U.S. International Trade Commission

Publication 4464 May 2014

Washington, DC 20436

Circular Welded Carbon Quality 

Steel Line Pipe from China 

Investigation No. 701-TA-455 and 731-TA-1149 (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

William English, Acting Investigator 

Karen Taylor, Industry Analyst 

Rhonda Hughes, Attorney 

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

Washington, DC 20436 

www.usitc.gov

Publication 4464 May 2014

Circular Welded Carbon Quality 

Steel Line Pipe from China 

Investigation No. 701-TA-455 and 731-TA-1149 (Review)

i.

CONTENTS

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

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

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

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

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

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

Commerce’s reviews................................................................................................................. I-4

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

The product...................................................................................................................................... I-6

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

U.S. tariff treatment ................................................................................................................. I-7

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

Description and uses ................................................................................................................ I-8

Production process................................................................................................................. I-10

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

Channels of distribution ......................................................................................................... I-12

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

The industry in the United States.................................................................................................. I-14

U.S. producers ........................................................................................................................ I-14

U.S. producers’ trade and financial data................................................................................ I-15

U.S. importers......................................................................................................................... I-16

U.S. imports............................................................................................................................ I-17

Ratio of imports to U.S. production ....................................................................................... I-20

Apparent U.S. consumption and market shares .................................................................... I-20

The industry in China ..................................................................................................................... I-26

Background............................................................................................................................. I-26

Exports.................................................................................................................................... I-26

Tariff or non-tariff barriers to trade ....................................................................................... I-29

The global market.......................................................................................................................... I-29

Note.-Information that would reveal confidential operations of individuals concerns may not be 

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

UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation Nos. 701‐TA‐455 and 731‐TA‐1149 (Review)

Circular Welded Carbon Quality Steel Line Pipe from China

   

DETERMINATION

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

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

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

the antidumping duty on circular welded carbon quality steel line pipe from China would be

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

within a reasonably foreseeable time.2

   

BACKGROUND

The Commission instituted these reviews on December 2, 2013 (78 FR 72114) and

determined on March 7, 2014 that it would conduct expedited reviews (79 FR 15776, March 21,

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 was not a member of the Commission at the time of the

vote.

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

and antidumping duty orders on circular welded carbon quality steel line pipe (“line pipe”) 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 Investigations:  On April 3, 2008, Maverick Tube Corp., Tex‐Tube Co., U.S. Steel

Corp., and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied

Industrial and Service Workers International Union, AFL‐CIO‐CLC (collectively “the domestic

producers”), filed petitions in the original investigations.  On January 7, 2009, the Commission

determined that an industry in the United States was materially injured by reason of subsidized

imports of line pipe from China and on May 6, 2009, the Commission determined that an

industry in the United States was materially injured by reason of less‐than‐fair‐value (“LTFV”)

imports of line pipe from China.  The Department of Commerce (“Commerce”) issued

countervailing and antidumping duty orders on line pipe from China on January 23, 2009 and

May 13, 2009, respectively.2   

These First Reviews:  On January 2, 2014, the domestic producers submitted a joint

response to the December 2, 2013 Federal Register notice instituting these reviews.  On

February 14, 2014, the domestic producers jointly filed comments on the adequacy of the

responses to the notice of institution.  On March 7, 2014, the Commission found each domestic

producer’s individual response to be adequate and further determined that the domestic

interested party group response to the notice of institution was adequate because these

producers accounted for a substantial portion of domestic line pipe production.3

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

                                                      

1 Commissioner Schmidtlein was not a member of the Commission when the Commission voted

on its determinations in these reviews. 2 Confidential Report (“CR”) at I‐3 – I‐4, Public Report (“PR”) at I‐3.  Commissioners Lane,

Williamson, and Pinkert determined that a domestic industry was materially injured by reason of subject

imports of line pipe from China.  Commissioners Aranoff, Pearson, and Okun determined that a

domestic industry was threatened with material injury by reason of subject imports of line pipe from

China.  Circular Welded Carbon Quality Steel Line Pipe from China, Inv. No. 701‐TA‐455 (Final), USITC

Pub. 4055, at 3 nn.2‐3 (Jan. 2009) (“Original CVD Views”); Circular Welded Carbon Quality Steel Line Pipe

from China, Inv. No. 731‐TA‐1149 (Final), USITC Pub. 4075, at 3 nn.2‐3 (May 2009) (“Original AD Views”).  

Because the AD views simply incorporated the prior CVD views by reference, we cite only to the original

CVD views in summarizing the original determinations.

3 CR at I‐1 – I‐2 n.4, PR at I‐2 n.4; Explanation of Commission Determination on Adequacy (EDIS

Doc. No. 529586).
4

group response was inadequate.  In the absence of any circumstances warranting full reviews,

the Commission unanimously determined to conduct expedited reviews of the orders.4

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 orders under

review as follows:

circular welded carbon quality steel pipe of a kind used for oil and gas pipelines, not

more than 406.4 mm (16 inches) in outside diameter, regardless of wall thickness,

length, surface finish, end finish or stenciling.  The term "carbon quality steel" includes

both carbon steel and carbon steel mixed with small amounts of alloying elements that

may exceed the individual weight limits for non alloy steels imposed in the Harmonized

Tariff Schedule of the United States ("HTSUS").  Specifically, the term "carbon quality"

includes products in which (1) iron predominates by weight over each of the other

contained elements, (2) the carbon content is 2 percent or less by weight and (3) none

of the elements listed below exceeds the quantity by weight respectively indicated:

(i) 2.00 percent of manganese,

(ii) 2.25 percent of silicon,

(iii) 1.00 percent of copper,

(iv) 0.50 percent of aluminum,

(v) 1.25 percent of chromium,

(vi) 0.30 percent of cobalt,

(vii) 0.40 percent of lead,

                                                      

4 CR at I‐1 – I‐2 n.4, PR at I‐2 n.4.   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‐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).
5

(viii) 1.25 percent of nickel,

(ix) 0.30 percent of tungsten,

(x) 0.012 percent of boron,

(xi) 0.50 percent of molybdenum,

(xii) 0.15 percent of niobium,

(xiii) 0.41 percent of titanium,

(xiv) 0.l5 percent of vanadium, or

(xv) 0.15 percent of zirconium.

Welded line pipe is normally produced to specifications published by the American

Petroleum Institute ("API") (or comparable foreign specifications) including API A‐25,

5LA, 5LB, and X grades from 42 and above, and/or any other proprietary grades or non‐

graded material.  Nevertheless, all pipe meeting the physical description set forth above

that is of a kind used in oil and gas pipelines, including all multiple‐stenciled pipe with an

API welded line pipe stencil is covered by the scope of this investigation.

Excluded from this scope are pipes of a kind used for oil and gas pipelines that are

multiple‐stenciled to a standard and/or structural specification and have one or more of

the following characteristics:  is 32 feet in length or less; is less than 2.0 inches (50 mm)

in outside diameter; has a galvanized and/or painted surface finish; or has a threaded

and/or coupled end finish.  (The term "painted" does not include coatings to inhibit rust

in transit, such as varnish, but includes coatings such as polyester.) 8

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

consisting of circular welded carbon quality steel line pipe, 16 inches or less in outside

diameter, corresponding to the scope of the investigations.  No party advocated defining the

domestic like product differently.9

In these five‐year reviews, the domestic producers did not object to the definition of the

domestic like product in their response to the notice of institution.10  The record of these

reviews contains no information that would suggest a reconsideration of the domestic like

                                                      

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

Countervailing Duty Order on Circular Welded Carbon Steel Line Pipe from the People’s Republic of China

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

to Paul Piquado, Assistant Secretary for Enforcement and Compliance, at 3‐4 (Mar. 11, 2014).  We note

that Commerce defined the scope of the antidumping duty order simply as “circular welded carbon

quality steel pipe of a kind used for oil and gas pipelines (welded line pipe), not more than 406.4 mm (16

inches) in outside diameter, regardless of wall thickness, length, surface finish, end finish or stenciling.”  

79 Fed. Reg. 19052, 19052‐53 (Apr. 7, 2014).

9 Original CVD Views, USITC Pub. 4055 at 6‐7.

10 Domestic Producers’ Response to Notice of Institution at 26.
6

product definition is necessary.11  Therefore, we again define the domestic like product as

consisting of circular welded carbon quality steel line pipe, 16 inches or less in outside

diameter, corresponding to the scope of the investigations, for the same reasons articulated in

the original investigations.

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 toll‐

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

In the original investigations, no domestic producer was a related party.  Accordingly, in

view of its definition of the domestic like product, the Commission defined a single domestic

industry consisting of all domestic producers of line pipe.13

In these reviews, the domestic producers did not object to the definition of the

domestic industry in their response to the notice of institution.14  The record of these reviews

contains no information that would suggest a reconsideration of the domestic industry

definition is necessary and there again are no related party issues.  Thus, we again define a

single domestic industry consisting of all domestic producers of line pipe, as the Commission

did in the original investigations.

III. Revocation of the Antidumping and Countervailing Duty Orders Would

Likely Lead to Continuation or Recurrence of Material Injury Within a

Reasonably Foreseeable Time  

A. Legal Standards

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

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

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

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

to lead to continuation or recurrence of material injury within a reasonably foreseeable time.”15  

                                                      

11 See CR at I‐9 – I‐18, PR at I‐7 – I‐13. 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 Original CVD Views, USITC Pub. 4055 at 7. 14 Domestic Producers’ Response to Notice of Institution at 26.

15 19 U.S.C. § 1675a(a).
7

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

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

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

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

effects on volumes and prices of imports.”16  Thus, the likelihood standard is prospective in

nature.17  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.18  

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.”19 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.”20

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

                                                      

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

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

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

suspended investigations that were never completed.”  Id. at 883. 17 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.

18 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’”).

19 19 U.S.C. § 1675a(a)(5).

20 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.
8

investigation is terminated.”21  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).22  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.23

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.24  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.25

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.26

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

                                                      

21 19 U.S.C. § 1675a(a)(1). 22 19 U.S.C. § 1675a(a)(1).  Commerce has not issued any duty absorption findings regarding

circular welded carbon quality steel line pipe from China.  CR at I‐4, PR at I‐4.

23 19 U.S.C. § 1675a(a)(5).  Although the Commission must consider all factors, no one factor is

necessarily dispositive.  SAA at 886.

24 19 U.S.C. § 1675a(a)(2).

25 19 U.S.C. § 1675a(a)(2)(A‐D).

26 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.
9

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

more advanced version of the domestic like product.27  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.28

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

therefore, contains limited new information with respect to the line pipe industry in China.

There also is somewhat limited information on the line pipe market in the United States during

the period of review. Accordingly, for our determinations, we rely as appropriate on the facts

available from the original investigations, and the limited new information on the record in

these five‐year reviews.

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

1. Demand Conditions

In the original determinations, the Commission found that the demand for line pipe is

derived from oil and gas exploration and the level of home construction.  Oil and gas

exploration is directly affected by oil and gas prices.  The expansion of drilling for natural gas,

rather than oil exploration, was responsible for much of the increase in demand during the

original period of investigation.30  The domestic producers have not indicated that there have

been any significant changes since the original investigations concerning factors affecting the

demand for line pipe.  

In the original investigations the Commission also found that the domestic industry

enjoyed a period of strong demand until the end of the period of investigation.  Apparent U.S.

consumption increased 57.5 percent from 2005 to 2007, and was slightly lower in January‐

September (interim) 2008 than in interim 2007.  There were a number of large transmission

                                                      

27 19 U.S.C. § 1675a(a)(4).

