 Six firms *** provided data regarding their exports of LWR 

pipe and tube between 2008 and 2013, with *** being the largest exporter of LWR pipe and 

tube in the United States.4 Canada and Mexico were cited as the principal export markets by 

U.S. producers. 

Data were gathered on U.S. producers’ U.S. production of corrosion-resistant LWR pipe 

and tube versus black LWR pipe and tube. Data submitted indicated that black LWR pipe and 

tube accounted for the vast majority of U.S. producers’ share of production in 2013. 

Table III-5

LWR pipe and tube: U.S. producers’ U.S. shipments, exports shipments, and total shipments, 

2008-13

Item

Calendar year

2008 2009 2010 2011 2012 2013

Quantity (short tons)

Commercial U.S. shipments *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Subtotal, U.S. shipments 448,481 350,966 411,632 435,122 480,782 517,350

Export shipments 23,179 15,002 20,591 24,590 29,435 27,266

Total shipments 471,660 365,968 432,223 459,712 510,217 544,616

Value (1,000 dollars)

Commercial U.S. shipments *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Subtotal, U.S. shipments 530,498 296,130 390,680 478,167 500,975 514,216

Export shipments 27,384 13,352 19,515 26,373 31,185 27,918

Total shipments 557,882 309,482 410,195 504,540 532,160 542,134

Table continued on next page.

3 ***. 4 ***.

III-6

 
Table III-5 --Continued

LWR pipe and tube: U.S. producers’ U.S. shipments, exports shipments, and total shipments, 

2008-13

Unit value (dollars per short ton)

Commercial U.S. shipments $*** $*** $*** $*** $*** $***

Transfers to related firms *** *** *** *** *** ***

Subtotal, U.S. shipments 1,183 844 949 1,099 1,042 994

Export shipments 1,181 890 948 1,073 1,059 1,024

Total shipments 1,183 846 949 1,098 1,043 995

Share of quantity (percent)

Commercial U.S. shipments *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Subtotal, U.S. shipments 95.1 95.9 95.2 94.7 94.2 95.0

Export shipments 4.9 4.1 4.8 5.3 5.8 5.0

Total shipments 100.0 100.0 100.0 100.0 100.0 100.0

Share of value (percent)

Commercial U.S. shipments *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Subtotal, U.S. shipments 95.1 95.7 95.2 94.8 94.1 94.9

Export shipments 4.9 4.3 4.8 5.2 5.9 5.1

Total shipments 100.0 100.0 100.0 100.0 100.0 100.0

 Source: Compiled from data submitted in response to Commission questionnaires.

U.S. PRODUCERS’ INVENTORIES

Table III-6 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.

Table III-6

LWR pipe and tube: U.S. producers’ inventories, 2008-13

Item

Calendar year

2008 2009 2010 2011 2012 2013

Quantity (short tons)

U.S. producers' end-of-period 

inventories 68,574 68,290 84,699 97,742 90,177 85,212

Ratio (percent)

Ratio of inventories to--

 U.S. production 14.6 18.6 18.9 20.7 17.9 15.8

U.S. shipments 15.3 19.5 20.6 22.5 18.8 16.5

Total shipments 14.5 18.7 19.6 21.3 17.7 15.6

 

Source: Compiled from data submitted in response to Commission questionnaires.

III-7
U.S. PRODUCERS’ IMPORTS 

As noted earlier, *** U.S. producers, *** directly import the subject merchandise.5

Table III-7 presents data on these firms’ U.S. production and U.S. imports of LWR pipe and tube 

over the period.

Table III-7

LWR pipe and tube: U.S. producers’ U.S. production, imports, and import ratios to U.S. 

production, 2008-13

* * * * * * *

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

Table III-8 shows U.S. producers’ employment-related data during the period examined. 

As detailed in table III-8, the average number of production-related workers (PRWs), total hours 

work, and total wages paid following similar trends as other U.S. producer trade data, 

decreasing between 2008 and 2009, before increasing every year between 2009 and 2013.6

Table III-8

LWR pipe and tube: Average number of production and related workers, hours worked, wages 

paid to such employees, hourly wages, productivity, and unit labor costs, 2008-13

Item

Calendar year

2008 2009 2010 2011 2012 2013

Production-related workers (PRWs) 876 779 800 857 879 976

Total hours worked (1,000 hours) 1,923 1,605 1,741 1,931 1,997 2,198

Hours worked per PRW (hours) 2,195 2,060 2,176 2,253 2,272 2,252

Wages paid ($1,000) 62,827 57,173 59,255 63,829 67,032 72,462

Hourly wages (dollars per hour) $32.67 $35.62 $34.04 $33.05 $33.57 $32.97

Productivity (short tons per hour) 244.6 228.9 257.7 244.7 251.6 246.0

Unit labor costs (dollars per short 

ton) $134 $156 $132 $135 $133 $134

 Source: Compiled from data submitted in response to Commission questionnaires.

5 ***. ***. ***. 6 ***. 

III-8

 
III‐9

PART III:FINANCIAL EXPERIENCE OF U.S. PRODUCERS

Background

Eighteen producers provided usable financial data on their operations producing LWR

pipe and tube.11 The responding producers are believed to represent the substantial majority of

U.S. production. The firms differ considerably in size in terms of sales volume and value.  The

three largest producers, ***, reported average annual sales volumes over *** short tons. In

contrast, three firms, ***, reported average annual sales of less than *** short tons.12 Overall,

net sales consisted of commercial sales and minor amounts of related party transfers by ***.13

No U.S. producer reported internal consumption.

Operations on LWR pipe and tube

The results of operations of the responding firms on their LWR pipe and tube operations

are presented in table III‐9, which includes data on a per‐short ton basis as well as operating

income (loss) to net sales ratios.14 To summarize, the financial results of the U.S. producers

deteriorated substantially from 2008 to 2009 as sales quantities and unit sales values decreased

much greater than the decrease of unit costs. The quantity of total sales increased continuously

between 2009 and 2013, as total sales values increased during the same period. Average unit

net sales values increased between 2009 and 2011, then decreased from 2011 to 2013. Per‐unit

values of cost of goods sold (“COGS”) decreased from 2008 to 2009, due to lower raw material

costs, and then increased somewhat from 2009 to 2011 as raw material costs increased, more

than offsetting the continuing decline in conversion costs (direct labor and factory overhead

combined). The combined producers’ operating income increased from an operating loss of

$8.1 million in 2009 to an operating income of $53.1 million in 2011, then decreased to $38.1

million in 2012 and to $34.1 million in 2013 as a result of lower per‐unit sales values, despite

increased sales quantities and lower per‐unit total costs. The ratio of operating income to net

sales decreased by 12.7 percentage points from 10.2 percent in 2008 to a negative 2.5 percent

in 2009 and increased by 13.4 percentage points between 2009 and 2011, then decreased to

7.4 percent in 2012 and further fell to 6.4 percent in 2013.

The largest change in the operating income occurred between 2008 and 2009, an

operating income of $55.8 million in 2008 changed to an operating loss of $8.1 million in 2009,

due primarily to a substantial decrease of per‐unit value sales in 2009 (a 23.8 percent decrease

 

11 The producers with fiscal year ends other than December 31 are Allied (September 30), Atlas

(September 30), EXL Tube (April 30), and Searing (February 28).  Some differences between data

reported in the trade and financial sections of the Commission’s producers’ questionnaire mainly are

attributable to timing differences (calendar year vs. fiscal year). 12 Evraz submitted ***. E‐mails from ***, March 20, 25, and 26, 2014.

13 ***. 14 There were some data changes from *** in this review to correct data errors made in the original

investigations. E‐mail from ***, January 29, 2014.
III‐10

in average unit value from $1,139 per short ton in 2008 to $868 per short ton in 2009, in spite

of a somewhat lower total cost per short ton in 2009, which negatively impacted financial

performance. While the average unit sales value decreased by $271 per short ton, average unit

total cost (COGS plus selling, general, and administrative (“SG&A”) expenses) decreased by

$132 per short ton, which resulted in a decreased per‐unit operating income by $139 per short

ton.   
III‐11

Table III-9 

LWR pipe and tube: Results of operations of U.S. producers, fiscal years 2008-13 

Item Fiscal year

2008 2009 2010 2011 2012 2013

Quantity (short tons)

Net sales1 480,053 369,862 426,764 453,226 501,480 546,511 

Value ($1,000)

Net sales1 546,642 321,192 399,436 488,907 516,553 533,566 

COGS 454,994 305,308 357,052 405,077 444,447 463,763 

Gross profit 91,648 15,884 42,384 83,830 72,106 69,803 

SG&A expenses 35,851 23,953 27,305 30,739 33,980 35,714 

Operating income 55,797 (8,069) 15,079 53,091 38,126 34,089 

Interest expense 2,975 4,192 4,413 3,975 4,215 4,482 

Other expense 3,761 1,491 1,387 1,491 1,469 1,796 

Other income 1,022 217 407 416 508 588 

Net income (loss) 50,083 (13,535) 9,686 48,041 32,950 28,399 

Depreciation 6,767 7,084 7,139 6,487 7,746 8,445 

Cash flow 56,850 (6,451) 16,825 54,528 40,696 36,844 

Value (per short ton)

Net sales $1,139 $868 $936 $1,079 $1,030 $976 

COGS 948 825 837 894 886 849 

Gross profit 191 43 99 185 144 128 

SG&A expenses 75 65 64 68 68 65 

Operating income 116 (22) 35 117 76 62 

Ratio to net sales (percent)

COGS 83.2 95.1 89.4 82.9 86.0 86.9 

Gross profit 16.8 4.9 10.6 17.1 14.0 13.1 

SG&A expenses 6.6 7.5 6.8 6.3 6.6 6.7 

Operating income 10.2 (2.5) 3.8 10.9 7.4 6.4 

Number of firms reporting

Operating losses 3 10 6 3 4 4 

Data 17 18 18 18 18 18 

1 ***. 

 
III‐12

Selected financial data, by firm, are presented in table III‐10.  Total net sales (quantities

and values), operating income (loss), the ratio of operating income (loss) to net sales, and per‐

unit values (sales, COGS, SG&A expenses), are presented in this table on a firm‐by‐firm basis.  

Seven of the 18 reporting producers generated positive operating income in each fiscal year

during 2008‐13, while the remaining ten reported operating losses in certain years during the

period. However, the combined operating income and operating income margins of the 18

producers decreased between 2008 and 2013 (and in particular between 2008 and 2010). From

2008 to 2009, 15 of the 18 producers reported decreases in sales values, 14 reported decreases

in operating income and decreases in the operating income margin. When comparing 2009

results to 2008 results, only four producers, ***, reported improved profitability. Four

producers, ***, reported operating losses in 2013, compared to three in 2008.

***, performed toll processing during 2009‐13.15  Toll processing revenue accounted for

less than *** percent of the total net sales value and revenue for all firms combined in 2013.

These limited toll operations are not reflected in the aggregate results of operations of LWR

pipe and tube due to their completely different revenue and cost structures.   

Table III-10 

LWR pipe and tube: Results of operations of U.S. producers (by firm), fiscal years 2008-13 

* * * * * * * 

The data show that ***.  ***.16 ***.17  

***.18  

***.19 ***.20 ***.21

***. Per‐unit SG&A expenses of ***.22

For non‐recurring items, ***.

Selected aggregate per‐unit cost data of the producers on their operations, i.e., COGS

and SG&A expenses, are presented in table III‐11.23  Overall per‐unit COGS and total cost (which

includes SG&A expenses) decreased somewhat from 2008 to 2009, driven mainly by changes

(decreases) in raw material costs (i.e., reflecting changes in the cost of hot‐rolled steel coils).  

