U.S. International Trade Commission

Publication 4469 June 2014

Washington, DC 20436

Small Diameter 

Graphite Electrodes from China

Investigation No. 731-TA-1143 (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

Douglas Corkran, Investigator 

Jeffrey Okun-Kozlowicki, Commodity Industry Analyst 

Peter Sultan, Attorney 

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

Washington, DC 20436 

www.usitc.gov

Publication 4469 June 2014

Small Diameter 

Graphite Electrodes from China

Investigation No. 731-TA-1143 (Review)

CONTENTS

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

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

Information obtained in the review.......................................................................................... I-1

Introduction ..................................................................................................................................... I-1

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

The original investigation ......................................................................................................... I-2

Commerce’s reviews ................................................................................................................ I-3

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

The product...................................................................................................................................... I-4

Commerce’s scope.................................................................................................................... I-4

U.S. tariff treatment ................................................................................................................. I-5

Domestic like product and domestic industry.......................................................................... I-5

Description and uses ................................................................................................................ I-6

Interchangeability and customer and producer perceptions .................................................. I-7

Channels of distribution ........................................................................................................... I-8

Pricing and related information ............................................................................................... I-8

The industry in the United States.................................................................................................... I-9

U.S. producers .......................................................................................................................... I-9

U.S. producers’ trade and financial data................................................................................ I-10

U.S. imports and apparent consumption....................................................................................... I-11

U.S. importers......................................................................................................................... I-11

U.S. imports............................................................................................................................ I-11

Apparent U.S. consumption and market shares .................................................................... I-14

The industry in China ..................................................................................................................... I-16

Background............................................................................................................................. I-16

Exports.................................................................................................................................... I-17

Tariff or non-tariff barriers to trade ....................................................................................... I-18

The global market.......................................................................................................................... I-18

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

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

i

UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation No. 731-TA-1143 (Review)

SMALL DIAMETER GRAPHITE ELECTRODES FROM CHINA

DETERMINATION

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

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

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

diameter graphite electrodes from China would be likely to lead to continuation or recurrence 

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

BACKGROUND

The Commission instituted this review on January 2, 2014 (79 F.R. 145) and determined 

on April 7, 2014 that it would conduct an expedited review (79 F.R. 22531, April 22, 2014).

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.

 

Views of the Commission

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

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

on small diameter graphite electrodes (“SDGE”) from China would be likely to lead to 

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

reasonably foreseeable time.1

I. Background

Original Investigation: On January 17, 2008, SGL Carbon LLC (“SGL”) and Superior

Graphite Company (“Superior”) filed an antidumping petition regarding SDGE from China. On 

February 19, 2009, the Commission issued its determination that the domestic industry was 

materially injured by reason of imports of SDGE from China that Commerce had determined 

were sold at less-than-fair value.2 On February 26, 2009, Commerce published an antidumping 

duty order.

3

Current Review: On February 3, 2014, GrafTech International Ltd. (“GrafTech”), SGL, and 

Superior submitted a joint response to the Commission’s notice instituting this review. On April 

7, 2014, the Commission found each domestic producer’s response to be adequate. It further 

determined that the domestic interested party group response to the notice of institution was 

adequate because these domestic producers accounted for a substantial portion of domestic 

SDGE production in 2013. The Commission did not receive a response to the notice of 

institution from any respondent interested party. Consequently, it determined that the 

respondent interested party group response was inadequate. In the absence of any 

circumstances warranting a full review, the Commission unanimously determined to conduct an 

expedited review of the order.4

1 Commissioner Schmidtlein did not participate in this review. 2 Small Diameter Graphite Electrodes from China, Inv. No. 731-TA-1143 (Final), USITC Pub. 4062

(Feb. 2009). 3 74 Fed. Reg. 8669, 8775 (Feb. 26, 2009). 4 Explanation of Commission Determination on Adequacy in Small Diameter Graphite Electrodes 

from China, Inv. No. 731-TA-1143 (Review), EDIS Doc. No. 531769.

3

 
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.”5

 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.”6 The Commission’s 

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

investigation and consider whether the record indicates any reason to revisit the prior findings.7

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

review as follows:

(A)ll SDGEs of any length, whether or not finished, of a kind used in furnaces, with a 

nominal or actual diameter of 400 millimeters (16 inches) or less, and whether or not 

attached to a graphite pin joining system or any other type of joining system or 

hardware. The merchandise covered by the order also includes graphite pin joining 

systems for SDGEs, of any length, whether or not finished, of a kind used in furnaces, 

and whether or not the graphite pin joining system is attached to, sold with, or sold 

separately from, the SDGE. SDGEs and graphite pin joining systems for SDGEs are most 

commonly used in primary melting, ladle metallurgy, and specialty furnace applications 

in industries including foundries, smelters, and steel refining operations. SDGEs and 

graphite pin joining systems for SDGEs that are subject to the order are currently 

classified under the HTSUS subheadings 8545.11.0010,a 3801.10,b and 8545.11.0020.c

 

The HTSUS numbers are provided for convenience and customs purposes, but the 

written description of the scope remains dispositive.

a The scope described in the order refers to the HTSUS subheading 8545.11.000. 

We note that, starting in 2010, imports of SDGEs are classified in the HTSUS 

under subheading 8545.11.0010 and imports of large diameter graphite 

electrodes are classified under subheading 8545.11.0020.

5 19 U.S.C. § 1677(4)(A).

6 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). 7 See, e.g., Internal Combustion Industrial Forklift Trucks from Japan, Inv. No. 731-TA-377 

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

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

4

 
b See First Circumvention Determination, and accompanying IDM at Comment 6 

(the scope of the order is amended to include imports classifiable under HTSUS 

3801.10, i.e., un-finished SDGEs).

c See Second Circumvention Determination, and accompanying IDM at Comment 

2 and 1 (the scope of the order is amended to include large diameter graphite 

electrodes, specifically those of 17 inches produced by Jilin Carbon classifiable 

under HTSUS 8545.11.0020).8

In the original investigation, the Commission defined a single domestic like product 

consisting of SDGE made in the United States corresponding to the SDGE in the scope of the 

investigation. The Commission considered and rejected respondents’ request to define the 

domestic like product to include large diameter graphite electrodes (“LDGE”) that were not 

within the scope definition.

9

The domestic producers stated that they agree with the Commission’s definition of the 

domestic like product in the original investigation.10 The record of this review does not indicate 

that there have been any significant changes in the characteristics or uses of SDGE since the 

original investigation.11 Therefore, we define the domestic like product as consisting of SDGE 

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

Antidumping Duty Order on Small Diameter Graphite Electrodes from the People’s Republic of China

from Christian Marsh, Deputy Assistant Secretary for Antidumping and Countervailing Duty Operations

to Paul Piquado, Assistant Secretary for Import Administration at 4 (May 2, 2014).

9 The Commission found the issue to be a close one. It recognized that there were a number of 

ways in which SDGE and LDGE might be viewed as forming a continuum, including that price, current 

carrying capacity, and premium needle coke content all tended to increase with the size of the 

electrode, and that electrodes of adjacent sizes were most comparable with respect to these attributes. 

The Commission concluded, however, that, on balance, the record supported limiting the domestic like 

product to SDGE. It found that the features of graphite electrodes established a clear dividing line 

between SDGE and LDGE at 16 inches in diameter. First, there was very little overlap in end uses. SDGE 

were used generally in foundry, specialty furnace applications, and steel mill ladle applications, whereas 

the great majority of LDGE were used for primary melting of steel scrap in mini-mill electric arc furnaces. 

Second, there was very limited overlap in manufacturing facilities and equipment used to produce SDGE 

and LDGE. Of the four producers of graphite electrodes during the original investigation, only one, SGL, 

was able to produce both products on the same equipment using the same employees. Third, although 

interchangeability of all graphite electrodes was generally limited to adjacent diameter sizes, SDGE 

could not be substituted for LDGE in heavy melting applications due to coke content and other physical 

characteristics. Finally, purchasers did not use SDGE and LDGE for the same applications, often 

purchased them in separate transactions, and that the level of technical support and service for SDGE 

and LDGE could vary. USITC Pub. 4062 at 9-10.

