U.S. International Trade Commission

Publication 4453 February 2014

Washington, DC 20436

Steel Wire Garment Hangers From China

Investigation No. 731-TA-1123 (Review)
U.S. International Trade Commission

COMMISSIONERS 

 

Irving A. Williamson, Chairman 

Shara L. Aranoff 

Dean A. Pinkert 

David S. Johanson 

Meredith M. Broadbent 

F. Scott Kieff

Robert B. Koopman

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Director of Operations

Stefania Pozzi Porter, Investigator 

Kathryn Lundquist, Industry Analyst 

Carolyn Holmes, Statistical Assistant 

Darlene Smith, Statistical Assistant 

Charles St. Charles, Attorney 

David Goldfine, Attorney 

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

Washington, DC 20436 

www.usitc.gov

Publication 4453 February 2014

Steel Wire Garment Hangers From China

Investigation No. 731-TA-1123 (Review)

CONTENTS

Page

i

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

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

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

Introduction............................................................................................................................... I‐1

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

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

Commerce’s final results of expedited first five‐year review ............................................... I‐3

Commerce’s administrative reviews..................................................................................... I‐4

Commerce’s circumvention reviews..................................................................................... I‐4

Previous and related title VII investigations.......................................................................... I‐5

The product............................................................................................................................... I‐6

Commerce’s scope ................................................................................................................ I‐6

U.S. tariff treatment .............................................................................................................. I‐6

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

Description and uses ............................................................................................................. I‐7

Production process................................................................................................................ I‐9

Interchangeability and customer and producer perceptions............................................. I‐10

Channels of distribution ...................................................................................................... I‐11

Pricing and related information .......................................................................................... I‐11

The industry in the United States ........................................................................................... I‐11

U.S. producers..................................................................................................................... I‐11

Related party issues............................................................................................................. I‐12

U.S. producers’ trade and financial data............................................................................. I‐12

U.S. imports and apparent consumption................................................................................ I‐13

U.S. imports......................................................................................................................... I‐13

Ratio of imports to U.S. production .................................................................................... I‐14

Apparent U.S. consumption and market shares................................................................. I‐15
CONTENTS

Page

ii

The industry in China............................................................................................................... I‐16

Background.......................................................................................................................... I‐16

Capacity and production ..................................................................................................... I‐17

Exports................................................................................................................................. I‐17

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

The global market ................................................................................................................... I‐18

Appendixes

A. Purchaser questionnaire responses..................................................................................A‐1

B. Summary data................................................................................................................... B‐1

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

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

UNITED STATES INTERNATIONAL TRADE COMMISSION

 Investigation No. 731-TA-1123 (Review) 

 STEEL WIRE GARMENT HANGERS FROM CHINA 

DETERMINATION

On the basis of the record1

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

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

1930 (19 U.S.C. ' 1675(c)), that revocation of the antidumping duty order on steel wire garment hangers 

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. 

BACKGROUND 

The Commission instituted this review on September 3, 2013 (78 F.R. 54272) and determined on 

December 20, 2013, that it would conduct an expedited review (79 F.R. 1885, January 10, 1014). 

 

 1 The record is defined in sec. 207.2(f) of the Commission=s Rules of Practice and Procedure (19 CFR ' 207.2(f)). 

3

Views of the Commission

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

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

on steel wire garment (“SWG”) hangers 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.

I. Background

Original Investigation:  The original investigation of SWG hangers from China was

initiated in response to an antidumping duty petition filed on July 31, 2007, by M&B Metal

Products Company, Inc. (“M&B”), a domestic producer of SWG hangers.1  On September 29,

2008, the Commission determined that an industry in the United States was materially injured

by reason of imports of SWG hangers from China that the U.S. Department of Commerce

(“Commerce”) had determined were sold in the United States at less than fair value (“LTFV”).2

  

Commerce issued an antidumping duty order on imports of SWG hangers from China on

October 6, 2008.3  

Current Review:  The Commission instituted this review on September 3, 2013.4

  M&B,

Innovative Fabrication LLP/Indy Hanger (“Indy Hanger”), and U.S. Hanger Co., LLC (“U.S.

Hanger”), domestic producers of SWG hangers (collectively “Domestic Producers”), filed a joint

response to the notice of institution.5  On December 20, 2013, the Commission found the

domestic interested party group response to be adequate.  In the absence of an adequate

respondent interested party group response, or any other circumstances that would warrant a

full review, the Commission determined to conduct an expedited review of the subject order.6

II. 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.”7  The Tariff Act defines “domestic like

                                                       

1 Confidential Report (“CR”) at I‐3, Public Report (“PR”) at I‐2.    2 Steel Wire Garment Hangers from China, Inv. No. 731‐TA‐1123 (Final), USITC Pub. 4034 (Sept.

2008) (“USITC Pub. 4034”).   3 Antidumping Duty Order:  Steel Wire Garment Hangers from the People’s Republic of China, 73

Fed. Reg. 58111 (Oct. 6, 2008); CR at I‐3 & n.7, PR at I‐2 n.7.   4 78 Fed. Reg. 54272 (Sept. 3, 2013); CR at I‐2, PR at I‐2.   5 CR at I‐2 n.4, PR at I‐1 n.4.

6 See Explanation of Commission Determination on Adequacy, SWG Hangers from China, Inv. No.

731‐TA‐1123 (Review), EDIS Doc. No. 524784.    7 19 U.S.C. § 1677(4)(A).
4

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.”8

  The Commission’s

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

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

findings.9

  

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

review as follows:  

Steel wire garment hangers, fabricated from carbon steel wire, whether or not

galvanized or painted, whether or not coated with latex or epoxy or similar

gripping materials, and/or whether or not fashioned with paper covers or capes

(with or without printing) and/or nonslip features such as saddles or tubes.  

These products may also be referred to by a commercial designation, such as

shirt, suit, strut, caped, or latex (industrial) hangers.  Specifically excluded from

the scope of the order are wooden, plastic, and other garment hangers that are

not made of steel wire.  Also excluded from the scope of the order are chrome‐

plated steel wire garment hangers with a diameter of 3.4 mm or greater. 10 11  

SWG hangers are produced primarily for use by the dry cleaning, industrial laundry,

textile, and uniform rental industries.  SWG hangers are designed and formed to permit

clothing and other textiles to be draped and/or suspended from the product.  The four most

common types of dry cleaning hangers are caped hangers, shirt hangers, suit hangers, and strut

                                                      

8 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).

9 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 (Jul. 2003); Steel Concrete Reinforcing Bar from Turkey, Inv. No. 731‐

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

10 Steel Wire Garment Hangers from the People’s Republic of China:  Final Results of Expedited

Sunset Review of the Antidumping Duty Order, 79 Fed. Reg. 1829 (Jan. 10, 2014); see also CR at I‐8, PR at

I‐6.    11 As defined in Commerce’s scope, “[t]he products subject to the order are currently classified

under U.S. Harmonized Tariff Schedule (“HTS”) 7326.20.0020, 7323.99.9060, and 7323.99.9080.” Steel

Wire Garment Hangers from the People’s Republic of China:  Final Results of Expedited Sunset Review of

the Antidumping Duty Order, 79 Fed. Reg. 1829 (Jan. 10, 2014); see also CR at I‐9, PR at I‐6.  HTS

7323.99.9060 was included as a statistical reporting number in the original investigation.  However, this

HTS number was discontinued in 2011.  Subject goods that had been reported under HTS 7323.99.9060

are now covered by HTS 7323.99.9080.  CR at I‐9 n.18, PR at I‐6 n.18.  
5

hangers.  Each of these general categories includes a range of hangers in varying sizes and

finishes, with common distinguishing features.  Caped hangers have a paper cape or cover,

normally white and often with commercial or custom printing.  Strut hangers have a paper tube

that runs along the length of the bottom of the hanger.  The wire does not run through the

paper tube, but is instead folded in at the ends.  This paper tube or strut may be coated with a

nonslip material to prevent the garment from falling off the hanger.  Hangers for light items,

such as basic shirt hangers, are produced using the thinnest wire, while hangers for heavier

items are produced from heavier wire.  SWG hangers are generally painted or epoxy‐coated to

prevent rusting.12  

A. The Original Investigation

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

coextensively with Commerce’s scope, as all SWG hangers.13  In finding a single domestic like

product, the Commission rejected the argument by a respondent that type‐2 vinyl‐dipped

garment hangers (“type‐2 VDG hangers”) were a separate domestic like product.14   

B. The Current Review  

In this review, Domestic Producers agree with the Commission’s definition of the

domestic like product from the original investigation.15  The record contains no information

suggesting that the characteristics and uses of domestically produced SWG hangers have

changed since the original investigation or that the like product definition should be revisited.16  

Therefore, we define the domestic like product as SWG hangers, coextensive with the scope of

Commerce’s review.  

                                                      

12 CR at I‐8‐14, PR at I‐6‐10.

13 USITC Pub. 4034 at 5‐7.

14 USITC Pub. 4034 at 6‐7.  As the Commission explained, the record in the original investigation

indicated that type‐2 VDG hangers were not currently produced in the United States and therefore were

ineligible to be considered as a separate domestic like product.  USITC Pub. 4034 at 7.  Under such

circumstances, the analysis focused on which product was “‘most similar in characteristics and uses with

the article subject to the investigation.’”  USITC Pub. 4034 at 7 (quoting 19 U.S.C. §1677(10)).  Based on

the record in the original investigation, the Commission found that the product most similar in

characteristics and uses to type‐2 VDG hangers consisted of all domestically produced SWG hangers.  

USITC Pub. 4034 at 7.   15 Domestic Producers’ Response to Notice of Institution at 24; Domestic Producers’ Comments

at 2.

