U.S. International Trade Commission

Publication 4070 April 2009

Washington, DC 20436

Certain Steel Threaded Rod From China

Investigation No. 731-TA-1145 (Final)
U.S. International Trade Commission

COMMISSIONERS 

 

Shara L. Aranoff, Chairman 

Daniel R. Pearson, Vice Chairman 

Deanna Tanner Okun 

Charlotte R. Lane 

Irving A. Williamson 

Dean A. Pinkert

Robert A. Rogowsky

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Director of Operations

Joanna Lo, Investigator 

Jeremy Wise, Industry Analyst 

Craig Thomsen, Economist 

Mary Klir, Accountant 

Peter Sultan, Attorney 

Steve Hudgens, Statistician 

Jim McClure, Supervisor Investigator
U.S. International Trade Commission

Washington, DC 20436 

www.usitc.gov

Publication 4070 April 2009

Certain Steel Threaded Rod From China

Investigation No. 731-TA-1145 (Final)

i

CONTENTS

Page

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

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

Part I: Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1

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

Statutory criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-2

Organization of the report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-3

U.S. market summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-3

Summary data and data sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-4

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

Sales at LTFV . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-4

The subject merchandise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-5

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

Tariff treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-6

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

Physical characteristics and uses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-6

Manufacturing process and production employees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-7

Interchangeability and customer and producer perceptions . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

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

Price . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

Domestic like product and the domestic industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

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

U.S. market segments and channels of distribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1

Geographic markets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1

Purchaser characteristics ........................................................ II-2

Supply and demand considerations ................................................ II-3

Supply ................................................................... II-3

Demand . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6

Substitutability issues .......................................................... II-10

Knowledge of country sources ................................................ II-10

Factors affecting purchasing decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10

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

Elasticity estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-17

U.S. supply elasticity ........................................................ II-17

U.S. demand elasticity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-17

Substitution elasticity ....................................................... II-17

Part III: U.S. producers’ production, shipments, and employment ...................... III-1

U.S. producers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1

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

U.S. producers’ shipments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-4

U.S. producers’ imports and purchases ............................................. III-4

U.S. producers’ inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-4

U.S. employment, wages, and productivity ......................................... III-5
ii

CONTENTS

Page

Part IV: U.S. imports, apparent consumption, and market shares . . . . . . . . . . . . . . . . . . . . . . IV-1

U.S. importers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-1

U.S. imports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-1

Subject imports from China . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-1

Nonsubject sources of imports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-3

Negligibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-3

Apparent U.S. consumption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-4

U.S. market shares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-5

Ratio of imports to U.S. production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-5

Part V: Pricing and related information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-1

Factors affecting prices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-1

Raw materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-1

Transportation costs to the U.S. market . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-2

U.S. inland transportation costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-2

Exchange rates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-3

Pricing practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-3

Pricing methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-3

Sales terms and discounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-4

Price leadership . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-5

Price data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-5

Price trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-6

Price comparisons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-14

Lost sales and lost revenues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-15

Part VI: Financial condition of U.S. producers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-1

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-1

Operations on threaded rod . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-1

Capital expenditures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-2

Assets and return on investment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-2

Capital and investment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-3

Part VII: Threat considerations and information on nonsubject countries ............... VII-1

The industry in the China ....................................................... VII-1

U.S. importers’ inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VII-2

U.S. importers’ imports subsequent to September 30, 2008 ............................. VII-2

Antidumping duty orders in third-country markets ................................... VII-2

Information on nonsubject countries .............................................. VII-2

Global market . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VII-2
iii

CONTENTS

Page

Appendixes

A. Federal Register notices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

B. Hearing witnesses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

C. Summary data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1

D. U.S. producers' and importers' total shipments of threaded rod by diameter . . . . . . . . . . . . . . . D-1

E. Additional quarterly price data excluding Bay Standard . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1

F. Additional quarterly price data including *** . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . F-1

G. U.S. producers’ aggregate financial data fiscal years 2005 through 2007, 

 January-September 2007, and January-September 2008 . . . . . . . . . . . . . . . . . . . . . . . . . . . . G-1

H. Alleged effects of subject imports on U.S. producers’ existing development and

 and production efforts, growth, investment, and ability to raise capital . . . . . . . . . . . . . . . . . H-1

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

and therefore has been bracketed ( *** ) or identified with lines in the margins in this report.

 1

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

UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation No. 731-TA-1145 (Final)

CERTAIN STEEL THREADED ROD FROM CHINA

DETERMINATION

On the basis of the record1

 developed in the subject investigation, the United States International

Trade Commission (Commission) determines, pursuant to section 735(b) of the Tariff Act of 1930 (19

U.S.C. § 1673d(b)) (the Act), that an industry in the United States is materially injured by reason of

imports from China of certain steel threaded rod, provided for in subheading 7318.15.50 of the

Harmonized Tariff Schedule of the United States, that have been found by the Department of Commerce

(Commerce) to be sold in the United States at less than fair value (LTFV).