28 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.

29 19 U.S.C. § 1675a(a)(4).

30 Original CVD Views, USITC Pub. 4055 at 11.
10

projects during the period examined that boosted demand for line pipe.31  However, the U.S.

line pipe market was projected to weaken in 2009 because a global economic downturn had

caused a dramatic decline in the prices of oil and natural gas.32

The record in these reviews indicates that in 2012, apparent U.S. consumption of line

pipe was *** short tons.  By contrast, apparent U.S. consumption ranged from 872,471 in 2005

to 1.4 million short tons in 2006 and 2007 on an annual basis during the original

investigations.33

2. Supply Conditions

Regarding supply, in the original investigations the Commission found that nine

domestic producers accounted for more than 95 percent of U.S. production of line pipe during

the period.  Between 2005 and September 2008, the industry had experienced several mergers

and acquisitions.  Despite this restructuring and some associated production curtailments, the

U.S. producers increased their shipments and capacity over the period.  The volume of subject

imports also increased.34

Nonsubject imports increased from 2005 to 2006, before declining in 2007, and were

higher in interim 2008 than in interim 2007.  Nonsubject import market share fell from 2005 to

2007, as subject import volume rose rapidly.  Major nonsubject sources of line pipe included

Korea, Mexico, Taiwan, Japan, and Brazil.35

The Commission found that due to the growth in imports, the domestic industry’s

market share declined.  However, because of the strong market, the domestic industry’s

capacity, production, and capacity utilization rose from 2005 to 2007.36

In 2012, the domestic industry had a *** percent share of apparent U.S. consumption,

subject imports had a *** percent share and nonsubject imports had a *** percent share.37  

Since 2008, subject imports from China have been present in the U.S. market in very small

quantities.  Nonsubject imports have increased; Korea was the largest source of imports of line

pipe to the U.S. market during every year from 2009 to 2013.38  The domestic industry’s share

of apparent U.S. consumption in 2012 was below that of any year from 2005 to 2007,39 and the

domestic industry contends that its market share continues to fall.  According to data submitted

by the domestic producers, the domestic industry’s market share declined to *** percent

during the first 10 months of 2013.40

                                                      

31 Original CVD Views, USITC Pub. 4055 at 11‐12.

32 Original CVD Views, USITC Pub. 4055 at 12.

33 CR/PR at Table I‐8.

34 Original CVD Views, USITC Pub. 4055 at 12‐13.

35 Original CVD Views, USITC Pub. 4055 at 13.

36 Original CVD Views, USITC Pub. 4055 at 13.

37 CR/PR at Table I‐9.

38 CR/PR at Table I‐6.

39 CR/PR at Table I‐9.

40 Domestic Producers’ Response to Notice of Institution at 25.
11

3. Substitutability

The record in the original investigations indicated that line pipe produced to given

specifications was interchangeable and that the subject imports from China were typically

produced to the same specifications as domestically produced line pipe, resulting in a high

degree of substitutability between the subject imports and the domestic like product.41  

Nothing in the record of these current reviews indicates any significant change in

substitutability.  Accordingly, we again find a high degree of substitutability between subject

line pipe and the domestic like product.

4. Other Conditions

Both domestic and Chinese producers indicated during the original investigations that

line pipe is typically produced on the same equipment and with the same workers that produce

other forms of welded pipe, in particular standard pipe, oil country tubular goods (“OCTG”),

and large diameter line pipe.  Thus, producers of other forms of welded pipe could shift their

production to subject merchandise in response to changes in demand.42

The Commission found that purchasers generally bought line pipe on the spot market

and negotiated prices for each transaction.  For pipeline projects, the end users could solicit

bids directly from a manufacturer for a contract.  The record also indicated that line pipe

produced to given specifications was interchangeable and that the subject imports from China

were typically produced to the same specifications as domestic line pipe, resulting in a high

degree of substitutability between the subject imports and domestic line pipe.43

The Commission found that the domestic industry’s cost of goods sold (“COGS”)

increased from 2005 to 2007, with raw material costs responsible for much of the increase as

they accounted for approximately 75 percent of COGS.  Prices for hot‐rolled steel, the primary

input for production of line pipe, reached their peak in May 2008, then dropped sharply during

the fourth quarter of 2008.44

During the original investigations, domestic producers sold to both end users and

distributors.  U.S. producers sold a majority of their line pipe to end users in 2007, although in

2005 and 2006 they made most of their sales to distributors.  Commodity grades of line pipe

tended to be sold through distributors and, as a result, importers shipped virtually all their

shipments to distributors during the period.45

                                                      

41 Original CVD Views, USITC Pub. 4055 at 13‐14.

42 Original CVD Views, USITC Pub. 4055 at 13.

43 Original CVD Views, USITC Pub. 4055 at 13‐14. 44 Original CVD Views, USITC Pub. 4055 at 14.

45 Original CVD Views, USITC Pub. 4055 at 14.
12

The most commonly sold lengths of U.S.‐produced line pipe were double random

lengths, as were the most commonly sold lengths of imported line pipe.  A substantial amount

of imported line pipe was sold as single random lengths. 46

Nothing in the record of these reviews indicates that the above‐mentioned conditions

have changed appreciably since the original investigations.

C. Likely Volume of Subject Imports

1. Original Investigations

The Commission found in the original investigations that the volume of subject imports

increased rapidly, by over 1,400 percent between 2005 and 2007.  Despite a large increase in

apparent U.S. consumption, the subject imports captured substantial market share from both

the domestic industry and nonsubject imports.  The market share of subject imports, as

measured by quantity, rose from 1.8 percent in 2005 to 17.2 percent in 2007, while the

domestic industry’s market share declined from 59.9 percent in 2005 to 52.9 percent in 2007.  

Nonsubject imports lost market share, declining from 38.3 percent of the market in 2005 to

30.0 percent in 2007.  The ratio of the quantity of subject imports to U.S. production rose from

2.7 percent in 2005 to 30.7 percent in 2007.47

The Commission found that subject imports were lower in interim 2008 than in interim

2007, and attributed the decline to the filing of the petitions in April 2008.  Consequently, the

Commission accorded less weight to the 2008 data in its analysis.48  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.49

                                                      

46 Original CVD Views, USITC Pub. 4055 at 14. 47 Original CVD Views, USITC Pub. 4055 at 15.  Commissioners Aranoff, Pearson, and Okun

likewise found, in the discussion of their affirmative threat of material injury determinations, that

subject imports captured substantial market share from both the domestic industry and nonsubject

imports as nonsubject imports’ market share declined.  The domestic industry’s overall loss of market

share to subject imports was due in part to the rapid increase in subject imports.  Original CVD Views,

USITC Pub. 4055 at 21.

48 Original CVD Views, USITC Pub. 4055 at 15.  Commissioners Aranoff, Pearson, and Okun also

attributed the declines in subject imports in 2008 to the filing of the petitions.  Original CVD Views,

USITC Pub. 4055 at 21.

49 Original CVD Views, USITC Pub. 4055 at 15.  Commissioners Aranoff, Pearson, and Okun found

that China was the world’s largest producer of welded pipe products.  Current Chinese production

capacity for line pipe was estimated to total 8.5 million short tons.  They noted that welded pipe and

tube production capacity in China was projected to increase further and that much of the new

production would be devoted to export markets, with a substantial share of these exports likely to be

directed to the U.S. market.  Although unused production capacity in China was difficult to quantify, the

limited evidence in the record indicated that the Chinese producers possessed unused capacity

equivalent to approximately 34.6 percent of apparent U.S. consumption in 2007.  There was also the

potential for production facilities in China that were currently being used to produce other pipe

(Continued...)
13

2. Current Reviews

In the current reviews, the available information indicates that the antidumping and

countervailing duty orders have had a disciplining effect on the volume of subject imports of

line pipe from China.  In 2007, the last full year of the original investigations, subject imports

from China totaled 236,358 short tons.  Subject imports fell to 127,511 short tons in 2008,

2,313 short tons in 2009, and have thereafter remained at low levels.  In 2012, several years

after the orders were imposed, they totaled 8,449 short tons.50

In the original investigations, the Commission did not receive any completed

questionnaires from producers of line pipe in China during the preliminary phase of the original

investigations and only received one completed questionnaire in the final phase of the

investigations.  Consequently, information in the original investigations concerning the subject

industry was limited.51

Although the domestic industry identified 52 known producers or exporters of line pipe

in China in its response to the notice of institution, no foreign producer or exporter of line pipe

participated in these expedited reviews.52  Nonetheless, available record data indicate that the

industry in China continues to manufacture53 and export54 substantial volumes of line pipe and

its overall welded pipe capacity is quite large.55  China continues to be a substantial world

exporter of line pipe, as it was during the original investigations.56

The United States remains an attractive market to the line pipe industry in China.  As

stated above, subject imports remain in the U.S. market despite imposition of the orders.  The

                                                                                                                                                                              

(...Continued)

products to shift to the production of subject line pipe.  In addition, Chinese producers had incentives to

shift to the production of line pipe from standard pipe and other products because of import restrictions

or active investigations in the United States as well as third countries.  The Chinese government had

encouraged the shift to the production and increased exportation of line pipe by imposing a 15 percent

export tax on hot‐rolled strip and other welded pipe products, while providing a 13‐percent value added

tax rebate on exported line pipe.  Original CVD Views, USITC Pub. 4055 at 22‐23.

50 CR/PR at Table I‐8.

51 Original CVD Views, USITC Pub. 4055 at VII‐6.

52 CR at I‐34, PR at I‐26.

53 Because no Chinese producers responded to the notice of institution, data specific to the

production or capacity of subject line pipe in China are unavailable.  However, whereas production of all

welded pipe totaled 23.7 million short tons in 2007, it totaled 40.5 million short tons in 2011, according

to data gathered from the World Steel Association.  CR/PR at Table I‐10.    54 According to data gathered by Global Trade Information Services, China’s exports of line pipe

totaled 745,587 short tons in 2008, and fluctuated at lower levels thereafter.  Chinese exports of line

pipe in 2013 totaled 603,215 short tons.  CR/PR at Table I‐11. 55 According to data obtained from China’s National Bureau of Statistics and provided by the

domestic producers, welded pipe capacity totaled more than 71 million short tons in 2012.  Domestic

Producers’ Response to Notice of Institution, Exh. 6.    56 CR/PR at Table I‐12.  China exported 603,221 short tons of line pipe in 2013, or 23.8 percent of

the world total.  Id.
14

domestic producers have provided information indicating that China has a great deal of unused

capacity to make welded pipe, and that this unused capacity increased during the period of

review. 57  In addition, they claim, the Chinese industry continues to add new capacity to make

welded pipe.58  On the basis of the Chinese producers’ production alone and without taking into

account their unused capacity, the domestic producers maintain that Chinese producers could

***.59

There is also evidence on the record that the Chinese industry has increased ***. 60  

These ***, along with ***, would encourage Chinese producers to increase exports to the U.S.

market upon revocation of the orders.

Chinese producers of welded pipe face export barriers in other markets.  The European

Union (“EU”) maintains antidumping duties on welded steel non‐alloy pipe from China, and

Canada maintains antidumping duties on certain carbon steel welded pipe from China.61  The

increases in capacity and in unused capacity, along with these export barriers, provide an

incentive for the Chinese producers to increase sharply the supply of subject merchandise to

the U.S. market, as they did during the original investigations, should the orders be revoked.