16 See generally CR at I‐9‐15, PR at I‐7‐11.   
6

III. 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.”17  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.  If appropriate

circumstances exist, the statute provides the Commission with the authority to exclude from

the domestic industry producers that are related to an exporter or importer of subject

merchandise, or are themselves importers.18  Exclusion of such a producer from the domestic

industry as a related party is within the Commission’s discretion based upon the facts

presented in each investigation.19

In the original investigation, the Commission found that *** domestic producers

qualified as related parties based on their importation of subject merchandise, but concluded

that appropriate circumstances existed to exclude only two of these firms from the domestic

industry, Laidlaw Company LLC (“Laidlaw”) and United Wire Hangers Corporation (“United

Wire”).20  

In this five‐year review, Domestic Producers reported that they did not import SWG

hangers from China during the period of review and that they were not affiliated with any

Chinese producers or exporters of SWG hangers.21  Accordingly, based on the information

available in this expedited five‐year review, there are no related party issues.  We therefore

define the domestic industry as all domestic producers of SWG hangers.    

                                                       

17 19 U.S.C. § 1677(4)(A).  The definitions in 19 U.S.C. § 1677 apply 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.

18 19 U.S.C. § 1677(4)(B); see Torrington Co v. United States, 790 F. Supp. 1161, 1168 (Ct. Int’l

Trade 1992), aff’d mem., 991 F.2d 809 (Fed. Cir. 1993); Sandvik AB v. United States, 721 F. Supp. 1322,

1331‐32 (Ct. Int’l Trade 1989), aff’d mem., 904 F.2d 46 (Fed. Cir. 1990); Empire Plow Co. v. United States,

675 F. Supp. 1348, 1352 (Ct. Int’l Trade 1987).

19 See, e.g., Torrington, 790 F. Supp. at 1168.

20 USITC Pub. 4034 at 9, 11‐13.  In finding that appropriate circumstances existed to exclude

Laidlaw and United Wire from the domestic industry, the Commission underscored that both firms

ceased domestic production of SWG hangers in the latter half of the investigation period and that, by

the end of the period, their primary interests had shifted from domestic production to importation.  

USITC Pub. 4034 at 9, 12‐13; cf. id. at 9 n.41 (finding of Commissioners Williamson and Pinkert that

appropriate circumstances did not exist to exclude Laidlaw and United Wire from the domestic

industry).

21 Domestic Producers’ Response to Notice of Institution at 13‐14.
7

IV. Revocation of the Antidumping Duty Order Would Likely Lead to

Continuation or Recurrence of Material Injury Within a Reasonably

Foreseeable Time  

A. Legal Standards

In five‐year reviews 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.”22  

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.”23  Thus, the likelihood standard is prospective in

nature.24  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.25  

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

                                                       

22 19 U.S.C. § 1675a(a).

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

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

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

were never completed.”  Id. at 883.

24 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.

25 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 F. App’x 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’”).
8

time.”26 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.”27

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

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

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

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

investigation is terminated.”28  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 orders

under review, whether the industry is vulnerable to material injury if the orders are revoked,

and any findings by Commerce regarding duty absorption pursuant to 19 U.S.C. § 1675(a)(4).29  

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.30

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

review were revoked, 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.31  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.32

In evaluating the likely price effects of subject imports if the order under review were

revoked, the Commission is directed to consider whether there is likely to be significant

                                                      

26 19 U.S.C. § 1675a(a)(5).

27 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. 28 19 U.S.C. § 1675a(a)(1).

29 19 U.S.C. § 1675a(a)(1).  Commerce has not made any duty absorption findings regarding

imports of SWG hangers from China.  CR at I‐5, PR at I‐4; 76 Fed. Reg. 27994 (May 13, 2011), 77 Fed.

Reg. 11191 (Mar. 30, 2012), 78 Fed. Reg. 28803 (May 16, 2013), 79 Fed. Reg. 1829 (Jan. 10, 2014).   30 19 U.S.C. § 1675a(a)(5).  Although the Commission must consider all factors, no one factor is

necessarily dispositive.  SAA at 886.

31 19 U.S.C. § 1675a(a)(2).

32 19 U.S.C. § 1675a(a)(2)(A‐D).
9

underselling by subject imports as compared to the domestic like product and whether 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.33

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

review were revoked, the Commission is directed to consider all relevant economic factors that

are likely to have a bearing on the state of the industry in the United States, including but not

limited to the following:  (1) likely declines in output, sales, market share, profits, productivity,

return on investments, and utilization of capacity; (2) likely negative effects on cash flow,

inventories, employment, wages, growth, ability to raise capital, and investment; and (3) likely

negative effects on the existing development and production efforts of the industry, including

efforts to develop a derivative or more advanced version of the domestic like product.34  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 order under review and whether the industry is vulnerable to material injury

upon revocation.35

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

therefore, contains limited new information with respect to the SWG hangers industry in China.  

There also is limited information regarding the SWG hangers market in the United States during

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

available from the original investigation and the limited new information on the record in this

five‐year review.

B. Conditions of Competition and the Business Cycle

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

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

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

the affected industry.”36  The following conditions of competition, several of which also existed

during the original investigation, inform our determinations.

                                                      

33 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.

34 19 U.S.C. § 1675a(a)(4).

35 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.

36 19 U.S.C. § 1675a(a)(4).
10

1. Demand Conditions

In the original investigation, the Commission found that SWG hangers were used

primarily by the dry cleaning, industrial laundry, textile, and uniform rental industries.37  It also

found that apparent U.S. consumption of SWG hangers was moderately higher at the end of the

January 2005‐March 2008 period of investigation (“POI”) than at the beginning of the period.38

In this review, the available information indicates that SWG hangers continue to be used

primarily by the dry cleaning, industrial laundry, textile, and uniform rental industries.39   As

measured by apparent U.S. consumption, demand was *** hangers in 2012.40  It was 3.3 billion

hangers in 2007, the last full year of the original POI.41

2. Supply Conditions

In the original investigation, the Commission received questionnaire responses from

seven U.S. producers of SWG hangers, which accounted for the vast majority of domestic

production during the POI.42   The Commission found that there were three primary sources of

supply of SWG hangers in the U.S. market:  subject imports, nonsubject imports from Mexico,

and domestic product.43  It found that the market share of subject imports dramatically

increased over the POI,44 nonsubject imports held a relatively steady share of the market,45 and

domestic producers’ market share declined.46  It also observed that the POI was marked by U.S.

                                                      

37 USITC Pub. 4034 at 14.

38 Apparent U.S. consumption was 2.9 billion hangers in 2005, 2.8 billion hangers in 2006, and

3.3 billion hangers in 2007; it was 778.8 million hangers in January‐March 2007 (“interim 2007”) and ***

million hangers in January‐March 2008 (“interim 2008”).  USITC Pub. 4034 at 14 n.89. 39 CR/PR at I‐10; PR at I‐7.

40 CR/PR at Table I‐7.    41 CR/PR at Table I‐7.   42 The seven producers were Ganchos N.V., Inc. (“Ganchos”), Laidlaw, M&B, Metro Supply Co.

(“Metro Supply”), Merrick, Shanti Industries, and United Wire.  CR at I‐16, PR at I‐11.

43 USITC Pub. 4034 at 15.

44 Subject imports increased their share of the U.S. market from 36.0 percent in 2005 to 63.2

percent in 2006 and 80.9 percent in 2007.  USITC Pub. 4034 at 15 n.94.  Subject imports’ market share

was 76.2 percent in interim 2007 and *** percent in interim 2008.  USITC Pub. 4034 at 15 n.94.

45 Nonsubject imports accounted for 10.9 percent of the U.S. market in 2005, 11.1 percent in

2006 and 10.4 percent in 2007.  USITC Pub. 4034 at 15 n.95.  Their market share was 12.1 percent in

interim 2007 and *** in interim 2008.  USITC Pub. 4034 at 15 n.95.

46 USITC Pub. 4034 at 15.  U.S. producers’ market share dropped from *** percent in 2005 to

*** percent in 2006 and *** percent in 2007.   U.S. producers’ market share was *** percent in interim

2007 and *** percent in interim 2008.  USITC Pub. 4034 at 18 n.120 & 122.  
11

plant closures and the shuttering of much of the domestic industry’s capacity as the volume of

subject imports increased.47     

In their response to the notice of institution in this review, Domestic Producers

identified six known U.S. producers of SWG hangers:  Eagle Hangers, Inc.; Ganchos; M&B;

Metro Supply; Indy Hanger; and U.S. Hanger.48  The market share of the domestic industry

increased from *** percent in 2007 to *** percent in 2012.49

China remained the largest source of imports of SWG hangers in 2012,50 although

subject imports’ market share declined from 80.9 percent in 2007 to *** percent in 2012.51  The

market share of nonsubject imports increased from 10.4 percent in 2007 to *** percent in

2012,52 with Vietnam and Mexico the largest sources in 2012.53  Domestic Producers assert that

the significant decline in the volume of subject imports following issuance of the antidumping

duty order on SWG hangers from China in 2008 led to increased domestic production as well as

increased imports from nonsubject countries, most notably from Taiwan and Vietnam. 54  They

claim that nonsubject imports from Taiwan and Vietnam declined after 2011, when those

imports became subject to U.S. antidumping and countervailing duty investigations and

subsequent orders.55

                                                      

47 USITC Pub. 4034 at 16.   48 CR at I‐16, PR at I‐11; Domestic Producers’ Response to Notice of Institution at 12.   49 CR/PR at Table I‐7 and Appendix B.

50 CR at I‐19, PR at I‐14.

51 CR/PR at Table I‐7.

52 CR/PR at Table I‐7.    53 CR at I‐19, PR at I‐14.  Vietnam accounted for 24.4 percent of total SWG hanger imports in

2012 and Mexico accounted for 22.9 percent.  Id.

54 Domestic Producers’ Response to Notice of Institution at 15‐17.  According to the Domestic

Producers, in addition to increased production by certain producers, the following five firms entered the

U.S. market after the original investigation:  Indy Hanger, U.S. Hanger, Platinum Hanger, Great Plains

Hanger, and Eagle Hangers.  See e.g., Domestic Producers’ Response to Notice of Institution at 17.  Three

of these firms are not included in Domestic Producers’ listing of current U.S. SWG hanger producers.   55 Domestic Producers’ Response to Notice of Institution at 17‐18.  On December 29, 2011,

M&B, Indy Hanger, and U.S. Hanger filed antidumping duty petitions with respect to SWG hangers from

Taiwan and Vietnam and a countervailing duty petition with respect to SWG hangers from Vietnam.  The

Commission reached affirmative determinations.  Steel Wire Garment Hangers from Taiwan, Inv. No.