10 Domestic Producers’ Response to Notice of Institution at 23. 11 See generally, Confidential Report (“CR”) at I-6-12, Public Report (“PR”) at I-5-8. We note that 

GrafTech became a domestic SDGE producer by acquiring C/G Electrodes LLC, a producer of LDGE and 

later ***. CR at I-13, PR at I-9. It is unclear from the limited record in this expedited review whether 

GrafTech ***. 

5

 
made in the United States corresponding to the SDGE in the scope of the order for the same 

reasons articulated in the original investigation.

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

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

In the original investigation, the Commission defined the domestic industry to consist of 

all domestic producers of SDGE, which, at that time were SGL and Superior. GrafTech, the third 

domestic producer that responded to the notice of institution of this review, started producing 

SDGE in 2013.13 The domestic producers stated that they agree with the Commission’s 

definition of the domestic industry in the original investigation, with the proviso that the new 

producer GrafTech be included.14 There are no related parties issues in this review.15 

Accordingly, we define the domestic industry as consisting of all domestic producers of SDGE, 

namely GrafTech, SGL, and Superior.

III. Revocation of the Antidumping Duty Order 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.”16 

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 

12 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.

13 Domestic Producers’ Response to Notice of Institution at 22 and Exhibit 2. 14 Domestic Producers’ Response to Notice of Institution at 23.

15 See Domestic Producers’ Response to Notice of Institution at 20 and Exh. 10.

16 19 U.S.C. § 1675a(a).

6

 
elimination of its restraining effects on volumes and prices of imports.”17 Thus, the likelihood 

standard is prospective in nature.18 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.19

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.”20 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.”21

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.”22 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 

17 Uruguay Round Statement of Administrative Action (1994) (“SAA”), H.R. Rep. 103-316, vol. I

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.

18 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.

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

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

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

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

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

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

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

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

‘possible’”).

20 19 U.S.C. § 1675a(a)(5). 21 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. 22 19 U.S.C. § 1675a(a)(1).

7

 
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).23 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.24

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.25 In doing so, the Commission 

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

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

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

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

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

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

produce other products.26

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.27

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.28 All relevant economic factors are to be 

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

23 19 U.S.C. § 1675a(a)(1). Commerce has not made any duty absorption findings with respect to 

SDGE from China. CR at I-3, PR at I-3. 24 19 U.S.C. § 1675a(a)(5). Although the Commission must consider all factors, no one factor is 

necessarily dispositive. SAA at 886. 25 19 U.S.C. § 1675a(a)(2).

26 19 U.S.C. § 1675a(a)(2)(A-D).

27 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.

28 19 U.S.C. § 1675a(a)(4).

8

 
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 order under 

review and whether the industry is vulnerable to material injury upon revocation.29

No respondent interested party participated in this expedited review. The record, 

therefore, contains limited new information with respect to the SDGE industry in China. There 

also is limited information on the SDGE market in the United States during the period of review. 

Accordingly, for our determination, we rely as appropriate on the facts available from the 

original investigation, and the limited new information on the record in this first five-year 

review.

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.”30 The following conditions of competition inform our determination.

1. Demand Conditions

In the original investigation, the Commission stated that demand for SDGE is largely 

determined by demand for steel.31 The Commission characterized much of the original period 

of investigation (2005-2007) as “a boom period for domestic steel production.”32 During that 

period, apparent U.S. consumption of SDGE increased by *** percent.33

Demand for SDGE remains driven by demand for steel.34 According to the domestic 

producers, U.S. steel production dropped by more than 40.7 percent between 2007 and 2009, 

and although it has grown since 2009, it had not fully recovered to pre-recession levels by 2013. 

Apparent U.S. consumption of SDGE was *** metric tons in 2013, or *** percent lower than the 

*** metric tons in 2007.

35 The domestic producers state that demand for SDGE is expected to 

remain fairly stable in 2014 compared to 2013, and to improve slightly in 2015.36

29 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.

30 19 U.S.C. § 1675a(a)(4).

31 USITC Pub. 4062 at 14.

32 USITC Pub. 4062 at 14.

33 Confidential Original Views, EDIS Doc. 319695 at 19, USITC Pub. 4062 at 14.

34 CR at I-8 n.20, PR at I-6 n.20. 35 CR/PR at Table I-4.

36 Domestic Producers’ Response to Notice of Institution at 22, Domestic Producers’ Final 

Comments at 4.

9

 
2. Supply Conditions

During the original investigation, the U.S. SDGE market was supplied by the domestic 

industry, subject imports, and nonsubject imports. The domestic industry consisted of SGL and 

Superior. The domestic industry’s capacity to produce SDGE declined from *** metric tons in 

2005 and 2006 to *** metric tons in 2007, and its market share fell from *** percent to ***

percent in this period. The market share of subject imports increased from *** percent in 2005 

to *** percent in 2007, and the market share of nonsubject imports increased from ***

percent to *** percent in this period.37

Since the original investigation, a third domestic producer, GrafTech, entered the SDGE 

market. In 2010, GrafTech acquired C/G Electrodes LLC, a producer of LDGE, and *** to 

produce SDGE.38 In 2013, the domestic industry supplied a larger share of apparent U.S. 

consumption, *** percent, than it did in 2007. By contrast, the 2013 market share of subject 

imports was *** percent, lower than it was in 2007. Nonsubject imports supplied the largest 

share of the U.S. market in 2013, with *** percent of apparent U.S. consumption.39 In 2013, 

the three largest suppliers of nonsubject imports to the U.S. market were Japan, Mexico, and 

Canada.40

3. Substitutability

In the original investigation, the Commission stated that the record indicated that the 

domestic like product and subject imports were at least moderately interchangeable. *** U.S. 

producers and a majority of importers reported that SDGE from China and SDGE produced in 

the United States were frequently interchangeable; and nearly all of the responding purchasers 

reported that SDGE from China and SDGE produced in the United States were always or 

frequently interchangeable.41

There is nothing on the current record indicating that this level of interchangeability 

between SDGE made in China and in the United States has changed since the original 

investigation. Accordingly, we again find at least a moderate degree of interchangeability 

between SDGE made in the United States and China.

C. Likely Volume of Subject Imports

1. The Original Investigation

In the original investigation, the volume of subject imports, which was already sizeable 

at the beginning of the period of investigation, increased by 36.7 percent between 2005 and

37 Confidential Original Views at 20-21; USITC Pub. 4062 at 14-15. 38 CR at I-13, PR at I-9. 39 CR/PR at Table I-5. 

40 CR/PR at Table I-3. 41 Confidential Original Views at 21; USITC Pub. 4062 at 15.

10

 
2007, rising from 10,082 metric tons to 13,784 metric tons. The market share of subject 

imports rose from *** percent in 2005 to *** percent in 2007. The ratio of subject imports to 

U.S. production rose from *** percent in 2005 to *** percent in 2007.

42

The Commission found that subject imports captured market share from the domestic 

industry despite overall rising demand during the period of investigation. The domestic 

industry’s market share by quantity declined from *** percent in 2005 to *** percent in 2007. 

The domestic industry’s U.S. shipments declined in each year as subject imports increased and 

demand increased overall from 2005 to 2007. The Commission also observed that, in contrast 

to the decline in the domestic industry’s market share, nonsubject imports’ market share by 

quantity followed the trend in demand, increasing from *** percent in 2005 to *** percent in 

2006, and decreasing to *** percent in 2007.43 

The Commission found that the volume of subject imports and the increase in that 

volume was significant, both in absolute terms and relative to consumption and production in 

the United States.44

2. This First Review

The available information in this review indicates that the antidumping duty order has

had a disciplining effect on the volume of subject imports of SDGE from China. The volume of 

subject imports from China in the U.S. market in 2013 was substantially lower than in 2007.45

No foreign producer or exporter of SDGE participated in this expedited review and 

therefore the record contains limited data concerning the SDGE industry in China. There is, 

however, available public data concerning production and exports of all graphite electrodes, a 

category that includes both subject and nonsubject merchandise. The available data indicate

that China is the world’s largest producer and exporter of all graphite electrodes,

46 and that the 

graphite electrode industry in China likely has excess capacity that likely exceeds apparent U.S. 

consumption of SDGE.

47

42 Confidential Original Views at 22-23; USITC Pub. 4062 at 16. During the January-September 

interim 2008 period, subject import volume was slightly lower, but market share was higher, than in 

interim 2007.