Notwithstanding the imposition of the orders in 2009, subject imports have remained in

the U.S. market.  The Chinese industry has the incentive to increase exports of line pipe to the

United States because of its increased and unused capacity to produce line pipe and the

outstanding orders in the EU on welded steel non‐alloy pipe from China and in Canada on

certain carbon steel welded pipe from China.  We find that subject producers in China are likely,

absent the restraining effects of the orders, to direct substantial and increasing volumes of line

pipe to the U.S. market, as they did during the original investigations.  We find that the likely

volume of subject imports would be significant if the orders were revoked, both in absolute

terms and relative to production and consumption.

D. Likely Price Effects  

1. Original Investigations

In the original investigations, the Commission found that subject imports from China

and domestic line pipe were highly substitutable and that most sales of both the domestic like

product and subject imports were made on the spot market to distributors.  Price, as well as

                                                      

57 The domestic producers reported the Chinese industry’s unused welded pipe capacity was

20.95 million short tons in 2013, an increase of 1.93 million short tons over the 2012 level.  Domestic

Producers’ Response to Notice of Institution at 10‐11; Domestic Producers’ Comments at 12.

58 Domestic Producers’ Response to Notice of Institution at 11‐12.

59 Domestic Producers’ Response to Notice of Institution at 10‐11.  Total apparent consumption

of all welded pipe was *** metric tons in 2012.  Id. 60 Domestic Producers’ Response to Notice of Institution at 12; Domestic Producers’ Comments

at 14.     61 Domestic Producers’ Response to Notice of Institution at 13.
15

quality that meets industry standards, were reported to be the two most important purchasing

factors.62

The Commission’s pricing data showed that subject imports were priced lower than

domestic line pipe in all 56 quarterly comparisons for all four pricing products and undersold

the domestic like product by margins that averaged 30.4 percent.  The Commission found the

underselling to be significant.63  Prices for domestically produced line pipe were generally

steady, only fluctuating within a narrow range from 2005 through the first quarter of 2008,

despite the large growth in apparent U.S. consumption in 2006 and 2007, and concurrent cost

increases.  The Commission found that subject imports prevented price increases that

otherwise would have occurred to a significant degree.  The domestic industry was unable to

raise its prices to cover increases in costs, notwithstanding a substantial increase in demand

from 2005 to 2007.  However, in 2008 when subject imports declined due to the filing of the

petition, the domestic industry was able to increase its prices to cover its increasing costs and

the industry increased its profitability.64

2. Current Reviews

As indicated above, in these reviews we continue to find that subject imports from

China are highly substitutable for line pipe manufactured in the United States.  Nothing in the

record of these reviews indicates that price is no longer 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 these reviews, as well

as the fact that there have been few subject imports since 2008.65  We find that the significant

underselling observed during the original investigations would likely recur if the antidumping

and countervailing duty orders were revoked.  This in turn would likely cause the domestic

industry to lower prices or, as was the case in the original investigations, to forgo price

increases to cover costs.  Given our finding that subject imports would likely increase in the

event of revocation, we conclude that the likely significant volume of subject imports of line

                                                      

62 Original CVD Views, USITC Pub. 4055 at 15‐16.

63 Original CVD Views, USITC Pub. 4055 at 16.  Commissioners Aranoff, Pearson, and Okun made

similar findings in their affirmative threat determinations.  Original CVD Views, USITC Pub. 4055 at 23‐

24.

64 Original CVD Views, USITC Pub. 4055 at 16.  The ratio of COGS to net sales rose from 79.9

percent in 2005 to 86.3 percent in 2007.  Original CVD Views, USITC Pub. 4055 at Table VI‐1.  

Commissioners Aranoff, Pearson, and Okun also found that the subject imports prevented prices

increases for the domestic product that otherwise would have occurred during the period, and only

after the petition was filed could the domestic producers raise prices to cover their rising costs.  They

found subject imports would have further significant depressing and suppressing effects on U.S. prices

and be likely to increase demand for imports.  Original CVD Views, USITC Pub. 4055 at 24.

65 Published data regarding average transaction prices for a combination of domestic and import

shipments appear in CR/PR at Table I‐2 (2013) and Figure I‐1 (2008‐13).
16

pipe from China would again undersell the domestic like product to a significant degree to gain

market share and would have likely price suppressing or depressing effects.

E. Likely Impact66  

1. Original Investigations

In the original investigations, the Commission found that as demand for line pipe

increased, the domestic industry increased its production, capacity utilization, shipments, and

net sales quantities.  Most of the domestic industry’s employment indicators improved over the

period.  The number of production and related workers, aggregate hours worked, aggregate

wages paid, and hourly wages all increased.  There was a small decline in productivity, but the

industry increased its capital expenditures.67

However, even with the increase in the output of the domestic industry during a period

of strong demand, the industry’s profitability and market share suffered.  While growth in

demand enabled the industry to remain profitable, it experienced a 25.9 percent decline in

operating income from 2005 to 2007 and a 49.5 percent decline from 2006 to 2007.  The

industry lost seven percentage points of market share, despite its increased capacity and

production.68

The Commission found that nonsubject imports were present in the market in

significant quantities.  Most purchasers reported that welded line pipe from the major

nonsubject supplying countries was interchangeable with the domestic product.  Yet

nonsubject imports were consistently priced above subject imports, indicating that nonsubject

                                                      

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

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

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

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

title.”  19 US.C. § 1677(35)(C)(iv); see also SAA at 887.  After conducting an expedited review of the

antidumping duty order on line pipe from China, Commerce determined that revocation of the order

would likely lead to continuation or recurrence of dumping at weighted‐average margins of 73.87

percent for individually listed producers/exporters and 101.10 for the PRC‐wide rate.  79 Fed. Reg.

19052, 19053 (Apr. 7, 2014).  In its expedited view of the countervailing duty order, Commerce

determined that revocation of the order would likely lead to continuation or recurrence of

countervailable subsidies ranging from 33.43 to 40.05 percent for individually listed producers/exporters

and 36.74 percent for all others.  79 Fed. Reg. 15313, 15314 (Mar. 19, 2014).      67 Original CVD Views, USITC Pub. 4055 at 17‐18.  Commissioners Aranoff, Pearson, and Okun

made similar findings in their affirmative threat determinations.  Original CVD Views, USITC Pub. 4055 at

24.

68 Original CVD Views, USITC Pub. 4055 at 18.  The operating income margin declined from 16.3

percent in 2005 to 8.9 percent in 2007.  Id. at Table VI‐1.  Commissioners Aranoff, Pearson, and Okun

also found that the domestic industry’s profitability suffered as subject imports increased between 2005

and 2007.   They also found the domestic industry to be vulnerable to material injury from large and

increasing volumes of subject imports.  Original CVD Views, USITC Pub. 4055 at 24‐25.
17

imports did not compete as aggressively and would not have captured market share from the

domestic industry to the same extent as subject imports.  Producers in nonsubject countries

lost substantial U.S. market share to subject imports over the period just as domestic producers

did.69

The Commission noted that the business cycle of the welded line pipe industry was such

that domestic producers must maximize profits during high demand periods to carry them

through the low periods when orders decline due to the cyclical nature of the oil and gas

industries.  By taking market share and suppressing domestic producers’ prices, the subject

imports limited profits of the domestic industry during 2007 when demand was strong.70   In

view of the foregoing, the Commission concluded that subject imports had a significant adverse

impact on the condition of the domestic industry.71

2. Current Reviews

In the current reviews, the available information concerning the domestic industry’s

condition consists of data provided by 10 domestic producers in their joint response to the

notice of institution.  These producers accounted for *** percent of total U.S. production in

2012.72   

Various indicators in the record of these reviews show that the condition of the industry

has improved since the orders were imposed in 2009.  As in the original investigations,

apparent U.S. consumption increased, ***, in terms of quantity, between 2007 and 2012.73  

Domestic capacity appears to have increased,74 and production75 and shipments76 were also

larger in 2012 than in 2007.  Capacity utilization, however, was *** lower in 2012 than in

2007.77

                                                      

69 Original CVD Views, USITC Pub. 4055 at 19.  Commissioners Aranoff, Pearson, and Okun did

not find that likely material injury to the domestic industry could be attributed to the effects of weak

demand or nonsubject imports.  Once subject imports left the market, the industry’s fortunes improved

despite weakening demand.  Also, nonsubject imports were consistently priced above subject imports

during the period, indicating that nonsubject imports did not compete as aggressively and would not

have captured market share from the domestic industry to the same extent as subject imports.  Original

CVD Views, USITC Pub. 4055 at 25.

70 Original CVD Views, USITC Pub. 4055 at 19. 71 Original CVD Views, USITC Pub. 4055 at 20.

72 Domestic Producers’ Response to Notice of Institution at 1, 24.

73 Apparent U.S. consumption was 1.4 million short tons in 2007 and totaled *** tons in 2012.  

CR/PR at Table I‐8. 74 Capacity totaled 1.0 million short tons in 2007 and was higher in 2012, although this reflects in

part the failure of certain domestic producers to allocate capacity properly.  CR/PR at Table I‐4 & note. 75 Production totaled 769,607 short tons in 2007 and *** short tons in 2012.  CR/PR at Table I‐4.

76 U.S. shipments rose from 727,185 short tons in 2007 to *** short tons in 2012.  CR/PR at

Table I‐4.

77 Calculated capacity utilization fell from 74.3 percent in 2007 to *** percent in 2012, but this

reflects in part the failure of certain domestic producers to allocate capacity properly between all

(Continued...)
18

Although the domestic industry accounted for the majority of the U.S. market in 2007,

its share of the market was appreciably lower in 2012.  Whereas the domestic producers’ U.S.

shipments accounted for 52.9 percent of the U.S. market in 2007, they accounted for only ***

percent in 2012.78  This loss of market share did not become a gain for subject Chinese

producers, however.  Their market share was 17.2 percent in 2007, but fell to *** percent by

2012 as a result of the imposition of the orders.  Nonsubject imports gained market share

during this period, rising from 30.0 percent in 2007 to *** percent in 2012.79

The limited financial data show that the domestic industry had improved profitability

after the orders were imposed.  The operating income margin was *** percentage points

higher in 2012 than in 2007.80  The value of net sales was also significantly higher.81  Even

though COGS was significantly higher in 2012 than in 2007,82 the COGS to net sales margin was

significantly lower in 2012 than in 2007.83 84

Based on the record, we find that, should the orders 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 profitability and market share, as they did in the

original investigations, when demand was also strong.

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

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

imports.  In 2012, imports from nonsubject sources had the largest market share of all market

participants.85  We also observe that, despite the large presence of nonsubject imports in the

U.S. market, the domestic industry’s production, shipments, and financial performance were

better in 2012 than in 2007.

Accordingly, we conclude that, if the antidumping and countervailing duty orders were

revoked, subject imports from China would likely have a significant adverse impact on the

domestic industry within a reasonably foreseeable time.

                                                                                                                                                                              

(...Continued)

welded pipe and line pipe not more than 16 inches in diameter in response to the notice of institution.  

CR/PR at Table I‐4 & note.   78 CR/PR at Table I‐9.

79 CR/PR at Table I‐9.

80 The operating income margin was 8.9 percent in 2007 and *** percent in 2012.  CR/PR at

Table I‐4.

81 The value of net sales rose from $780.9 million in 2007 to $*** in 2012.  CR/PR at Table I‐4.

82 COGS was $674.1 million in 2007 and $*** in 2012.  CR/PR at Table I‐4.

83 COGS relative to net sales was 86.3 percent in 2007 and *** percent in 2012.  CR/PR at Table

I‐4.