731‐TA‐1197 (Final), USITC Pub. 4363 (Nov. 2012); Steel Wire Garment Hangers from Vietnam, Inv. No.

701‐TA‐487 and 731‐TA‐1198 (Final), USITC Pub. 4371 (Jan. 2013).  Commerce issued the antidumping

duty order on SWG hangers from Taiwan in December 2012 and the antidumping and countervailing

duty orders on SWG hangers from Vietnam in February 2013.  Certain Steel Wire Garment Hangers from

the Socialist Republic of Vietnam:  Antidumping Duty Order, 78 FR 8105 (Feb. 5, 2013); Certain Steel Wire

Garment Hangers from the Socialist Republic of Vietnam: Countervailing Duty Order, 78 FR 8107 (Feb. 5,

2013); Steel Wire Garment Hangers from Taiwan:  Antidumping Duty Order, 77 FR 73424 (Dec. 10, 2012).   
12

3. Substitutability

In the original investigation, a majority of responding U.S. producers, importers, and

purchasers reported that the U.S. product, the subject imports, and nonsubject imports were

frequently or always interchangeable and that price was the largest single factor affecting

purchasing decisions.56  The Commission, thus, found that there was a high degree of

substitutability between domestically produced SWG hangers and the subject merchandise.57

There is no indication on the current record that the substitutability between subject

imports and domestic SWG hangers has changed since the original investigation.  Accordingly,

we again find that there is generally a high degree of substitutability between domestic and

subject SWG hangers and that price continues to be an important factor in purchasing

decisions.    

     

C. Likely Volume of Subject Imports

1. Original Investigation  

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

was significant and increased significantly during the POI, both in absolute terms and relative to

consumption and production in the United States.58  Specifically, the volume of subject imports

increased from 1.0 billion hangers in 2005 to 1.8 billion hangers in 2006 and then to 2.7 billion

hangers in 2007.59    

The Commission also found that subject imports made significant gains in market share

over the POI.60  Subject imports’ market share increased from 36.0 percent in 2005 to 63.2

percent in 2006 and 80.9 percent in 2007.61  At the same time, the domestic industry’s market

share declined from *** percent in 2005 to *** percent in 2007.62  Moreover, nonsubject

                                                      

56 USITC Pub. 4034 at 17.  Respondent parties did not dispute the assertion that there was a

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

57 USITC Pub. 4034 at 17.   58 USITC Pub. 4034 at 17.

59 USITC Pub. 4034 at 17.  The volume of subject imports was 593.4 million hangers in interim

2007 and 626.4 million hangers in interim 2008.  Id. at 17 n.113.  The ratio of subject imports to U.S.

production increased from 69.3 percent in 2005 to 260.7 percent in 2006 and 994.5 percent in 2007.  Id.

at 18.

60 USITC Pub. 4034 at 18.  Apparent  U.S. consumption increased 14.9 percent between 2005

and 2007, while the volume of subject imports increased 158.2 percent and gained 44.9 percentage

points of market share over the same period.  Id. at C‐4.     61 USITC Pub. 4034 at 17.    62 As explained above, in the original investigation, the Commission found that appropriate

circumstances existed to exclude two firms (Laidlaw and United Wire) from the domestic industry

definition under the related parties provision of the statute.  These two producers’ share of the U.S.

(Continued...)
13

import volume declined during the POI, both in absolute terms and relative to U.S.

consumption.63  Based on these data, the Commission found that subject imports gained

substantial market share at the direct expense of the domestic industry during the POI.64

2. Current Review

In the current review, the available information indicates that the volume and market

share of subject imports, although lower in 2012 than in 2007, have remained at substantial

levels.  Subject imports were 2.7 billion hangers in 2007, declined the next three years to a

period low of 220.0 million hangers in 2010, and then increased to 588.9 million hangers in

2011 and 941.7 million hangers in 2012.65  Subject imports accounted for *** percent of

apparent U.S. consumption in 2012.66

The data collected in the original investigation indicated that producers of SWG hangers

in China had substantial capacity in 2007 and that their capacity and production increased

during the POI.67  The record in this review contains no current data specific to subject SWG

hanger capacity or production because subject producers in China failed to participate or

furnish information.  Nonetheless, the data available in the record show that subject producers

continue to manufacture SWG hangers and are highly export oriented.  The record indicates

that total Chinese exports within a broader classification that encompasses the subject

merchandise increased substantially from 2008 to 2012.68  This increased export volume

suggests that the increases in capacity, production, and exports observed during the original

POI have continued.69   Accordingly, the available data indicate that the Chinese industry has

the ability to continue to increase exports of the subject merchandise upon revocation.

The United States remains an attractive market to Chinese producers.  Subject imports

have remained in the U.S. market in substantial volumes, and available data suggest that the

United States is the largest export market for a category of iron and steel wire products from

                                                                                                                                                                              

(...Continued)

market was *** percent in 2005, *** percent in 2006, and *** percent in 2007.  USITC Pub. 4034 at 18

n.120.

63 Nonsubject imports’ market share declined from 10.9 percent in 2005 to 10.4 percent in

2007.  USITC Pub. 4034 at 18 n.124.

64 USITC Pub. 4034 at 18.   65 CR/PR at Table I‐4.

66 CR/PR at Table I‐7.            67 USITC Pub. 4034 at Table VII‐2.

68 CR/PR at Tables I‐8, I‐9 (the available data are based on an HTS classification for exports of

iron or steel wire not elsewhere specified or identified, which encompasses subject SWG hangers but

also nonsubject merchandise).    69 The record in the original investigation showed that exports accounted for the overwhelming

majority of Chinese producers’ total shipments of SWG hangers and that home market shipments were

minimal.  USITC Pub. 4034 at Table VII‐2.  
14

China that includes SWG hangers.70  In light of the attractiveness of the U.S. market, we find

that if the order were revoked, the industry in China would likely increase exports of subject

merchandise to the United States.71   

Based on the significant increase in the volume of subject imports during the original

investigation, the continued significant levels of subject imports since then, the capacity and

export orientation of the Chinese industry, and the importance of the U.S. market to Chinese

producers, we find that Chinese producers would have the incentive and ability to ship

significant volumes of additional exports to the United States if the order were revoked.  

Therefore, we find that the likely volume of subject imports, both in absolute terms and relative

to production and consumption in the United States, would be significant if the order were

revoked.

D. Likely Price Effects

1. Original Investigations

In the original investigation, the Commission found that the domestic like product and

the subject imports were largely substitutable and that price was an important factor in

purchasing decisions.  The Commission observed that there was underselling by the subject

merchandise in 94 of 95 quarterly price comparisons, with margins of underselling ranging from

0.1 percent to 57.7 percent and averaging 30.0 percent.  Based on these data, the Commission

found that there was significant price underselling of the domestic like product by subject

imports during the POI.72   

Nonetheless, the Commission found that the record evidence did not indicate that

subject imports significantly depressed or suppressed domestic prices during the POI.  Instead,

it found that the domestic industry sacrificed sales volume in order to maintain its prices in the

face of underselling by subject imports.  On that basis, the Commission found that the

significant underselling by the increasing volumes of subject imports had significant adverse

effects on the domestic industry during the POI.73  

                                                      

70 CR/PR at Tables I‐6, I‐8.

71 Due to the failure of any foreign producer, exporter, or importer of subject merchandise from

China to participate in this review, the record does not contain current information regarding any

existing inventories of subject merchandise or any likely increase in such inventories or whether the

subject producers have the ability to shift production from other products to SWG hangers.  The record

also does not indicate the existence of tariff or non‐tariff barriers specific to SWG hangers from China in

any third‐country markets.  CR at I‐23, PR at I‐17.

72 USITC Pub. 4034 at 19.

73 USITC Pub. 4034 at 20.
15

2. Current Review

The record does not permit pricing comparisons for the review period due to the

expedited nature of the review.  We continue to find, in the absence of record evidence

indicating changes in the conditions of competition, that the domestic like product and the

subject imports are largely substitutable and that price is an important factor in purchasing

decisions.  Consequently, if the order were revoked, subject imports would likely undersell the

domestic like product.  This in turn would likely cause the domestic producers to lose sales

volume, cut prices, or restrain price increases.

For the foregoing reasons, we find that, in the event of revocation, increasing volumes

of low‐priced subject imports would likely have significant adverse price effects on the

domestic industry.

  

E. Likely Impact74

1. Original Investigations

In its original determination, the Commission found that the subject imports had a

significant adverse impact on the domestic industry’s performance.75  Most of the domestic

industry’s performance indicators declined sharply during the POI.76  Although the domestic

industry’s capacity increased slightly, its production, capacity utilization, shipments, and sales

revenue all declined sharply overall from 2005 to 2007 and remained at near period lows during

the interim period.77  The average number of production‐related workers, hours worked, and

wages paid each declined during the POI.78  The domestic industry’s capital expenditures fell

during the POI, although worker productivity increased due to the industry’s layoffs.79

                                                      

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

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

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

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

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

antidumping duty order on SWG hangers from China, Commerce determined that revocation of the

order would likely lead to continuation or recurrence of dumping at weighted average margins ranging

from 15.83 to 55.31 percent for 17 Chinese subject producers/exporters and 187.25 percent for the

PRC‐Entity.  79 Fed. Reg. 1829 (Jan. 10, 2014); CR/PR at Table I‐1.