43 Confidential Original Views at 22-23; USITC Pub. 4062 at 16. 44 USITC Pub. 4062 at 16.

45 The volume of subject imports was 13,784 metric tons in 2007 and 2,352 metric tons in 2013. 

CR/PR at Table I-2. We recognize that the import data cited were compiled from different sources for 

2007 and 2013 – namely, from questionnaire responses and adjusted official Commerce statistics for 

2007, and from official Commerce statistics for 2013. CR at I-17, PR at I-11-12. 46 Domestic Producers’ Response to Notice of Institution at 10; CR/PR at Table I-7. 47 In the absence of published statistics on SDGE, Domestic Producers provided capacity data for 

all graphite electrodes. They provided data showing that 23 of the Chinese industry’s producers have 

the collective capacity to produce about 871,000 metric tons of graphite electrodes, and that the 

Chinese graphite electrode industry likely had excess capacity of at least 226,013 metric tons in 2012. 

To put the Chinese industry’s capacity and excess capacity in perspective, apparent U.S. consumption of 

11

 

(Continued...)
The United States likely remains an attractive market to the SDGE industry in China. 

Chinese SDGE producers maintain a significant interest in the U.S. market, as evidenced by their 

continued exports of SDGE to the United States since the imposition of the order.

48 The 

circumstances underlying Commerce’s two anticircumvention determinations involving subject 

imports also demonstrate Chinese producers’ interest in accessing the U.S. market.

49 

Moreover, Chinese SDGE producers have considerable third-country exports that could be 

redirected to the U.S. market.50 Finally, antidumping duty investigations and orders against 

SDGE from China in other countries (namely Brazil, India, Mexico, and South Africa) provide 

another incentive for subject SDGE producers to increase exports to the United States upon 

revocation of the order.51

In light of these considerations, we find that subject producers in China are likely, 

absent the restraining effects of the order, to direct substantial and increasing volumes of SDGE 

to the U.S. market, as they did during the original investigation.

52 We find that the likely 

volume of subject imports both in absolute terms and relative to production and consumption 

in the United States would be significant if the order were revoked.

SDGE in 2013 was estimated at *** metric tons. Domestic Producers’ Response to Notice of Institution 

at 9-13. CR/PR at Table I-4. 48 CR/PR at Table I-2. 49 Commerce has issued two anticircumvention rulings issues since the original antidumping 

duty order was issued. In the first, Commerce found that electrodes finished in the United Kingdom by 

UK Carbon & Graphite Company Ltd. from Chinese-origin artificial graphite/unfinished SDGE 

components and sold in the United States circumvented the antidumping duty order on SDGE. Small 

Diameter Graphite Electrodes from the People's Republic of China: Affirmative Final Determination of 

Circumvention of the Antidumping Duty Order, 77 Fed. Reg. 47596 (August 9, 2012). In the second 

ruling, Commerce concluded that imports from China of certain graphite electrodes, produced and/or 

exported by Jilin Carbon, with a diameter of 17 inches, and otherwise meeting the description of inscope merchandise, “constitute merchandise altered in form or appearance in such minor respects that 

it is properly subject to the Order.” Small Diameter Graphite Electrodes from the People's Republic of 

China: Affirmative Final Determination of Circumvention of the Antidumping Duty Order and Rescission 

of Later-Developed Merchandise Anticircumvention Inquiry, 78 Fed. Reg. 56864 (September 16, 2013).

50 See CR/PR at Table I-6 (showing China’s exports of all graphite electrodes to various markets, 

2008-2013).

51 CR at I-26, PR at I-18. 52 The record of this expedited review does not contain current information regarding any 

existing inventories of subject merchandise, any likely increase in such inventories, or the potential for 

product shifting if production facilities in China which can be used to produce SDGE are currently being 

used to manufacture other products.

12

 

(...Continued)
D. Likely Price Effects 

1. The Original Investigation

In the original investigation, the Commission found that price was an important factor in 

purchasing decisions. It indicated that domestic producers and a majority of importers 

reported that non-price differences between subject imports and the domestic like product 

were only *** in purchasing decisions. While a sizeable minority of responding importers 

reported that non-price differences were always or frequently an important factor in 

purchasing decisions, and almost all purchasers indicated that reliability, availability, product 

consistency, and whether the quality meets industry standards were among the most 

important factors in purchasing decisions in addition to price, few market participants could 

identify instances when Chinese imports failed to satisfy quality and availability requirements.53

The Commission collected quarterly pricing data for five types of SDGE for sales to both 

end users and distributors. The pricing data showed pervasive underselling by subject imports, 

with subject imports underselling the domestic like product in 54 of 60 price comparisons by 

margins ranging from 2.3 percent to 36.2 percent.54 The Commission found that the effects of 

underselling on the domestic industry differed with respect to the two domestic producers. 

Superior, which competed head-to-head with subject imports for sales across most SDGE sizes, 

submitted evidence of substantial lost sales to low-priced imports. SGL, on the other hand, 

rather than lowering its prices to meet subject import prices and maintain customers for 10-

and 12-inch diameter SDGE, made a business decision to cede its market share for those 

products and to focus only on customers for whom Chinese quality was not yet acceptable.55 

The Commission found that the effects of underselling were in the lost volumes of 

domestic sales rather than in direct effects on domestic prices. Available data did not indicate 

that subject imports had significant depressing effects on domestic prices, as domestic prices 

for all five products for which data were collected rose over the period of investigation, 

reflecting strong demand for SDGE and rising raw material prices.56 The Commission also found 

that available data did not support a finding that subject imports suppressed domestic prices to 

a significant degree over the full period of investigation.

57

53 Confidential Original Views at 24; USITC Pub. 4062 at 17. 54 USITC Pub. 4062 at 17. 55 USITC Pub. 4062 at 17. 56 USITC Pub. 4062 at 18. The Commission did observe, however, that for one of the pricing 

products, which constituted *** percent of the quantity of product for which it had received pricing 

data and which had the largest margins of underselling by subject imports, the increase in domestic 

prices was *** than for the other products. Confidential Original Views at 25-26; USITC Pub. 4062 at 18. 57 USITC Pub. 4062 at 18. The Commission found, however, that there was evidence that lowpriced subject imports had adversely affected domestic producers’ prices in certain instances. 

Specifically, in 2007, domestic unit sales values increased by less than the increase in unit cost of goods 

sold (“COGS”), despite continued strong demand in that year, and the ratio of COGS to net sales rose 

13

 

(Continued...)
The Commission found that there was significant underselling by subject imports and 

that this underselling led to lost sales in 2006 and 2007. It noted that the underselling allowed 

subject imports to gain market share at the expense of the domestic industry and that the 

domestic industry’s U.S. shipments declined throughout the period of investigation, despite 

generally rising demand. The Commission therefore determined that subject imports had 

significant adverse price effects on the domestic industry.58

2. This First Review

In this review, we continue to find that subject imports from China are at least 

moderately interchangeable with SDGE manufactured in the United States and that price is an 

important factor in purchasing decisions. The record does not contain current pricing 

comparisons due to the failure of respondent interested parties to participate and the 

expedited nature of this review. We find that the significant underselling observed during the 

original investigation would likely recur if the antidumping duty order were revoked. This in 

turn would likely cause the domestic industry to lose sales and market share, as was the case in 

the original investigation.

E. Likely Impact 

1. The Original Investigation

In the original investigation, the Commission found that the domestic industry’s 

performance indicators showed declining overall trends despite strong demand conditions, and 

that these declines corresponded to increases in subject imports’ volume and market share.59 

U.S. producers’ production, capacity utilization, and U.S. shipments all declined steadily from 

2005 to 2007, but experienced some improvement when the interim periods were compared.60 

Employment-related indicators generally declined, although hourly wages rose.61

The Commission found that the domestic industry’s financial indicators were lackluster 

despite rising prices and very strong demand throughout the period of investigation. The 

domestic industry’s net sales quantities declined from 2005 to 2007. Net sales by value 

declined from 2005 to 2006, and then increased from 2006 to 2007. The domestic industry’s 

operating income improved from *** in 2005 to *** in 2006, but declined in 2007. The 

from *** percent in 2006 to *** percent in 2007. Confidential Original Views at 26-27; USITC Pub. 4062 

at 18-19.