BACKGROUND

The Commission instituted this investigation effective March 5, 2008, following receipt of a

petition filed with the Commission and Commerce by Vulcan Threaded Products, Pelham, AL. The final

phase of the investigation was scheduled by the Commission following notification of a preliminary

determination by Commerce that imports of certain steel threaded rod from were being sold at LTFV

within the meaning of section 733(b) of the Act (19 U.S.C. § 1673b(b)). Notice of the scheduling of the

final phase of the Commission’s investigation and of a public hearing to be held in connection therewith

was given by posting copies of the notice in the Office of the Secretary, U.S. International Trade

Commission, Washington, DC, and by publishing the notice in the Federal Register of November 21,

2008 (73 FR 70671). The hearing was held in Washington, DC, on February 25, 2009, and all persons

who requested the opportunity were permitted to appear in person or by counsel.

The Commission transmitted its determination in this investigation to the Secretary of Commerce

on April 6, 2009. The views of the Commission are contained in USITC Publication 4070 (April 2009),

entitled Certain Steel Threaded Rod from China: Investigation No. 731-TA-1145 (Final).

 1

 Confidential Staff Report, Memorandum INV-GG-020 (March 16, 2009) (“CR”) at Table III-1. Another

producer, Rods Indiana, provided a questionnaire response in the preliminary phase, but not the final phase, of this

investigation. Its data were not included in the domestic industry data in the final-phase staff report. CR/PR at

Table III-1 n.5.

 2 Three firms from China (one producer and two exporters) provided usable questionnaire responses in the

preliminary phase of the investigation.

 3 19 U.S.C. § 1677(4)(A).

 4 19 U.S.C. § 1677(4)(A).

 5 19 U.S.C. § 1677(10).

-3-

VIEWS OF THE COMMISSION

Based on the record in the final phase of this investigation, we find that an industry in the United

States is materially injured by reason of imports of certain steel threaded rod (“CSTR”) from the People’s

Republic of China (“China”) that have been found by the U.S. Department of Commerce (“Commerce”)

to be sold in the United States at less than fair value.

I. BACKGROUND

The petition in this investigation was filed on March 5, 2008, by Vulcan Threaded Products, Inc.

(“Vulcan”). Petitioner appeared at the staff conference and hearing and filed briefs. Two other domestic

producers, Bay Standard Mfg. Inc. (“Bay Standard”) and Watson Metal Products Corporation

(“Watson”), also appeared at the hearing. The Commission received questionnaire responses from these

three firms and from the following other domestic producers: All-Ohio Threaded Rod Company (“All

Ohio”); Conklin & Conklin Inc. (“Conklin & Conklin”); Lancaster Threaded Products, Inc. (“Lancaster”);

and Threaded Rod Company, Inc. (“Threaded Rod”).1

 

No producers or exporters of subject threaded rod from China participated in the preliminary or

final phase of this investigation or provided responses to the Commission’s data requests in the final

phase of this investigation.2

Three U.S. importers of the subject merchandise, Porteous Fastener Company (“Porteous”),

Industrial Threaded Products, and Fastenal Company (“Fastenal”), appeared at the staff conference and

submitted postconference briefs. Only Porteous filed briefs in the final phase of this investigation.

II. DOMESTIC LIKE PRODUCT

A. In General

In determining whether an industry in the United States is materially injured or threatened with

material injury by reason of imports of the subject merchandise, the Commission first defines the

“domestic like product” and the “industry.”3

 Section 771(4)(A) of the Tariff Act of 1930, as amended

(“the Tariff Act”), defines the relevant domestic industry as the “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.”4

 In turn, the Tariff Act defines “domestic like

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

with, the article subject to an investigation . . . .”5

The decision regarding the appropriate domestic like product(s) in an investigation is a factual

determination, and the Commission has applied the statutory standard of “like” or “most similar in
 6

 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); Torrington Co. v. United States, 747 F. Supp. 744, 749 n.3 (Ct. Int’l Trade 1990), aff’d, 938 F.2d 1278 (Fed.

Cir. 1991) (“every like product determination ‘must be made on the particular record at issue’ and the ‘unique facts

of each case’”). The Commission generally considers a number of factors including the following: (1) physical

characteristics and uses; (2) interchangeability; (3) channels of distribution; (4) customer and producer perceptions

of the products; (5) common manufacturing facilities, production processes, and production employees; and, where

appropriate, (6) price. See Nippon, 19 CIT at 455 n.4; Timken Co. v. United States, 913 F. Supp. 580, 584 (Ct. Int’l

Trade 1996).