75 USITC Pub. 4034 at 24.   76 USITC Pub. 4034 at 21.   77 USITC Pub. 4034 at 21‐22.   78 USITC Pub. 4034 at 23.   79 USITC Pub. 4034 at 23.
16

The domestic industry’s financial indicators – operating income, operating margins, and

net sales – declined irregularly during the POI.80  In fact, the domestic industry experienced

operating losses for most of the POI.81  The domestic industry’s ratio of operating income to net

sales followed a similar trend and reflected the industry’s general operating losses.82   

Based on these data, the Commission found that subject imports had a significant

adverse impact on the condition of the domestic industry during the POI.  It found that subject

import levels had increased significantly, both absolutely and relative to domestic production

and consumption, and that subject imports had gained market share at the expense of the

domestic industry, undersold the domestic like product, adversely affected the financial

performance of the domestic industry, and adversely affected the numbers and wages of

domestic workers.83  It also found that significant underselling by subject imports, combined

with the sales volumes lost to subject imports, had caused significant declines in the domestic

industry’s financial performance over the POI.84

   

2. Current Review

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

the domestic industry’s financial performance, consisting of data that Domestic Producers

provided in response to the notice of institution.  The limited record is insufficient for us to

make a finding on whether the domestic industry is vulnerable to the continuation or

recurrence of material injury in the event of revocation of the order.85

In 2012, the capacity of the U.S. producers of SWG hangers was *** hangers, production

was *** hangers, and capacity utilization was *** percent.86  U.S. shipments were *** hangers,

and Domestic Producers reported an operating *** of $*** on sales of $*** hangers, resulting

in an operating *** margin of *** percent.87   

                                                      

80 USITC Pub. 4034 at 23.

81 USITC Pub. 4034 at 23.

82 USITC Pub. 4034 at 23‐24.   83 USITC Pub. 4034 at 24.

84 USITC Pub. 4034 at 24.  In the original investigation, the Commission conducted a

replacement/benefit analysis pursuant to Bratsk Aluminium Smelter v. United States, 444 F.3d 1369

(Fed. Cir. 2006), and determined that nonsubject imports would not have replaced subject imports

during the POI and prevented the domestic industry from benefitting from the imposition of an order.  

USITC Pub. 4034 at 29‐30.    85 Based on the record of this review, Commissioner Pinkert finds that the domestic industry is

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

antidumping duty order on SWG hangers from China.  Although the domestic industry’s performance

has improved in many regards since 2007 (the last year of the original POI), the industry in 2012

continued to have a ***.  CR/PR at Table I‐3.    86 CR/PR at Table I‐3.

87 CR/PR at Table I‐3.
17

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

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

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

domestic industry.  The likely declines in these factors would, in turn, likely have a direct

adverse impact on the domestic industry’s profitability.

In our analysis, we typically examine known factors other than subject imports which

may cause injury so as not to attribute likely injury caused by these factors to the subject

imports.  In this review, however, there are no factors other than the subject imports that are

known to be a likely cause of material injury.

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

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

time.

V. Conclusion

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

on SWG hangers 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

INFORMATION OBTAINED IN THE REVIEW  

INTRODUCTION

Background

Effective September 3, 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 a review to determine whether revocation of the antidumping duty

order on steel wire garment (“SWG”) hangers from China would be likely to lead to the

continuation or recurrence of material injury to a domestic industry.2 3 On December 20, 2013,

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.  The Commission determined that it would conduct expedited

reviews pursuant to section 751(c)(3) of the Act.4  

                                                       1 19 U.S.C. 1675(c). 2 Steel Wire Garment Hangers from China Institution of Five‐Year Reviews, 78 FR 54272, September 3,

2013. All interested parties were requested to respond to this notice by submitting the information

requested by the Commission.

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

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

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

Review, 78 FR 54237, September 3, 2013. 4 Steel Wire Garment Hangers from China; Scheduling of an Expedited Five‐Year Review Concerning

the Antidumping Duty Order on Steel Wire Garment Hangers from China, (79 FR 1885, January 10, 2014),

https://federalregister.gov/a/2014‐00209.

The Commission received one submission in response to its notice of institution in the subject

review.  The submission was filed on behalf of M&B Metal Products Company, Inc. (“M&B”), Innovative

Fabrication LLP / Indy Hanger (“Indy Hanger”), and US Hanger Co., LLC (“US Hanger”), U.S. producers of

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

importers of the subject merchandise from China.
I‐2

The following tabulation presents information relating to the background and schedule

of this proceeding:

Effective date Action 

October 6, 2008 

Commerce’s antidumping duty order on SWG hangers from China (73 FR 58111) 

https://federalregister.gov/a/E8-23569

September 3, 2013 

Commission’s institution of the first five-year review (78 FR 54272) 

https://federalregister.gov/a/2013-21305

September 3, 2013 

Commerce’s initiation of the first five-year review (78 FR 54237) 

https://federalregister.gov/a/2013-21386

December 20, 2013 

Commission’s determination to conduct an expedited five-year review 

(78 FR 1885, January 10, 2014) 

https://federalregister.gov/a/2014-00209

The press release announcing the Commission’s determination concerning 

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

http://usitc.gov/press_room/news_release/2013/er1220ll1.htm

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

expedited reviews, and the Commission’s explanation of its determination can be 

found at http://pubapps2.usitc.gov/sunset/caseProf/show/10243

January 10, 2014 

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

order 

https://federalregister.gov/a/2014-00170

February 6, 2014 Commission’s vote 

February 18, 2014 Commission’s determination 

The original investigations

The original investigation resulted from a petition filed on July 31, 2007, by M&B

Metal Products Company, Inc. (“M&B”), Leeds, AL, alleging that an industry in the United States

was materially injured and threatened with material injury by reason of less‐than‐fair‐value

(“LTFV”) imports of SWG hangers from China. On August 14, 2008, Commerce determined that

imports of SWG hangers from China were being sold at LTFV.

5 On September 29, 2008, the

Commission issued its determination that an industry in the United States was materially

injured by reason of LTFV imports of SWG hangers from China.6 Commerce issued an

antidumping duty order of SWG hangers from China on October 6, 2008.7  

                                                       5 Steel Wire Garment Hangers from the People's Republic of China: Final Determination of Sales at

Less Than Fair Value, 73, FR 47587, August 14, 2008. Steel Wire Garment Hangers from the People's

Republic of China: Amended Final Determination of Sales at Less Than Fair Value, 73 FR 53188,

September 15, 2008.

6 Steel Wire Garment Hangers from China Determination, 73 FR 57654, October 3, 2008. 7 Steel Wire Garment Hangers from the People's Republic of China: Notice of Antidumping Duty Order,

73 FR 58111, October 6, 2008.
I‐3

Commerce’s final results of expedited first five‐year review

Commerce’s results of its expedited sunset review of the subject antidumping duty

order were issued on January 10, 2014. Commerce determined that revocation of the

antidumping duty order on SWG hangers from China would likely lead to continuation or

recurrence of dumping at weighted‐average margins of 15.83 to 55.31 percent for individually

listed exporters/producers and 187.25 percent for the PRC‐Entity rate. 8

   

Table I‐1 presents Commerce’s antidumping duty margins with respect to imports of

SWG hangers from China.

Table I-1 

SWG hangers: Commerce’s original and first five-year review weighted-average dumping 

margins, by firm

Exporter/producer

Dumping margin (percent) 

Original investigation First five-year review 

Shanghai Wells Hanger Co., Ltd. 15.83 15.83 

Shaoxing Metal Companies: 

 Shaoxing Gangyuan Metal Manufacured Co., Ltd. 

 Shaoxing Andrew Metal Manufactured Co., Ltd. 

 Shaoxing Tongzhou Metal Manufactured Co., Ltd 94.78 94.78 

Jiangyin Hongji Metal Products Co., Ltd. 55.31 55.31 

Shaoxing Meideli Metal Hanger Co., Ltd. 55.31 55.31 

Shaoxing Dingli Metal Clotheshorse Co., Ltd. 55.31 55.31 

Shaoxing Liangbao Metal Manufactured Co., Ltd. 55.31 55.31 

Shaoxing Zhongbao Metal Manufactured Co., Ltd. 55.31 55.31 

Shangyu Baoxiang Metal Manufactured Co., Ltd. 55.31 55.31 

Zhejiang Lucky Cloud Hanger Co., Ltd. 55.31 55.31 

Pu Jiang County Command Metal Products Co., Ltd. 55.31 55.31 

Shaoxing Shunji Metal Clotheshorse Co., Ltd. 55.31 55.31 

Ningbo Dasheng Hanger Ind. Co., Ltd. 55.31 55.31 

Jiaxing Boyi Medical Device Co., Ltd. 55.31 55.31 

Yiwu Ao-Si Metal Products Co., Ltd. 55.31 55.31 

Shaoxing Guochao Metallic Products Co., Ltd. 55.31 55.31 

PRC-wide rate 187.251 187.25 

1

 The original investigation’s China-wide entity includes Tianjin Hongtong Metal Manufacture Co., Ltd. 

Source: Steel Wire Garment Hangers from the People's Republic of China: Amended Final Determination of 

Sales at Less Than Fair Value, 73 FR 53188, September 15, 2008, and Steel Wire Garment Hangers from the 

People’s Republic of China: Final Results of Expedited Sunset Review of the Antidumping Duty Order, 79 FR 

1829, January 10, 2014.

 

                                                       8 Steel Wire Garment Hangers from the People's Republic of China: Final Results of the Expedited

Sunset Review of the Antidumping Duty Order, January 10, 2014, 79 FR 1829.
I‐4

Commerce’s administrative reviews

Commerce has completed three administrative reviews of the antidumping duty order

on SWG hangers from China. The results of the administrative reviews are shown in table I‐2.   