84 Although, as discussed above, we have some data pertaining to the condition of the domestic

industry, we find the evidence on the record of these reviews to be insufficient for us to make a finding

as to whether the domestic industry is vulnerable to the continuation or recurrence of material injury in

the event of revocation of the antidumping and countervailing duty orders.

85 CR/PR at Table I‐9.
19

IV. Conclusion

For the foregoing reasons, we determine that revocation of the countervailing and

antidumping duty orders on circular welded carbon quality steel line pipe from China would

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

within a reasonably foreseeable time.

I-1

I INFORMATION OBTAINED IN THE REVIEWS

INTRODUCTION

Background

On December 2, 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 or antidumping duty orders on circular welded carbon quality steel line pipe (“line pipe”)

from China would likely lead to the continuation or recurrence of material injury to a domestic 

industry.2 3 On March 7, 2014, the Commission determined that it would conduct expedited

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

relating to the background and schedule of this proceeding:

 

1

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

2

Circular Welded Carbon Quality Steel Line Pipe From China; Institution of Five-Year Reviews, 78 FR 

72114, December 2, 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 a five-year review of the subject countervailing duty and antidumping 

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

Review, 78 FR 72061, December 2, 2013.

4

Scheduling of expedited five-year reviews concerning the countervailing and antidumping duty 

orders on circular welded carbon quality steel line pipe from China, 79 FR 15776, March 21, 2014. The 

Commission received one submission in response to its notice of institution in the subject reviews. A 

joint response was filed on behalf of United States Steel Corporation, Maverick Tube Corporation, 

American Cast Iron Pipe Company, California Steel Industries, Inc., JMC Steel Group, Northwest Pipe 

Company, Stupp Corporation, Tex-Tube Co., TMK IPSCO, and Welspun Tubular LLC USA, U.S. producers 

believed to account for a substantial portion of U.S. production of the domestic like product in 

2012. 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 full reviews, the Commission determined to conduct 

expedited reviews.
I-2

Effective date Action

January 23, 

2009

Commerce’s countervailing duty order on line pipe from China (74 FR 4136) 

http://www.gpo.gov/fdsys/pkg/FR-2009-01-23/pdf/E9-1446.pdf

May 13, 2009

Commerce’s antidumping duty order on line pipe from China (74 FR 22515) 

http://www.gpo.gov/fdsys/pkg/FR-2009-05-13/pdf/E9-11174.pdf

December 2, 

2013

Commission’s institution of first five-year reviews (78 FR 72114) 

http://www.gpo.gov/fdsys/pkg/FR-2013-12-02/pdf/2013-28791.pdf

December 2, 

2013

Commerce’s initiation of first five-year reviews (78 FR 72061) 

http://www.gpo.gov/fdsys/pkg/FR-2013-12-02/pdf/2013-28807.pdf

March 7, 2014

Commission’s determination to conduct expedited five-year reviews (79 FR 15776, 

March 21, 2014)

http://www.gpo.gov/fdsys/pkg/FR-2014-03-21/pdf/2014-06178.pdf

The press release announcing the Commission’s determination concerning adequacy 

and the conduct of expedited reviews can be found at 

http://www.usitc.gov/press_room/news_release/2014/er0307mm1.htm

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

expedited reviews can be found at 

http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11646

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

http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11649

March 19, 2014 

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

(79 FR 15313) 

http://www.gpo.gov/fdsys/pkg/FR-2014-03-19/pdf/2014-05972.pdf

April 7, 2014

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

(79 FR 19052)

http://www.gpo.gov/fdsys/pkg/FR-2014-04-07/pdf/2014-07595.pdf

April 23, 2014 Commission’s vote

May 2, 2014 Commission’s determination
I-3

The original investigations

The original investigations resulted from a petition filed on April 3, 2008, by Maverick 

Tube Corp. (Houston, Texas), Tex-Tube Co. (Houston, Texas), U.S. Steel Corp. (Pittsburgh, 

Pennsylvania), and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied 

Industrial and Service Workers International Union, AFL-CIO-CLC (Pittsburgh, Pennsylvania)

5

alleging that an industry in the United States was materially injured and threatened with 

material injury by reason of subsidized and less-than-fair-value (“LTFV”) imports of line pipe

from China. On November 24, 2008, Commerce determined that countervailing subsidies were 

being provided to producers and exporters of line pipe from China.6 On March 31, 2009, 

Commerce determined that imports of line pipe from China were being sold at LTFV.7 On 

January 7, 2009, the Commission determined that an industry in the United States was 

materially injured by reason of subsidized imports of circular welded line pipe from China.

8 On 

May 6, 2009, the Commission determined that an industry in the United States was materially 

injured by reason of LTFV imports of circular welded line pipe from China.9 Commerce issued

countervailing duty and antidumping duty orders on line pipe from China on January 23, 2009, 

and May 13, 2009, respectively.

 

5 On April 4, 2008, Wheatland Tube Co. (Sharon, Pennsylvania) separately filed an entry of 

appearance in support of the petitions. Counsel for petitioning firm Tex-Tube Co. amended its entry of 

appearance on October 31, 2008, to also include domestic producers Northwest Pipe Co. (Vancouver, 

Washington); Stupp Corp. (Baton Rouge, Louisiana ); and TMK IPSCO Tubulars (Lisle, Illinois); and again 

on November 3, 2008, to add domestic producer American Steel Pipe Division of ACIPCO (Birmingham, 

Alabama). 

6

Commerce examined 30 programs and found the following programs to be countervailable: “Two 

Free, Three Half” Program; Provision of Land for Less ThanAdequate Remuneration; Provision of HotRolled Steel for Less Than Adequate Remuneration; Foreign Trade Development Fund Program (Grants 

and VAT refunds); Export Interest Subsidies; Export Loans; Liaoning Province Grants–Five Points One Line 

Program; Income Tax Credits on Purchases of Domestically-Produced Equipment by Domestically Owned 

Companies; and Preferential Lending of Policy Loans to State-Owned Enterprises and the Steel Industry 

by State-Owned and Controlled Banks. Issues and Decision Memorandum for Final Determination in the 

Countervailing Duty Investigation of Circular Welded Carbon Quality Steel Line Pipe (Line Pipe) from the 

People’s Republic of China, November 17, 2008; Circular Welded Carbon Quality Steel Line Pipe from the 

People’s Republic of China: Final Affirmative Countervailing Duty Determination, 73 FR 70961, November 

24, 2008.

7

Certain Circular Welded Carbon Quality Steel Line Pipe from the People’s Republic of China: Final

Determination of Sales at Less Than Fair Value and Postponement of Final Determination, 74 FR 14514, 

March 31, 2009.

8

Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final),

USITC Publication 4055, January 2009, p. 1.

9

Certain Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 731–TA–1149 

(Final), USITC Publication 4075, May 2009, p.1.
I-4

Commerce’s reviews

Commerce has not conducted any administrative reviews of either the antidumping 

duty or countervailing duty order. Commerce has not issued any duty absorption findings and 

has not conducted any separate new shipper reviews or changed circumstances reviews. 

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

published in the Federal Register on March 19, 2014. Commerce determined that revocation of 

the subject order would likely lead to continuation or recurrence of countervailable subsidies at

rates of 33.43-40.05 percent.10 Commerce’sresults of its expedited review of the subject

antidumping duty order were published in the Federal Register on April 7, 2014. Commerce

determined that revocation of the subject order would likely lead to continuation or recurrence

of dumping at rates of 73.87 – 101.10 percent.

11

Previous and related investigations

The Commission has conducted a number of import relief investigations on line pipe. 

Table I-1 presents information regarding previous Title VII and safeguard investigations

concerning line pipe.

12

 

10 Circular Welded Carbon Quality Steel Line Pipe From the People’s Republic of China: Final Results of 

Expedited Sunset Review of the Countervailing Duty Order, 79 FR 15313, March 19, 2014.

11 Circular Welded Carbon-Quality Steel Line Pipe From the People’s Republic of China: Final Results of 

the Expedited First Sunset Review of the Antidumping Duty Order, 79 FR 19052, April 7, 2014.

12 The Commission also has conducted several investigations that either covered a broad range of 

tubular products (including line pipe) or focused on standard and structural pipe and tube, but included 

certain welded pipe that was dual-stenciled to line pipe specifications. See Circular Welded Carbon 

Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), USITC Publication 4055, January 

2009, p. I-6.
I-5

Table I-1

Line pipe: Previous and related title VII investigations

Investigations Dates

Outcome Number Product / Country Begin End

 701-TA-165, 168 Welded Carbon Steel

Pipes and Tubes from

Brazil and Korea

05/07/1982 12/27/1982 Brazil - terminated after Commission

preliminary affirmative determination

02/08/1983 Korea - Commission final affirmative 

determination;1order revoked by

Commerce effective October 1, 1984

731-TA-212 Welded Carbon Steel Pipes

and Tubes from Venezuela

12/18/1984 02/01/1985 Commission preliminary negative

determination2

701-TA-242 &

731-TA-253

Welded Carbon Steel Pipes

and Tubes from Venezuela

02/28/1985 12/05/1985 Terminated by Commerce following

Commission preliminary affirmative

determination2

 701-TA-252-253 &

 731-TA-272-274

Welded Carbon Steel Pipes

and Tubes from Taiwan,

Turkey, and Yugoslavia

07/16/1985 01/08/1986 Taiwan and Yugoslavia - terminated

by Commerce following Commission

preliminary affirmative determinations

02/21/1986 Turkey - Commission final affirmative

determination;2countervailing duty

order revoked by Commerce effective

January 1, 2000

731-TA-375 Certain Line Pipes and

Tubes from Canada

02/11/1987 03/30/1987 Commission preliminary negative

determination3

TA-201-70

Circular Welded Carbon

Quality Line Pipe

06/30/1999 12/22/1999 Commission affirmative determination

with respect to all countries except

Mexico and Canada;

4

relief ended

effective March 1, 2003.

731-TA1073-1075Circular Welded Carbon

Quality Line Pipe from

China, Korea, Mexico

10/06/2004 12/14/2004 China - terminated by Commerce

following Commission preliminary

affirmative determination

02/17/2005 Korea and Mexico - terminated after

petition withdrawn5

731-TA-1150 Circular Welded Carbon

Quality Steel Line Pipe from

Korea

04/03/2008 11/25/2008 Terminated after petition withdrawn

1 The Commission found small (16 inches or less) diameter welded carbon steel standard, line, and structural pipes and

tubes to constitute a single like product.

2 The Commission found separate like products consisting of welded standard pipe and welded line pipe.

3 The Commission found that the product “like” welded line pipe from Canada was welded line pipe.

Commissioner Brunsdale concurred with reservations, writing that “...while I do not do so here, it appears appropriate to find

that the like product consists of both standard and line pipe.”

4 The Commission found that the domestic product “like or directly competitive” with line pipe (including

multiple-stenciled line pipe) was line pipe. Commissioner Crawford concluded that the record would justify defining the like

or directly competitive product as both line pipe and standard pipe, although she declined to do so.

5 The Commission found small (16 inches or less) diameter welded line pipe to constitute a single like product but in the final

phase sought data on both welded standard pipe and welded line pipe.