 

15 In toll processing, the firm that owns raw materials (the tollee) arranges for unrelated processors

(the tollers) to process the materials for a fee, and then the tollee arranges for the final sale of the

products to other parties.   16 E‐mail from ***, February 20, 2014. 17 E‐mail from ***, February 20, 2014.

18 E‐mail from ***, February 18, 2014 and E‐mails from ***, March 20, 25, and 26, 2014.

19 E‐mail from ***, February 12, 2014.

20  E‐mail from ***, February 12, 2014. 

21 E‐mail from ***, February 17, 2014. 22 E‐mail from ***, February 14, 2014.

23 ***.
III‐13

Per‐unit COGS increased from 2009 to 2011, due to the increases in raw material costs, in spite

of declines in conversion costs. Per‐unit COGS and total costs decreased between 2011 and

2013, due mainly to the decreases in raw material costs. Per‐unit SG&A expenses remained

relatively the same over the period.

Table III-11 

LWR pipe and tube: Average unit costs of U.S. producers, fiscal years 2008-13

Item Fiscal year

2008 2009 2010 2011 2012 2013

Value (per short ton)

COGS: 

 Raw materials $794 $656 $689 $749 $735 $695 

 Direct labor 50 54 48 50 52 52 

 Factory overhead 104 116 100 95 99 102 

 Total COGS 948 825 837 894 886 849 

SG&A expenses 75 65 64 68 68 65 

 Total cost 1,022 890 901 962 954 914 

Source: Compiled from data submitted in response to Commission questionnaires. 

A variance analysis showing the effects of prices and volume on the producers’ sales of

LWR pipe and tube, and of costs and volume on their total costs, is shown in table III‐12.24  The

data presented in table III‐12 are comparable to changes in operating income as presented in

table III‐9. The analysis is summarized at the bottom of the table.  The variance analysis

indicates that the decrease in operating income of $21.7 million between 2008 and 2013

resulted from the negative effect of lower average price ($88.8 million) which was partially

offset by the positive effects of lower costs/expenses ($59.3 million) and increased sales

volume ($7.7 million). Between 2012 and 2013, it indicates that the decrease in operating

income of $4.0 million resulted from the combined effects of decreased average sales values

and decreased costs/expenses, as well as increases in sales volume.

 

24 The Commission’s variance analysis is calculated in three parts:  sales variance, COGS variance,

and SG&A expenses variance.  Each part consists of a price variance (in the case of the sales variance) or

a cost variance (in the case of the COGS and SG&A variances) and a volume variance.  The sales or cost

variance is calculated as the change in unit price/cost times the new volume, while the volume variance

is calculated as the change in volume times the old unit price/cost.  Summarized at the bottom of the

respective tables, the price variance is from sales, the cost/expense variance is the sum of those items

from COGS and SG&A, respectively, and the net volume variance is the sum of the price, COGS, and

SG&A volume variance.  All things being equal, a stable overall product mix generally enhances the

utility of the Commission’s variance analysis.
III‐14

Table III-12 

LWR pipe and tube: Variance analysis of operations of U.S. producers, between fiscal years 2008-13 

Item

Between fiscal years

2008-13 2008-09 2009-10 2010-11 2011-12 2012-13

Value ($1,000)

Net sales: 

 Price variance (“var”) (88,753) (99,974) 28,830 64,704 (24,407) (29,371)

 Volume variance 75,677 (125,476) 49,414 24,767 52,053 46,384 

 Total net sales var. (13,076) (225,450) 78,244 89,471 27,646 17,013 

Cost of sales: 

 Cost variance 54,220 45,247 (4,773) (25,886) 3,758 20,594 

 Volume variance (62,989) 104,439 (46,971) (22,139) (43,128) (39,910)

 Total cost variance (8,769) 149,686 (51,744) (48,025) (39,370) (19,316)

Gross profit variance (21,845) (75,764) 26,500 41,446 (11,724) (2,303)

SG&A expenses: 

 Expense variance 5,100 3,669 333 (1,741) 32 1,317 

 Volume variance (4,963) 8,229 (3,685) (1,693) (3,273) (3,051)

 Total SG&A variance 137 11,898 (3,352) (3,434) (3,241) (1,734)

Operating income var. (21,708) (63,866) 23,148 38,012 (14,965) (4,037)

Summarized as: 

 Price variance (88,753) (99,974) 28,830 64,704 (24,407) (29,371)

 Net cost/expense var. 59,320 48,916 (4,440) (27,626) 3,789 21,911 

 Net volume variance 7,724 (12,808) (1,241) 935 5,652 3,424 

Note.--Unfavorable variances are shown in parentheses; all others are favorable. The data are comparable to 

changes in operating income as presented in table III-9. 

Source: Compiled from data submitted in response to Commission questionnaires. 

 
III‐15

Capital expenditures and research and development expenses

The responding firms’ aggregate data on capital expenditures and research and

development (“R&D”) expenses are presented in table III‐13.  All U.S. producers except for ***

reported at least nominal capital expenditures, while three producers, (***), reported sizable

amounts of capital expenditures during 2008‐13.25 Data for capital expenditures on a firm‐by‐

firm basis are shown in table III‐14. While capital expenditures fluctuated during the entire

period, they generally decreased between 2008 and 2013, while they increased from 2009 to

2010, due to capital spending by *** in 2010. R&D expenses remained relatively small over the

period. Only *** of the responding firms, ***, reported R&D expenses.

Table III-13 

LWR pipe and tube: Capital expenditures and R&D expenses by U.S. producers, fiscal years 2008-

13

Item

Fiscal year 

2008 2009 2010 2011 2012 2013

Value ($1,000)

Capital expenditures1 12,320 9,905 13,621 11,846 10,444 8,050 

R&D expenses2

*** *** *** *** *** *** 

1 All companies except *** reported capital expenditures. 

2 Only *** reported R&D expenses. 

 

Source: Compiled from data submitted in response to Commission questionnaires.

Table III-14 

LWR pipe and tube: Capital expenditures by U.S. producers, by firm, fiscal years 2008-13 

* * * * * * * 

Assets and return on assets

U.S. producers were requested to provide data on their assets used in the production

and sales of LWR pipe and tube during the period for which data were collected to assess their

return on assets (“ROA”).  Although ROA can be computed in different ways, a commonly used

method is income earned during the period divided by the total assets utilized for the

operations.  Therefore, staff calculated ROA as operating income divided by total assets used in

the production and sales of LWR pipe and tube.  Data on the U.S. producers’ total assets and

their ROA are presented in table III‐15. The return on assets decreased substantially from 2008

 

25 As presented and discussed in some detail in table III‐14, *** accounted for a substantial portion

of reported capital expenditures.
III‐16

to 2009 and increased from 2009 to 2011, then decreased in 2012 and 2013.26 The trend of

ROA over the period was the same as the trend of the operating income margin shown in table

III‐9.

Table III-15 

LWR pipe and tube: Value of assets and return on assets of U.S. producers, fiscal years 2008-13

Item Fiscal year

2008 2009 2010 2011 2012 2013

Value ($1,000)

Operating income 55,797 (8,069) 15,079 53,091 38,126 34,089 

Value ($1,000)

Total assets (net) 268,242 209,563 226,834 244,211 274,392 291,959 

Ratio of operating income to total assets (percent) 

Return on assets 20.8 (3.9) 6.6 21.7 13.9 11.7 

Source: Compiled from data submitted in response to Commission questionnaires. 

 

26 Other variations and changes of the value of PPE may be attributable to the allocated assets based

on the relative sales value of the subject merchandise compared to total sales.
PART IV: U.S. IMPORTS AND THE FOREIGN INDUSTRIES

U.S. IMPORTS

Overview

Forty-three firms provided the Commission with data on their U.S. imports of LWR pipe 

and tube in the original investigations. In these reviews, 14 firms provided data and information 

in response to the Commission’s questionnaire. Based on official Commerce statistics, as 

adjusted to exclude Nexteel of Korea, the 14 responding firms accounted for 63.4 percent of all 

U.S. imports of LWR pipe and tube in during 2008-13, including *** percent coverage of subject 

imports.

1

Imports from subject and nonsubject countries

Table IV-1 presents information on U.S. imports of LWR pipe from China, Korea, Mexico, 

Turkey and all other sources over the period examined. Mexico was the largest subject source 

of LWR pipe and tube, accounting for *** percent of all subject imports between 2008 and 

2013 and 56.8 percent of total LWR pipe and tube imports from all countries over the same 

period. The largest nonsubject source of LRW pipe and tube imports was Canada, which 

accounted for 36.7 percent of total imports from all countries in 2013. 

1 LWR pipe and tube is currently classified under HTS subheadings 7306.61.50 and 7306.61.70 

(limited to goods imported under statistical reporting number 7306.61.7060, which consists of lightwalled square and rectangular pipe and tube made of an alloy steel other than stainless steel). Nexteel 

is excluded from the antidumping orders on LWR pipe and tube from Korea. For the purposes of this 

report, the quantity and value of entries of LWR pipe and tube from Nexteel are classified as imports 

from “all other sources” during 2008-2010. There were no U.S. imports of LWR pipe and tube from 

Korea during 2011-2013. 

IV-1

 
Table IV-1

LWR pipe and tube: U.S. imports by source, 2008-13

Item

Calendar year

2008 2009 2010 2011 2012 2013

Quantity (short tons)

U.S. imports from--

 China 687 31 109 277 282 126

Korea1 *** *** *** 0 0 0

Mexico 115,179 68,311 67,692 60,925 64,684 82,710

Turkey 0 36 0 564 5,920 2,101

Subtotal, subject sources *** *** *** 61,766 70,885 84,937

All other sources *** *** *** 56,148 60,298 71,756

Total U.S. imports 173,888 114,234 120,731 117,914 131,183 156,693

Value (1,000 dollars)

U.S. imports from--

 China 627 74 235 438 350 144

Korea1 *** *** *** 0 0 0

Mexico 115,638 44,664 52,906 57,051 55,172 66,982

Turkey 0 24 0 507 4,831 1,836

Subtotal, subject sources *** *** *** 57,997 60,353 68,962

All other sources *** *** *** 62,823 64,025 70,782

Total U.S. imports 183,896 82,603 103,553 120,820 124,378 139,744

Unit value (dollars per short ton)

U.S. imports from--

 China $912.17 $2,368.82 $2,161.17 $1,582.88 $1,241.84 $1,139.02

Korea1 *** *** *** (

2

) (

2

) (

2

)

Mexico 1,003.98 653.84 781.58 936.43 852.95 809.85

Turkey (

2

) 649.82 (

2

) 898.67 816.11 873.56

Subtotal, subject sources *** *** *** 938.98 851.42 811.91

All other sources *** *** *** 1,118.87 1,061.80 986.43

Total U.S. imports 1,057.56 723.10 857.72 1,024.64 948.12 891.83

 Table continued on the next page.