Table I-2 

SWG hangers: Administrative reviews of the antidumping duty order 

Date results 

published 

Period of 

review 

Producer or exporter 

Weightedaverage 

margin 

(percent) 

May 13, 2011 

(76 FR 27994) 

3/25/2008 – 

11/30/09 

Shanghai Wells Hanger Co.Ltd. and/or Hong Kong 

Wells Limited 0.15 

Shaoxing Dingli Metal Clotheshorse Co., Ltd 1.71 

Shaoxing Gangyuan Metal Manufactured Co. Ltd 1.71 

Shaoxing Andrew Metal Manufactured Co., Ltd 1.71 

Shaoxing Tongzhou Metal Manufactured Co. Ltd 1.71 

Shaoxing Shunji Metal Clotheshorse Co. Ltd 1.71 

Yiwu Ao-Si Metal Products Co., Ltd 1.71 

Shangyu Baoxiang Metal Manufactured Co., Ltd 1.71 

Jiaxing Boyi Medical Device Co., Ltd 1.71 

Pu Jiang County Command Metal Products Co. Ltd 1.71

Shaoxing Meideli Metal Hanger Co., Ltd 1.71

Shaoxing Zhongbao Metal Manufactured Co., Ltd 1.71 

Zhejiang Lucky Cloud Hanger Co., Ltd 1.71 

Ningbo Dasheng Hanger Ind. Co., Ltd 1.71 

Shaoxing Guochao Metallic Products Co. Ltd 1.71 

Shanghai Jianhai International Trade Co., Ltd 1.71 

Shaoxing Liangbao Metal Manufactured Co., Ltd 1.71 

PRC-Wide Entity 187.25 

March 30, 2012 

(77 FR 11191) 

10/01/09 – 

09/30/10 

Shanghai Wells Hanger Co.,Ltd. and/or Hong Kong 

Wells Limited 0.81 

PRC–Wide Entity 187.25 

May 16, 2013 

(78 FR 28803) 

10/01/10 – 

09/30/11 

Shanghai Wells Group 0.00 

PRC-Wide Entity 187.25 

Source: Cited Federal Register notice. 

Commerce’s circumvention reviews

Commerce has conducted one circumvention review of the antidumping duty order.  

The review resulted in an affirmative final determination of circumvention of the antidumping

duty order regarding Quyky’s and Angang’s Vietnamese exports of garment hangers produced

from PRC‐origin.9

                                                       9 Steel Wire Garment Hangers from the People’s Republic of China:  Affirmative Final Determination

of Circumvention of the Antidumping Duty Order, 76 FR 66895, October 28, 2011.
I‐5

Previous and related title VII investigations

On November 27, 2002, CHC, M&B, and United Wire, producers of steel wire garment

hangers, filed a petition pursuant to section 421 of the Trade Act of 1974 alleging that certain

steel wire garment hangers from China were being imported into the United States in such

increased quantities or under such conditions as to cause or threaten to cause market

disruption to the domestic garment hanger industry.  On January 27, 2003, the Commission

voted unanimously to determine that Chinese imports were causing market disruption. The

Commission found that shipments from China had increased by more than 800 percent from

1997 to 2001 and had more than doubled between January‐September 2001 (interim 2001)

and January‐September 2002 (interim 2002). The Commission also found that rapidly increasing

imports from China were a significant cause of material injury to the domestic industry.

Accordingly, on February 5, 2003, the Commission majority voted to propose to the President a

remedy consisting of an additional duty on imports of garment hangers from China for a three‐

year period, beginning at 25 percent ad valorem in the first year, 20 percent ad valorem in the

second year, and 15 percent ad valorem in the third year. On April 25, 2003, the President

opted to grant expedited consideration for trade adjustment assistance claims by U.S. workers

displaced by foreign competition but not to impose duties, citing “a strong possibility that if

additional tariffs on Chinese wire hangers were imposed, production would simply shift to third

countries, which could not be subject to section 421’s China‐specific restrictions.”10

On December 29, 2011, M&B Metal Products Company, Inc.; Innovation Fabrication

LLC/Indy Hanger; and US Hanger Company, LLC filed an antidumping  duty petition against

Taiwan, and antidumping and  countervailing duty petitions against imports of SWG hangers

from  Vietnam.11  Following affirmative determinations by Commerce, on November 30, 2012,

the Commission found that the domestic industry was materially injured by reason of imports

of SWG hangers from Taiwan and Vietnam.12  Commerce issued antidumping duty orders on

Taiwanese and Vietnamese imports of SWG hangers with margins ranging from 69.98 percent

to 125.43 percent for Taiwan, and 157.00 percent to 220.68 percent ad valorem for Vietnam.

Commerce issued countervailing duties on Vietnam, ranging from 31.58 percent to 90.42

percent ad valorem.13

                                                       10 Certain Steel Wire Garment Hangers from China, Inv. No. TA‐421‐2, USITC Publication 3575,

February 2003, pp. 1‐3 and I‐2; Presidential Determination on Wire Hanger Imports from the People’s

Republic of China, 68 FR 23019, April 25, 2003; Steel Wire Garment Hangers from the People’s Republic

of China: Final Determination of Sales at Less Than Fair Value, 73 FR 47587, August 14, 2008. 11 Steel Wire Garment Hangers from Taiwan and Vietnam: Institution of Antidumping and

Countervailing Duty Investigations and Scheduling of Preliminary Phase Investigations, 77 Fed. Reg. 806

(January 6, 2012) 12 Steel Wire Garment Hangers from Taiwan, Investigation No. 731‐TA‐1197 (Final). USITC Publication

4363, November 2012, p. 3, and Steel Wire Garment Hangers from Vietnam, Investigation Nos. 701‐TA‐

487 and 731‐TA‐1198 (Final), USITC Pub. 4371, January 2013, p. 3.

13 The antidumping order on steel wire garment hangers from Taiwan was issued in December 2012,

and the antidumping and countervailing duty orders on Vietnam were issued in February 2013. Steel

Wire Garment Hangers From Taiwan: Antidumping Duty Order, 77 FR 73,424 (December 10, 2012); Steel
I‐6

THE PRODUCT

Commerce’s scope

Commerce has defined the imported product subject to this investigation as:14

Steel wire garment hangers, fabricated from carbon steel wire, whether or not

galvanized or painted, whether or not coated with latex or epoxy or similar gripping

materials, and/or whether or not fashioned with paper covers or capes (with or without

printing) and/or nonslip features such as saddles or tubes. These products may also be

referred to by a commercial designation, such as shirt, suit, strut, caped, or latex

(industrial) hangers. Specifically excluded from the scope of the order are wooden,

plastic, and other garment hangers that are not made of steel wire. Also excluded from

the scope of the order are chrome‐plated steel wire garment hangers with a diameter of

3.4 mm or greater.

On June 29, 2012, Commerce gave notice that Robert H. Ham Associates Ltd.’s retail

display hangers are not within the scope of the antidumping duty order.15  On August 20, 2012,

Commerce gave notice that Great American Hanger Company’s four wooden hangers, three

steel wire, swivel looped‐neck hangers, and one vinyl‐coated flattened steel hanger are not

within the scope of the antidumping duty order.16  On February 8, 2013, Commerce gave notice

that PetEdge Inc.’s steel wire Canine Pet Fashion Hangers, with dog‐shaped, rubber tipped

hooks, are not within the scope of the antidumping duty order.17

U.S. tariff treatment

Imports of SWG hangers subject to this review are currently imported under the

following Harmonized Tariff Schedule of the United States (“HTSUS”) statistical reporting

numbers: 7326.20.0020 and 7323.99.9080.18 The column 1‐general (normal trade relations)

rate of duty for subheading 7326.20.0020 is 3.9 percent ad valorem and the general rate of

duty for 7323.99.9080 is 3.4 percent ad valorem.

                                                                                                                                                                              

Wire Garment Hangers From the Socialist Republic of Vietnam: Antidumping Duty Order, 78 FR 8,105

(February 5, 2013); Certain Steel Wire Garment Hangers From the Socialist Republic of Vietnam:

Countervailing Duty Order, 78 FR 8,107 (February 5, 2013). 14 Steel Wire Garment Hangers from the People’s Republic of China: Final Results of Expedited Sunset

Review of the Antidumping Duty Order, 79 FR 1829, January 10, 2014.

15 Notice of Scope Rulings, 77 FR 38767, June 29, 2012.

16 Notice of Scope Rulings, 77 FR 50084, August 20, 2012. 17 Notice of Scope Rulings, 78 FR 50084, February 8, 2013.

18 HTS 7323.99.9060 was included as a statistical reporting number in the original investigation.

However, this HTS was discontinued in 2011. Subject goods that had been reported under HTS

7323.99.9060 are now covered by HTS 7323.99.9080.
I‐7

Domestic like product and domestic industry

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

like product comprised of all SWG hangers that correspond to the scope of the investigation.

The Commission rejected respondents’ request to exclude type‐2 vinyl‐dipped garment

hangers. The Commission found that these hangers did not differ substantially from other SWG

hangers and concluded that all shared similar physical characteristics and end uses; channels of

distribution; manufacturing facilities, production process, and employees; producer and

customer perceptions; and price were generally interchangeable.19 The Commission excluded

*** from the domestic industry.20

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

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

the domestic interested parties’ response to the Commission’s notice of institution, they

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

domestic industry as defined by the Commission in the original investigation.21  

Description and uses22

SWG hangers are produced primarily for use by the dry cleaning, industrial laundry,

textile, and uniform rental industries.  SWG hangers are designed and formed to permit

clothing and other textiles to be draped and/or suspended from the product.  The four most

common varieties of dry‐cleaning hangers are caped hangers, shirt hangers, suit hangers, and

strut hangers (figure I‐1).  Each of these general categories includes a range of hangers in

varying sizes and finishes, but with common distinguishing features.  Caped hangers have a

paper “cape” or cover, normally white and often with commercial or custom printing.  Strut

hangers have a paper tube that runs along the length of the bottom of the hanger.  The wire

does not run through the paper tube, but is instead folded in at the edges. This paper tube, or

“strut,” may be coated with a nonslip material to prevent the garment from falling off of the

hanger.  Hangers for light items, such as the basic shirt hanger, are produced using the thinnest

wire, while hangers for heavier items, such as suit hangers, are produced from heavier wire.

SWG hangers are generally painted and sold in a variety of colors.  Despite some obvious

differences in finishes and paper accessories, all of these hangers share the same basic

configuration, characteristics, and end use.