Source: USITC Publication 4055, January 2009, p. I-5
I-6

THE PRODUCT

Commerce’s scope

Commerce has defined the subject merchandise as:

circular welded carbon quality steel pipe of a kind used for oil and gas pipelines, not 

more than 406.4 mm (16 inches) in outside diameter, regardless of wall

thickness, length, surface finish, end finish or stenciling. The term “carbon quality steel”

includes both carbon steel and carbon steel mixed with small amounts of alloying

elements that may exceed the individual weight limits for nonalloy steels imposed in the

Harmonized Tariff Schedule of the United States (HTSUS). Specifically, the term

“carbon quality” includes products in which (1) iron predominates by weight over each 

of the other contained elements, (2) the carbon content is 2 percent or less by weight 

and (3) none of the elements listed below exceeds the quantity by weight respectively 

indicated: (i) 2.00 percent of manganese, (ii) 2.25 percent of silicon, (iii) 1.00 percent of 

copper, (iv) 0.50 percent of aluminum, (v) 1.25 percent of chromium, (vi) 0.30 percent of 

cobalt, (vii) 0.40 percent of lead, (viii) 1.25 percent of nickel, (ix) 0.30 percent of 

tungsten, (x) 0.012 percent of boron, (xi) 0.50 percent of molybdenum, (xii) 0.15 percent 

of niobium,(xiii) 0.41 percent of titanium, (xiv) 0.15 percent of vanadium, or (xv) 0.15 

percent of zirconium. Welded line pipe is normally produced to specifications published 

by the American Petroleum Institute (API) (or comparable foreign specifications) 

including API A–25, 5LA, 5LB, and X grades from 42 and above, and/or any other 

proprietary grades or nongraded material. Nevertheless, all pipe meeting the physical 

description set forth above that is of a kind used in oil and gas pipelines, including all 

multiple-stenciled pipe with an API line pipe stencil is covered by the scope of these 

investigations.

13

Excluded from this scope are pipes that are multiple-stenciled to a standard and/or 

structural specification and have one or more of the following characteristics: is 32 feet 

in length or less; is less than 2.0 inches (50 mm) in outside diameter; has a galvanized 

and/or painted surface finish; or has a threaded and/or coupled end finish. (The term 

“painted” does not include coatings to inhibit rust in transit, such as varnish, but 

includes coatings such as polyester.)

The welded line pipe products that are the subject of this order are currently classifiable 

in the HTSUS under subheadings 7306.19.10.10, 7306.19.10.50, 7306.19.51.10, and 

 

13 Circular Welded Carbon Quality Steel Line Pipe from the People’s Republic of China: Final 

Affirmative Countervailing Duty Determination, 73 FR 70961, November 24, 2008.
I-7

7306.19.51.50. While HTSUS subheadings are provided for convenience and customs 

purposes, the written description of the scope of this order is dispositive.14

Beginning with its final countervailing duty determination with respect to line pipe from 

China, Commerce modified the scope to eliminate the overlap that had existed between the 

scope of a recently completed circular welded (standard and structural) pipe investigation and 

that of the subject line pipe investigation. 15

U.S. tariff treatment

Subject line pipe is currently classifiable in the Harmonized Tariff Schedule of the United 

States (“HTS”) under statistical reporting numbers 7306.19.1010, 7306.19.1050, 7306.19.5110, 

and 7306.19.5150.

16 Line pipe imported from China enters the U.S. market at a column 1-

general duty rate of “free.”

Domestic like product and domestic industry

In the final phase of the original investigations, the Commission defined a single 

domestic like product including all welded line pipe, coextensive with the scope of the 

investigations. The Commission observed that “no party advocates defining the domestic like 

product differently” and no new information had been developed since its conclusions in the 

preliminary phase of the investigations to suggest that a different definition was warranted.17 

The Commission did not find any of the U.S. producers to be related parties.18

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

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

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

 

14 Circular Welded Carbon Quality Steel Line Pipe From the People’s Republic of China: Final Results of 

Expedited Sunset Review of the Countervailing Duty Order, 79 FR 15313, March 19, 2014.

15 Circular Welded Carbon Quality Steel Line Pipe from the People’s Republic of China: Preliminary 

Affirmative Countervailing Duty Determination, 73 FR 52297, September 9, 2008; Circular Welded 

Carbon Quality Steel Line Pipe from the People’s Republic of China: Final Affirmative Countervailing Duty 

Determination, 73 FR 70961, November 24, 2008.

16 Questionnaire responses in the original investigations indicated that the amount of subject line 

pipe imported under the statistical reporting numbers for alloy line pipe was minimal. Circular Welded 

Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), USITC Publication 4055, 

January 2009, p. I-10.

17 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), 

USITC Publication 4055, January 2009, p. 6.

18 Circular Welded Carbon Quality Steel Pipe from China, Investigation No. 701-TA-455 (Final), USITC 

Publication 4055, January 2009, p. 7.
I-8

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

industry that were adopted in the original investigations.19 No further comment on the 

domestic like product or domestic industry has been filed with the Commission in this 

proceeding.

Description and uses20

In general, steel pipes and tubes21 are produced in various grades of carbon,stainless, or 

other alloy steel. Tubular productsfrequently are distinguished by the following six end uses as

defined by the American Iron and Steel Institute (“AISI”).

 Standard pipe is ordinarily used for low-pressure conveyance of air, steam, gas,

water, oil, or other fluidsfor mechanical applications. It is used primarily in

machinery, buildings,sprinkler systems, irrigation systems, and water wells rather

than in pipe lines or utility distribution systems. It may carry fluids at elevated

temperatures which are not subject to external heat applications. It is usually

produced in standard diameters and wall thicknessesto American Society for Testing

and Materials (“ASTM”) specifications.

 Line pipe is used for transportation of gas, oil, or water, generally in a pipeline

or utility distribution system. It is produced to API-5L and American Water

Works Association (“AWWA”)specifications.

 Structural pipe and tubing is welded or seamless pipe and tubing generally used for

structural or load-bearing purposes above ground by the construction industry, as well

as for structural members in ships, trailers, farm equipment, and other similar uses. It is

produced in nominal wall thicknesses and sizes to ASTM specificationsin round, square,

rectangular, or other cross-sectionalshapes.

 Mechanical tubing is welded or seamlesstubing produced in a large number of shapes

of varied chemical composition in sizes 3/16 inch to 103⁄4 inches O.D. inclusive for

carbon and alloy material. It is not normally produced to meet any specification other

than that required to meet the end use. It is produced to meet exact O.D. and

decimal wall thickness.

 Pressure tubing is used to convey fluids at elevated temperatures or pressures, or

both, and is suitable to be subjected to heat applications. It is produced to exact

 

19 The Domestic Industry’s Substantive Response To The Notice of Institution, January 2014, p. 23.

20 Unless otherwise noted this information is based on Circular Welded Carbon Quality Steel Line Pipe 

from China, Investigation No. 701-TA-455 (Final), USITC Publication 4055, January 2009, p. I-10.

21 Pipe dimensions(e.g., outside diameter (“O.D.”) and wall thickness) are standardized while tube

dimensions are design-specific. The HTS generally makes no distinction between pipes and tubes.
I-9

O.D. and decimal wall thickness in sizes 1⁄2 inch to 6 inches O.D. inclusive, usually to

specificationssuch as ASTM.

 Oil country tubular goods (“OCTG”) are pipe produced to API specifications and used in

wells to extract oil and natural gas:

o Casing is the structural retainer for the walls of oil or gas wells and coverssizes

41⁄2 to 20 inches O.D., inclusive.

o Tubing is used within casing oil wells to convey oil to ground level and

ordinarily includes sizes 1.050 to 4.500 inches O.D., inclusive.

o Drill pipe is used to transmit power to a rotary drilling tool below ground

level and covers sizes 2 3/8 to 63⁄4 inches O.D., inclusive.

The line pipe subject to these reviews is made from “carbon quality steel” which 

includes both carbon steel and carbon steel combined with small amounts of alloying elements 

that may exceed the individual weight limits for nonalloy steels imposed in the HTS.22 The 

welded line pipe at issue is a circular pipe product not more than 406.4 mm (16 inches) in 

outside diameter, regardless of wall thickness, length, surface finish, end finish or stenciling. 

Line pipe generally is produced in the United States in lengths of 40 feet or greater, and with 

either a bare finish or a black (lacquered) finish to protect the pipe from rust, which is especially 

important for storage in humid climates or for waterborne transportation. End finishes typically 

include square cut or beveled for welding in the field.

The welded pipe at issue includes pipe of a kind used in oil and gas pipelines, whether or 

not stenciled. Such line pipe normally is produced in conformance with the American Petroleum 

Institute’s specification API 5L, and generally bears an API line pipe stencil. A “stencil” is 

information marked by the manufacturer with paint on the outside surface of the pipe 

indicating the specification in conformance with which it has been manufactured. 

The API 5L specification for line pipe indicates that the markings and class (e.g., A-25, A, 

B, and X-42 through X-80), process of manufacture (seamless pipe, electric resistance welded 

pipe, or continuous welded pipe), heat treatment, and test pressure. The API 5L grades define 

the strength level of the pipe and of the steel that is used to make the pipe. For grades A-25 

and X-42 to X-80, the last two digits reflect the tensile strength of the steel. Lower grades of line 

pipe, namely, A-25, grade A, and grade B, have lower strength but have other desirable 

 

22 Specifically, the term “carbon quality” includes products in which (1) iron predominates by weight 

over each of the other contained elements, (2) the carbon content is 2 percent or less by weight and (3) 

none of the elements listed below exceeds the quantity by weight respectively indicated: 2.00 percent 

of manganese, 2.25 percent of silicon, 1.00 percent of copper, 0.50 percent of aluminum, 1.25 percent 

of chromium, 0.30 percent of cobalt, 0.40 percent of lead, 1.25 percent of nickel, 0.30 percent of 

tungsten, 0.012 percent of boron, 0.50 percent of molybdenum, 0.15 percent of niobium, 0.41 percent 

of titanium, 0.15 percent of vanadium, or 0.15 percent of zirconium.
I-10

properties. For example, grade A line pipe is more malleable and more readily weldable than 

pipes of higher grades.23

Production process24

U.S. mills commonly manufacture line pipe by the electric resistance weld (“ERW”) 

process;25 however, the continuous weld (“CW”) process can be used for pipe up to 4.5 inches 

(114.3 mm) in diameter.26 The manufacture of welded line pipe by the ERW process begins with 

coils of hot-rolled sheet steel,27 which are cut by a slitting machine into strips of the precise 

width needed to produce a desired diameter of pipe.28 The slit coils are fed into the tube mills, 

which cold-form the flat ribbon of steel into a tubular cylinder by a series of tapered forming 

rolls. The product then is welded along the joint axis. The welded tube next passes under a tool 

that removes the outside flash resulting from the pressure during welding. Inside flash is 

 

23 The API 5L specification also specifies that “products in compliance with multiple compatible 

standards may be marked with the name of each standard.” Because welded line pipe for use in oil and 

gas pipelines requires higher hydrostatic test pressures and more restrictive weight tolerances than 

standard pipe, pipe that is in conformance with API Specification 5L Grade B automatically is in 

conformance with the less restrictive standard pipe specification of the American Society for Testing and 

Materials, ASTM A-53 Grade B. As a consequence, manufacturers often mark such product with both 

specifications (a practice known as “dual stenciling”) so that it may be applied for either use. Product 

also may be simultaneously in conformance with both Grade B and Grade X-42 of the API 5L 

specification; indeed, much of the line pipe used in the United States meets the specifications of both 

Grades B and X-42. Such product may be marked with API 5L Grade B, API 5L Grade X-42, and ASTM A53 Grade B (a “triple stencil”). Finally, some standard pipe customers require product marked as being in 

compliance with the American Society of Manufacturing Engineers (“ASME”) AS-53, which is identical to 

ASTM A-53; including this information can result in a “quad stencil.”