IV-2
Table IV-1—Continued 

LWR pipe and tube: U.S. imports by source, 2008-13

Item

Calendar year

2008 2009 2010 2011 2012 2013

Share of quantity (percent)

U.S. imports from--

 China 0.4 0.0 0.1 0.2 0.2 0.1

Korea1 *** *** *** 0.0 0.0 0.0

Mexico 66.3 61.4 57.0 51.7 49.3 52.8

Turkey 0.0 0.0 0.0 0.5 4.5 1.3

Subtotal, subject sources *** *** *** 52.4 54.0 54.2

All other sources *** *** *** 47.6 46.0 45.8

Total U.S. imports 100.0 100.0 100.0 100.0 100.0 100.0

Share of value (percent)

U.S. imports from--

 China 0.3 0.1 0.2 0.4 0.3 0.1

Korea1 *** *** *** 0.0 0.0 0.0

Mexico 63.0 55.8 51.9 47.2 44.4 47.9

Turkey 0.0 0.0 0.0 0.4 3.9 1.3

Subtotal, subject sources *** *** *** 48.0 48.5 49.3

All other sources *** *** *** 52.0 51.5 50.7

Total U.S. imports 100.0 100.0 100.0 100.0 100.0 100.0

Ratio to U.S. production (percent)

U.S. imports from--

 China 0.1 0.0 0.0 0.1 0.1 0.0

Korea1 *** *** *** 0.0 0.0 0.0

Mexico 24.5 18.5 15.1 12.9 12.9 15.3

Turkey 0.0 0.0 0.0 0.1 1.2 0.4

Subtotal, subject sources *** *** *** 13.1 14.1 15.7

All other sources *** *** *** 11.9 12.0 13.3

Total U.S. imports 36.9 30.2 26.4 24.9 26.1 28.9

 

1 Excludes Nexteel.

2 Not applicable.

Note: Unit values derived from unrounded numbers.

Source: Compiled from data submitted in response to Commission questionnaires and from official 

import statistics of the U.S. Department of Commerce adjusted to exclude Nexteel of Korea.

Two importers indicated that their firms have experienced changes to relation in the 

importation of LWR pipe and tube since January 1, 2008. ***. Data were gathered on U.S. 

importers’ imports of corrosion-resistant LWR pipe and tube versus black LWR pipe and tube. 

Data submitted indicated that black LWR pipe and tube accounted for the vast majority of U.S. 

imports reported by responding U.S. importers in 2013. 

U.S. importers were asked to describe the significance of the existing orders in terms of 

its effect on their firm’s imports. Several firms *** indicated that the orders have not 

IV-3
significantly impacted their firm’s operations. ***. Other firms *** reported that the orders 

have limited their U.S. sales and have forced them to look to other markets (home markets or 

other export markets); and one firm ***.

Importers were asked if they would anticipate any changes in their operations in the 

future if the orders were to be revoked. Two firms *** reported that revocation of the orders 

may allow them to recover and/or increase sales in the U.S.; however, ***. ***. 

U.S. IMPORTERS’ IMPORTS SUBSEQUENT TO DECEMBER 31, 2013

The Commission requested importers to indicate whether they had imported or 

arranged for the importation of LWR pipe and tube from China, Korea, Mexico, and Turkey for 

delivery after December 31, 2013. Four firms *** reported importing or arranging for 

importation of *** short tons of LWR pipe and tube from Mexico and three firms *** reported 

importing or arranging for importation of *** short tons of LWR pipe and tube from Turkey for

the first quarter of 2014.

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. Channels of distribution and 

fungibility (interchangeability) are discussed in Part II of this report. The domestic interested 

parties argue that imports from all four countries should be cumulated.2

U.S. producers reported selling LWR pipe and tube to all regions in the United States. 

Importers reported selling LWR pipe and tube from Mexico to all regions in the contiguous 

United States except the Northeast and reported selling LWR pipe and tube from Turkey in the 

*** regions.

According to official Commerce statistics, the vast majority of U.S. imports of LWR pipe 

and tube from China entered through the ports of Houston-Galveston, TX and New York City; 

the vast majority of U.S. imports of LWR pipe and tube from Korea entered through the ports of 

Los Angeles, CA and San Juan, PR; the vast majority of U.S. imports of LWR pipe and tube from 

Mexico entered through Laredo, TX; and the vast majority of U.S. imports of LWR pipe and tube 

from Turkey entered through the port of Savannah, GA. 

2 Domestic interested parties’ prehearing brief, p. 5. Hearing transcript, pp. 8 and 60 (Schagrin). 

IV-4

 
Presence in the market

Imports from Mexico were present in every month for the period for which data were 

collected. Table IV-2 presents data on the monthly entries of U.S. imports of LWR pipe and 

tube, by source, during 2008-13.

Table IV-2

LWR pipe and tube: U.S. imports monthly entries, by source, 2008-2013

Country

Calendar year

2008 2009 2010 2011 2012 2013

China 9 3 5 10 10 5

Korea 10 7 4 0 0 0

Mexico 12 12 12 12 12 12

Turkey 0 1 0 1 8 7

Source: Compiled from official Commerce statistics.

THE INDUSTRY IN CHINA

Operations on LWR pipe and tube

At the time of the Commission’s original investigations, usable questionnaire responses 

were received from three Chinese producers of LWR pipe and tube (Guangdong Walsall Steel, 

Shanghai Jiayi Cold-Formed Section Steel, and Zhangjiagang Zhongyuan Pipe Making Co). In 

these reviews, the Commission received no responses from producers of LWR pipe and tube 

from China. According to Simdex (a market research firm), there are approximately thirty-nine 

known producers of carbon-welded pipes having rectangular and square cross-sections with a 

wall thickness of less than four millimeters.3

Global Trade Atlas (“GTA”) statistics for exports of LWR pipe and tube from China under 

HS subheading 730661 are presented in table IV-3. These statistics are somewhat overstated as 

they may contain products outside the scope of the orders, including other hollow profiles of 

rectangular and square cross sections, and other alloy LWR pipe and tubes having a wall 

thickness greater than four millimeters.

Between 2008 and 2013, China exported LWR pipe and tube to 197 countries. In 2013, 

the top five export destinations for Chinese LWR pipe and tube by quantity were South Korea 

(7.9 percent of total Chinese exports), Angola (6.3 percent), the Philippines (6.3 percent), 

Singapore (5.3 percent), and Peru (5.2 percent). The United States accounted for less than one 

percent (5,708 short tons) of China’s total LWR pipe and tube exports in 2013. China was a net 

3 Simdex Steel Tube Manufacturers Worldwide Guide, 2013.

IV-5

 
exporter of LWR pipe and tube during 2008 to 2013 as indicated in table IV-4. China’s net 

exports of LWR pipe and tube more than doubled from 2008 to 2013. 

Table IV-3

LWR pipe and tube: China’s reported exports by quantity and value, 2008-13 

Country Quantity (short tons)

2008 2009 2010 2011 2012 2013

South Korea 37,415 35,013 84,891 65,495 70,104 68,041

Angola 34,095 32,096 48,581 60,878 69,490 53,432

Philippines 3,717 11,634 25,109 34,175 39,729 53,068

Singapore 10,172 18,189 28,371 25,090 35,820 45,129

Peru 1,092 3,277 15,411 29,263 24,275 44,918

Australia 42,394 40,308 46,366 33,126 43,018 40,087

Venezuela 12 213 604 25,653 11,611 36,005

United Arab 

Emirates 15,208 9,250 20,131 23,148 24,797 28,459

Ghana 13,679 17,407 12,022 27,511 13,909 27,855

Panama 9,561 3,908 20,820 22,320 21,542 27,436

All Others 208,188 206,860 354,783 415,944 430,080 426,267

 Total 375,533 378,155 657,090 762,604 784,374 850,696

Value (1,000 dollars) 

South Korea 28,216 19,556 51,591 46,691 44,341 40,044

Singapore 9,173 11,899 20,079 21,130 28,939 37,657

Australia 41,119 29,821 36,201 31,485 39,445 36,197

Philippines 2,653 6,746 17,050 28,274 28,639 35,712

Angola 24,507 18,445 28,904 42,680 46,340 33,814

Venezuela 38 291 488 20,998 9,075 26,483

Peru 998 1,779 9,299 19,549 15,116 25,875

Indonesia 3,570 6,817 11,762 16,749 22,954 24,696

Myanmar 5,223 5,627 13,792 19,293 17,738 22,198

United Arab 

Emirates 13,409 6,229 14,999 17,768 17,672 20,066

All Others 187,433 139,911 258,967 360,546 355,616 358,775

 Total 316,339 247,120 463,132 625,163 625,875 661,519

Note - Original quantity data were published in kilograms, which were converted to short tons by 

multiplying by 0.00110231. Because of rounding, figures may not add to the totals shown.

Source: Compiled from Global Trade Atlas, HS 730661 (Tubes, pipes and hollow profiles, of iron or 

steel, welded, of a square or rectangular cross-section).

IV-6
Table IV-4

LWR pipe and tube: China’s reported net exports, 2008-13 

Quantity (short tons)

2008 2009 2010 2011 2012 2013

Exports 375,533 378,155 657,090 762,604 784,374 850,696

Imports 21,785 18,254 18,183 14,315 17,729 16,786

Net exports1 353,748 359,901 638,907 748,289 766,645 833,910

1 Exports minus imports 

Note - Original quantity data were published in kilograms, which were converted to short tons by 

multiplying by 0.00110231. Because of rounding, figures may not add to the totals shown. 

Source: Compiled from Global Trade Atlas, HS 730661 (Tubes, pipes and hollow profiles, of iron or 

steel, welded, of a square or rectangular cross-section) 

From 2008 to 2010, Chinese producers of LWR pipe and tube increased capacity by 

opening new manufacturing plants and were often the subject of acquisitions by larger Chinese 

steel companies. In 2008, Shandong Shengli Steel Pipe, a major producer of carbon welded 

pipes of rectangular and square cross-section, announced plans to start up a pipe mill with a 

production capacity of 250,000 metric tons of tubes per year.4 In April 2009, Italian-based 

steelmaker Marcegaglia S.p.A. announced plans to construct a $194 million tube mill in Jiangsu, 

China that will manufacture stainless and carbon tubes with an annual production capacity of 

approximately 350,000 metric tons.5 Marcegaglia’s website states that its Jiangsu plant 

produces carbon welded pipes with rectangular and square cross-sections with a minimum wall 

thickness of 1.5 millimeters to 16 millimeters.6 In March 2010, Japanese-based steelmaker JFE 

Steel bought a 24 percent share in Pancheng Yihong Pipe Co., a LWR pipe and tube producer 

based in Chengdu, China.7 In 2010, Anshan Iron and Steel Group, a Chinese producer of mostly 

flat-rolled steel, merged with Pangang Group Steel Vanadium and Titanium Co. Ltd., a Chinese 

4 “Shandong Shengli to start up 250,000 tpy pipe mill in Oct,” Metal Bulletin, September 9, 2008, 

found at http://www.metalbulletin.com/Article/2007964/Search/Shandong-Shengli-to-start-up-250000-

tpy-pipe-mill-in-Oct.html?PageId=196010&Keywords=shandong+shengli&OrderType=1, accessed on 

February 27, 2014. 5 Preston Pipe and Tube Report, Volume 27, No. 4, April 2009, page 13. 

6 Marcegaglia Steel’s website, “Marcegaglia China Yangzhou Plant” 

http://www.marcegaglia.com/pdf/stabilimenti/MMYangzhou_EN__slide.pdf, accessed February 27, 

2014. 7 “JFE buys 24% of Pancheng Yihong Pipe,” Metal Bulletin, March 5, 2010, 

http://www.metalbulletin.com/Article/2406022/Search/JFE-buys-24-of-Pancheng-YihongPipe.html?PageId=196010&Keywords=Pangang+Group&OrderType=1, accessed on February 27, 2014. 