 7 See, e.g., S. Rep. No. 96-249 at 90-91 (1979).

 8 Nippon, 19 CIT at 455; Torrington, 747 F. Supp. at 748-49; see also S. Rep. No. 96-249 at 90-91 (1979)

(Congress has indicated that the like product standard should not be interpreted in “such a narrow fashion as to

permit minor differences in physical characteristics or uses to lead to the conclusion that the product and article are

not ‘like’ each other, nor should the definition of ‘like product’ be interpreted in such a fashion as to prevent

consideration of an industry adversely affected by the imports under consideration.”).

 9 See, e.g., USEC, Inc. v. United States, 34 Fed. Appx. 725, 730 (Fed. Cir. 2002) (“The ITC may not modify the

class or kind of imported merchandise examined by Commerce.”); Algoma Steel Corp. v. United States, 688 F.

Supp. 639, 644 (Ct. Int’l Trade 1988), aff’d, 865 F.3d 240 (Fed. Cir.), cert. denied, 492 U.S. 919 (1989).

 10 Hosiden Corp. v. Advanced Display Mfrs., 85 F.3d 1561, 1568 (Fed. Cir. 1996) (the Commission may find a

single like product corresponding to several different classes or kinds defined by Commerce); Cleo, 501 F.3d at 1298

n.1 (“Commerce’s {scope} finding does not control the Commission’s {like product} determination.”); Torrington,

747 F. Supp. at 748-52 (affirming the Commission’s determination defining six like products in investigations where

Commerce found five classes or kinds).

-4-

characteristics and uses” on a case-by-case basis.6 No single factor is dispositive, and the Commission

may consider other factors it deems relevant based on the facts of a particular investigation.7

 The

Commission looks for clear dividing lines among possible like products and disregards minor variations.8

Although the Commission must accept Commerce’s determination as to the scope of the imported

merchandise that is subsidized or sold at less than fair value,9

 the Commission determines what domestic

product is like the imported articles Commerce has identified.10

B. Scope

 Commerce defined the imported merchandise within the scope of this investigation as follows:

The merchandise covered by this investigation is steel threaded rod. Steel threaded rod is

certain threaded rod, bar, or studs, of carbon quality steel, having a solid, circular cross

section, of any diameter, in any straight length, that have been forged, turned, colddrawn, cold-rolled, machine straightened, or otherwise cold-finished, and into which

threaded grooves have been applied. In addition, the steel threaded rod, bar, or studs

subject to this investigation are non-headed and threaded along greater than 25 percent of

their total length. A variety of finishes or coatings, such as plain oil finish as a temporary

rust protectant, zinc coating (i.e., galvanized, whether by electroplating or hot-dipping),

paint, and other similar finishes and coatings, may be applied to the merchandise.

Included in the scope of this investigation are steel threaded rod, bar, or studs, in which:

(1) iron predominates, by weight, over each of the other contained elements;

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

below exceeds the quantity, by weight, respectively indicated: 
 11 Steel Threaded Rod from the People’s Republic of China: Final Determination of Sales at Less Than Fair

Value, 74 Fed Reg. 8907 (Feb. 28, 2009). 

 12 CR at II-1, PR at II-1.

 13 CR at I-7-I-8, PR at I-6-I-7.

 14 CR at I-7, PR at I-6.

-5-

1. 1.80 percent of manganese, or

2. 1.50 percent of silicon, or

3. 1.00 percent of copper, or

4. 0.50 percent of aluminum, or

5. 1.25 percent of chromium, or

6. 0.30 percent of cobalt, or

7. 0.40 percent of lead, or

8. 1.25 percent of nickel, or

9. 0.30 percent of tungsten, or

10. 0.012 percent of boron, or

11. 0.10 percent of molybdenum, or

12. 0.10 percent of niobium, or

13. 0.41 percent of titanium, or

14. 0.15 percent of vanadium, or

15. 0.15 percent of zirconium.

Steel threaded rod is currently classifiable under subheading 7318.15.5050 and

7318.15.5090 of the HTSUS. Although the HTSUS subheading is provided for

convenience and customs purposes, the written description of the merchandise is

dispositive.