24 Unless otherwise noted this information is based on Circular Welded Carbon Quality Steel Line Pipe 

from China, Investigation No. 701-TA-455 (Final), USITC Publication 4055, January 2009, p. I-12.

25 ERW is a process where the strip edges are mechanically pressed together and welded. The heat 

for welding is generated by resistance of the steel to the flow of an electric current. In one process, a 

low frequency current (typically 60 to 360 hertz) is conducted to the strip edges by a pair of copper alloy 

discs which rotate as the pipe is propelled under them. A second variation uses high frequency current 

(in the range of 400 to 500 kilohertz) which enters the tubing through shoes which act as sliding 

contacts. An induction coil can also be used with the high frequency current to induce current in the 

edges of the steel. No direct contact between the induction coil and the tubing is required. 

26 CW is a process of forming a seam by heating the steel in a furnace and mechanically pressing the 

formed edges together as it passes through a series of round welding rolls. Successive coils are joined 

together to provide a continuous flow of steel to the welding mill. This process is also known as 

continuous butt welding. See, API, Specification for Line Pipe: API Specification 5L, March 2004, p. 35. 

According to this specification, only grade A-25 can be manufactured using the CW process. 

27 Flat-rolled steel that is more than 0.1875 inch in thickness if more than 48 inches in width, or more 

than 0.230 inch in thickness if 48 inches or less in width, may be called “plate in coils.”

28 The required diameter and wall thickness of a pipe are a function of the intended volume and 

pressure of material that is to flow through the pipe.
I-11

likewise removed by cutting tools. The tube is then subjected to such post-weld heat treatment 

as is required. Such treatment may involve heat treatment of the welded seam only or 

treatment of the full cross-section of the pipe. After heat treatment, sizing rolls shape the tube 

to specific diameter tolerances. The product is cooled and then cut to size at the end of the 

tube mill. The same equipment and workers can be used to produce standard pipe as well as 

other tubular products, most commonly oil country tubular goods (“OCTG”).29

Interchangeability and customer and producer perceptions

As discussed previously, line pipe generally is produced in conformance with API 

specification 5L for use in the transmission of petroleum products through oil and gas pipelines. 

As such, U.S. mills produce the domestic like product in a range of grade, length, size, and wall 

thickness combinations. Certain line pipe can be certified to non-line pipe applications as well 

(generally standard pipe certified to ASTM specification A53 for use in low-pressure conveyance 

of water or gas), however, the scope exclusions discussed previously based on length, diameter, 

surface finish, and end finish eliminate much of this potential overlap. 

In its original investigations, the Commission observed that there was a “high degree of 

substitutability between the subject imports and domestic line pipe.” 30 The Commission 

specifically pointed to use of common specifications.31 Indeed, the majority of U.S. producers’

shipments during January 2005 – September 2008 were in grades A through X56, as were all 

U.S. shipments of imports of line pipe from China.32 The Commission also noted that the most 

commonly sold lengths of U.S.-produced line pipe were double random lengths,

33 as were line 

pipe imported from China, albeit with a substantial amount sold as single random lengths.34

Overall, large majorities of producers and purchasers, as well as generally smaller majorities of 

 

29 Welded OCTG includes casing (the structural retainer for the walls of oil and gas wells) and tubing 

(used with casing to convey hydrocarbons to ground level).

30 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), 

USITC Publication 4055, January 2009, p. 14.

31 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), 

USITC Publication 4055, January 2009, p. 13.

32 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), 

USITC Publication 4055, January 2009, table IV-9.

33 Random lengths are sold without a guarantee they will be a certain length but that pipes will be 

within a set ranges of lengths. Single random lengths are very roughly 20 feet in length and double 

random lengths are roughly 40 feet in length. 

34 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), 

USITC Publication 4055, January 2009, p. 14. U.S. producers also sold substantial volumes of longerlength pipe, unlike U.S. importers. Id. See also table IV-10.
I-12

U.S. importers, reported that line pipe from different sources was “always” or “frequently” 

interchangeable (that is, can be physically used in the same applications). 35

Channels of distribution

During 2005-07, U.S. producers and U.S. importers primarily shipped line pipe to 

distributors. For U.S. producers, distributor sales accounted for 47.3– 60.3 percent of U.S. 

shipments. For U.S. importers, distributor sales accounted for 100 percent of U.S. shipments of 

imported line pipe from China and 97.3 percent of U.S. shipments of imported line pipe from 

nonsubject countries.

36

 

Pricing and related information

In the original investigations, the Commission collected price data for four line pipe 

products. All four price items were API 5L Grades B/X-42, with outside diameters ranging from 

4.5 inches to 12.75 inches. Prices of imports from China were consistently lower than domestic

prices in all quarters for all four products. Margins of underselling ranged from 15.8 to 56.7 

percent. 37

Table I-2 presents pricing data from January 2013 to December 2013 as published by 

Preston Pipe and Tube, in dollars per net (short) ton. Average monthly market prices for small 

diameter and larger diameter line pipe increased from January to December 2013. As

presented in figure I-I, over a longer time horizon U.S. prices for line pipe rose steeply through 

the first nine months of 2008, then declined sharply. Prices recovered partially during 2010-11, 

then fluctuated over the course of 2012-13 (generally weakening in 2012 and strengthening in 

2013).

Table I-2

Line pipe: Average market prices (in dollars per net (short) ton) for line pipe, monthly, 2013

Type of product

Jan 

'13

Feb 

'13

Mar 

'13

Apr 

'13

May 

'13

Jun 

'13

Jul 

'13

Aug 

'13

Sep 

'13

Oct 

'13

Nov 

'13

Dec 

'13

CARBON ERW – 0” 

– 4 1⁄2” 987 982 986 982 991 1,002 1,005 1,011 1,015 1,028 1,021 1,024

CARBON ERW – 5” 

– 16” 1,003 996 1,002 997 1,006 1,014 1,009 1,014 1,017 1,033 1,028 1,031

Note.—Prices are average transaction prices by weighted average value. Prices are a combination of both domestic 

(U.S.) and import shipments.

Source: Data from Preston Pipe & Tube Report, Vols. 26-31. 

 

35 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), 

USITC Publication 4055, January 2009, table II-5.

36 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), 

USITC Publication 4055, January 2009, table II-1.

37 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), 

USITC Publication 4055, January 2009, table V-6.
I-13

 Note.—The reported prices represent the average transaction price (by weighted average value) for the 

 designated products. These prices are a combination of both domestic and import shipments. The 

 domestic prices include both contract and spot market values and are first point of sale (FOB mill). 

 Import values are calculated CIF, duty paid from official U.S. Customs declarations. Import prices may 

 lag behind domestic values by a minimum delay of 90 days due to shipment times. All values are in 

 U.S. dollars per net ton. Land freight has not been included.

Source: Preston Publishing Co., Preston Pipe & Tube Report, February 2009, February 2010, February

 2011, February 2012, February 2013, and February 2014 isues, http://prestonpipe.com/ , 

The principal raw material used in line pipe is hot-rolled steel sheet. Price information 

regarding hot-rolled steel sheet shown in figure I-2.

* * * * * * * *

0

200

400

600

800

1000

1200

1400

1600

1800

2008 2009 2010 2011 2012 2013

Dollars per short ton

Figure I-I

Line pipe: Monthly average prices, January 2008-December 2013

ERW line pipe 0 - 4.5 inches in diameter ERW line pipe 5-16 inches in diameter
I‐14

THE INDUSTRY IN THE UNITED STATES

U.S. producers

In its original investigations, the Commission collected data from nine U.S. producers of

line pipe that accounted for more than 95 percent of U.S. production in 2007.  Three producers,

California Steel, Maverick, and U.S. Steel, together accounted for *** percent of reported 2007

production of line pipe.38  During 2005‐07, the domestic industry experienced a series of

mergers and acquisitions (involving Atlas Tube, IPSCO, Lone Star Technologies Inc., Maverick,

Sharon Tube, Tenaris, and Wheatland) as well as several mill closures (Wheatland closed four

facilities.

In their substantive response to the Commission’s notice of institution, the domestic

interested parties identified 12 known and currently operating line pipe producers in the United

States.  Table I‐3 lists the ten domestic interested parties (believed to account for *** percent

of total 2012 production), each company’s position on the subject orders, production

location(s), related and/or affiliated firms, and share of reported production of circular welded

pipe in 2012. No U.S. producer directly imports the subject merchandise from China, and none

are known to have any affiliation with Chinese producers of line pipe.39

 

 

38 Circular Welded Carbon Quality Steel Line Pipe From China, Investigation No. 701‐TA‐455  (Final),

USITC Publication 4055, January 2014, p. III‐1.

39 The Domestic Industry’s Substantive Response To The Notice of Institution, January 2, 2009, pp. 23‐

24.
I-15

Table I-3

Line pipe: U.S. producers, positions on the subject orders, U.S. production locations, related 

and/or affiliated firms, and shares of 2012 reported U.S. production

Firm

Position on 

orders U.S. plant location(s)

Share of 

production 

(percent)

American Cast Iron Pipe 

Company Support Birmingham, AL ***

California Steel Industries Support Fontana, CA ***

JMC Steel Industries Support

Sharon, PA

Wheatland, PA 

Warren, OH

Chicago, IL

Little Rock, AK ***

Maverick Tube 

Corporation Support

Hickman, AR

Blytheville, AR 

Counce, TN ***

Northwest Pipe Company Support Atchison, KS ***

Stupp Corporation Support Baton Rouge, LA ***

Tex-Tube Co Support Houston, TX ***

TMK IPSCO Support

Camanche, IA

Blytheville, AR

Wilder, KY ***

U.S. Steel Corp. Support

McKeesport, PA

Lone Star, TX ***

Welspun Pipes Support Little Rock, AR ***

Note.—Does not include the operations of Boomerang Tube (Chesterfield, MO) and Paragon Industries (Sapulpa, 

OK).

Source: The Domestic Industry’s Substantive Response To The Notice Of Institution, January 2, 2014, exhibit 25.

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 reviews of the subject orders. Table I4 presents the data reported by responding U.S. producers from both the original investigations

(2005-07) and the response to the notice of institution (2012). The data presented in the table 

were provided by 9 firms for the period 2005-07 and by 10 firms, accounting for an estimated 

*** percent of the total domestic production of line pipe,for the year 2012.

40

 

40 The Domestic Industry’s Substantive Response To The Notice Of Institution, January 2, 2014, p. 21. 

JMC reported data separately for its Atlas and Wheatland operations.
I-16

Table I-4

Line pipe: U.S. producers’ trade and financial data, 2005-07 and 2012

Item 2005 2006 2007 2012

Capacity 946,891 947,312 1,035,515 ***

Production (short tons) 570,076 749,202 769,607 ***

Capacity utilization (percent) 60.2 79.1 74.3 ***

U.S. shipments

 Quantity (short tons) 522,831 694,012 727,185 ***

 Value (1,000 dollars) 507,703 694,165 757,701 ***

 Unit value (dollars per short ton) 971 1,000 1,042 ***

Net sales 

 Quantity (short tons) 586,170 745,701 741,853 N/A

 Value (1,000 dollars) 574,930 749,831 780,944 ***

 Unit value (dollars per short ton) 981 1,006 1,053 ***

Cost of goods sold (COGS) ($1,000) 457,816 577,876 674,102 ***

Gross profit or (loss) ($1,000) 117,114 171,955 106,842 ***

SG&A ($1,000) 23,599 34,702 37,561 ***

Operating income or (loss) ($1,000) 93,515 137,253 69,281 ***

COGS/sales (percent) 79.6 77.1 86.3 ***

Operating income or (loss)/sales 

(percent)

16.3 18.3 8.9 ***

Note.—Several producers did not allocate capacity between line pipe and other tubular products produced on the 

same equipment. Capacity, therefore, is substantially overstated.