                                                       19 Steel Wire Garment Hangers from China, Investigation No. 731‐TA‐1123 (Final), USITC Publication

4034, September 2008, pp. 5‐6.

20 Steel Wire Garment Hangers from China, Investigation No. 731‐TA‐1123 (Final), USITC Publication

4034, September 2008, pp. 9‐13. 21 M&B Metal Products, Innovative Fabrication LLP/Indy Hanger, and US Hanger’s Response to the

Commission’s Notice of Institution, October 18, 2013, p. 19. 22 Unless otherwise noted, this information is based on the following publication: Steel Wire Garment

Hangers from China, Investigation No. 731‐TA‐1123 (Final), USITC Publication 4034, September 2008. No

changes in product description or end use were reported.  M&B Metal Products, Innovative Fabrication

LLP/Indy Hanger, and US Hanger’s Response to the Commission’s Notice of Institution, October 18, 2013.
I‐8

Figure I-1 

SWG hangers: Common varieties 

 Caped hanger Shirt hanger 

 Suit hanger Strut hanger 

Source: M&B website at http://www.mbhangers.com/, retrieved January 8, 2014. 

Steel wire hangers produced for use in industrial laundries or the uniform rental market

are known as textile or uniform rental hangers or as industrial hangers.  These hangers are

normally produced using a 13‐gauge wire23 to support the weight of newly washed textiles and

uniforms.  Industrial laundries and uniform rental companies typically require a more

substantial gauge hanger in a consistent shape to fit their high‐speed processing equipment.  

These hangers are sometimes made out of galvanized (zinc‐coated) steel wire. The bottom bar

of these hangers may be coated with a latex or other coating to prevent pants slippage after

laundering.24

                                                       23 The term “gauge” refers to the diameter of wire. A 13‐gauge wire has a diameter of 0.0915 inch.

24 Steel Wire Garment Hangers from Taiwan, Investigation No. 731‐TA‐1197 (Final), USITC Publication

4363, November 2012, p. I‐9.
I‐9

Production process25

There are no substantial differences in the production process or uses for industrial

hangers and dry‐cleaning hangers.  The manufacturing process to produce SWG hangers

consists of purchasing low‐carbon steel wire in coils, whether or not galvanized, or drawing

wire from low‐carbon steel wire rod, cutting the wire to length, and fabricating the hangers

(figure I‐2).  After the wire is straightened and cut to length, the hangers are formed and

painted.  The process may be continuous or require separate stages to straighten, cut, and form

the hanger, and painting may take place either before or after the hanger is formed.  The

manufacturing equipment and process for galvanized wire hangers are similar, but galvanized

SWG hangers do not require painting because the zinc coating prevents the steel wire from

rusting. In all cases, the forming machines are dedicated to the production of hangers; they are

not used and cannot be used to produce other products.  Wire forming machines may be made

in‐house by SWG hanger manufacturers or purchased from a small number of companies in

China, Switzerland, and Taiwan that produce these machines.26

After forming and painting, some hangers require the addition of a paper covering or

“cape,” which can be plain or printed with custom or stock messages for drycleaner customers.  

In addition, strut hangers receive a cardboard tube or “strut” along the bottom bar on which

drycleaners hang pants.  Although referred to by a separate name in the industry, these

hangers are produced using the same equipment and workers as the various types of dry‐

cleaning hangers described above.

The formation of the hanger itself is similar throughout the world.  Operations such as

the addition of capes and struts and painting the wire may differ in the amount of the

processing that is done by machine versus that which is performed manually. Most hangers

going to dry cleaners are packed in boxes containing 500 hangers.  However, thicker hangers

(struts, drapery, and polo knit hangers) are packed 250 in a box.  In the United States the

quantity to be packed in a box is determined by weight while in China the hangers are counted

and packed manually. All of the common types of SWG hangers mentioned above are produced

in China.

                                                       25 Unless otherwise noted, this information is based on the following publication: Steel Wire Garment

Hangers from China, Investigation No. 731‐TA‐1123 (Final), USITC Publication 4034, September 2008. No

major changes in production technology or production methods were reported since the original

investigation. M&B Metal Products, Innovative Fabrication LLP/Indy Hanger, and US Hanger’s Response

to the Commission’s Notice of Institution, October 18, 2013.

26 Steel Wire Garment Hangers from Taiwan, Investigation No. 731‐TA‐1197 (Final), USITC Publication

4363, November 2012, p. I‐9.
I‐10

Figure I-2 

SWG hangers: Formation process 

 

Wire enters machine . . . . . . is pulled to formation area in machine 

           

Detailed view of wire entering formation process. Hanger is formed. 

Source: Website of Wuxi Anber Machine Com Ltd., found at www.chinanbermachine.com/product17.htm, 

retrieved January 19, 2011. 

Interchangeability and customer and producer perceptions

There are some limitations in interchangeability among various types of SWG hangers,

as shirt hangers are used for shirts, suit hangers for suits, and latex and other rental hangers for

uniforms. In the original investigation, producers and importers of SWG hangers all viewed

SWG hangers as falling within the same basic product category.27

                                                       27 Steel Wire Garment Hangers from China, Inv. No. 731‐TA‐1123 (Final), USITC Publication 4034,

September 2008, at p. 6.
I‐11

Channels of distribution

 In the original investigation, all types of SWG hangers were typically sold to distributors,

although they were increasingly being sold directly to end users.28  In 2005, a majority of U.S.

producers’ U.S. shipments was to distributors; thereafter, however, the majority was to end

users. Imported product from China was sold primarily through trading companies and

distributors but the share sold to end users grew after 2005.29

Pricing and related information

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

Reported pricing data accounted for 28.1 percent of the total quantity of U.S. producers'

shipments during January 2005‐March 2008 and 55.9 percent of imports from China.30 The

Commission found that pricing data showed underselling of domestic hangers by the subject

imports in nearly every comparison, and by substantial margins. Subject imports undersold the

domestic industry’s SWG hangers in 94 of 95 quarterly price comparisons, with margins of

underselling ranging from 0.1 percent to 57.7 percent and averaging 30.0 percent. The

Commission also noted that price was the most important factor affecting purchasing

decisions.31

The primary raw material used in the production of SWG hangers in the United States is

low‐carbon steel wire. During the final investigation, the price of low‐carbon steel wire rod had

risen by 81.5 percent from January 2005 to July 2008. Between 2005 and 2007, the share of

cost of goods sold accounted for by raw materials increased from *** percent to *** percent.

By the first quarter of 2008, the share reached *** percent.32

THE INDUSTRY IN THE UNITED STATES

U.S. producers

In the original investigation, the Commission received questionnaire responses from the

following seven U.S.  producers of SWG hangers:  Ganchos N.V., lnc.; Laidlaw Corp.; M&B;

Metro Supply Co.;  Merrick International; Shanti Industries, lnc.; and United Wire Hangers Corp,

which accounted  for *** percent of U.S. production of SWG hangers during 2007 and all

                                                       28 Steel Wire Garment Hangers from China, Inv. No. 731‐TA‐1123 (Final), USITC Publication 4034,

September 2008, at p. 6.

29 Steel Wire Garment Hangers from China, Inv. No. 731‐TA‐1123 (Final), USITC Publication 4034,

September 2008, at p. II‐1.

30 Steel Wire Garment Hangers from China, Investigation No. 731‐TA‐1123 (Final), USITC Publication

4034, September 2008, p. V‐3.

31 Steel Wire Garment Hangers from China, Investigation No. 731‐TA‐1123 (Final), USITC Publication

4034, September 2008, p. 19.

32 Steel Wire Garment Hangers from China, Investigation No. 731‐TA‐1123 (Final), USITC Publication

4034, September 2008, p. V‐1.
I‐12

confirmed U.S. production in January‐March 2008.33  In its response to the Commission’s notice

of institution, the domestic industry identified six current U.S. producers: Eagle Hangers, Inc.,

Ganchos N.V., Inc., M&B, Metro Supply Co., Indy Hanger, and US Hanger.34  Since the original

investigation, three U.S. producers have ceased production: Great Plains has ceased production

of SWG hangers in 2011, Platinum Hanger ceased production of SWG hangers in 2009, and

Shanti filed for bankruptcy in January 2010.35

M&B, Indy Hanger, and US Hanger produce the vast majority of SWG hangers made in

the United States. Indy Hanger and US Hanger were established following the antidumping

investigation of steel wire garment hangers from China.36  Metro Supply Company and Ganchos

N.V., Inc. are small regional producers and Eagle Hangers, Inc. appears to be operating only

episodically.37

Related party issues

During the original period of investigation, *** domestic producers, M&B, United Wire,

Laidlaw, *** imported SWG hangers from China during the period of investigation.  Thus, they

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

that “appropriate circumstances” existed only to exclude two U.S. producers, Laidlaw and

United Wire, from the domestic industry.  Both of these firms ceased domestic production of

SWG hangers in the latter half of the investigation period and became *** importers of *** and

increasing volumes of subject merchandise, indicating that, by the end of the period, their

primary interest had shifted from domestic production to importation. The domestic interested

parties reported in their response to the notice of institution in this first five‐year review that

they do not import SWG hangers from China and that they are not affiliated with any Chinese

producers or exporters of SWG hangers.38  

U.S. producers’ trade and financial data

The Commission requested domestic interested parties to provide trade and financial

data in their response to the notice of institution of the five‐year review of the subject order.

Table I‐3 presents the data reported by responding U.S. producers from both the original

investigation (2005‐07) and the response to the notice of institution (2012).

 

                                                       33 Steel Wire Garment Hangers from China, Inv. No. 731‐TA‐1123 (Final), Staff Report to the

Commission, Memorandum INV‐FF‐109, August 27, 2008, p. III‐1 and table III‐1.

34 Domestic Industry’s Response to the Notice of Institution, October 17, 2013, p. 12.

35 Steel Wire Garment Hangers from Taiwan, Investigation No. 731‐TA‐1197 (Final). USITC Publication

4363, November 2012, p. III‐1, fns. 4‐6.