Excluded from the scope of the investigation are: (a) threaded rod, bar, or studs which

are threaded only on one or both ends and the threading covers 25 percent or less of the

total length; and (b) threaded rod, bar, or studs made to American Society for Testing and

Materials (“ASTM”) A193 Grade B7, ASTM A193 Grade B7M, ASTM A193 Grade

B16, or ASTM A320 Grade L7.11

CSTR is primarily used in commercial construction to suspend electrical conduits, plumbing

pipes, HVAC ductwork, and fire protection sprinkler pipes. It is also used to hang suspended ceilings and

elevated conveyor belts, in joint restraint systems for underground piping, in structural tie downs in

earthquake and hurricane-resistant systems for roofing, as headless screws, for bolting together pipe joints

in waterworks applications, and for basic industrial repair.12 The low carbon steel used to make CSTR

allows the rod to be cut to the desired length on site by contractors.13 CSTR is threaded along its entire

length.14

C. Domestic Like Product Analysis

In its preliminary determination in this investigation, the Commission found a single domestic

like product that was coextensive with the scope of the investigation. It based this finding on record

evidence that showed that all CSTR has common physical characteristics (threaded grooves and

composed of low and medium carbon steel) and uses (non-critical bolting applications); that CSTR is not

interchangeable with other threaded rod or other products; that almost all U.S.-produced CSTR is sold in
 15 Certain Steel Threaded Rod From China, Inv. No. 731-TA-1145 (Preliminary), USITC Pub. 3996

(“Preliminary Determination”) at 6-7.

 16 19 U.S.C. § 1677(4)(A).

 17 19 U.S.C. § 1677(4)(B). 

 18 The primary factors the Commission has examined in deciding whether appropriate circumstances exist to

exclude a related party include (1) the percentage of domestic production attributable to the importing producer; (2)

the reason the U.S. producer has decided to import the product subject to investigation, i.e., whether the firm benefits

from the LTFV sales or subsidies or whether the firm must import in order to enable it to continue production and

compete in the U.S. market; and (3) the position of the related producer vis-a-vis the rest of the industry, i.e.,

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

Torrington Co. v. United States, 790 F. Supp. 1161 (Ct. Int’l Trade 1992), aff’d without opinion, 991 F.2d 809 (Fed.

Cir. 1993). The Commission has also considered the ratio of import shipments to U.S. production for related

producers and whether the primary interest of the related producer lies in domestic production or importation. These

latter two considerations were cited as appropriate factors in Allied Mineral Products, Inc. v. United States, Slip Op.

04-139 (Ct. Int’l Trade November 12, 2004) at 5-6, 27 ITRD 1010, 1012 (“The most significant factor considered by

the Commission in making the ‘appropriate circumstances’ determination is whether the domestic producer accrued

a substantial benefit from its importation of the subject merchandise.”); USEC, Inc. v. United States, 132 F. Supp. 2d

1, 12 (Ct. Int’l Trade 2001) (“the provision’s purpose is to exclude from the industry headcount domestic producers

substantially benefitting from their relationships with foreign exporters.”), aff’d, Slip Op. 01-1421 (Fed. Cir. April

22, 2002); S. Rep. No. 249, 96th Cong. 1st Sess. at 83 (1979) (“where a U.S. producer is related to a foreign exporter

and the foreign exporter directs his exports to the United States so as not to compete with his related U.S. producer,

this should be a case where the ITC would not consider the related U.S. producer to be a part of the domestic

(continued...)

-6-

one channel of trade, that is, through distributors; that the full range of CSTR products is produced using

common manufacturing facilities, production processes, and employees; and that customers perceive

CSTR as having distinct properties from other types of threaded rod in that CSTR can easily be cut to

desired lengths.15

No party challenged the definition of the like product made in the preliminary determination, and

there is no evidence in the record calling that definition into question. We therefore again find a single

domestic like product coextensive with the scope of the investigation.

III. DOMESTIC INDUSTRY

1. In General

The domestic industry is defined 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.”16 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.

2. Related Parties

We must determine whether any producer of the domestic like product should be excluded from

the domestic industry pursuant to section 19 U.S.C. § 1677(4)(B). Subsection 1677(4)(B) allows the

Commission, if appropriate circumstances exist, to exclude from the domestic industry producers that are

related to an exporter or importer of subject merchandise or which are themselves importers.17 Exclusion

of such a producer is within the Commission’s discretion based upon the facts presented in each

investigation.18
 18 (...continued)

industry”).

 19 CR/PR at Table III-1. Another producer, Rods Indiana, provided a questionnaire response in the preliminary,

but not the final, phase of this investigation. Its data were not included in the domestic industry data in the finalphase staff report. CR/PR at Table III-1 n.5. Rods Indiana accounted for *** percent of the reported production of

threaded rod in 2007. Id.

 20 CR at III-6 and Table III-5, PR at III-4. In the preliminary phase of this investigation it appeared that *** also

imported the subject merchandise, and we considered whether to exclude that firm from the domestic industry as a

related party. Preliminary Determination at 10. In the final phase of this investigation it became apparent that ***. 

***, to Commission staff (Jan 22, 2009). The Commission has on occasion found that a domestic producer that ***

to be a related party.