IV-7

 
producer of LWR pipe and tube.8 As a result of the merger, Anshan Iron and Steel Group 

became the third largest steel company in China.9 In July 2010, Tangshen Zhengyuan Steel Pipe 

Co. Ltd., a Chinese LWR pipe producer, finished construction of a new pipe mill in China capable 

of producing galvanized tubes with a total annual production capacity of 1.5 million tons of 

tubes by 2013.10

THE INDUSTRY IN KOREA

Operations on LWR pipe and tube

The Commission received no responses from Korean producers in the final phase of the 

original investigations; however, in the preliminary phase of the original investigations, six 

Korean producers provided the Commission with completed foreign producer questionnaire 

responses. In these reviews, the Commission received no responses from producers of LWR 

pipe and tube from Korea.

GTA statistics for exports of LWR pipe and tube from Korea HS subheading 730661 are 

presented in table IV-5. These statistics are somewhat overstated as they may contain products 

outside the scope of the orders, including other hollow profiles of rectangular and square cross 

sections, and other alloy LWR pipe and tubes having a wall thickness greater than four

millimeters.

Between 2008 and 2013, Korea exported LWR pipe and tube to over 60 countries. In 

2013, the top five export destinations for Korean LWR pipe and tube by quantity were the 

United States (51.2 percent of total Korean total exports), Mexico (12.3 percent), Japan (11.4 

percent), United Arab Emirates (6.4 percent) and Saudi Arabia (5.3 percent). Korea was a net 

exporter of LWR pipe and tube from 2008 to 2013, as indicated in table IV-6. Korea’s net 

exports of LWR pipe and tube dropped from 2008 to 2009, spiked from 2010 to 2011, and have 

been relatively steady since.

8 “Angang gets approval for merger with Pansteel,” Steel Guru, May 26, 2010, found at 

http://www.steelguru.com/chinese_news/Angang_gets_approval_for_merger_with_Pansteel/147387.h

tml, retrieved on February 27, 2014. 

9 “Ansteel to bring Pangang under its umbrella,” China Daily, May 25, 2010, found at 

http://www.chinadaily.com.cn/bizchina/2010-05/25/content_9888794.htm, retrieved on February 27, 

2014. 

10 Preston Pipe and Tube Report, Volume 28, No. 6, July 2010, page 19. 

IV-8

 
Table IV-5

LWR Pipe and Tube: Korea’s reported exports by quantity and value, 2008-2013 

Country Quantity (short tons) 

2008 2009 2010 2011 2012 2013

United States 31,093 8,242 34,129 58,295 55,535 59,780

Mexico 662 0 4,028 11,107 16,744 14,429

Japan 5,835 5,640 7,457 8,696 6,975 13,317

United Arab 

Emirates 2,571 7,819 4,779 4,363 7,659 7,497

Saudi Arabia 2,328 788 915 1,891 409 6,232

Australia 16,768 11,047 15,231 10,738 8,731 4,475

Taiwan 2,020 2,037 1,436 2,387 2,870 3,378

Singapore 785 520 888 1,218 1,116 2,565

Philippines 389 495 1,506 1,076 2,502 1,718

Colombia 0 0 0 0 980 834

All Others 10,585 17,338 9,160 2,950 2,412 2,508

 Total 73,038 53,924 79,528 102,721 105,931 116,733

Value (1,000 dollars) 

United States 29,067 5,714 21,159 42,159 37,534 36,412

United Arab 

Emirates 2,440 4,269 2,873 3,328 10,319 9,598

Mexico 412 0 2,391 7,216 10,597 8,998

Japan 5,497 4,394 6,105 7,803 6,008 8,766

Saudi Arabia 2,259 774 648 1,419 560 4,268

Australia 16,677 7,264 11,145 9,068 7,141 3,612

Taiwan 2,128 1,109 958 1,886 2,039 2,206

Singapore 851 297 614 923 844 1,650

Philippines 374 380 1,434 939 2,061 1,349

Colombia 0 0 0 0 809 594

All Others 9,929 11,127 8,429 4,746 3,211 2,057

 Total 69,634 35,329 55,755 79,487 81,124 79,510

Note - Original quantity data were published in kilograms, which were converted to short tons by 

multiplying by 0.00110231. Because of rounding, figures may not add to the totals shown. 

Source: Compiled from Global Trade Atlas, HS 730661 (Tubes, pipes and hollow profiles, of iron or 

steel, welded, of a square or rectangular cross-section) 

IV-9
Table IV-6

LWR pipe and tube: Korea’s reported net exports, 2008-2013

Quantity (short tons)

2008 2009 2010 2011 2012 2013

Exports 73,038 53,924 79,528 102,721 105,931 116,733

Imports 17,258 14,791 33,509 36,246 39,719 48,207

Net exports1 55,780 39,133 46,018 66,475 66,212 68,526

1 Exports minus imports 

Note - Original quantity data were published in kilograms, which were converted to short tons by 

multiplying by 0.00110231. Because of rounding, figures may not add to the totals shown.

Source: Compiled from Global Trade Atlas, HS 730661 (Tubes, pipes and hollow profiles, of iron or 

steel, welded, of a square or rectangular cross-section)

According to Simdex, there are approximately nine known manufacturers of LWR pipe 

and tube in Korea including Ahshin Pipe and Tube, Bookook Steel, Dongbu Steel, Histeel, 

Husteel, Hyundai HYSCO, Miju Steel MFG, Nexteel, and SeAH Steel.11 Dongbu Steel is one of the 

three major integrated steel makers in Korea.

12 In 2009, Dongbu Steel started operation of a 

new integrated hot rolling mill and expanded annual capacity to 10 million metric tons of rolled 

steel products per year.13 In 2012, Miju Steel had to undergo a corporate restructuring due to 

bankruptcy. In 2013, Korean steel companies including HiSteel, Aju Besteel and Pipe Line Co. 

and other foreign steel companies placed bids on Miju Steel for a potential acquisition.14

11 Simdex Steel Tube Manufacturers Worldwide Guide, 2013. 12 Dongbu Steel website, “Dongbu Steel Brochure,” found at 

www.edongbusteel.com/download/dongbusteel_brochure_englsih.pdf, retrieved on February 27, 2014. 13 “Dongbu Steel and Bao Steel Sign Strategic Alliance,” Japan Metal Bulletin, January 22, 2010, found 

at http://www.japanmetalbulletin.com/?p=6065, retrieved on February 27, 2014. 14 “Market Insight: Kabul and SM Group Facing off over Miju Steel,” Korean Economic Daily, February 

6, 2013, found at 

http://english.hankyung.com/news/apps/news.view?nkey=201302062248341&setct=print&popup=1, 

retrieved on February 27, 2014. 

IV-10

 
THE INDUSTRY IN MEXICO

Overview

In the original investigations, eight Mexican producers provided the Commission with 

information on their LWR pipe and tube operations: Arco Metal S.A. de C.V. (“Arco”); Hysla, S.A. 

de C.V. (“Hysla”); 15 Industrias Monterrey S.A. de C.V. (“IMSA”);16 Maquilacero, S.A. de C.V. 

(“Maquilacero”); Nacional de Acero S.A. de C.V. (“Nacional de Acero”); Perfiles y Herrajes LM 

S.A. de C.V. (“Perfiles y Herrajes”); Productos Laminados de Monterrey, S.A. de C.V. 

(“Prolamsa”); and Regiopytsa.

In their responses to the Commission’s notice of institution in the current reviews, 

counsel on behalf of Mexican producers Maquilacero and Regiopytsa identified eight producers 

of LWR pipe and tube in Mexico that export or that have exported LWR pipe and tube to the 

United States or elsewhere since 2008.17 In these reviews, the Commission received seven

responses from producers of LWR pipe and tube from Mexico, which are believed to account 

for the vast majority of LWR pipe and tube production in 2013.18

Operations on LWR pipe and tube

Table IV-7 presents data concerning capacity, production, shipments, and inventories 

for producers of LWR pipe and tube from Mexico. As detailed in table IV-7, Mexican producers 

reported both increased capacity and production of LWR pipe and tube between 2008 and 

2013. A number of Mexican firms reported changes to their operations with implications for 

capacity and production of LWR pipe and tube: ***. Home market sales in Mexico consistently 

accounted for the majority of Mexican producers’ shipments of LWR pipe and tube. The United 

States was the second largest market for Mexican-produced LWR pipe and tube, although it 

accounted for a decreasing share of total shipments between 2008 and 2013.

15 As noted in Part I, Commerce determined that Ternium is the susccessor-in-interest to Hysla. Final 

Results of Antidumping Duty Changed Circumstances Review: Light-Walled Rectangular Pipe and Tube 

from Mexico, 74 FR 41680, August 18, 2009.

16 Ternium purchased IMSA in 2007. “Ternium to take control of Mexico’s IMSA” 

http://www.reuters.com/article/2007/04/30/imsa-ternium-idUSN3019023020070430, retrieved 

February 25, 2014. 17 Counsel on behalf of the domestic interested parties identified the same eight producers as well as 

three others: Tuberia Nacional S.A. de C.V.; Tuberia Procarsa, SA de CV; and Pytco S.A. de C.V. 18 As noted earlier, Mexican producer Prolamsa is related to U.S. producer Prolamsa Laredo, while 

four of the six responding producers in Mexico also act as importers of record. 

IV-11

 
Table IV-7

LWR pipe and tube: Mexican capacity, production, shipments, and inventories, 2008-2013

* * * * * * *

The Commission requested that producers in Mexico report any changes in the 

character of operations relating to the production of LWR pipe and tube since January 1, 2008. 

These responses are provided in table IV-8.

Table IV-8

LWR pipe and tube: Changes in the character of operations since January 1, 2008

* * * * * * *

Six of the seven responding Mexican firms reported using the same equipment and/or 

employees to produce products other than LWR pipe and tube, including: circular mechanical 

tubing, other light-walled products, and heavy-walled products. These firms reported producing 

*** LWR pipe and tube and non-LWR pipe and tube products using the same equipment and/or 

employees during 2008-13. Mexican firms were asked to provide the percentage of their firm’s 

total sales in the most recent fiscal year that were represented by sales of LWR pipe and tube. 

These responses are provided in table IV-9.

Table IV-9

LWR pipe and tube: Share of Mexican firm’s total sales represented by LWR pipe and tube

* * * * * * *

Mexican firms were also asked to report constraints in the manufacturing process for 

LWR pipe and tube. Constraints reported by these firms included: the availability of raw 

materials, the number of production lines and size of plants and warehouses, product mix, and 

limitations or restrictions on equipment. Firms identified Central America (***) and South 

America (***) as export markets (other than the United States) where their firm has developed 

or increased sales of LWR pipe and tube since 2008.19 

Mexican firms were asked to describe the significance of the existing antidumping duty 

orders on imports of LWR pipe and tube from Mexico in terms of its effect on their firm’s 

production capacity, production, home market shipments, exports to the United States and

other markets, and inventories. These responses are provided in table IV-10.

19 No responding Mexican firms indicated that their exports of LWR pipe and tube were subject to 

tariff or non-tariff barriers to trade in any countries other than the United States.

IV-12

 
Table IV-10

LWR pipe and tube: Significance of antidumping order on LWR pipe and tube from Mexico

* * * * * * *

Mexican firms were asked whether they would anticipate any changes in their

production capacity, production, home market shipments, exports to the United States and 

other markets, and inventories if the antidumping duty orders on LWR pipe and tube from 

Mexico were to be revoked. *** indicated that ***.