58 USITC Pub. 4062 at 19. 59 USITC Pub. 4062 at 19. The Commission recognized that some indicators fluctuated during 

the period of investigation before recovering *** during interim 2008, after the petition was filed. 

Confidential Original Views at 28; USITC Pub. 4062 at 19.

60 USITC Pub. 4062 at 20. 61 USITC Pub. 4062 at 20.

14

 

(...Continued)
domestic industry’s operating income margin increased from 2005 to 2006, and then fell in 

2007.62

The Commission examined the role of nonsubject imports in the U.S. market during the 

period of investigation. It found that SDGE was not a commodity product because the SDGEs

were produced to individual customer specifications. The Commission observed that 

nonsubject imports were generally priced above subject imports, particularly later in the period 

of investigation, and although nonsubject imports were present in substantial quantities, 

nonsubject import volume and market share fluctuated in the same manner as trends in 

apparent U.S. consumption. Moreover, nonsubject imports’ market share declined significantly 

in 2007 when the domestic industry’s condition worsened. The Commission concluded that 

adverse changes to the domestic industry’s condition could not be attributed to nonsubject 

imports.63

The Commission concluded that subject imports had a significant adverse impact on the 

condition of the domestic industry during the period of investigation. It explained that subject 

imports gained market share at the expense of the domestic industry and caused domestic U.S. 

shipments to dwindle as subject imports aggressively undersold the domestic product. This 

pattern of underselling resulted in significant lost sales and suppressed domestic prices to some 

extent in 2007. The increase in subject imports and their adverse effects on U.S. prices 

materially impacted the domestic industry’s profitability and market share over the period of 

investigation.64

2. This First Review

Because this is an expedited review, we have only limited information with respect to 

the domestic industry’s trade and financial performance, consisting of data that the domestic 

producers provided in response to the notice of institution. Many of the domestic industry’s 

performance indicators showed deterioration in 2013, as compared with 2007.65 Nonetheless, 

the limited record66 is insufficient for us to make a finding on whether the domestic industry is 

62 USITC Pub. 4062 at 20-21. 63 USITC Pub. 4062 at 21. The Commission addressed and rejected arguments by respondents 

that any adverse changes to the domestic industry’s condition were not caused by subject imports, but 

rather by the poor performance of one of the two domestic producers (specifically by that producer’s 

inability to control its direct labor, and selling, general and administrative costs) or by a *** in the 

domestic industry’s export shipments. Confidential Original Views at 32; USITC Pub. 4062 at 22. It also 

addressed and rejected arguments that there was no adverse impact on the domestic industry because 

its profitability increased during the period of investigation, or because it allegedly could not supply the 

entire SDGE market. USITC Pub. 4062 at 23.

64 USITC Pub. 4062 at 23. 65 See CR/PR at Table I-1.

66 We recognize that the domestic industry performed poorly in 2013, but this is based on only a 

single year of data. 

15

 
vulnerable to the continuation or recurrence of material injury in the event of revocation of the 

order.67

In 2013, the capacity of the U.S. producers of SDGE was *** metric tons, production was 

*** metric tons, and capacity utilization was *** percent.68 U.S. shipments were *** metric

tons, and the domestic producers reported an operating *** of $*** from sales of $***, 

resulting in an operating *** margin of *** percent in 2013.

69 

Based on the record, we find that, should the order be revoked, the likely significant 

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

adverse impact on the domestic industry’s production, shipments, sales, market share, and 

revenues, particularly because available information suggests that current and projected 

demand conditions in the U.S. market are less favorable than during the original investigation. 

These declines would likely cause the domestic industry’s profitability to fall.

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

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

imports. In the original investigation, the Commission concluded that SDGE is not a commodity 

product.70 While we acknowledge that imports from nonsubject sources continue to have a 

sizeable U.S. market presence, and, in fact have increased their market share since the time of 

the original investigation,

71 no party has argued that nonsubject imports or any other factor is

likely to be an alternative cause of material injury to the domestic industry. We thus find that 

upon revocation, the significant volume of subject imports would again likely take market share 

from the domestic industry through significant underselling and result in impaired industry 

performance, as occurred during the original investigation.

Accordingly, we conclude that, if the antidumping duty order were revoked, subject 

imports from China would likely have a significant impact on the domestic industry within a 

reasonably foreseeable time.

IV. Conclusion

For the foregoing reasons, we determine that revocation of the antidumping duty order

on SDGE from China would likely lead to continuation or recurrence of material injury to an 

industry in the United States within a reasonably foreseeable time.

67Commissioner Pinkert finds the domestic industry to be vulnerable. He bases this conclusion 

largely on the industry’s operating margin *** and COGS/net sales ratio *** in 2013. He notes in 

addition that the industry’s market share in that year was *** and that its sales volume was lower than 

in 2007. CR/PR at Table I-1, Table I-5.

68 CR/PR at Table I-1.

69 CR/PR at Table I-1. 70 USITC Pub. 4062 at 21. 71 The market share of nonsubject imports was *** percent in 2013, compared with *** percent 

in 2007. CR/PR at Table I-5.

16

 
I. INFORMATION OBTAINED IN THE REVIEW

INTRODUCTION

Background

On January 2, 2014, 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 a review to determine whether revocation of the antidumping duty order on 

small diameter graphite electrodes (“SDGE”) from China would likely lead to the continuation 

or recurrence of material injury to a domestic industry.2 3 On April 7, 2014, the Commission 

determined that it would conduct an expedited review pursuant to section 751(c)(3) of the 

Act.4 The following tabulation presents information relating to the background and schedule of 

this proceeding:

1 19 U.S.C. 1675(c).

2 Small Diameter Graphite Electrodes from China; Institution of a Five-Year Review, 79 FR 145, 

January 2, 2014. 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 a five-year review of the subject antidumping duty order concurrently 

with the Commission’s notice of institution. Initiation of Five-Year (“Sunset”) Review, 79 FR 110, January 

2, 2014. 4 Small Diameter Graphite Electrodes from China; Scheduling of an Expedited Five-Year Review, 79 FR 

22531, April 22, 2014. The Commission received one submission in response to its notice of institution in 

the subject review. A joint response was filed on behalf of GrafTech International Ltd., SGL Carbon LLC, 

and Superior Graphite Company, U.S. producers believed to account for all U.S. production of the 

domestic like product in 2013. The Commission did not receive any responses from producers in China 

or importers of the subject merchandise from China. The Commission determined that the domestic 

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

interested party group response was inadequate. In the absence of respondent interested party 

responses and any other circumstances that would warrant the conduct of a full review, the Commission 

determined to conduct an expedited review.

I-1

 
Effective date Action

February 26, 2009

Commerce’s antidumping duty order on SDGE from China (74 FR 8775)

http://www.gpo.gov/fdsys/pkg/FR-2009-02-26/pdf/E9-4126.pdf

January 2, 2014

Commission’s institution of first five-year review (79 FR 145) 

http://www.gpo.gov/fdsys/pkg/FR-2014-01-02/pdf/2013-30798.pdf

January 2, 2014

Commerce’s initiation of first five-year review (79 FR 110) 

http://www.gpo.gov/fdsys/pkg/FR-2014-01-02/pdf/2013-31429.pdf

April 7, 2014

Commission’s determination to conduct expedited five-year review 

(79 FR 22531, April 22, 2014)

http://www.gpo.gov/fdsys/pkg/FR-2014-04-22/pdf/2014-09081.pdf

The press release announcing the Commission’s determination concerning 

adequacy and the conduct of the expedited review can be found at 

http://www.usitc.gov/press_room/news_release/2014/er0407mm1.htm

A summary of the Commission’s votes concerning the adequacy and the conduct of 

the expedited review can be found at 

http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11650

The Commission’s explanation of its determination can be found at 

http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11651

May 7, 2014

Commerce’s final result of expedited five-year review of the antidumping duty order

(79 FR 26208)

http://www.gpo.gov/fdsys/pkg/FR-2014-05-07/pdf/2014-10513.pdf

May 21, 2014 Commission’s vote

June 2, 2014 Commission’s determination

The original investigation

The original investigation resulted from a petition filed with Commerce and the 

Commission by SGL Carbon LLC, Charlotte, North Carolina and Superior Graphite Co., Chicago, 

Illinois, on January 17, 2008, alleging that an industry in the United States was materially 

injured and threatened with material injury by reason of less-than-fair-value (“LTFV”) imports 

of SDGE from China. On January 14, 2009, Commerce determined that imports of SDGE from

China were being sold at LTFV, by margins of 132.90 to 159.64 percent.