 21 Petitioner’s Prehearing Brief at 7-10.

 22 Porteous Prehearing Brief at 3-5.

-7-

The Commission obtained data from the following seven domestic producers of CSTR: ***,

Bay Standard, Conklin & Conklin, Lancaster, Threaded Rod, Vulcan, and Watson.19 ***, imported the

subject merchandise during the period of investigation20 and thus are related parties under the statute. 

Therefore, we must consider whether “appropriate circumstances” exist to exclude any of these U.S.

producers from the domestic industry on the basis of those importations.

a. Parties' Arguments

Petitioner maintains that appropriate circumstances do not exist to exclude any of the domestic

producers from the domestic industry. It argues that these producers have apparently ***. Petitioner

cites the support of *** for the petition as evidence that these firms consider domestic production to be

their primary area of interest. Petitioner also cites the data for interim 2008 as further support for a

decision not to exclude any related parties from the domestic industry. It notes that the ratio of imports to

domestic production ***. It particularly emphasizes that for ***. Finally, Petitioner argues that the fact

that CSTR production accounts for a substantial share of total production for the domestic producers

further underscores the importance of steel threaded rod production to these firms.21 

Porteous argues that *** should be excluded from the domestic industry because it is primarily an

importer. It notes that the ratio of *** imports to its domestic production ***. Porteous also argues that

the inclusion of *** in the domestic industry “appears to have skewed portions of the data for the

domestic industry as a whole.” Porteous maintains that most of *** domestic production is of CSTR

meeting the ASTM A36 specification (“A36 CSTR”), that this is a specialty product which commands

premium prices, and that subject imports do not compete with A36 CSTR. Porteous contends that ***

may have adopted a strategy whereby it ***. Porteous concludes that the inclusion of *** in the domestic

industry has skewed the data in the record in two respects: (1) it has skewed domestic prices upwards,

and, (2) it has skewed the domestic industry’s financial data because *** financial condition cannot be

reflective of any injury caused by subject imports.22 

b. Analysis

We now consider whether appropriate circumstances exist to exclude any related parties from the

domestic industry.
 23 *** accounted for *** percent of domestic production in 2007. CR/PR at Table III-1. The company ***. Id.

Its imports of the subject merchandise were equivalent to *** percent of its production in 2005, 2006, and 2007, and

to *** percent of its production in interim 2007 and interim 2008. CR/PR at Table III-5. The company explained

that it ***. CR/PR at Table III-3 n.1.

 24 *** accounted for *** percent of domestic production in 2007. CR/PR at Table III-1. The company supports

the petition. Id. Its imports of the subject merchandise were equivalent to *** percent of its production in 2005,

2006, and 2007, and to *** percent of its production in interim 2007 and interim 2008. CR/PR at Table III-5. In

addition, in 2007 ***. The company explained that it imports from China ***. CR/PR at Table III-3 n.3.

 25 *** accounted for *** percent of domestic production in 2007. CR/PR at Table III-1. The company supports

the petition. Id. Its imports of the subject merchandise were equivalent to *** percent of its production in 2005 and

2006; the company ***. CR/PR at Table III-3. The company explained that it imports from China ***. CR/PR at

Table III-3 n. 5.

 26 See CR/PR at Table VI-2.

 27 Consistent with her practice in past investigations and reviews, Chairman Shara L. Aranoff does not rely on

individual-company operating income margins in assessing whether a related party has benefitted from importation

of subject merchandise. Rather, she determines whether to exclude a related party based principally on its ratio of

subject imports to domestic production and whether its primary interests lie in domestic production or importation.

 28 Commissioner Pinkert does not rely upon any related party’s financial performance as a factor in determining

whether there are appropriate circumstances to exclude it from the domestic industry in this investigation. He would

only do so if a link were indicated between the relationship in question and financial performance.

 29 CR/PR at Table III-1.

 30 Id.

 31 CR/PR at Table III-5.

 32 CR/PR at Table III-3 n.2.

 33 Hearing Tr. at 25-26.

 34 Chairman Aranoff and Commissioner Williamson concur with the Commission majority with respect to the

inclusion of Bay Standard in the domestic industry. In the preliminary investigation, they found that appropriate

circumstances existed to exclude Bay Standard from the domestic industry largely because of Bay Standard’s ***,

which reached *** percent in 2007. Bay Standard’s *** provides further evidence, not apparent in the preliminary

investigation, that its primary interest is in domestic production.

-8-

*** We find that appropriate circumstances do not exist to exclude ***,23 ***,24 or ***25 from

the domestic industry. The volume of threaded rod produced by these firms in the United States was in

each case consistently greater than the volume of subject merchandise they imported from China. 