THE INDUSTRY IN TURKEY

Overview

In the original investigations, the Commission received completed questionnaire

responses from seven producers in Turkey, including Cinar Boru Profil San Tic A.S. (“Cinar 

Boru”), Guven Boru ve Panfil Sanayi ve Ticovet Ltd. Std. (“Guven”), MMZ Onur Boru Profil 

Uretim Sanve Tic A.S. (“MMZ”), Noksel Celik Boru Sanyi A.S. (“Noksel”), Ozborsan Boru San ve 

Tic A.S. (“Ozborsan”), Ozdemir Boru Profil San ve Tic Ltd. Std. (“Ozdemir”), and Tosçelik Profil ve 

Sac Endustrisi A.S. (“Tosçelik”).

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

Government of Turkey identified ten producers of LWR pipe and tube in Turkey that export or 

that have exported LWR pipe and tube to the United States or elsewhere between 2008 and 

2012. In these reviews, the Commission received two responses from producers of LWR pipe 

and tube from Turkey.20

Operations on LWR pipe and tube

Table IV-11 presents data concerning capacity, production, shipments, and inventories 

for producers of LWR pipe and tube from Turkey. As detailed in table IV-11, responding Turkish

producers reported increases in capacity and production over the period. With the exception of 

2008, home market shipments accounted for the largest share of total shipments for Turkish 

producers with the European Union accounting for its largest export market.

Table IV-11

Turkish capacity, production, shipments, and inventories, 2008-2013

* * * * * * *

20 One Turkish producer *** in the United States.

IV-13

 
The Commission requested that producers in Turkey report any changes in the character 

of operations relating to the production of LWR pipe and tube since January 1, 2008. ***. ***. 

Turkish firms reported producing *** LWR pipe and tube and non-LWR pipe and tube 

products using the same equipment and/or employees during 2008-2013.21 *** indicated that 

*** percent of its total shares in its most recent fiscal year were represented by sales of LWR 

pipe and tube, while *** indicated that *** percent of its total shares in its most recent fiscal 

year were represented by sales of LWR pipe and tube. 

Turkish firms reported that constraints in the manufacturing process for LWR pipe and

tube primarily involve constraints based on product mix, maintenance and change-over times, 

as well as limitations on storage space. Turkish firms identified European Union countries as 

those export markets (other than the United States) where they have developed or increased 

sales of LWR pipe and tube since 2008.22 

Turkish firms where asked to describe the significance of the existing antidumping duty 

orders on imports of LWR pipe and tube from Turkey in terms of its effect on their firm’s 

production capacity, production, home market shipments, exports to the United States and 

other markets, and inventories and to describe the anticipated changes if the order were 

revoked. Noksel reported that ***. The firm added that it ***. 

GLOBAL MARKET

Global Exports

Global export data on iron and steel welded tubes, pipes and hollow profiles with 

rectangular or square cross sections as indicated under Harmonized System (HS) subheading 

730661 is presented in table IV-12. This product category includes products outside the scope 

of the orders, including other hollow profiles of rectangular and square cross sections, and 

other LWR pipe and tubes having a wall thickness greater than 4 millimeters. However, HS 

730661 does encompass the two HTS statistical reporting numbers defined under Commerce’s 

scope: HTS 7306.61.50.00 (other tubes, pipes and hollow profiles made of iron and steel having 

a rectangular and square cross sections and a wall thickness of less than 4 millimeters) and HTS 

7306.61.70.60 (other tubes, pipes and hollow profiles of made of other alloy steel, other than 

stainless steel, having rectangular or square cross sections). Global exports of HS 730661 

dropped from 2008 to 2009, but steadily increased from 2009 to 2012. Exports under HS 

730661 totaled approximately 6.23 million short tons in 2012. The leading exporting countries 

for HS 730661 by quantity were Italy (17.8 percent of global exports), China (12.5 percent), 

Turkey (10.7 percent), Mexico (10.6 percent) and Canada (3.2 percent).

21 During 2008-13, Turkish firms produced *** short tons of LWR pipe and tube and *** short tons of 

products other than LWR pipe and tube (primarily ***), using the same equipment and/or employees. 22 ***.

IV-14

 
Table IV-12

Global export data for tubes, pipes and hollow profiles of iron or steel, welded and of a square of 

rectangular cross section (HS 730661) for 2008-12 

Calendar Year 

Country 2008 2009 2010 2011 2012

Quantity (short tons)

Italy 794,065 765,329 902,849 957,664 1,110,281

China 375,533 378,155 657,090 762,604 784,374

Turkey 0 427,775 537,946 565,508 670,946

Canada 340,015 194,181 208,112 226,564 204,098

Mexico 281,096 74,525 100,055 125,036 666,385

United States 169,570 149,792 173,264 204,696 237,154

Austria 261,163 157,180 208,770 211,871 192,248

United Kingdom 230,518 130,074 161,177 203,908 187,051

Netherlands 193,622 148,017 185,919 202,541 128,897

Germany 196,323 135,848 159,306 174,337 152,274

All other countries 1,608,742 1,196,690 1,533,142 1,922,288 1,901,051

Total 4,450,647 3,757,567 4,827,629 5,557,017 6,234,758

Note – No trade data is available for Turkey in 2008, and for Italy, Turkey, Mexico, Austria, United 

Kingdom, Netherlands, and Germany in 2013 under HTS subheading 730661. Complete trade data is 

unavailable for 2013. 

Source: Global Trade Atlas, retrieved on February 12, 2014. 

Canada

As shown in table IV-13, there are several LWR pipe and tube producers in Canada that 

manufacture the subject merchandise in conjunction with other tubular products. Some 

Canadian producers of LWR pipe and tube are owned by non-Canadian parent companies. Atlas 

Tube Inc. of Canada is a division of JMC Steel Group, a steel company based in Chicago, Illinois 

that is owned by the Carlyle Group, a U.S private equity firm.23 ArcelorMittal, based in 

Luxembourg, is the parent company to ArcelorMittal Dofasco Tubular Products.24 Bull Moose 

23 JMC Steel Group website, http://www.jmcsteelgroup.com/, retrieved on February 18, 2014. 24 ArcelorMittal Dofasco Tubular Products’ website, http://www.dofascotube.com, retrieved on 

February 18, 2014.

IV-15

 
Tube Ltd. (Canada) is owned by Bull Moose Tube Company, a U.S. steel company based in 

Chesterfield, Missouri.25

In 2012, Nova Steel Inc. upgraded its Montreal tube mill with two new standard and 

structural lines valued at a combined $12.1 million (US). Nova Steel Inc. stated that its Montreal 

mill will produce square hollow structural sections, and is expected to open in the fall of 2013.26

In August 2012, Welded Tube of Canada announced that it will close its Berkeley, West Virginia 

facility that currently produces standard pipe due to slow market conditions. Welded Tube of 

Canada stated that its customers will be serviced from its Toronto, Canada facility.27

Table IV-13

LWR pipe and tube: Locations, capacity, and product standards of production facilities in Canada 

Firm

Production

Location

Capacity 

(short tons) Product Standards

ArcelorMittal Dofasco 

Tubular Products 

Hamilton, Ontario;

Brampton, Ontario; 

Mississauga, Ontario (

1

) ASTM A500; ASTM A513

Atlantic Tube and Steel 

Inc. Mississauga, Ontario (

1

) ASTM A500; ASTM A513

Atlas Tube Inc. (Canada) Harrow, Ontario 849,882 ASTM 500

Bolton Steel Tube Co. 

Ltd. 

Bolton, Ontario; Mississauga, 

Ontario (

1

)

ASTM A500; ASTM A501; 

ASTM A513

Bull Moose Tube Ltd. 

(Canada) Burlington, Ontario (

1

) ASTM A500; ASTM A513

Delhi-Solac 

Delhi, Ontario;

St. Jerome, Quebec (

1

) ASTM A513

Nova Steel Inc. 

Baie d’Urfe, Quebec; Lasalle, 

Quebec 80,468 (

1

)

Welded Tube of Canada 

Ltd. Concord, Ontario (

1

) ASTM A500; ASTM A-513

Note.--Capacity may be overstated because LWR pipe and tube is only one among the many products 

manufactured by the companies. Capacity figures were denoted in metric tons, and converted to short 

tons by multiplying by 1.102311.

Note.--Bull Moose Tube Ltd., Nova Steel Inc., Atlas Tube Inc., and ArcelorMittal also have manufacturing 

facilities in the United States. 

1 Not available. 

Source: Companies’ internet sites and the Simdex Steel Manufacturers Worldwide Guide, 2013. 

25 Bull Moose Tube Company website, http://www.bullmoosetube.com/, retrieved on February 18, 

2014.

26 Preston Pipe and Tube Monthly, Vol. 30, No. 5, May 2012. 27 Preston Pipe and Tube Monthly, Vol. 30, No. 8, August 2012. 

IV-16

 
Italy

The only known producer of LWR pipe and tube in Italy is Marcegaglia Group based in 

Gazoldo Ippoliti, Italy. Marcegaglia Group consists of three divisions in Italy producing LWR pipe 

and tube, including Lombarda Tubi, Marcegaglia Stainless Division, and Marcegaglia Tube 

Division. The production facilities for these three divisions are located in Boltiere and Lomagna, 

Italy. The Marcegaglia Group’s annual capacity for carbon steel welded tubes is 3 million tons 

per year across its 150 global manufacturing plants.28

Prices

Firms were asked to compare prices of LWR pipe and tube in U.S. and foreign markets.

Most U.S. producers reported that they do not have knowledge of prices in other markets. Two 

U.S. producers reported that prices are generally higher in the United States and one reported 

that U.S. market prices are similar to other market prices. Among importers, two reported that 

prices in the U.S. and Mexican markets were similar, one reported that U.S. prices were higher 

than those in Mexico, and one reported that since 2008, U.S. prices have been about 2 percent 

lower than those in the Mexican market. Among foreign producers, one firm noted that there is 

a global price for LWR pipe and tube while others reported that prices vary among markets 

because of product availability, currency rates, prices and availability of raw materials, and 

freight prices. One Mexican producer reported that it tends to charge lower prices in its home 

market than in other markets because of shipping costs and because its export market 

customers have higher standards regarding product presentation. 

Foreign demand

Firms’ responses regarding LWR pipe and tube demand outside the United States since

2008 and anticipated future demand are summarized in table IV-14. Most U.S. producers, 

importers, and purchasers reported that demand did not change or fluctuated.29 Most foreign 

producers reported that demand outside the United States and in their home markets has 

increased or fluctuated since 2008, and indicated that they expect these trends to continue. No 

firms reported that they expect demand to decline in foreign markets. 

28 Marcegaglia Group’s website, http://www.tubes.marcegaglia.com/marcegaglia_product/carbonsteel-welded-tubes/, retrieved on February 18, 2014. According to the company’ website, Marcegaglia 

Group also has a production facility in Munhall, Pennsylvania that produces carbon steel welded tubing 

in square and rectangular cross-sections.

29 Most of these firms do not participate in foreign markets and therefore are likely to have limited 

knowledge of these markets.

IV-17

 
Most Mexican producers anticipate increased demand in the home market. One noted 

that housing construction in Mexico avoided the financial problems that affected the United 

States and Europe. *** reported that Turkey’s growth rate has increased over the last few 

years.

Table IV-14

LWR pipe and tube: Firms’ responses regarding demand outside of the United States

Item

Number of firms reporting

Increase No change Decrease Fluctuate

Demand outside the United States since 2008:

 U.S. producers 0 3 1 6

Importers 3 1 0 4

Purchasers 0 5 2 0

Foreign producers 4 1 0 2

Demand in home market since 2008:

 Foreign producers 6 1 0 1

Anticipated demand outside the United States:

 U.S. producers 2 1 0 7

Importers 4 1 0 3

Purchasers 2 5 0 3

Foreign producers 6 1 0 0

Anticipated demand in home market:

 Foreign producers 6 1 0 1

Source: Compiled from data submitted in response to Commission questionnaires.