5 On February 19, 2009, 

the Commission determined that an industry in the United States was materially injured by 

reason of LTFV imports of SDGE from China, but found that critical circumstances did not exist 

with respect to the subject imports covered by Commerce’s affirmative critical circumstances 

5 Final Determination of Sales at Less Than Fair Value and Affirmative Determination of Critical 

Circumstances: Small Diameter Graphite Electrodes from the People’s Republic of China, 74 FR 2049, 

January 14, 2009.

I-2

 
determination.

6

 Commerce issued an antidumping duty order on SDGE from China on February 

26, 2009.7

Commerce’s reviews

Commerce has not issued any duty absorption findings and has not conducted any new 

shipper reviews or changed circumstances reviews. Commerce has published final results for 

administrative reviews covering three review periods: August 21, 2008 – January 31, 2010; 

February 1, 2010 – January 31, 2011; and February 1, 2011 – January 31, 2012.

 

• Commerce calculated the following margins in its first administrative review (revised to 

correct for ministerial errors): Beijing Fangda Carbon Tech Co., Ltd., Fangda Carbon New 

Material Co., Ltd., Fushun Carbon Co., Ltd., Hefei Carbon Co., Ltd., 1.10 percent; Fushun 

Jinly Petrochemical Carbon Co., Ltd., 39.83 percent; and Xinghe County Muzi Carbon Co., 

Ltd., 16.00 percent. 8

• Commerce calculated the following margins in its second administrative review: for 

eight specified companies, 36.79 percent; for the PRC-wide entity, 159.64 percent.

9

• Commerce calculated the following margins in its third administrative review: Fushun 

Jinly Petrochemical Carbon Co., Ltd., Beijing Fangda Carbon Tech Co., Ltd., Chengdu 

Rongguang Carbon Co., Ltd., Fangda Carbon New Material Co., Ltd., Fushun Carbon Co., 

Ltd., Hefei Carbon Co., Ltd., and Xinghe County Muzi Carbon Co., Ltd., 0.00 percent; and 

the PRC-wide entity, 159.64 percent.

10

Commerce’sresults of its expedited review of the subject antidumping duty order were

published in the Federal Register on May 7, 2014. Commerce determined that revocation of 

the subject order would likely lead to continuation or recurrence of dumping at rates of 132.90 

percent to 159.64 percent.

11

6 Small Diameter Graphite Electrodes from China, 74 FR 8568, February 25, 2009. 7 Antidumping Duty Order: Small Diameter Graphite Electrodes from the People's Republic of China, 

74 FR 8775, February 26, 2009.

8 Small Diameter Graphite Electrodes from the People’s Republic of China: Amended Final Results of 

the First Administrative Review of the Antidumping Duty Order, 77 FR 15042, March 14, 2012.

9 Small Diameter Graphite Electrodes from the People’s Republic of China: Final Results of the 

Antidumping Duty Administrative Review, 77 FR 40854, July 11, 2012.

10 Small Diameter Graphite Electrodes from the People’s Republic of China: Final Results of 

Antidumping Duty Administrative Review; 2011–2012, 78 FR 55680, September 11, 2013. 11 Small Diameter Graphite ElectrodesFrom the People’s Republic of China: Final Results of the 

Expedited Sunset Review of the Antidumping Duty Order, 79 FR 26208, March 7, 2014.

I-3

 
Previous and related investigations

SDGE has not been the subject of any prior antidumping or countervailing duty 

investigations in the United States.

THE PRODUCT

Commerce’s scope

Commerce initially defined the subject merchandise as:

(A)ll small diameter graphite electrodes of any length, whether or not finished, of a kind 

used in furnaces, with a nominal or actual diameter of 400 millimeters (16 inches) or 

less, and whether or not attached to a graphite pin joining system or any other type of 

joining system or hardware. The merchandise covered by this investigation also 

includes graphite pin joining systems for small diameter graphite electrodes, of any 

length, whether or not finished, of a kind used in furnaces, and whether or not the 

graphite pin joining system is attached to, sold with, or sold separately from, the small 

diameter graphite electrode. Small diameter graphite electrodes and graphite pin 

joining systems for small diameter graphite electrodes are most commonly used in 

primary melting, ladle metallurgy, and specialty furnace applications in industries 

including foundries, smelters, and steel refining operations. 12 

Commerce has examined two circumvention issues since the issuance of the original 

antidumping duty order. In the first instance, Commerce found that electrodes finished in the 

United Kingdom by UK Carbon & Graphite Company Ltd. from Chinese-origin artificial 

graphite/unfinished SDGE components and sold in the United States circumvented the 

antidumping duty order on SDGE.13 In the second instance, Commerce concluded that imports 

from China of certain graphite electrodes, produced and/or exported by Jilin Carbon, with a 

diameter of 17 inches, and otherwise meeting the description of in-scope merchandise, 

12 Final Determination of Sales at Less Than Fair Value and Affirmative Determination of Critical 

Circumstances: Small Diameter Graphite Electrodes from the People’s Republic of China, 74 FR 2049, 

January 14, 2009. Commerce also noted the Harmonized Tariff Schedule of the United States (HTSUS) 

subheading for the small diameter graphite electrodes and graphite pin joining systems for small 

diameter graphite electrodes subject to investigation, while observing that the written description of the 

scope was dispositive. See also the next section of this report for current U.S. tariff treatment.

13 Small Diameter Graphite Electrodes from the People's Republic of China: Affirmative Final 

Determination of Circumvention of the Antidumping Duty Order, 77 FR 47596, August 9, 2012.

I-4

 
“constitute merchandise altered in form or appearance in such minor respects that it is 

properly subject to the Order.”14

U.S. tariff treatment

At the time of the original investigation, imports of SDGE were classifiable in the 

Harmonized Tariff Schedule of the United States (“HTS”) under subheading 8545.11.00 (carbon 

or graphite electrodes of a kind used for furnaces) and were free of duty under the general duty 

rate, applicable to China. This subheading contained other products besides SDGE (all carbon 

or graphite electrodes of a kind used in furnaces). Effective on January 1, 2010, this subheading 

was annotated for statistical reporting purposes by action of the Committee for Statistical 

Annotation of Tariff Schedules. SDGE are currently imported under HTS statistical reporting 

number 8545.11.0010 (graphite electrodes, not exceeding 425 mm in diameter, of a kind used 

for furnaces). SDGE imported from China continues to enter the U.S. market at a column 1-

general duty rate of “free.” 

Domestic like product and domestic industry

The Commission examined the issue of the appropriate domestic like product in both 

the preliminary phase and the final phase of the original investigation. Characterizing the issue 

as “a close question,” in the preliminary phase, the Commission defined the domestic like 

product as SDGE corresponding to the scope, while finding both differences and similarities 

between SDGE and large (greater than 16 inches) diameter graphite electrodes (“ LDGE”).

15

In the final phase of the original investigation, the Commission noted that “we find the 

issue to be a close one,” but ultimately concluded “on balance” that the record “merits limiting 

the domestic like product to SDGE.” The Commission noted that price, current carrying 

capacity, and premium needle coke content all tend to increase with the size of the electrode 

and electrodes of adjacent sizes are most comparable with respect to these attributes; thus, 

“SDGE and LDGE might be viewed as forming a continuum.” However, the Commission focused 

on such distinguishing features as:

• “very little” overlap in end uses between SDGE (foundry, specialty furnace 

applications and steel mill ladle applications) and LDGE (primary melting of steel 

scrap in mini-mill electric arc furnaces);

14 Small Diameter Graphite Electrodes from the People's Republic of China: Affirmative Final 

Determination of Circumvention of the Antidumping Duty Order and Rescission of Later-Developed 

Merchandise Anticircumvention Inquiry, 78 FR 56864, September 16, 2013.

15 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), USITC 

Publication 4062, February 2009, p. 6.

I-5

 
• “very limited” overlap in manufacturing facilities and equipment that produce SDGE 

and LDGE, (only one of four domestic manufacturers of graphite electrodes made 

both products). 

• SDGE “cannot” be substituted for LDGE in heavy melting applications due to coke 

content and other physical characteristics. 