Accordingly, even though *** imported ***. Also, ***’s and ***.26 27 28

Bay Standard. Bay Standard accounted for *** percent of domestic production in 2007.29 The

company supports the petition.30 Its imports of the subject merchandise were equivalent to *** percent of

its production in 2005, 2006 and 2007, and to *** percent of its production in interim 2007 and interim

2008.31 The company explained that it imports from China ***.32 At the hearing, a representative from

Bay Standard further explained that its ability to maintain domestic production was also strained by the

minimum rolling requirements of the mills from which it obtains its steel wire rod.33

 We find that appropriate circumstances do not exist to exclude Bay Standard from the domestic

industry.34 Although the levels of its imports relative to its domestic production ***. It is particularly

significant that the company's ratio of subject imports to domestic production declined to *** percent in
 35 See CR/PR at Table VI-2.

 36 Hearing Tr. at 103( Mr. Iverson).

 37 The exclusion of Bay Standard’s pricing data would reduce only *** of the 105 U.S. quarterly prices

presented in the staff report, in most cases by only $***, while increasing *** of the prices. Only *** quarterly

comparisons showing underselling by subject imports would become instances of overselling if the Bay Standard

pricing data were excluded. See CR/PR at Tables V-1-V-7 and E-1-E-7.

 38 Compare CR/PR Tables C-1 with C-2.

 39 CR/PR at Table III-1.

 40 CR/PR at Table III-3.

 41 CR/PR at Table III-5 n.5.

 42 See CR/PR at Table VI-2.

 43 Negligibility is not an issue in this investigation under 19 U.S.C. § 1677(24). The petition was filed on March

5, 2008. Subject imports from China accounted for 73.6 percent of total imports of CSTR for the most recent 12-

month period for which data were available that preceded the filing of the petition (March 2007 through February

2008). CR/PR at Table IV-3.

 44 19 U.S.C. §§ 1671d(b), 1673d(b).

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interim 2008. It supports the petition, and its reason for importing is that it was driven to do so by the

competitive pressure of subject imports. Also, its financial results were generally ***.35 

We are not persuaded by Porteous’s argument that Bay Standard benefitted from its importation

of subject merchandise by pursuing a strategy wherein it ***. While Porteous contends that A36 CSTR is

a premium product, a witness for Bay Standard testified that its A36 CSTR is not more costly to produce

or higher in price than other CSTR.36 Moreover, as noted above, Bay Standard’s ***. Nor is there

evidence that Bay Standard’s pricing data skew the overall domestic pricing data. The exclusion of Bay

Standard’s prices ***.37 In addition, Porteous’s argument that the inclusion of Bay Standard skews the

domestic industry’s financial data is not supported by the record. Bay Standard accounts for only a small

share of domestic production, therefore its data have little effect on the data for the domestic industry as a

whole.38

Vulcan. Vulcan accounted for *** percent of domestic production in 2007.39 Vulcan is the

petitioner. It imported the subject merchandise in ***, and these imports were equivalent to *** percent

of its production in that year.40 The company explained that it imported ***.41

 We find that appropriate circumstances do not exist to exclude Vulcan from the domestic

industry. As it is the petitioner, we conclude that its interests lie more with domestic production than with

importing. Compared to its domestic production, the volume of its imports was ***. Vulcan’s financial

results were ***42***.

In sum, we define the domestic industry as consisting of all producers of the domestic like

product.

IV. MATERIAL INJURY BY REASON OF SUBJECT IMPORTS FROM CHINA43

A. Legal Standards

In the final phase of antidumping or countervailing duty investigations, the Commission

determines whether an industry in the United States is materially injured or threatened with material

injury by reason of the imports under investigation.44 In making this determination, the Commission must

consider the volume of subject imports, their effect on prices for the domestic like product, and their

impact on domestic producers of the domestic like product, but only in the context of U.S. production
 45 19 U.S.C. § 1677(7)(B)( i). The Commission “may consider such other economic factors as are relevant to the

determination” but shall “identify each {such} factor ... {a}nd explain in full its relevance to the determination.” 

19 U.S.C. § 1677(7)(B).

 46 19 U.S.C. § 1677(7)(A).

 47 19 U.S.C. § 1677(7)(C)(iii).

 48 19 U.S.C. § 1677(7)(C)(iii).

 49 19 U.S.C. §§ 1671d(a), 1673d(a).

 50 Angus Chemical Co. v. United States, 140 F.3d 1478, 1484-85 (Fed. Cir. 1998) (“{T}he statute does not

‘compel the commissioners’ to employ {a particular methodology}.”), aff’g 944 F. Supp. 943, 951 (Ct. Int’l Trade

1996).