Source: Compiled from Circular Welded Carbon Quality Steel Line Pipe From China, Investigation No. 701-TA-455,

USITC Publication 4055 January 2009, table C-1 and The Domestic Industry’s Substantive Response To The Notice 

Of Institution, January 2, 2014, exhs. 25, 26, 27, 28, and 29.

The domestic interested parties contend that their current condition is extremely 

vulnerable to any increase in the volume of unfairly traded imports. They point to declining 

demand and import penetration.41

U.S. Imports and Apparent Consumption

U.S. importers42

In response to Commission questionnaires issued to importers during the original 

investigations, 31 firms supplied usable data. Responding importers were believed to account 

for 64 percent of the quantity of subject U.S. line pipe imports from China and 54 percent of 

U.S. imports from nonsubject sources during January 2005 to September 2008. During this 

 

41 The Domestic Industry’s Substantive Response To The Notice Of Institution, January 2, 2014, p. 20-

21.

42 All information is from the original staff report unless otherwise indicated. Circular Welded Carbon 

Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), USITC Publication 4055, January 

2009, pp. IV-1 to IV-2.
I-17

timeframe, largest importers of subject line pipe from China were (***) and the largest 

importers of line pipe from other sources were (***).

In their substantive response to the Commission’s notice of institution, the domestic 

interested parties observed that the number of U.S. importers importing the subject 

merchandise from China had likely declined following the issuance of the subject orders. 

Nonetheless, they identified one possible U.S. importer (***) in addition to the original 31

identified by the Commission. 43

U.S. imports

In its original investigations, the Commission found that the subject import volume and 

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

consumption and production in the United States.

44 Data regarding U.S. imports of welded line

pipe from the period 2005 to 2007, 2012 and 2013, are presented in table I-5. The Commission 

noted that the volume of subject imports from China was 15,549 short tons in 2005, and 

increased by over 1400 percent from 2005 to 2007, to 236,358 short tons. This increase in 

subject imports greatly exceeded the increase in apparent U.S. consumption from 2005 to 

2007, and subject imports from China increased their share of the U.S. market from 1.8 percent 

in 2005 to 17.2 percent in 2007 (presented details “Apparent U.S consumption and market 

shares”). As a ratio to U.S. production, subject imports from China increased from 2.7 percent 

in 2005 to 30.7 percent in 2007 (presented in “Ratio of imports to U.S. productions”).

 

43 The Domestic Industry’s Substantive Response To The Notice Of Institution, January 2014, p. 23 and 

exh. 22.

44 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), 

USITC Publication 4055, January 2009, p. 15
I-18

Table I-5

Line pipe: U.S. imports data, 2005-07 and 2012-2013

Item 2005 2006 2007 2012 2013

Quantity (short tons)

China 15,549 169,652 236,358 8,449 2,721

All other 334,091 539,671 412,183 1,065,609 915,947

 Total imports 349,640 709,323 648,541 1,074,059 918,668

Value ($1,000)

China 11,543 105,754 153,881 7,655 2,274

All other 260,929 412,384 315,411 1,053,180 814,018

 Total imports 272,472 518,138 469,292 1,060,835 816,292

Unit value (dollars per short ton)

China 742 623 651 906 836

All other 781 764 765 988 889

 Average, total 779 730 724 988 889

Share of quantity (percent)

China 4.4 23.9 36.4 0.8 0.3

All other 95.6 76.1 63.6 99.2 99.7

 Total 100 100 100 100 100.0

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

Source: Circular Welded Carbon Quality Steel Line Pipe From China, Investigation No. 701-TA-455, USITC 

Publication 4055, January 2009, table C-1. 

The domestic producers participating in the current five-year review acknowledged the 

Commission’s findings in its original investigations.45 Also, the domestic producers stated in 

their response to the Commission’s notice of institution that “in the instant reviews, the 

evidence clearly establishes that the Orders have kept dumped and subsidized imports of 

welded line pipe from China out of the U.S. market.”46 According to U.S. producers, the U.S 

market remains attractive and the number and diversity of nonsubject import sources 

establishes that the U.S. market remains an attractive market for imports generally. Moreover, 

they contend, Chinese welded line pipe producers continue to solicit sales opportunities, even 

from U.S. producers, notwithstanding the subject orders.

47

Table I-6 presents the quantity, value, unit value, and share of quantity for the top

sources of U.S. imports as well as China. Imports of line pipe from China decreased from 

127,511 short tons in 2008 to 2,721 short tons in 2013. In 2013, Korea was the largest source 

of imports, having increased from 241,596 to 570,365 short tons between 2008 and 2013. 

Imports from Korea now account for 62.1 percent of total U.S. imports of line pipe.

 

45 The Domestic Industry’s Substantive Response To The Notice Of Institution, January 2, 2014, pp. 5-

6.

46 Ibid. p. 19.

47 Ibid. pp. 16-17.
I-19

Table I-6

Line pipe: U.S. imports data, 2008-13

Source 2008 2009 2010 2011 2012 2013

Quantity (short tons)

China 127,511 2,313 3,607 7,068 8,449 2,721

Korea (nonsubject) 241,596 143,275 261,252 484,132 596,717 570,365

Mexico (nonsubject) 159,167 67,133 125,144 139,696 113,511 120,202

All other sources 144,466 98,101 100,237 213,636 355,381 225,380

 Subtotal,

 nonsubject 545,229 308,509 486,633 837,464 1,065,609 915,947

 Total imports 672,740 310,822 490,240 844,532 1,074,058 918,668

Value ($1,000)

China 99,206 2,707 2,398 7,342 7,655 2,274

Korea (nonsubject) 230,409 134,776 208,389 451,816 557,473 501,055

Mexico (nonsubject) 230,342 77,567 124,402 164,400 127,365 117,536

All other sources 153,849 117,861 92,675 213,997 368,342 195,427

 Subtotal,

 nonsubject 614,600 330,204 425,466 830,213 1,053,180 814,018

 Total imports 713,806 332,911 427,864 837,555 1,060,835 816,292

Unit value (dollars per short ton)

China 778 1,170 665 1,039 906 836

Korea (nonsubject) 954 941 798 933 934 878

Mexico (nonsubject) 1,447 1,155 994 1,177 1,122 978

All other sources 1,065 1,201 925 1,002 1,036 867 

 Subtotal,

 nonsubject 1,127 1,070 874 991 988 889

 Average 1,061 1,117 845 1,038 1,000 890

Share of quantity (percent)

China 19.0 0.7 0.7 0.8 0.8 0.3

Korea (nonsubject) 35.9 46.1 53.3 57.3 55.6 62.1

Mexico (nonsubject) 23.7 21.6 25.5 16.5 10.6 13.1

All other sources 21.5 31.6 20.4 25.3 33.1 24.5

 Subtotal,

 nonsubject 81.0 99.3 99.3 99.2 99.2 99.7

 Total 100.0 100.0 100.0 100.0 100.0 100.0

Note. -- Because of rounding, figures may not add to totals shown.

Source: Compiled from official statistics of Commerce for HTS statistical reporting numbers 7306.19.1010 and

7306.19.1050. Line pipe may also be imported under the statistical reporting numbers for alloy line pipe, 

(7306.19.5110, and 7306.19.5150) but during the original investigation, these imports were minimal. Circular Welded 

Carbon Quality Steel Line Pipe from China, Inv. No. 701-TA-455 (Final), Publication 4055, January 2009, p. IV-1.n.2.
I-20

Ratio of imports to U.S. production

Table I-7 presents the ratio of U.S. imports to U.S. production 

Table I-7

Line welded pipe: Ratio of imports to U.S. production, 2005-07 and 2012

Item Calendar year

2005 2006 2007 2012

Ratio of imports to U.S. production

China 2.7 22.6 30.7 ***

Nonsubject 

countries 58.6 72.0 53.6 ***

 Total 61.3 94.7 84.3 ***

Source: Compiled from Circular Welded Carbon Quality Steel Line Pipe From China, Investigation No. 701-TA-455 

(Final), USITC Publication 4055, July 2008, table C-1, and The Domestic Industry’s Substantive Response To The 

Notice Of Institution, January 2009.

Apparent U.S. consumption and market shares

Table I-8 presents U.S. shipments of domestic product, U.S. imports and apparent U.S. 

consumption in 2005-07 and 2012. Data on U.S. market share during 2005-07 and 2012 are 

presented in Table I-9. U.S. consumption in terms of quantity increased from 872,471 short tons 

in 2005 to 1,375,726 short tons in 2007. Since then, consumption has increased to *** short tons 

in 2012. The responding producers’ share of consumption was 59.9 percent in 2007 and *** 

percent in 2012.

Table I-8

Line pipe: U.S. shipments of domestic product, U.S. imports, and apparent U.S. consumption, 

2005-07 and 2012

Item 2005 2006 2007 2012

Quantity (short tons)

U.S. producers’ 

U.S. shipments 522,831 694,012 727,185 ***

China 15,549 169,652 236,358 8,449

All other 334,091 539,671 412,183 1,065,609

 Total imports 349,640 709,323 648,541 ***

Apparent U.S. 

consumption 872,471 1,403,335 1,375,726 ***

Value (1,000 dollars)

U.S. producers’ 

U.S. shipments 507,703 694,165 757,701 ***

China 11,543 105,754 153,881 7,655

All other 260,929 412,384 315,411 1,053,180

 Total imports 272,472 518,138 469,292 1,060,835

Apparent U.S. 

consumption 780,175 1,212,303 1,226,993 ***

Source: Compiled from Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 

(Final), USITC Publication 4055, January 2009, table C-1, and The Domestic Industry’s Substantive Response To 

The Notice Of Institution, January 2, 2014.
I-21

Table I-9

Line pipe: U.S. market shares, 2005-07 and 2012

Item 2005 2006 2007 2012

Quantity (short tons)

Apparent U.S. 

consumption 872,471 1,403,335 1,375,726 ***

Value (1,000 dollars)

Apparent U.S. 

consumption 780,175 1,212,303 1,226,993 ***

Share of quantity (percent)

Producer’s share 59.9 49.5 52.9 ***

China 1.8 12.1 17.2 ***

All other sources 38.3 38.5 30.0 ***

 Total imports 40.1 50.5 47.1 ***

Share of value (percent)

Producer’s share 65.1 57.3 61.8 ***

China 1.5 8.7 12.5 ***

All other sources 33.4 34.0 25.7 ***

 Total imports 34.9 42.7 38.2 ***

Source: Compiled from Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 

(Final) USITC Publication 4055, January 2009, table C-1, and The Domestic Industry’s Substantive Response To The 

Notice Of Institution, January 2, 2014.

As the Commission noted in its views, “end users generally use line pipe for gathering oil 

and gas from the point of production, as well as for distributing oil and gas to consumers, and in 

some instances for transmission of oil and gas in extensive pipelines.48 Demand for line pipe is 

therefore derived from oil and gas exploration and the level of home construction. Oil and gas 

exploration is, in turn, directly affected by oil and gas prices.” Figures I-3 through I-7 track these 

factors.