• purchasers identify similarities between SDGE and LDGE but “do not” use SDGE and 

LDGE for the same applications, often purchase them in separate transactions and 

note that the level of technical support and service for SDGE and LDGE may vary.16

In its notice of institution for this review, the Commission solicited comments from

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

their joint response to the Commission’s notice of institution, the domestic producers of SDGE 

indicated that they agree with the Commission’s definitions of the domestic like product and 

domestic industry, while requesting that GrafTech, which became a U.S. producer of SDGE after 

the original investigation, be included in the definition of the domestic industry. The domestic 

producers of SDGE reserved the right to comment further on the appropriate definitions during 

the course of this proceeding.

17

Description and uses18

SDGE are cylindrical in shape, produced from various grades of petroleum coke,19 and 

used primarily in ladle metallurgy, primary low-duty melting, and specialty furnace applications, 

such as the electric arc furnace (“EAF”).20 As a result of the different raw materials used, SDGE 

are produced in a variety of grades, including regular power (“RP”), normal power (“NP”), 

medium power (“MP”), high power (“HP”), super high power (“SHP”), and ultra high power 

(“UHP”).

SDGE conduct electricity, generating the heat necessary to melt scrap metal, iron ore, or 

other raw materials used to produce steel or other metals. Electricity at very high amperes 

(units of electric current in the meter-kilogram-second system) passes though the SDGE and 

creates an electric arc between the electrodes and the raw material. Typically, electrodes are 

16 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), USITC 

Publication 4062, February 2009, pp. 9-10. 17 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), p. 23.

18 Unless otherwise noted this information is based on Small Diameter Graphite Electrodes from

China, Investigation No. 731-TA-1143 (Final), USITC Publication 4062, February 2009, pp. I-6 through I-8.

19 SDGE are manufactured from a range of petroleum coke grades, from low-grade anode coke to 

premium high-grade needle coke. The grade of coke, along with other characteristics such as size and 

impregnation, determines the level of current an electrode can carry. SDGE typically have lower current 

carrying capacity ranging from 15,000 to 60,000 amps, but do not exceed 70,000 amps.

20 SDGE are primarily used in steel refining, but are also used in foundry applications, steel melting, 

and other uses. Foundries are the primary users of electrodes that are 8 inches or less in diameter.

I-6

 
joined in columns by a threaded connecting system, most commonly a graphite connecting pin 

that is tapered and threaded at both ends. Alternating current electric arc furnaces generally 

use three columns of electrodes and direct current furnaces use one column. The electrodes 

are fed through holes in the top of the EAFs and held in place by electrical current carrying 

holders and arms designed for the specific size of electrode to be used. Because of the 

intensity of the melting process, the electrodes are consumed continuously during the course 

of the production of metal. 

Production process21

The production of graphite electrodes begins with the high temperature blending of 

crushed and screened petroleum coke with coal or petroleum tar pitch. The mix is then 

charged into a ram type hydraulic press from which a cylindrical column is extruded and cooled. 

These “green electrodes” then enter an oven to undergo a baking process. The heating process 

follows a predetermined and gradually increasing heating curve, reaching a final temperature of 

approximately 900 degrees centigrade. During this stage, the petroleum pitch is converted into 

hard coke, and impurities are removed. After the baking process, the electrode forms may be 

impregnated with a special pitch and rebaked, filling pores to increase density and strength, 

and lowering the electrical resistivity.22 The electrode forms are packed in electric furnaces 

surrounded by carbon particles to form a solid mass for graphitization. An electric current is 

passed through the furnace, raising the temperature to approximately 3,000 degrees 

centigrade (5,000 degrees Fahrenheit). The graphite electrodes, after cooling, may then go to a 

final stage to be machined to exact dimensions and tolerances. This stage may also include 

machining and fitting the ends of the electrode with a threaded graphite pin joining system 

(also known as a pinning or connecting system). The electrode size and prevailing industrial 

standards dictate the diameter size and threading of the connecting pin. The finished product 

is then packaged for shipment, typically placed between wooden chocks, and packed in 

wooden crates for protection during shipping. SDGE may also be bundled in steel strips before 

packing.

Interchangeability and customer and producer perceptions

With respect to distinctions between SDGE and graphite electrodes produced in 

diameters larger than 16 inches, the Commission observed that *** reported different 

applications and thus perceived SDGE and larger diameter graphite electrodes to be different 

products. Purchasers’ views were mixed, but tended to support the notion of different end 

uses. The Commission also viewed interchangeability to be limited by the size requirements of 

21 Unless otherwise noted this information is based on Small Diameter Graphite Electrodes from

China, Investigation No. 731-TA-1143 (Final), USITC Publication 4062, February 2009, pp. I-9 through I11.22 SDGE are not always impregnated, in contrast to larger diameter graphite electrodes.

I-7

 
installed equipment (whereby even shifting between adjacent sizes might be cost prohibitive) 

as well as the need for higher grade coke for larger graphite electrodes used in high intensity 

applications.

23

The Commission characterized U.S.-produced SDGE and subject imports of SDGE from

China as “at least moderately interchangeable.” It specifically noted the large share of market 

participants (collectively, producers, importers, and purchasers) that reported these products 

to be “always” or “frequently” interchangeable.24

Channels of distribution

In general, graphite electrodes are sold directly to end users. In 2007, approximately 

*** percent of U.S. producers’ U.S. commercial shipments of SDGE were to end users, as were 

*** percent of U.S. commercial shipments of electrodes in diameters larger than 16 inches. 

While comparable data are not available for more recent periods, the leading purchasers 

identified in the domestic producers’ response to the notice of institution were all end users –

***.

25

Pricing and related information

At the time of the original investigation, the average unit values of U.S. shipments of 

U.S.-produced SDGE increased from $*** per metric ton in 2005 to $*** in 2006, $*** in 2007, 

and $*** in January–September 2008 – lower than the average unit values of U.S.-produced 

graphite electrodes in diameters greater than 16 inches, but higher than U.S. shipments of 

imports of SDGE from China.26 With respect to price comparisons for specific forms of SDGE, 

prices of imports from China were lower than the U.S. producer prices in 54 of 60 quarterly 

comparisons by margins ranging from 2.3 percent to 36.2 percent, and higher in six instances by 

margins ranging from 0.1 to 17.4 percent.27

23 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), Confidential 

Views of the Commission, pp. 10-12.

24 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), Confidential 

Views of the Commission, p. 21.

25 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), p. 21.

26 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), 

Memorandum INV-GG-004, January 23, 2009, p. I-17 (table I-3).

27 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), USITC 

Publication 4062, February 2009, p. V-5.

I-8

 
THE INDUSTRY IN THE UNITED STATES

U.S. producers

At the time of the original investigation, two companies produced SDGE in the United 

States: SGL Carbon and Superior Graphite. SGL Carbon produced 14-inch and 16-inch SDGE as 

well as graphite electrodes in larger diameters (18-inch through 32-inch LDGE), while Superior 

Graphite produced 8-inch to 16-inch diameter SDGE. Two additional companies, Showa Denko 

and C/G Electrodes, produced graphite electrodes in diameters greater than 16 inches but did 

not produce SDGE. SGL Carbon, the only one of the four graphite electrode producers to 

produce in size both larger and smaller than 16 inches in diameter, accounted for *** percent 

of U.S. production of SDGE in 2007.28 No domestic producer was related to an exporter or 

importer of SDGE from China or imported SDGE from China during the original investigation, or 

was otherwise a related party as defined by the statute.

In response to the Commission’s notice of institution in this current review, domestic 

producers of SDGE provided a list of three known and currently operating U.S. producers of 

SDGE: GrafTech (accounting for *** percent of 2013 U.S. SDGE production), SGL Carbon (***

percent); and Superior Graphite (*** percent).

29 Domestic producers are not aware of any 

related parties among the U.S. producers. 30

As noted by the domestic producers of SDGE, in April 2010, “GrafTech acquired 100 

percent interest in C/G Electrodes LLC, which is a producer of large diameter graphite 

electrodes. *** its graphite electrode facility in St. Marys, PA to produce small diameter 

graphite electrodes.” Thus, two of the current three U.S. producers of SDGE (SGL Carbon and 

GrafTech) produce graphite electrodes in size ranges above and below 16 inches in diameter; 

these two companies accounted for *** percent of 2013 U.S. SDGE production.