 51 The Federal Circuit, in addressing the causation standard of the statute, observed that “{a}s long as its effects

are not merely incidental, tangential, or trivial, the foreign product sold at less than fair value meets the causation

requirement.” Nippon Steel Corp. v. USITC, 345 F.3d 1379, 1384 (Fed. Cir. 2003). This was further ratified in

Mittal Steel Point Lisas Ltd. v. United States, 542 F.3d 867, 873 (Fed. Cir. 2008), where the Federal Circuit, quoting

Gerald Metals, Inc. v. United States, 132 F.3d 716, 722 (Fed. Cir. 1997), stated that “this court requires evidence in

the record ‘to show that the harm occurred “by reason of” the LTFV imports, not by reason of a minimal or

tangential contribution to material harm caused by LTFV goods.’” See also Nippon Steel Corp. v. United States, 458

F.3d 1345, 1357 (Fed. Cir. 2006); Taiwan Semiconductor Industry Ass’n v. USITC, 266 F.3d 1339, 1345 (Fed. Cir.

2001).

 52 Statement of Administrative Action (“SAA”) on Uruguay Round Agreements Act (“URAA”), H.R. Rep. 103-

316, Vol. I at 851-52 (1994) (“{T}he Commission must examine other factors to ensure that it is not attributing

injury from other sources to the subject imports.”); S. Rep. 96-249 at 75 (1979) (the Commission “will consider

information which indicates that harm is caused by factors other than less-than-fair-value imports.”); H.R. Rep. 96-

317 at 47 (1979) (“in examining the overall injury being experienced by a domestic industry, the ITC will take into

account evidence presented to it which demonstrates that the harm attributed by the petitioner to the subsidized or

dumped imports is attributable to such other factors;” those factors include “the volume and prices of nonsubsidized

(continued...)

-10-

operations.45 The statute defines “material injury” as “harm which is not inconsequential, immaterial, or

unimportant.”46 In assessing whether the domestic industry is materially injured by reason of subject

imports, we consider all relevant economic factors that bear on the state of the industry in the United

States.47 No single factor is dispositive, and all relevant factors are considered “within the context of the

business cycle and conditions of competition that are distinctive to the affected industry.”48

Although the statute requires the Commission to determine whether the domestic industry is

“materially injured by reason of” unfairly traded imports,49 it does not define the phrase “by reason of,”

indicating that this aspect of the injury analysis is left to the Commission’s reasonable exercise of its

discretion.50 In identifying a causal link, if any, between subject imports and material injury to the

domestic industry, the Commission examines the facts of record that relate to the significance of the

volume and price effects of the subject imports and any impact of those imports on the condition of the

domestic industry. This evaluation under the “by reason of” standard must ensure that subject imports are

more than a minimal or tangential cause of injury and that there is a sufficient causal, not merely a

temporal, nexus between subject imports and material injury.51

In many investigations, there are other economic factors at work, some or all of which may also

be having adverse effects on the domestic industry. Such economic factors might include non-subject

imports; changes in technology, demand, or consumer tastes; competition among domestic producers; or

management decisions by domestic producers. The legislative history explains that the Commission must

examine factors other than subject imports to ensure that it is not attributing injury from other factors to

the subject imports, thereby inflating an otherwise tangential cause of injury into one that satisfies the

statutory material injury threshold.52 In performing its examination, however, the Commission need not
 52 (...continued)

imports or imports sold at fair value, contraction in demand or changes in patterns of consumption, trade restrictive

practices of and competition between the foreign and domestic producers, developments in technology and the

export performance and productivity of the domestic industry”); accord Mittal Steel, 542 F.3d at 877.

 53 SAA at 851-52 (“{T}he Commission need not isolate the injury caused by other factors from injury caused by

unfair imports.”); Taiwan Semiconductor Industry Ass’n v. USITC, 266 F.3d 1339, 1345 (Fed. Cir. 2001) (“{T}he

Commission need not isolate the injury caused by other factors from injury caused by unfair imports . . . . Rather,

the Commission must examine other factors to ensure that it is not attributing injury from other sources to the subject

imports.” (emphasis in original)); Asociacion de Productores de Salmon y Trucha de Chile AG v. United States, 180

F. Supp. 2d 1360, 1375 (Ct. Int’l Trade 2002) (“{t}he Commission is not required to isolate the effects of subject

imports from other factors contributing to injury” or make “bright-line distinctions” between the effects of subject

imports and other causes.); see also Softwood Lumber from Canada, Inv. Nos. 701-TA-414 and 731-TA-928

(Remand), USITC Pub. 3658 at 100-01 (Dec. 2003) (Commission recognized that “{i}f an alleged other factor is

found not to have or threaten to have injurious effects to the domestic industry, i.e., it is not an ‘other causal factor,’

then there is nothing to further examine regarding attribution to injury”), citing Gerald Metals, Inc. v. United States,

132 F.3d 716, 722 (Fed. Cir. 1997) (the statute “does not suggest that an importer of LTFV goods can escape

countervailing duties by finding some tangential or minor cause unrelated to the LTFV goods that contributed to the

harmful effects on domestic market prices.”). 