 

48 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final), 

USITC Publication 4055, January 2009, p. 11. 
I-22

Source: Baker Hughes, Inc., North American Rotary Rig Count (January 2000-Current), 

 http://phx.corporate-ir.net/phoenix.zhtml?c=79687&p=irol-reportsother, accessed April 2, 2014. 

0

500

1,000

1,500

2,000

2,500

2008 2009 2010 2011 2012 2013

Active rig count

Figure I-3

U.S. rotary rig count, oil and gas transmission, by month, January 2008-

December 2013

Oil Gas Total
I-23

Source: Baker Hughes, Inc., North American Rotary Rig Count (January 2000-Current), 

 http://phx.corporate-ir.net/phoenix.zhtml?c=79687&p=irol-reportsother, accessed 

 April 2, 2014. 

0

500

1000

1500

2000

2500

2008 2009 2010 2011 2012 2013

Active rig count

Figure I-4

U.S. rotary rig count, land and offshore, by month, January 2008-December 

2013

Land Offshore Total
I-24

Source: RigData. A Division of DataWright Corp., Our Permit Count, annual issues during 2008-13, 

http://www.rigdata.com/index.aspx.

0

500

1000

1500

2000

2500

2008 2009 2010 2011 2012 2013

Drilling permits Figure I-5

U.S. drilling permits, weekly averages, by month, January 2008-December 

2013
I-25

 Note.—Natural gas wellhead prices are unavailable for 2013. 

 Source: U.S. Energy Information Administration, “Petroleum & Other Liquids, Data,” 

 http://www.eia.gov/dnav/pet/pet_pri_spt_s1_d.htm, and “Natural Gas, Data,” 

 http://www.eia.gov/dnav/ng/ng_pri_sum_dcu_nus_m.htm, accessed April 2, 2014. 

Source: U.S. Census Bureau, “Residential Construction, Historical Data,” 

http://www.census.gov/construction/nrc/historical_data/, accessed April 2, 2014. 

0

20

40

60

80

100

120

140

160

2008 2009 2010 2011 2012 2013

January 2008=100

Figure I-6

Indexed prices for West Texas intermediate crude oil and U.S. natural gas 

wellhead prices, by month, January 2008-December 2013

Natural gas Oil

200

400

600

800

1,000

1,200

2008 2009 2010 2011 2012 2013

Housing units (in thousands) Figure I-7

New privately-owned housing units under construction, seasonally 

adjusted, by month, January 2008-December 2013
I-26

THE INDUSTRY IN CHINA

Background

During the final phase of the original investigations, the Commission issued

questionnaires to 65 firms that were identified as possible producers or exporters of line pipe

from China. Only a single firm, Kunshan Pearl, provided data, although the staff report also 

included aggregate information from five companies that produced both standard and 

structural pipe and line pipe, indicating that those five firms were operating with capacity 

utilization of 94.4 percent in 2007 (based on operations for all welded pipe). These five firms 

were: Benxi Northern Steel Pipe Co., Ltd.; Liaoning Northern Steel Pipe Co., Ltd.; Shanghai 

Alison Steel Pipe Co., Ltd.; Tai Feng Qiao Metal Products Co. Ltd.; and Tianjin Lifengyuanda Steel 

Group Co., Ltd.49

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

producers or exporters. The domestic industry identified fifty-two known producers or 

exporters of line pipe.

50

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

available specific to the production or capacity of subject line pipe in China. Table I-10 shows 

Chinese production of all welded pipe during both 2005-07 and 2008-11, the most recent 

period available. Production of all welded pipe in China has increased by over 16 million short 

tons since 2007.

51

Table I-10

Welded pipe: Chinese production of all welded pipe 

Quantity (thousand short tons)

2005 2006 2007 2008 2009 2010 2011

China 17,468 21,213 23,711 27,068 31,425 32,555 40,487

Source: All data gathered from the World Steel Association, Steel Statistical Yearbook 2012, Economics Committee, 

Brussels, 2012.

Exports

The leading markets for Chinese line pipe since 2008 are presented in Table I-11.

 

49 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final),

USITC Publication 4055, January 2009, p. VII-4 – VII-7.

50 The Domestic Industry’s Substantive Response To The Notice Of Institution, January 2, 2014, Exhibit 

2.

51 According to China’s National Bureau of statistics, welded pipe capacity exceeded 53 million short 

tons in 2012, The Domestic Industry’s Substantive Response To The Notice Of Institution, January 2, 

2014, Exhibit 6.
I-27

Table I-11

Line pipe: China’s exports, by quantity and average value, 2008-13

Item 2008 2009 2010 2011 2012 2013

Quantity (short tons)

Venezuela 134 3,828 10,989 20,232 77,723 74,167

Canada 105,965 50,201 58,010 135,348 156,062 68,997

Chile 40,346 18,572 54,396 63,223 74,048 61,942

Mexico 5,333 13,987 7,044 22,714 30,095 38,770

Australia 40,404 10,144 20,044 27,859 65,944 34,472

Colombia 21,044 18,540 28,400 32,369 30,519 32,336

Pakistan 6,703 7,566 8,787 640 6,254 25,396

Hong Kong 8,541 5,743 12,424 15,674 22,545 24,808

Thailand 12,446 7,804 8,342 11,501 12,941 23,172

Bangladesh 3,847 857 2,316 9,009 2,969 23,068

Saudi Arabia 4,105 2,761 3,934 4,588 17,130 15,638

South Africa 6,062 12,411 4,928 11,278 8,343 14,864

Philippines 21,321 12,270 17,722 16,532 9,792 12,287

Oman 231 48,683 0 248 0 10,783

Sudan 25,561 29,004 18,155 10,609 21,657 9,718

All others 443,544 217,391 187,244 180,354 160,802 132,797

 Total 745,587 459,763 442,737 562,178 696,824 603,215

– Table continued on following page 

 
I-28

Table I-11—Continued 

Line pipe: China’s exports, by quantity and average value, 2008-13

Unit value (dollars per short ton)

Venezuela 1,009 985 1,049 772 772 746

Canada 742 607 594 677 661 588

Chile 755 594 656 734 730 730

Mexico 695 563 601 718 651 686

Australia 842 767 618 743 823 746

Colombia 1,075 825 639 690 729 743

Pakistan 772 925 739 719 932 979

Hong Kong 838 610 638 751 714 621

Thailand 734 665 617 752 691 645

Bangladesh 621 661 662 650 695 718

Saudi Arabia 833 706 632 713 676 607

South Africa 841 585 673 712 706 627

Philippines 735 564 604 699 678 593

Oman 838 1,664 (

1

) 1,281 (

1

) 951

Sudan 866 1,084 834 924 1,274 805

All others 796 781 709 833 815 811

 Average 796 850 682 753 759 731

1 Not applicable.

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

 

Source: Global Trade Information Services, Inc., Global Trade Atlas, HTS subheading 7306.19.Data may include 

product that is out of scope of this review, i.e. line pipe greater than 16 inches in diameter and line pipe made from 

alloy steel.
I-29

Tariff or non-tariff barriers to trade

During the original investigations, Chinese respondents identified no outstanding 

antidumping or countervailing duty orders on line pipe in other countries. There were a 

number of findings that covered product that could be produced on shared equipment (namely, 

standard and structural pipe). 52 The domestic industry, as part of its response to the notice of 

institution in these reviews, provided details on barriers to trade in Chinese-origin welded pipe. 

These continued to include antidumping duties on standard and structural pipe in the European 

Union, Canada, and the United States (which also maintains a countervailing duty on standard 

and structural pipe from China). 53

THE GLOBAL MARKET

Table I-12 shows the largest export sources of line pipe in the world. Table I-13 presents 

the largest import markets for line pipe in the world. 

 

52 Circular Welded Carbon Quality Steel Line Pipe from China, Investigation No. 701-TA-455 (Final),

USITC Publication 4055, January 2009, p. VII-8.

53 The Domestic Industry’s Substantive Response To The Notice Of Institution, January 2014, p. 13.
I-30

Table I-12

Line pipe: Global exports by major sources, 2008-13

Item 2008 2009 2010 2011 2012 2013

Quantity (short tons)

United States 139,535 67,714 85,281 67,790 65,058 77,759

China

 

745,595 

 

459,767 

 

442,741 

 

562,184 

 

696,832 603,221 

Korea

 

438,825 

 

238,553 

 

473,737 

 

622,135 

 

714,768 

 

697,511 

Turkey 

 

464,769 

 

494,083 

 

391,248 

 

300,934 

 

355,649 

 

380,372 

All others 958,013 803,092 754,863 947,850 999,647 854,259

 Total 2,746,737 2,063,209 2,147,870 2,500,893 2,831,954 2,535,363

Value ($1,000)

United States 167,802 107,567 137,999 112,876 111,442 117,118 

China

 

593,149 

 

390,884 

 

301,913 

 

423,082 

 

529,023 

 

441,060 

Korea 431,285 183,353 361,386 543,238 595,642 521,527 

Turkey 519,763 492,574 362,941 315,906 319,207 337,618 

All others 1,881,108 1,216,125 862,779 1,244,302 1,274,813 1,012,253

 Total

 

3,073,344

 

2,390,503

 

2,027,018

 

2,639,404

 

2,830,127 

 

2,429,576 

Unit value (dollars per short ton)

United States 1,203 1,589 1,618 1,665 1,713 1,506

China 796 850 682 753 759 731

Korea 983 769 763 873 833 748

Turkey 1,118 997 807 1050 898 888

All others 1,964 1,514 1,143 1,313 1,275 1,185

Average 1,119 1,159 944 1,055 999 958

Note. – The data presented in this table are for HTS 7306.19 which covers all welded line pipe

excluding stainless steel. The data thus include welded line pipe of an outside diameter larger than 16 inches, which 

is not subject to this proceeding.

Source: Global Trade Information Services, Inc., Global Trade Atlas, for HTS subheading 7306.19.
I‐31

Table I-13 

Line pipe: Global imports by major sources, 2008-13 

Item 2008 2009 2010 2011 2012 2013 

 Quantity (short tons) 

United States 680,958 314,002 498,272 865,283 1,110,399 931,987

Algeria 9,618 19,673 58,072 31,783 72,338 191,159

Canada 91,701 36,928 62,147 54,207 79,880 140,246

Australia 91,986 38,133 76,059 38,629 94,523 75,455

All others 878,326 1,077,236 1 1,314,797 1 618,142

 Total 1,752,589 1,485,972 1 2,304,699 1 1,956,988

 Value ($1,000) 

United States 677,041 315,188 403,886 801,771 1,033,459 740,794

Algeria 108,873 53,066 139,508 84,864 80,566 183,081

Canada 115,835 42,484 65,162 73,272 94,185 126,741

Australia 79,911 43,685 58,901 31,780 89,987 69,865

All others 1,107,747 1,285,089 1,027,964 1,411,952 1,682,813 755,089

 Total 2,089,406 1,739,512 1,695,421 2,403,638 2,981,010 1,875,570

 Unit value (dollars per short ton) 

United States 994 1,004 811 927 931 795

Algeria 1 2,697 2,402 2,670 1,114 958

Canada 1,263 1,150 1,049 1,352 1,179 904

Australia 869 1,146 774 823 952 926

All others 1,261 1,193 1 1,074 1 1,222

 Average 1,192 1,171 1 1,043 1 958

1 Anomalous data.

Note.--Data may include product outside the scope of this investigation, i.e. line pipe with diameter larger than 16 

inches and line pipe made from alloy steel. 

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

Source: Global Trade Information Services, Inc. Global Trade Atlas, HTS subheading 7306.19.