31 Although 

comparable 2013 data are not available for total or larger-diameter graphite electrode 

production, SGL Carbon and C/G Electrodes (now GrafTech) together accounted for *** percent 

of 2007 U.S. production of graphite electrodes in diameters greater than 16 inches, and for ***

percent of 2007 U.S. production of all graphite electrodes regardless of diameter.32

28 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), 

Memorandum INV-GG-004, January 23, 2009, pp. I-3 and III-1 through III-2 (including table III-1).

29 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), pp. 3, 21-22.

30 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), p. 20.

31 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), pp. 21-22.

32 Calculated from Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 

(Final), Memorandum INV-GG-004, January 23, 2009, p. III-2 (table III-1).

I-9

 
U.S. producers’ trade and financial data

The Commission asked domestic interested parties to provide trade and financial data in 

their response to the notice of institution of the five-year review of the subject order. Table I-1

presents the data reported by responding U.S. producers from both the original investigation 

(2005-07) and the response to the notice of institution (2013). The data presented in table I-1

were provided by two firms for the period 2005-07 and by three firms for 2013, but in all cases 

are believed to account for all known U.S. production of SDGE.

Table I-1

SDGE: U.S. producers’ trade and financial data, 2005-07 and 2013

Item 2005 2006 2007 2013

Capacity *** *** *** ***

Production (metric tons) *** *** *** ***

Capacity utilization (percent) *** *** *** ***

U.S. shipments

 Quantity (metric tons) *** *** *** ***

 Value (1,000 dollars) *** *** *** ***

 Unit value (dollars per metric ton) *** *** *** ***

Net sales 

 Quantity (metric tons) *** *** *** ***

 Value (1,000 dollars) *** *** *** ***

 Unit value (dollars per metric ton) *** *** *** ***

Cost of goods sold (COGS) ($1,000) *** *** *** ***

Gross profit or (loss) ($1,000) *** *** *** ***

SG&A ($1,000) *** *** *** ***

Operating income or (loss) ($1,000) *** *** *** ***

COGS/sales (percent) *** *** *** ***

Operating income or (loss)/sales (percent) *** *** *** ***

Source: Compiled from Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 

(Final), Memorandum INV-GG-004, January 23, 2009, p. C-3 (table C-1); and Response of GrafTech, 

SGL Carbon, and Superior Graphite to the notice of institution, February 3, 2014 (supplemented on 

February 28, 2014), exhibit 2.

The domestic producers of SDGE assert that the domestic industry “continues to find 

itself in an extremely vulnerable position.” They observe that lower steel production (relative 

to pre-2009 levels) has reduced consumption of SDGE, “creating a difficult market for domestic 

producers.” They contend that the domestic SDGE industry will not recover from its current 

condition based on 2014 market projections.

33

33 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), pp. 18-19.

I-10

 
U.S. IMPORTS AND APPARENT CONSUMPTION

U.S. importers

In the final phase of the original investigation, the Commission issued questionnaires to 

32 firms believed to be importers of subject SDGE, as well as to all U.S. producers of SDGE and 

LDGE. Usable questionnaire responses were received from 12 companies, representing 58.3 

percent of total imports from China under HTS subheading 8545.11.00, a broad category, for 

January 2005 – September 2008. *** and *** accounted for *** percent of reported imports 

of SDGE from China in 2007, and *** percent of adjusted imports from all other sources. ***

also reported imports from ***. *** accounted for *** percent of adjusted imports from all 

other sources in 2007.34

In their response to the Commission’s notice of institution in this review, domestic 

producers provided a list of 26 known and currently operating U.S. importers of SDGE from

China.35 

U.S. imports

In its original investigation, the Commission found that the volume of subject imports 

and the increase in that volume were significant, both in absolute terms and relative to 

consumption and production in the United States. The Commission characterized the volume of 

subject imports in 2005 as “sizeable,” and observed that the volume increased by 36.7 percent 

from 2005 to 2007, rising from 10,082 metric tons in 2005 to 13,161 metric tons in 2006, then 

to 13,784 metric tons in 2007. Subject imports also increased as a share of the market, and 

relative to U.S. production, during 2005-07. The ratio of subject imports to U.S. production was 

lower in January-September 2008, after the filing of the petition, than in January-September 

2007, as was the quantity of U.S. imports of SDGE from China, although the market share of 

SDGE from China was higher.36

Table I-2 presents data regarding U.S. imports of SDGE from the period 2005-07 and 

2013. Although intended to be similar, it should be noted that the presented data are compiled 

34 ***. Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), 

Memorandum INV-GG-004, January 23, 2009, p. IV-1 n.2.

35 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), exh. 10.

36 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), USITC 

Publication 4062, February 2009, p. 16.

I-11

 
from different sources – namely, questionnaire and adjusted official Commerce statistics for 

2005-07, and official import statistics of Commerce for 2013.37 

Table I-2

SDGE: U.S. imports, 2005-07 and 2013

Item 2005 2006 2007 2013

Quantity (metric tons)

China 10,082 13,161 13,784 2,352

All other *** *** *** 13,244

 Total imports *** *** *** 15,596

Landed, duty-paid value ($1,000)

China 15,819 21,638 24,003 7,931

All other *** *** *** 52,144

 Total imports *** *** *** 60,075

Unit value (dollars per metric ton)

China 1,569 1,644 1,741 3,372

All other *** *** *** 3,937

 Average, total *** *** *** 3,852

Share of quantity (percent)

China *** *** *** 15.1

All other *** *** *** 84.9

 Total 100.0 100.0 100.0 100.0

Share of value (percent)

China *** *** *** 13.2

All other *** *** *** 86.8

 Total 100.0 100.0 100.0 100.0

Ratio to production (percent)

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

All other *** *** *** ***

 Total *** *** *** ***

Note.--Because of rounding, figure may not add to total shown.

Source: Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), 

Memorandum INV-GG-004, January 23, 2009, pp. IV-4 (table IV-2) and IV-10 (table IV-5); official 

statistics of Commerce for HTS statistical reporting number 8545.11.0010.

37 As noted previously, HTS statistical reporting number 8545.11.0010 (graphite electrodes, not 

exceeding 425 mm in diameter, of a kind used for furnaces) did not enter into effect until January 1, 

2010, as a result of the annotation for statistical reporting purposes of subheading 8545.11 by action of 

the Committee for Statistical Annotation of Tariff Schedules.

I-12

 
Table I-3 presents the quantity, value, and unit value for imports from China as well as 

the other top sources of U.S. imports (shown in descending order of 2013 imports by quantity). 

Though substantially lower in quantity than during 2005-07, SDGE from China retain a presence 

in the U.S. market, with unit values below the average for total imports in each year between 

2010 and 2013, and in most instances below the unit values for the other individual leading 

sources of import supply.

Table I-3

SDGE: U.S. imports, 2010-13

Item 2010 2011 2012 2013

Quantity (metric tons)

China (subject) 2,792 1,190 2,406 2,352

Mexico 4,013 4,942 3,966 3,627

Japan 4,589 4,656 5,387 2,846

Canada 41 1,901 1,667 2,018

India 2,357 7,261 6,772 1,886

Germany 1,178 1,390 1,411 572

All other imports (nonsubject) 3,980 6,654 5,418 2,295

 Total imports 18,950 27,994 27,027 15,596

Landed, duty-paid value ($1,000)

China (subject) 6,715 2,979 8,082 7,931

Mexico 11,715 13,105 11,752 10,215

Japan 34,499 32,462 38,915 13,811

Canada 251 9,356 8,471 8,573

India 7,028 18,065 17,733 7,534

Germany 10,411 14,116 13,079 2,658

All other imports (nonsubject) 17,918 26,452 23,758 9,353

 Total imports 88,537 116,535 121,790 60,075

Unit value (dollars per metric ton)

China (subject) 2,405 2,503 3,359 3,372

Mexico 2,919 2,652 2,963 2,816

Japan 7,518 6,972 7,224 4,853

Canada 6,122 4,922 5,082 4,248

India 2,982 2,488 2,619 3,995

Germany 8,838 10,155 9,269 4,647

All other imports (nonsubject) 4,502 3,975 4,385 4,075

 Average, total 4,672 4,163 4,506 3,852

Note.--Because of rounding, figure may not add to total shown.