IV-18
V‐1

PART V: PRICING DATA

FACTORS AFFECTING PRICES

Raw material costs

Raw materials account for a major share of the cost of producing LWR pipe and tube.

During 2008‐13, raw material costs accounted for 79 to 84 percent of U.S. producers’ cost of

goods sold. Hot‐rolled sheet is the main raw material used in LWR pipe and tube production. It

is used in the production of black LWR pipe and tube, which accounts for most of U.S. LWR pipe

and tube production (about 85 percent in 2013) as well as in some corrosion resistant LWR pipe

and tube production.

Hot‐rolled and cold‐rolled sheet are raw material inputs for black LWR pipe and tube

and galvanized LWR pipe and tube that is made corrosion‐resistant through a zinc bath. Hot‐

dipped galvanized sheet is the raw material input for those producers that produce corrosion

resistant LWR pipe and tube with pre‐galvanized materials. Zinc is an important additional raw

material input for those producers that produce galvanized LWR pipe and tube through the

zinc‐dipping process. Prices for these raw materials fluctuated over the review period, with a

large decline in 2008 and 2009 and then subsequent recovery in 2010 (figure V‐1).  

Twelve of 18 U.S. producers expect changes in raw materials prices, with several firms

expecting increases over the next year. One producer noted that all U.S. flat rolled producers

increased prices in fourth quarter 2013. ***.

Transportation costs to the U.S. market

Transportation costs for LWR pipe and tube shipped from subject countries to the

United States were 1.3 percent for China, 6.8 percent for Korea, 3.5 percent for Mexico, and

11.9 percent for Turkey. These estimates are derived from official import data and represent

the transportation and other charges on imports. 1

                                                      

1 The estimated transportation costs were obtained by subtracting the customs value from the c.i.f.

value of the imports for 2012 and then dividing by the customs value based on the HTS subheading

7306.61.50. Korea data are based on 2010 import data. Transportation costs for all years combined

during the period of review were as follows:  8.7 percent for China, 8.9 percent for Korea, 3.1 percent

for Mexico, and 12.1 percent for Turkey.
V‐2

Figure V-1 

Raw materials: Monthly average prices, 2008-2013 

Source: American Metal Market, retrieved February 25, 2014.
V‐3

Six importers reported that they arranged international transportation to the customer

while five reported that the exporter arranged such transportation. Among foreign producers,

with respect to Mexico, 5 of 6 firms reported that the exporter arranged transportation, and

with respect to Turkey, 2 of 3 firms reported that the importer arranged transportation. Six

foreign producers reported the cost of shipping to the United States in 2013: four reported that

the cost from Mexico was $20 to $25 per short ton and one reported $100 per short ton, and

one firm reported that the cost from Turkey was *** per short ton. Four importers reported

that transportation costs from Mexico were $19 to $25 per short ton, and one reported that

such costs were $55 per short ton.2

  

U.S. inland transportation costs

Most responding U.S. producers (15 of 19) and importers (10 of 12) reported that they

typically arrange transportation to their customers. Most U.S. producers reported that their

U.S. inland transportation costs ranged from 1 to 5 percent while most importers reported

costs of 3 to 6 percent.3

PRICING PRACTICES

Pricing methods

U.S. producers and importers sell primarily on a transaction‐by‐transaction basis,

although many firms also use price lists (table V‐1). U.S. producers and importers reported

selling most of their LWR pipe and tube in the spot market (table V‐2).

Eight of 22 purchasers reported that they purchase product daily, 10 purchase weekly, 3

purchase monthly, and one purchases quarterly. All but one responding purchaser reported

that they did not expect their purchasing patterns to change in the next two years. Most

purchasers contact 1 to 5 suppliers before making a purchase.

                                                      

2 The average unit value of LWR pipe and tube imports from Mexico in 2013 was $810 per short ton

(landed duty‐paid value); transportation costs of $19 to $100 per short ton equate to 2.3 to 12.3 percent

of the landed duty‐paid value. The average unit value of LWR pipe and tube imports from Turkey in 2013

was $874 per short ton (landed duty‐paid value); transportation costs of $*** equate to ***percent of

the landed duty‐paid value.

3 Twelve producers reported costs ranging from 1 to 5 percent and four reported 6 to 10 percent.

Five importers reported costs ranging from 3 to 6 percent and two reported 8 to 10 percent.
V‐4

Table V-1 

LWR pipe and tube: U.S. producers and importers reported price setting methods, by number of 

responding firms1

Method U.S. producers U.S. importers 

Transaction-by-transaction 16 10

Contract 7 3

Set price list 12 5

Other 2 1

 1 The sum of responses down may not add up to the total number of responding firms as each firm was 

instructed to check all applicable price setting methods employed.

Source: Compiled from data submitted in response to Commission questionnaires. 

Table V-2 

LWR pipe and tube: 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 

Mexico Turkey 

Long-term contracts 0.3 0.0 *** 

Short-term contracts 13.9 8.9 *** 

Spot sales 85.8 91.1 *** 

 Source: Compiled from data submitted in response to Commission questionnaires.

Sales terms and discounts

U.S. producers reported quoting prices on both an f.o.b. and on a delivered basis, while

all but one importer reported quoting delivered prices. More than half of producers offer

quantity discounts and/or total volume discounts. Although most importers (8 of 13) do not

offer discounts, five reported that they offer quantity, total volume, or prompt payment

discounts. Producers and importers reported sales terms of net 30 days with more than half of

producers and several importers giving a discount (typically one‐half of one percent) for

payment within 10 days.  

Price leadership

The following firms were named as price leaders by at least three purchasers: Atlas Tube

(10 purchasers), Vest (4), Southland (4), and Bull Moose (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 LWR pipe and tube products shipped to

unrelated U.S. customers during 2008‐13.
V‐5

Product 1.‐‐ ASTM A‐513 (mechanical) or A‐500 grade A or B (ornamental), carbon

welded, not pickled and oiled, 2 inch square, 0.120 inch (+ or ‐10 percent) wall

thickness (11 gauge), 20 foot or 24 foot lengths.

Product 2.‐‐ ASTM A‐513 (mechanical) or A‐500 grade A or B (ornamental) tubing,

carbon welded, pickled and oiled, 1 inch square, 0.065 inch nominal wall

thickness (+ or ‐10 percent) (16 gauge), 20 foot or 24 foot mill lengths.

Product 3.‐‐ ASTM A‐513 (mechanical) or A‐500 grade A or B (ornamental), hot‐rolled,

not pickled and oiled, 11 gauge or 0.120 inch +/‐ 10% wall, three inch square to

four inches square, or in rectangular circumferences of 12 inches to 16 inches,

lengths of 20 to 24 feet.

Product 4.‐‐ ASTM A‐513 (mechanical) or A‐500 grade A or B (ornamental) tubing,

galvanized, 2.5 inch square, 0.083 nominal wall thickness (+ or – 10 percent) (14

gauge), lengths of 20 to 24 feet.

Sixteen U.S. producers, 4 importers of LWR pipe and tube from Mexico, and 2 importers

of LWR pipe and tube from Turkey provided usable pricing data for sales of the requested

products, although not all firms reported pricing data for all products for all quarters. Pricing

data reported by these firms accounted for *** percent of U.S. producers’ commercial

shipments of LWR pipe and tube, *** percent of U.S. commercial shipments of subject imports

from Mexico, and *** percent of U.S. commercial shipments of subject imports from Turkey

during 2008‐13. Price data for products 1‐4 are presented in tables V‐3 to V‐6 and figure V‐2.  
V‐6

Table V-3 

LWR pipe and tube: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 11

 and margins of underselling/(overselling), by quarters, 2008-2013 

Period 

United States Mexico Turkey 

 Price 

(dollars per 

short ton) 

Quantity 

(short tons) 

 Price 

(dollars per 

short ton) 

Quantity 

(short tons)

Margin 

(percent) 

 Price 

(dollars per 

short ton) 

Quantity 

(short tons) 

Margin 

(percent) 

2008:

 Jan.-Mar. 851 8,618 *** *** *** *** *** ***

 Apr.-Jun. 1,159 7,665 *** *** *** *** *** ***

 Jul.-Sep. 1,361 5,238 *** *** *** *** *** ***

 Oct.-Dec. 1,085 4,377 *** *** *** *** *** ***

2009:

 Jan.-Mar. 781 5,232 *** *** *** *** *** ***

 Apr.-Jun. 659 6,397 *** *** *** *** *** ***

 Jul.-Sep. 703 7,419 *** *** *** *** *** ***

 Oct.-Dec. 738 5,873 *** *** *** *** *** ***

2010:

 Jan.-Mar. 788 7,445 *** *** *** *** *** ***

 Apr.-Jun. 884 7,512 *** *** *** *** *** ***

 Jul.-Sep. 862 7,988 *** *** *** *** *** ***

 Oct.-Dec. 862 8,492 *** *** *** *** *** ***

2011:

 Jan.-Mar. 1,007 9,154 *** *** *** *** *** ***

 Apr.-Jun. 1,086 8,020 *** *** *** *** *** ***

 Jul.-Sep. 980 9,177 *** *** *** *** *** ***

 Oct.-Dec. 936 8,911 *** *** *** *** *** ***

2012:

 Jan.-Mar. 980 9,737 *** *** *** *** *** ***

 Apr.-Jun. 947 9,652 *** *** *** *** *** ***

 Jul.-Sep. 901 9,915 *** *** *** *** *** ***

 Oct.-Dec. 885 9,727 *** *** *** *** *** ***

2013:

 Jan.-Mar. 893 10,468 *** *** *** *** *** ***

 Apr.-Jun. 886 10,391 *** *** *** *** *** ***

 Jul.-Sep. 910 10,027 *** *** *** *** *** ***

 Oct.-Dec. 934 10,374 *** *** *** *** *** ***

 1 Product 1: ASTM A-513 (mechanical) or A-500 grade A or B (ornamental), carbon welded, not pickled 

and oiled, 2 inch square, 0.120 inch (+ or -10 percent) wall thickness (11 gauge), 20 foot or 24 foot 

lengths. 