36 Domestic Industry’s Response to the Notice of Institution, October 17, 2013, p. 3.

37 Domestic Industry’s Response to the Notice of Institution, October 17, 2013, p. 12.

38 Domestic interested parties’ response to the notice of institution (October 17, 2013), pp. 13‐14.
I‐13

Table I-3 

SWG hangers: U.S. producers’ trade and financial data, 2005-07 and 2012 

Item 2005 2006 2007 2012 

Capacity (1,000 hangers) 2,188,508 1,650,619 1,055,570 ***

Production (1,000 hangers) 1,508,585 681,843 271,237 ***

Capacity utilization (percent) 68.9 41.3 25.7 ***

U.S. shipments 

 Quantity (1,000 hangers) 1,541,264 721,553 289,409 ***

 Value ($1,000) 67,976 30,360 12,362 ***

 Unit value (per 1,000 hangers) 44.10 42.08 42.71 ***

Net sales value ($1,000) *** *** *** ***

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

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

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

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

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

Operating income or (loss)/sales 

(percent) *** *** *** ***

Source: Steel Wire Garment Hangers from China, Inv. No. 731-TA-1123 (Final), Staff Report to the 

Commission, Memorandum INV-FF-109, August 27, 2008, Tables III-3, III-4, and VI-1; and Domestic 

interested parties’ response to the notice of institution (October 17, 2013), exh. 5. 

U.S. IMPORTS AND APPARENT CONSUMPTION

U.S. imports

In its original investigation, the Commission received questionnaire responses from 27

importers.39 In response to the notice of institution in this five‐year review, the domestic

interested parties identified 98 importers of SWG hangers.40  The domestic interested parties

believe that these firms would likely resume importation of SWG hangers if the order were

revoked, and states that “the United States remains the largest market in the world for steel

wire garment hangers.”41  Table I‐4 presents U.S. import data by source, from 2008 to 2012.

   

                                                       39 Steel Wire Garment Hangers from China, Investigation No. 731‐TA‐1123 (Final), USITC Publication

4034, September 2008, p. IV‐1.

40 Domestic interested parties’ response to the notice of institution (October 17, 2013), exh. 2. 41 Domestic interested parties’ response to the notice of institution (October 17, 2013), p. 14.
I‐14

Table I-4 

SWG hangers: U.S. import data, by source, 2008-12 

Item 

Calendar year 

2008 2009 2010 2011 2012 

 Quantity (1,000 hangers) 

China 2,069,185 733,871 220,001 588,917 941,678 

All other sources 584,458 1,324,563 1,686,442 1,466,461 1,051,483

 Total imports 2,653,643 2,058,434 1,906,443 2,055,378 1,993,161 

 Value ($1,000) 

China 82,744 25,878 9,763 23,804 41,446 

All other sources 27,829 50,855 62,971 58,483 43,752 

 Total imports 110,573 76,733 72,734 82,287 85,198 

 Unit value (dollars per 1,000 hangers)

China 39.98 35.26 44.37 $40.41 $44.01 

All other sources 47.61 38.39 37.33 39.88 41.60 

 Total imports 41.66 37.27 38.15 40.03 42.74 

 Share of quantity (percent) 

China 78.0 35.7 11.5 28.7 47.2

All other sources 22.0 64.3 88.5 71.3 52.8

 Total imports 100.0 100.0 100.0 100.0 100.0 

 Share of value (percent)

China 74.8 33.7 13.4 28.9 48.6 

All other sources 25.2 66.3 86.6 71.1 51.4 

 Total imports 100.0 100.0 100.0 100.0 100.0 

Source: Compiled from official Commerce statistics, HTS number 7326.20.0020. 

According to official Commerce import data, China was the largest source of imported

SWG hangers in 2012, representing 47.2 percent of U.S. imports, by quantity.  The next largest

sources of imports were Vietnam, representing 24.4 percent of U.S. imports, by quantity and

Mexico, representing 22.9 percent of U.S. imports, by quantity.

Ratio of imports to U.S. production

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

shown in table I‐5 below.

Table I-5 

SWG hangers: Ratio of U.S. imports to U.S. production, 2005-07 and 2012 

Item Calendar year 

2005 2006 2007 2012 

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

China 69.3 260.7 994.5 ***

All other sources 20.9 45.8 128.2 ***

All countries 90.2 306.5 1,122.7 ***

Source: Steel Wire Garment Hangers from China, Inv. No. 731-TA-1123 (Final), USITC Publication 4034, 

September 2008, at IV-13, and compiled from official Commerce statistics, HTS number 7326.20.0020. 

Domestic interested parties’ response to the notice of institution (October 17, 2013). 
I‐15

Apparent U.S. consumption and market shares

Table I‐6 shows U.S. shipments of domestic product, U.S. imports and apparent U.S.

consumption in 2005‐07 and 2012. Table I‐7 shows U.S. market shares during 2005‐07 and

2012.

Table I-6 

SWG hangers: U.S. shipments of domestic product, U.S. imports, and apparent U.S. consumption, 

2005-07 and 2012 

Item 2005 2006 2007 2012 

Quantity (1,000 hangers) 

U.S. producers’ U.S. shipments 1,541,264 721,553 289,409 ***

U.S. imports from-- 

 China 1,044,701 1,777,680 2,697,369 ***

 All other sources 315,631 312,182 347,824 ***

 Total imports 1,360,331 2,089,862 3,045,193 ***

Apparent U.S. consumption 2,901,595 2,811,415 3,334,602 ***

 Value (1,000 dollars) 

U.S. producers’ U.S. shipments 67,976 30,360 12,362 ***

U.S. imports from-- 

 China 39,445 56,335 83,595 ***

 All other sources 12,231 10,928 11,802 ***

 Total imports 51,677 67,263 95,397 ***

Apparent U.S. consumption 119,653 97,623 107,759 ***

Source: Steel Wire Garment Hangers from China, Inv. No. 731-TA-1123 (Final), USITC Publication 4034, 

September 2008, table III-4 and IV-8. Steel Wire Garment Hangers from China, Inv. No. 731-TA-1123 

(Final), Staff Report to the Commission, Memorandum INV-FF-109, August 27, 2008, table III-4. Domestic 

interested parties’ response to the notice of institution (October 17, 2013). Because of rounding, figures 

may not add to the totals shown. 

According to information collected during the original investigation, SWG hangers are

used primarily by the dry cleaning, industrial laundry, textile, and uniform rental industries.  

Purchasers of steel wire garment hangers include national distributors to the dry‐cleaning

industry as well as industrial laundries which provide uniform rental services.42

                                                       42 Domestic interested parties’ response to the notice of institution (October 17, 2013), p. 13.
I‐16

Table I-7 

SWG hangers: U.S. market shares, 2005-07 and 2012 

Item 2005 2006 2007 2012 

Quantity (1,000 hangers) 

Apparent U.S. consumption 2,901,595 2,811,415 3,334,602 ***

 Value (1,000 dollars) 

Apparent U.S. consumption 119,653 97,623 107,759 ***

 Share of quantity (percent) 

U.S. producers’ U.S. shipments 53.1 25.7 8.7 ***

U.S. imports from-- 

 China 36.0 63.2 80.9 ***

 All other sources 10.9 11.1 10.4 ***

 Total imports 46.9 74.3 91.3 ***

 Share of value (percent) 

U.S. producers’ U.S. shipments 56.8 31.1 11.5 ***

U.S. imports from— 

 China 33.0 57.7 77.6 ***

 All other sources 10.2 11.2 11.0 ***

 Total imports 43.2 68.9 88.5 ***

Source: Steel Wire Garment Hangers from China, Inv. No. 731-TA-1123 (Final), USITC Publication 4034, 

September 2008, table III-4 and IV-9, Steel Wire Garment Hangers from China, Inv. No. 731-TA-1123 

(Final), Staff Report to the Commission, Memorandum INV-FF-109, August 27, 2008, and Domestic 

interested parties’ response to the notice of institution (October 17, 2013). Because of rounding, figures 

may not add to the totals shown. 

THE INDUSTRY IN CHINA

Background

During the original investigation, the petition identified 64 producers of SWG hangers in

China.43 The Commission received 14 usable foreign producer questionnaire responses.  

Between January 2005 and March 2008, more than 90 percent of reported Chinese‐produced

SWG hangers were exported to the United States.44

In their response to the notice of institution in this first five‐year review, the domestic

interested parties identified 36 firms as producers/exporters of SWG hangers in China.

                                                       43 Steel Wire Garment Hangers from China, Inv. No. 731‐TA‐1123 (Final), USITC Publication 4034,

September 2008, at p. VII‐2. 44 Steel Wire Garment Hangers from China, Inv. No. 731‐TA‐1123 (Final), USITC Publication 4034,

September 2008, at p. VII‐5.
I‐17

Capacity and production

During the original investigation, reported Chinese capacity and production of SWG

hangers increased by over 70 percent from 2005 to 2007; capacity utilization fluctuated from

2005 to 2007, but remained above 80 percent. Reported Chinese exports of SWG hangers to

the United States rose by 71.9 percent from 2005 to 2007.45  Exports to all other markets more

than doubled over the period.

Exports

Table I‐8 presents data for the top ten markets for Chinese exports of SWG hangers. The

United States is the largest market for Chinese product. Total Chinese exports increased from

2008 to 2012, by 46.7 percent, and Chinese exports to the United States increased by 17.6

percent.