Source: Official statistics of Commerce for HTS statistical reporting number 8545.11.0010.

I-13
Apparent U.S. consumption and market shares

Table I-4 presents U.S. shipments of domestic product, U.S. imports and apparent U.S. 

consumption in 2005-07 and 2013. Data on U.S. market shares during 2005-07 and 2013 are 

presented in Table I-5. 

Table I-4

SDGE: U.S. shipments of domestic product, U.S. shipments of imports, and apparent U.S. 

consumption, 2005-07 and 2013

Item 2005 2006 2007 2013

Quantity (metric tons)

U.S. producers’ 

U.S. shipments *** *** *** ***

U.S. shipments of 

imports from.--

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

All other *** *** *** ***

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

Apparent U.S. 

consumption *** *** *** ***

Value (1,000 dollars)

U.S. producers’ 

U.S. shipments *** *** *** ***

U.S. shipments of 

imports from.--

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

All other *** *** *** ***

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

Apparent U.S. 

consumption *** *** *** ***

Note.--Because of rounding, figure may not add to total shown.

Note.–Data for 2013 are based on U.S. imports rather than U.S. shipments of imports.

Source: Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), 

Memorandum INV-GG-004, January 23, 2009, pp. IV-7 (table IV-3); official statistics of Commerce for 

HTS statistical reporting number 8545.11.0010.

I-14
Table I-5

SDGE: U.S. market shares, 2005-07 and 2013

Item 2005 2006 2007 2013

Quantity (metric tons)

Apparent U.S. 

consumption *** *** *** ***

Value (1,000 dollars)

Apparent U.S. 

consumption *** *** *** ***

Share of quantity (percent)

Producer’s share *** *** *** ***

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

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

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

Share of value (percent)

Producer’s share *** *** *** ***

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

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

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

Note.--Because of rounding, figure may not add to total shown.

Note.–Data for 2013 are based on U.S. imports rather than U.S. shipments of imports.

Source: Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), 

Memorandum INV-GG-004, January 23, 2009, pp. IV-9 (table IV-4); official statistics of Commerce for 

HTS statistical reporting number 8545.11.0010.

I-15
THE INDUSTRY IN CHINA

Background

During the final phase of the original investigation, the Commission issued foreign 

producer/exporter questionnaires to 125 firms identified in the petition and Commerce’s notice 

as producers or exporters of SDGE in China, for which contact information was publicly 

available. Thirteen firms provided responses to the Commission’s questionnaires. The 

responding firms reported that they accounted for an estimated nearly *** percent of 

production of SDGE in China during 2007, and nearly *** percent of exports from China to the 

United States of SDGE during 2007.38

The Commission did not receive any responses to the notice of institution from foreign 

producers or exporters. The domestic producers of SDGE provided a list of 112 firms that they 

believe currently produce SDGE in China.39

During the original investigation, the responding producers of SDGE in China 

consistently operated at capacity utilization levels in excess of ***, and by January-September 

2008 were operating at *** of reported capacity. Home market shipments accounted for 

approximately *** of total shipments during 2005-07, while exports (primarily to markets other 

than the United States) accounted for approximately ***, although the share of shipments to 

the home market was *** higher in January-September 2008. Reported inventories declined 

both absolutely and relative to total shipments during 2005-07 and into 2008.40 

Since no Chinese producers responded to the notice of institution, no further primary 

source data are available specific to the production or capacity of subject SDGE in China. 

Domestic producers of SDGE, however, presented in their response to the notice of institution 

data published by the China Carbon Association indicating that Chinese production of all 

graphite electrodes fell markedly between 2008 and 2009 (from 586,700 metric tons to 481,100 

metric tons), but has since recovered to 644,987 metric tons by 2012.41 They further calculate 

the total graphite electrode capacity available to 23 Chinese companies that have requested 

separate antidumping duty rates from Commerce to be 871,000 metric tons, suggesting that 

the Chinese graphite electrode industry has available capacity of at least 226,013 metric tons.42

38 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), 

Memorandum INV-GG-004, January 23, 2009, p. VII-1.

39 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), exh. 4.

40 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), 

Memorandum INV-GG-004, January 23, 2009, p. VII-4 (table VII-2). 41 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), pp. 13-14 and exh. 4.

42 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), pp. 10-13.

I-16

 
Exports

The leading markets for Chinese graphite electrodes (of all sizes) since 2008 are 

presented in Table I-6.

Table I-6

Graphite electrodes: China’s exports, by quantity, 2008-13

Item 2008 2009 2010 2011 2012 2013

Quantity (metric tons)

Russia

 

10,306 4,783 12,838 19,555 19,856 22,125 

Italy

 

10,942 4,858 9,270 12,971 13,504 16,311 

Korea

 

15,375 6,065 9,940 12,935 11,818 11,715 

Germany

 

10,169 3,500 10,579 13,321 11,221 11,665 

Japan

 

13,606 5,768 10,718 11,468 11,583 10,290 

Malaysia

 

4,897 2,570 3,260 4,336 8,500 10,290 

United States

 

22,008 4,851 11,455 15,622 16,670 9,543 

India

 

22,042 15,100 21,525 34,624 13,053 9,190 

Vietnam

 

6,363 5,771 6,668 11,109 9,704 8,805 

Indonesia

 

7,602 5,200 6,832 7,240 8,326 7,534 

All other

 

117,300 60,632 87,923 107,102 107,192 96,604 

Total

 

240,610 119,098 191,006 250,283 231,427 214,070 

Note.--Because of rounding, figures may not add to total shown.

 

Source: Global Trade Information Services, Inc., Global Trade Atlas, HS subheading 8545.11. Data 

include product that is outside the scope of this review, i.e. graphite electrodes greater than 16 inches in 

diameter.

I-17
Tariff or non-tariff barriers to trade

During the original investigation, Chinese SDGE (and graphite electrodes of larger 

diameters) were subject to an existing antidumping duty order in India and an ongoing 

antidumping duty investigation in Brazil.43 Domestic producers of SDGE report current 

measures in place in Brazil (dumping margin of 145.3 percent) and in Mexico (dumping margins 

of 38 -250 percent), with additional ongoing proceedings in India and South Africa.

44

THE GLOBAL MARKET

Table I-7 presents the largest global export sources of graphite electrodes (of all sizes) 

during 2008-13. 

43 Small Diameter Graphite Electrodes from China, Investigation No. 731-TA-1143 (Final), USITC 

Publication 4062, February 2009, p. VII-3. 44 Response of GrafTech, SGL Carbon, and Superior Graphite to the notice of institution, February 3, 

2014 (supplemented on February 28, 2014), pp. 14-15 and exh. 7.

I-18

 
Table I-7

Graphite electrodes: Global exports by major sources, 2008-13

Item 2008 2009 2010 2011 2012 2013

Quantity (metric tons)

China 240,610 119,098 

 

191,006 

 

250,283 

 

231,427 214,070 

Japan

 

143,774 103,167 

 

135,241 

 

141,062 

 

133,963 118,466 

Spain

 

87,588 57,497 

 

72,886 

 

96,980 

 

78,234 94,619 

India

 

47,480 25,527 

 

46,265 

 

72,440 

 

79,973 80,120 

Germany

 

73,395 44,012 

 

49,848 

 

60,529 

 

57,450 41,434 

France

 

38,542 19,160 

 

31,851 

 

37,816 

 

29,415 36,823 

Russia

 

53,733 30,970 

 

43,824 

 

37,634 

 

40,088 32,809 

United States

 

65,321 14,183 

 

27,125 

 

24,857 

 

20,097 21,356 

South Africa

 

17,553 4,268 

 

10,392 

 

10,536 

 

12,242 15,672 

Mexico

 

32,612 14,011 

 

26,115 

 

24,981 

 

22,941 15,623 

All other

 

152,958 71,593 

 

109,773 

 

142,473 

 

123,402 94,009 

Total

 

953,565 503,487 

 

744,325 

 

899,591 

 

829,230 765,000 

Note.--Because of rounding, figures may not add to total shown.

 

Source: Global Trade Information Services, Inc., Global Trade Atlas, HS subheading 8545.11. Data 

include product that is outside the scope of this review, i.e. graphite electrodes greater than 16 inches in 

diameter.

I-19