Source: Compiled from data submitted in response to Commission questionnaires. 
V‐7

Table V-4 

LWR pipe and tube: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 21 and margins of underselling/(overselling), by quarters, 2008-2013 

Period 

United States Mexico Turkey 

 Price 

(dollars per 

short ton) 

Quantity 

(short tons) 

 Price 

(dollars per 

short ton) 

Quantity 

(short tons)

Margin 

(percent) 

 Price 

(dollars per 

short ton) 

Quantity 

(short tons) 

Margin 

(percent) 

2008:

 Jan.-Mar. 952 3,814 *** *** *** *** *** ***

 Apr.-Jun. 1,277 3,462 *** *** *** *** *** ***

 Jul.-Sep. 1,548 2,480 *** *** *** *** *** ***

 Oct.-Dec. 1,285 1,705 *** *** *** *** *** ***

2009:

 Jan.-Mar. 1,002 1,712 *** *** *** *** *** ***

 Apr.-Jun. 800 2,551 *** *** *** *** *** ***

 Jul.-Sep. 806 2,720 *** *** *** *** *** ***

 Oct.-Dec. 848 1,980 *** *** *** *** *** ***

2010:

 Jan.-Mar. 912 2,459 *** *** *** *** *** ***

 Apr.-Jun. 1,017 2,712 *** *** *** *** *** ***

 Jul.-Sep. 1,010 2,605 *** *** *** *** *** ***

 Oct.-Dec. 1,001 2,266 *** *** *** *** *** ***

2011:

 Jan.-Mar. 1,160 2,521 *** *** *** *** *** ***

 Apr.-Jun. 1,231 2,249 *** *** *** *** *** ***

 Jul.-Sep. 1,177 2,325 *** *** *** *** *** ***

 Oct.-Dec. 1,124 1,880 *** *** *** *** *** ***

2012:

 Jan.-Mar. 1,135 2,508 *** *** *** *** *** ***

 Apr.-Jun. 1,112 2,422 *** *** *** *** *** ***

 Jul.-Sep. 1,047 2,258 *** *** *** *** *** ***

 Oct.-Dec. 1,020 2,057 *** *** *** *** *** ***

2013:

 Jan.-Mar. 1,013 2,455 *** *** *** *** *** ***

 Apr.-Jun. 995 2,916 *** *** *** *** *** ***

 Jul.-Sep. 1,005 2,836 *** *** *** *** *** ***

 Oct.-Dec. 1,001 2,395 *** *** *** *** *** ***

 1 Product 2: ASTM A-513 (mechanical) or A-500 grade A or B (ornamental) tubing, carbon welded, 

pickled and oiled, 1 inch square, 0.065 inch nominal wall thickness (+ or -10 percent) (16 gauge), 20 foot 

or 24 foot mill lengths. 

Source: Compiled from data submitted in response to Commission questionnaires.
V‐8

Table V-5 

LWR pipe and tube: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 31

 and margins of underselling/(overselling), by quarters, 2008-2013 

Period 

United States Mexico Turkey 

 Price 

(dollars per 

short ton) 

Quantity 

(short tons) 

 Price 

(dollars per 

short ton) 

Quantity 

(short tons)

Margin 

(percent) 

 Price 

(dollars per 

short ton) 

Quantity 

(short tons) 

Margin 

(percent) 

2008:

 Jan.-Mar. 849 7,632 *** *** *** *** *** ***

 Apr.-Jun. 1,165 7,624 *** *** *** *** *** ***

 Jul.-Sep. 1,376 5,186 *** *** *** *** *** ***

 Oct.-Dec. 1,142 2,642 *** *** *** *** *** ***

2009:

 Jan.-Mar. 788 3,938 *** *** *** *** *** ***

 Apr.-Jun. 673 4,736 *** *** *** *** *** ***

 Jul.-Sep. 747 5,136 *** *** *** *** *** ***

 Oct.-Dec. 757 3,764 *** *** *** *** *** ***

2010:

 Jan.-Mar. 807 4,908 *** *** *** *** *** ***

 Apr.-Jun. 900 5,690 *** *** *** *** *** ***

 Jul.-Sep. 866 6,220 *** *** *** *** *** ***

 Oct.-Dec. 819 6,187 *** *** *** *** *** ***

2011:

 Jan.-Mar. 974 7,040 *** *** *** *** *** ***

 Apr.-Jun. 1,106 8,623 *** *** *** *** *** ***

 Jul.-Sep. 973 7,647 *** *** *** *** *** ***

 Oct.-Dec. 965 6,885 *** *** *** *** *** ***

2012:

 Jan.-Mar. 973 8,800 *** *** *** *** *** ***

 Apr.-Jun. 937 7,304 *** *** *** *** *** ***

 Jul.-Sep. 833 7,744 *** *** *** *** *** ***

 Oct.-Dec. 853 6,715 *** *** *** *** *** ***

2013:

 Jan.-Mar. 918 9,789 *** *** *** *** *** ***

 Apr.-Jun. 897 9,767 *** *** *** *** *** ***

 Jul.-Sep. 893 7,754 *** *** *** *** *** ***

 Oct.-Dec. 882 7,380 *** *** *** *** *** ***

 1 Product 3: ASTM A-513 (mechanical) or A-500 grade A or B (ornamental), hot-rolled, not pickled and 

oiled, 11 gauge or 0.120 inch +/- 10% wall, three inch square to four inches square, or in rectangular 

circumferences of 12 inches to 16 inches, lengths of 20 to 24 feet. 

Source: Compiled from data submitted in response to Commission questionnaires.
V‐9

Table V-6 

LWR pipe and tube: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 41

 and margins of underselling/(overselling), by quarters, 2008-2013 

* * * * * * * 

Figure V-2 

LWR pipe and tube: Weighted-average prices and quantities of domestic and imported product, by 

quarters, 2008-2013 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

Price trends

Prices fluctuated during the period of review, with large increases in the first part of

2008 followed by large declines in the second part of 2008 into 2009. Table V‐7 summarizes the

price trends, by country and by product. As shown in the table, domestic prices were 3.9 to

21.3 percent higher in fourth quarter 2013 than first quarter 2008. Prices of imports from

Mexico were 2.1 to 24.9 percent lower in fourth quarter 2013 than in first quarter 2008. Import

prices for Turkey for each of the products 1‐3 were available for only 8 to 14 quarters of the

period of review.  

Table V-7 

LWR pipe and tube: Summary of weighted-average f.o.b. prices for products 1-4 from the United 

States and subject countries 

Item 

Number of 

quarters 

Low price 

(per short ton) 

High price 

(per short ton) 

Change in 

price1

 (percent) 

Product 1 

United States 24 659 1,361 9.8

Mexico 24 *** *** (3.6)

Turkey 8 *** *** ***

Product 2 

United States 24 800 1,548 5.2

Mexico 24 *** *** (8.5)

Turkey 12 *** *** ***

Product 3 

United States 24 673 1,376 3.9

Mexico 24 *** *** (2.1)

Turkey 14 *** *** ***

Product 4 

United States 24 *** *** 21.3

Mexico 11 *** *** (24.9)
V‐10

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.

Note: No price data were reported for China or Korea. 

Source: Compiled from data submitted in response to Commission questionnaires.

Price comparisons

As shown in table V‐8, prices for LWR pipe and tube imported from Mexico were below

those for U.S.‐produced product in 72 of 83 instances; margins of underselling ranged from 0.1

to 26.1 percent. In the remaining 11 instances, prices for LWR pipe and tube from Mexico were

between 0.8 and 44.3 percent above prices for the domestic product. Prices for LWR pipe and

tube imported from Turkey were below those for U.S.‐produced product in 29 of 34 instances;

margins of underselling ranged from 0.3 to 34.0 percent. In the remaining 5 instances, prices for

LWR pipe and tube from Turkey were between 0.5 and 7.2 percent above prices for the

domestic product. Purchasers generally reported that since 2008, prices of U.S. product had

either stayed the same relative to prices of products from subject countries or that U.S. prices

were now relatively higher.

Table V-8 

LWR pipe and tube: Instances of underselling/overselling and the range and average of margins, 

by country, 2008-2013 

Source 

Underselling Overselling 

Number of 

instances 

Range 

(percent) 

Average 

margin 

(percent) 

Number of 

instances 

Range 

(percent) 

Average 

margin 

(percent) 

Mexico 72 0.1 to 26.1 9.2 11 (0.8) to (44.3) (21.2)

Turkey 29 0.3 to 34.0 11.4 5 (0.5) to (7.2) (3.0)

Total 101 0.1 to 34.0 9.8 16 (0.5) to (44.3) (15.5)

 Note: No price data were reported for China or Korea. 

Source: Compiled from data submitted in response to Commission questionnaires.
AͲ1

APPENDIX A

FEDERAL REGISTER NOTICES

AͲ3

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 19647,

April 2, 2013

Initiation of FiveͲYear (“Sunset”)

Review

http://www.gpo.gov/fdsys/pkg/FRͲ

2013Ͳ04Ͳ02/pdf/2013Ͳ07550.pdf

78 FR 19526,

April 1, 2013 LightͲWalled Rectangular Pipe and

Tube From China, Korea, Mexico, and

Turkey; Institution of FiveͲYear

Reviews

http://www.gpo.gov/fdsys/pkg/FRͲ

2013Ͳ04Ͳ01/pdf/2013Ͳ07329.pdf

78 FR 42546, July

16, 2013 LightͲWalled Rectangular Pipe and

Tube From China, Korea, Mexico, and

Turkey: Notice of Commission

Determinations to Conduct Full FiveͲ

Year Reviews

http://www.gpo.gov/fdsys/pkg/FRͲ

2013Ͳ07Ͳ16/pdf/2013Ͳ16873.pdf

78 FR 47671,

August 6, 2013

Final Results of Expedited Sunset

Reviews of Antidumping Duty Orders:

LightͲWalled Rectangular Pipe and

Tube From Mexico, Turkey, the

People’s Republic of China, and the

Republic of Korea

http://www.gpo.gov/fdsys/pkg/FRͲ

2013Ͳ08Ͳ06/pdf/2013Ͳ18973.pdf

78 FR 48416,

August 8, 2013 LightͲWalled Rectangular Pipe and

Tube From the People’s Republic of

China: Final Results of the Expedited

First Sunset Review of the

Countervailing Duty Order

http://www.gpo.gov/fdsys/pkg/FRͲ

2013Ͳ08Ͳ08/pdf/2013Ͳ18969.pdf

Table continued on the next page. 
AͲ4

Citation Title Link

78 FR 74161,

December 10,

2013

LightͲWalled Rectangular Pipe and

Tube From China, Korea, Mexico, and

Turkey; Scheduling of Full FiveͲYear

Reviews Concerning the

Countervailing Duty Order on LightͲ

Walled Rectangular Pipe and Tube

From China and the Antidumping

Duty Orders on LightͲWalled

Rectangular Pipe and Tube From

China, Korea, Mexico, and Turkey

http://www.gpo.gov/fdsys/pkg/FRͲ

2013Ͳ12Ͳ10/pdf/2013Ͳ29379.pdf

Note.–The press release announcing the Commission’s determinations concerning adequacy

and the conduct of a full or expedited review can be found at

http://usitc.gov/press_room/news_release/2012/er0409kk1.htm.A summary of the

Commission’s votes concerning adequacy and the conduct of a full or expedited review can be

found at http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11452.The

Commission’s explanation of its determinations can be found at

http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11453.
B-1

APPENDIX B

LIST OF HEARING WITNESSES

B-3

CALENDAR OF PUBLIC HEARING

Those listed below appeared as witnesses at the United States International Trade Commission’s 

hearing:

Subject: Light-Walled Rectangular Pipe and Tube from China, Korea, 

Mexico, and Turkey 

Inv. Nos.: 701-TA-449 and 731-TA-1118-1121 (Review) 

Date and Time: April 3, 2014 - 9:30 am 

A session was held in connection with these investigations in the Main Hearing Room (room 

101), 500 E Street, SW, Washington, DC. 