Table I-8

SWG hangers: Chinese exports, by country, 2008-12 

Country 

Value ($1,000) 

2008 2009 2010 2011 2012 

United States 227,414 158,054 187,435 215,001 267,400

Japan 77,400 62,407 67,898 85,569 87,811

Vietnam 1,484 3,246 6,207 26,133 31,540

United Kingdom 19,804 16,198 20,866 24,225 28,081

Australia 23,908 13,018 15,186 22,142 26,752

Germany 29,352 23,053 21,972 26,162 24,816

Malaysia 6,231 6,391 11,719 12,628 24,346

Indonesia 3,358 4,780 7,152 12,001 22,114

Netherlands 17,173 7,727 12,991 16,264 21,867

Korea South 14,852 10,605 12,859 18,047 21,216

All others 209,706 164,688 261,244 308,381 369,493

World 630,683 470,169 625,530 766,554 925,437

Source: Global Trade Information Service (“Global Trade Atlas”), HS code 732620, articles of iron or steel 

wire, not elsewhere specified or identified. This HS code is over inclusive and contains wire products 

beyond steel wire garment hangers. Data exported under HS code 732399 is not included because it 

primarily contains nonsubject articles of iron and steel. 

                                                       45 Steel Wire Garment Hangers from China, Inv. No. 731‐TA‐1123 (Final), USITC Publication 4034,

September 2008, at p. VII‐5.
I‐18

TARIFF OR NON‐TARIFF BARRIERS TO TRADE

There are no outstanding antidumping and/or countervailing duty measures against

SWG hangers produced in China in countries other than the United States.

THE GLOBAL MARKET

Table I‐9 shows the ten largest exporting countries of SWG hangers. Total world exports

decreased by 1.0 percent from 2008 to 2012.

Table I‐9

SWG Hangers: Exports by reporting country, 2008-12 

Country 

Value ($1,000) 

2008 2009 2010 2011 2012 

China 630,683 470,169 625,530 766,554 925,437

Germany 175,417 149,359 194,316 221,981 198,198

Belgium 210,898 177,869 179,781 182,122 191,982

United States 189,783 132,204 142,909 164,582 152,505

Poland 164,871 95,662 121,550 159,060 135,475

Italy 186,036 144,022 132,913 137,150 115,906

Czech Republic 127,587 82,100 95,994 126,391 110,283

France 89,722 70,788 80,045 98,568 78,794

India 21,752 19,569 27,239 55,765 78,025

Netherlands 142,177 78,855 78,308 81,259 73,409

All others 927,804 691,130 759,961 885,931 779,440

World 2,866,730 2,111,725 2,438,568 2,879,363 2,839,455

Source: Global Trade Information Service (“Global Trade Atlas”), HS code 732620, articles of iron or steel 

wire, not elsewhere specified or identified. This HS code is over inclusive and contains wire products 

beyond steel wire garment hangers. Data exported under HS code 732399 is not included because it 

primarily contains nonsubject articles of iron and steel. 

   
I‐19

Table I‐10 shows the ten largest importers of SWG hangers. Total world imports

decreased by 14.0 percent from 2008 to 2012.

Table I-10 

SWG hangers: Imports by reporting country, 2008-12 

Country 

Value ($1,000) 

2008 2009 2010 2011 2012 

United States 394,242 305,508 342,663 370,541 388,932

Germany 271,003 186,943 191,352 211,024 232,300

France 214,106 172,128 182,335 198,632 153,471

United Kingdom HMRC 166,203 114,758 143,609 168,077 124,909

Japan 78,089 65,665 82,855 104,625 105,989

Canada 70,987 59,233 72,140 86,668 86,965

Belgium 163,652 84,231 77,419 92,831 81,063

Netherlands 94,609 57,207 67,693 79,676 64,322

Mexico 63,521 43,226 60,419 56,409 64,033

Poland 57,264 42,851 38,883 51,029 50,250

All others 1,129,327 737,391 853,495 1,008,939 971,897

World 2,703,002 1,869,148 2,112,863 2,428,453 2,324,132

Source: Global Trade Information Service (“Global Trade Atlas”), HS code 732620, articles of iron or steel 

wire, not elsewhere specified or identified. This HS code is over inclusive and contains wire products 

beyond steel wire garment hangers. Data imported under HS code 732399 is not included because it 

primarily contains nonsubject articles of iron and steel. 

A‐1

APPENDIX A

PURCHASER QUESTIONNAIRE RESPONSES

A‐3

* * * * * * * 

B‐1

APPENDIX B

SUMMARY DATA

Table C-4

SWG hangers: Summary data concerning the U.S. market (excluding Laidlaw and United Wire), 2005-07, January-March 2007, and January-March 2008

(Quantity=1,000 hangers, value=1,000 dollars, unit values, unit labor costs, and unit expenses are per 1,000 hangers; period changes=percent, except where noted)

Reported data Period changes

January-March Jan.-Mar.

Item 2005 2006 2007 2007 2008 2005-07 2005-06 2006-07 2007-08

U.S. consumption quantity:

 Amount . . . . . . . . . . . . . . . . . . . . 2,901,595 2,811,415 3,334,602 778,773 *** 14.9 -3.1 18.6 ***

 Producers' share (1): *** ***

 Laidlaw & United Wire . . . . . . . *** *** *** *** *** *** *** *** ***

 All other producers . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Total producers . . . . . . . . . . . 53.1 25.7 8.7 11.7 *** -44.4 -27.5 -17.0 ***

 Importers' share (1): *** ***

 China . . . . . . . . . . . . . . . . . . . . 36.0 63.2 80.9 76.2 *** 44.9 27.2 17.7 ***

 Other sources . . . . . . . . . . . . . . 10.9 11.1 10.4 12.1 *** -0.4 0.2 -0.7 ***

 Total imports . . . . . . . . . . . . . 46.9 74.3 91.3 88.3 *** 44.4 27.5 17.0 ***

U.S. consumption value:

 Amount . . . . . . . . . . . . . . . . . . . . 119,653 97,623 107,759 24,199 *** -9.9 -18.4 10.4 ***

 Producers' share (1): *** ***

 Laidlaw & United Wire . . . . . . . *** *** *** *** *** *** *** *** ***

 All other producers . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Total producers . . . . . . . . . . . 56.8 31.1 11.5 15.3 *** -45.3 -25.7 -19.6 ***

 Importers' share (1): *** ***

 China . . . . . . . . . . . . . . . . . . . . 33.0 57.7 77.6 71.7 *** 44.6 24.7 19.9 ***

 Other sources . . . . . . . . . . . . . . 10.2 11.2 11.0 13.0 *** 0.7 1.0 -0.2 ***

 Total imports . . . . . . . . . . . . . 43.2 68.9 88.5 84.7 *** 45.3 25.7 19.6 ***

U.S. imports from--

 China:

 Quantity . . . . . . . . . . . . . . . . . . 1,044,701 1,777,680 2,697,369 593,419 626,354 158.2 70.2 51.7 5.6

 Value . . . . . . . . . . . . . . . . . . . . 39,445 56,335 83,595 17,342 22,682 111.9 42.8 48.4 30.8

 Unit value . . . . . . . . . . . . . . . . . $37.76 $31.69 $30.99 $29.22 $36.21 -17.9 -16.1 -2.2 23.9

 Ending inventory quantity . . . . . 78,475 109,418 249,269 132,506 185,476 217.6 39.4 127.8 40.0

 All other sources:

 Quantity . . . . . . . . . . . . . . . . . . 315,631 312,182 347,824 94,469 102,094 10.2 -1.1 11.4 8.1

 Value . . . . . . . . . . . . . . . . . . . . 12,231 10,928 11,802 3,147 3,812 -3.5 -10.7 8.0 21.1

 Unit value . . . . . . . . . . . . . . . . . $38.75 $35.01 $33.93 $33.31 $37.34 -12.4 -9.7 -3.1 12.1

 Ending inventory quantity . . . . . *** *** *** *** *** *** *** *** ***

 All sources:

 Quantity . . . . . . . . . . . . . . . . . . 1,360,331 2,089,862 3,045,193 687,888 728,448 123.9 53.6 45.7 5.9

 Value . . . . . . . . . . . . . . . . . . . . 51,677 67,263 95,397 20,489 26,494 84.6 30.2 41.8 29.3

 Unit value . . . . . . . . . . . . . . . . . $37.99 $32.19 $31.33 $29.79 $36.37 -17.5 -15.3 -2.7 22.1

 Ending inventory quantity . . . . . *** *** *** *** *** *** *** *** ***

U.S. producers': (2)

 Average capacity quantity . . . . . *** *** *** *** *** *** *** *** ***

 Production quantity . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Capacity utilization (1) . . . . . . . . *** *** *** *** *** *** *** *** ***

 U.S. shipments:

 Quantity . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Value . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Unit value . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Export shipments:

 Quantity . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Value . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Unit value . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Ending inventory quantity . . . . . . *** *** *** *** *** *** *** *** ***

 Inventories/total shipments (1) . . *** *** *** *** *** *** *** *** ***

 Production workers . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Hours worked (1,000s) . . . . . . . . *** *** *** *** *** *** *** *** ***

 Wages paid ($1,000s) . . . . . . . . *** *** *** *** *** *** *** *** ***

 Hourly wages . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Productivity (hangers per hour) . *** *** *** *** *** *** *** *** ***

 Unit labor costs . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Net sales:

 Quantity . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Value . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Unit value . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Cost of goods sold (COGS) . . . . *** *** *** *** *** *** *** *** ***

 Gross profit or (loss) . . . . . . . . . *** *** *** *** *** *** *** *** ***

 SG&A expenses . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Operating income or (loss) . . . . . *** *** *** *** *** *** *** *** ***

 Capital expenditures . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Unit COGS . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Unit SG&A expenses . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Unit operating income or (loss) . *** *** *** *** *** *** *** *** ***

 COGS/sales (1) . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Operating income or (loss)/

 sales (1) . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 U.S. shipments by Laidlaw/United Wire:

 Quantity . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Value . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Unit value . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 (1) "Reported data" are in percent and "period changes" are in percentage points.

 (2) Excluding Laidlaw and United Wire.

 (3) Undefined.

 (4) Not applicable.

Note.--Financial data are reported on a fiscal year basis and may not necessarily be comparable to data reported on a calendar year basis. Because of rounding,

figures may not add to the totals shown. Unit values and shares are calculated from the unrounded figures.

Source: Compiled from data submitted in response to Commission questionnaires and from official Commerce statistics.

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