OPENING REMARKS:

In Support of Continuation (Roger B. Schagrin, Schagrin Associates) 

In Support of the Continuation of the Antidumping and Countervailing Duty Orders: 

Schagrin Associates 

Washington, DC 

on behalf of 

Bull Moose Tube Company; California Steel & Tube; 

Hannibal Industries; JMC Steel Group; Maruichi American 

Corporation; Searing Industries Tube; Southland Tube; Vest, Inc.; 

and Western Tube & Conduit 

Jack Meyer, Bull Moose Tube Company 

Michael Blatz, President and Chief Executive Officer, Bull Moose Tube Company 

Lee Searing, President and Chief Executive Officer, Searing Industries 

John Montgomery, Jr., Vice President and General Manager, Southland Tube 

Roger B. Schagrin ) – OF COUNSEL 

CLOSING REMARKS:

In Support of Continuation (Roger B. Schagrin, Schagrin Associates) 

CͲ1

APPENDIX C

SUMMARY DATA

Table C-1

LWRPT: Summary data concerning the U.S. market, 2008-13

2008 2009 2010 2011 2012 2013 2008-13 2008-09 2009-10 2010-11 2011-12

U.S. consumption quantity:

Amount...................................................................... 622,369 465,200 532,363 553,036 611,965 674,043 8.3 (25.3) 14.4 3.9 10.7

Producers' share (fn1)............................................... 72.1 75.4 77.3 78.7 78.6 76.8 4.7 3.4 1.9 1.4 (0.1)

Importers' share (fn1):

China...................................................................... 0.1 0.0 0.0 0.1 0.0 0.0 (0.1) (0.1) 0.0 0.0 (0.0)

Korea...................................................................... *** *** *** 0.0 0.0 0.0 *** *** *** *** 0.0

Mexico.................................................................... 18.5 14.7 12.7 11.0 10.6 12.3 (6.2) (3.8) (2.0) (1.7) (0.4)

Turkey.................................................................... 0.0 0.0 0.0 0.1 1.0 0.3 0.3 0.0 (0.0) 0.1 0.9

 Subject Countries................................................ *** *** *** 11.2 11.6 12.6 *** *** *** *** 0.4

All others sources, nonsubject................................ *** *** *** 10.2 9.9 10.6 *** *** *** *** (0.3)

Total imports..................................................... 27.9 24.6 22.7 21.3 21.4 23.2 (4.7) (3.4) (1.9) (1.4) 0.1

U.S. consumption value:

Amount...................................................................... 714,394 378,733 494,233 598,987 625,353 653,960 (8.5) (47.0) 30.5 21.2 4.4

Producers' share (fn1)............................................... 74.3 78.2 79.0 79.8 80.1 78.6 4.4 3.9 0.9 0.8 0.3

Importers' share (fn1):

China...................................................................... 0.1 0.0 0.0 0.1 0.1 0.0 (0.1) (0.1) 0.0 0.0 (0.0)

Korea...................................................................... *** *** *** 0.0 0.0 0.0 *** *** *** *** 0.0

Mexico.................................................................... 16.2 11.8 10.7 9.5 8.8 10.2 (5.9) (4.4) (1.1) (1.2) (0.7)

Turkey.................................................................... 0.0 0.0 0.0 0.1 0.8 0.3 0.3 0.0 (0.0) 0.1 0.7

 Subject Countries................................................ *** *** *** 9.7 9.7 10.5 *** *** *** *** (0.0)

All others sources, nonsubject................................ *** *** *** 10.5 10.2 10.8 *** *** *** *** (0.2)

Total imports..................................................... 25.7 21.8 21.0 20.2 19.9 21.4 (4.4) (3.9) (0.9) (0.8) (0.3)

U.S. Imports from:

China:

Quantity.................................................................. 687 31 109 277 282 126 (81.6) (95.5) 250.4 154.3 1.7

Value...................................................................... 627 74 235 438 350 144 (77.0) (88.2) 219.7 86.3 (20.2)

Unit value................................................................ $912.17 $2,368.82 $2,161.17 $1,582.88 $1,241.84 $1,139.02 24.9 159.7 (8.8) (26.8) (21.5)

Ending inventory quantity........................................ 0 0 0 0 0 0 fn2 fn2 fn2 fn2 fn2

Korea:

Quantity.................................................................. *** *** *** 0 0 0 *** *** *** *** fn2

Value...................................................................... *** *** *** 0 0 0 *** *** *** *** fn2

Unit value................................................................ *** *** *** fn3 fn3 fn3 *** *** *** *** fn2

Ending inventory quantity........................................ *** *** *** 0 0 0 *** *** *** *** fn2

Mexico:

Quantity.................................................................. 115,179 68,311 67,692 60,925 64,684 82,710 (28.2) (40.7) (0.9) (10.0) 6.2

Value...................................................................... 115,638 44,664 52,906 57,051 55,172 66,982 (42.1) (61.4) 18.5 7.8 (3.3)

Unit value................................................................ $1,003.98 $653.84 $781.58 $936.43 $852.95 $809.85 (19.3) (34.9) 19.5 19.8 (8.9)

Ending inventory quantity........................................ 0 0 0 0 0 0 fn2 fn2 fn2 fn2 fn2

Turkey:

Quantity.................................................................. 0 36 0 564 5,920 2,101 fn2 fn2 (100.0) fn2 949.3

Value...................................................................... 0 24 0 507 4,831 1,836 fn2 fn2 (100.0) fn2 852.9

Unit value................................................................ fn3 $649.82 fn3 $898.67 $816.11 $873.56 fn2 fn2 fn2 fn2 (9.2)

Ending inventory quantity........................................ 258 170 66 52 1,711 1,290 400.0 (34.1) (61.2) (21.2) 3,190.4

Subject Countries:

Quantity.................................................................. *** *** *** 61,766 70,885 84,937 *** *** *** *** 14.8

Value...................................................................... *** *** *** 57,997 60,353 68,962 *** *** *** *** 4.1

Unit value................................................................ *** *** *** $938.98 $851.42 $811.91 *** *** *** *** (9.3)

Ending inventory quantity........................................ *** *** *** 52 1,711 1,290 *** *** *** *** 3,190.4

All other sources, nonsubject:

Quantity.................................................................. *** *** *** 56,148 60,298 71,756 *** *** *** *** 7.4

Value...................................................................... *** *** *** 62,823 64,025 70,782 *** *** *** *** 1.9

Unit value................................................................ *** *** *** $1,118.87 $1,061.80 $986.43 *** *** *** *** (5.1)

Ending inventory quantity........................................ *** *** *** 164 197 308 *** *** *** *** 20.1

Total imports:

Quantity.................................................................. 173,888 114,234 120,731 117,914 131,183 156,693 (9.9) (34.3) 5.7 (2.3) 11.3

Value...................................................................... 183,896 82,603 103,553 120,820 124,378 139,744 (24.0) (55.1) 25.4 16.7 2.9

Unit value................................................................ $1,057.56 $723.10 $857.72 $1,024.64 $948.12 $891.83 (15.7) (31.6) 18.6 19.5 (7.5)

Ending inventory quantity........................................ 1,595 170 123 216 1,908 1,598 0.2 (89.3) (27.6) 75.6 783.3

U.S. producers':

Average capacity quantity.......................................... 1,110,314 1,081,371 1,089,411 1,141,536 1,109,604 1,131,083 1.9 (2.6) 0.7 4.8 (2.8)

Production quantity.................................................... 470,375 367,451 448,691 472,564 502,426 540,664 14.9 (21.9) 22.1 5.3 6.3

Capacity utilization (fn1)............................................. 42.4 34.0 41.2 41.4 45.3 47.8 5.4 (8.4) 7.2 0.2 3.9

U.S. shipments:

Quantity.................................................................. 448,481 350,966 411,632 435,122 480,782 517,350 15.4 (21.7) 17.3 5.7 10.5

Value...................................................................... 530,498 296,130 390,680 478,167 500,975 514,216 (3.1) (44.2) 31.9 22.4 4.8

Unit value................................................................ $1,182.88 $843.76 $949.10 $1,098.93 $1,042.00 $993.94 (16.0) (28.7) 12.5 15.8 (5.2)

Export shipments:

Quantity.................................................................. 23,179 15,002 20,591 24,590 29,435 27,266 17.6 (35.3) 37.3 19.4 19.7

Value...................................................................... 27,384 13,352 19,515 26,373 31,185 27,918 2.0 (51.2) 46.2 35.1 18.2

Unit value................................................................ $1,181.41 $890.01 $947.74 $1,072.51 $1,059.45 $1,023.91 (13.3) (24.7) 6.5 13.2 (1.2)

Ending inventory quantity........................................... 68,574 68,290 84,699 97,742 90,177 85,212 24.3 (0.4) 24.0 15.4 (7.7)

Inventories/total shipments (fn1)................................ 14.5 18.7 19.6 21.3 17.7 15.6 1.1 4.1 0.9 1.7 (3.6)

Production workers.................................................... 876 779 800 857 879 976 11.4 (11.1) 2.7 7.1 2.6

Hours worked (1,000s).............................................. 1,923 1,605 1,741 1,931 1,997 2,198 14.3 (16.5) 8.5 10.9 3.4

Wages paid ($1,000)................................................. 62,827 57,173 59,255 63,829 67,032 72,462 15.3 (9.0) 3.6 7.7 5.0

Productivity (short tons per 1,000 hours)................... 244.6 228.9 257.7 244.7 251.6 246.0 0.6 (6.4) 12.6 (5.0) 2.8

Unit labor costs.......................................................... $133.57 $155.59 $132.06 $135.07 $133.42 $134.02 0.3 16.5 (15.1) 2.3 (1.2)

Net Sales:

Quantity.................................................................. 480,053 369,862 426,764 453,226 501,480 546,511 13.8 (23.0) 15.4 6.2 10.6

Value...................................................................... 546,642 321,192 399,436 488,907 516,553 533,566 (2.4) (41.2) 24.4 22.4 5.7

Unit value................................................................ $1,138.71 $868.41 $935.96 $1,078.73 $1,030.06 $976.31 (14.3) (23.7) 7.8 15.3 (4.5)

Cost of goods sold (COGS)....................................... 454,994 305,308 357,052 405,077 444,447 463,763 1.9 (32.9) 16.9 13.5 9.7

Gross profit of (loss).................................................. 91,648 15,884 42,384 83,830 72,106 69,803 (23.8) (82.7) 166.8 97.8 (14.0)

SG&A expenses......................................................... 35,851 23,953 27,305 30,739 33,980 35,714 (0.4) (33.2) 14.0 12.6 10.5

Operating income or (loss)......................................... 55,797 (8,069) 15,079 53,091 38,126 34,089 (38.9) fn2 fn2 252.1 (28.2)

Capital expenditures................................................... 12,320 9,905 13,621 11,846 10,444 8,050 (34.7) (19.6) 37.5 (13.0) (11.8)

Unit COGS................................................................ $947.80 $825.46 $836.65 $893.76 $886.27 $848.59 (10.5) (12.9) 1.4 6.8 (0.8)

Unit SG&A expenses................................................. $74.68 $64.76 $63.98 $67.82 $67.76 $65.35 (12.5) (13.3) (1.2) 6.0 (0.1)

Unit operating income or (loss).................................. $116.23 -$21.82 $35.33 $117.14 $76.03 $62.38 (46.3) fn2 fn2 231.5 (35.1)

COGS/sales (fn1)...................................................... 83.2 95.1 89.4 82.9 86.0 86.9 3.7 11.8 (5.7) (6.5) 3.2

Operating income or (loss)/sales (fn1)....................... 10.2 (2.5) 3.8 10.9 7.4 6.4 (3.8) (12.7) 6.3 7.1 (3.5)

Notes:

fn1.--Report data are in percent and period changes are in percentage points.

fn2.--Undefined. 

fn3.--Not applicable.

C-3

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)

Report data Period changes

Calendar year Comparison periods
D‐1

APPENDIX D

RESPONSES OF U.S. PRODUCERS AND U.S. PURCHASERS

CONCERNING THE ORDERS
 
    D‐3

 

This appendix is confidential in its entirety. All content has been redacted.