 54 S. Rep. 96-249 at 74-75; H.R. Rep. 96-317 at 47.

 55 See Nippon Steel Corp., 345 F.3d at 1381 (“an affirmative material-injury determination under the statute

requires no more than a substantial-factor showing. That is, the ‘dumping’ need not be the sole or principal cause of

injury.”).

 56 Mittal Steel, 542 F.3d at 877-78; see also id. at 873 (“While the Commission may not enter an affirmative

determination unless it finds that a domestic industry is materially injured ‘by reason of’ subject imports, the

Commission is not required to follow a single methodology for making that determination ... . {and has} broad

discretion with respect to its choice of methodology.”) citing United States Steel Group v. United States, 96 F.3d

1352, 1362 (Fed. Cir. 1996) and S. Rep. 96-249 at 75.

 57 Commissioner Pinkert does not join this paragraph or the following four paragraphs. He points out that the

Federal Circuit, in Bratsk, 444 F.3d 1369, and Mittal, held that the Commission is required, in certain circumstances,

to undertake a particular kind of analysis of non-subject imports. Mittal explains as follows:

What Bratsk held is that “where commodity products are at issue and fairly traded, price-competitive, nonsubject imports are in the market,” the Commission would not fulfill its obligation to consider an important

aspect of the problem if it failed to consider whether non-subject or non-LTFV imports would have

replaced LTFV subject imports during the period of investigation without a continuing benefit to the

domestic industry. 444 F.3d at 1369. Under those circumstances, Bratsk requires the Commission to

consider whether replacement of the LTFV subject imports might have occurred during the period of

investigation, and it requires the Commission to provide an explanation of its conclusion with respect to

that factor.

(continued...)

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isolate the injury caused by other factors from injury caused by unfairly traded imports.53 Nor does the

“by reason of” standard require that unfairly traded imports be the “principal” cause of injury or

contemplate that injury from unfairly traded imports be weighed against other factors, such as non-subject

imports, which may be contributing to overall injury to an industry.54 It is clear that the existence of

injury caused by other factors does not compel a negative determination.55

Assessment of whether material injury to the domestic industry is “by reason of” subject imports

“does not require the Commission to address the causation issue in any particular way” as long as “the

injury to the domestic industry can reasonably be attributed to the subject imports” and the Commission

“ensure{s} that it is not attributing injury from other sources to the subject imports.”56 57 Indeed, the
 57 (...continued)

542 F.3d at 878.

 58 Nucor Corp. v. United States, 414 F.3d 1331, 1336, 1341 (Fed. Cir. 2005); see also Mittal Steel, 542 F.3d at

879 (“Bratsk did not read into the antidumping statute a Procrustean formula for determining whether a domestic

injury was ‘by reason’ of subject imports.”).

 59 Mittal Steel, 542 F.3d at 875-79.

 60 Mittal Steel, 542 F.3d at 873 (quoting from Gerald Metals, 132 F.3d at 722), 875-79 & n.2 (recognizing the

Commission’s alternative interpretation of Bratsk as a reminder to conduct a non-attribution analysis).

 61 Commissioner Lane also refers to her dissenting views in Polyethylene Terephthalate Film, Sheet, and Strip

from Brazil, China, Thailand, and the United Arab Emirates, Inv. Nos. 731-TA-1131-1134 (Final), USITC Pub.

4040 (Oct. 2008), for further discussion of Mittal Steel.

 62 To that end, after the Federal Circuit issued its decision in Bratsk, the Commission began to present published

information or send out information requests in final phase investigations to producers in non-subject countries that

accounted for substantial shares of U.S. imports of subject merchandise (if, in fact, there were large non-subject

import suppliers). In order to provide a more complete record for the Commission’s causation analysis, these

requests typically seek information on capacity, production, and shipments of the product under investigation in the

major source countries that export to the United States. The Commission plans to continue utilizing published or

requested information in final phase investigations in which there are substantial levels of non-subject imports.

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Federal Circuit has examined and affirmed various Commission methodologies and has disavowed “rigid

adherence to a specific formula.”58

The Federal Circuit’s decisions in Gerald Metals, Bratsk, and Mittal Steel all involved cases

where the relevant “other factor” was the presence in the market of significant volumes of pricecompetitive non-subject imports. The Commission interpreted the Federal Circuit’s guidance in Bratsk as

requiring it to apply a particular additional methodology following its finding of material injury in cases

involving commodity products and a significant market presence of price-competitive non-subject

imports.59 The additional “replacement/benefit” test looked at whether non-subject imports might have

replaced subject imports without any benefit to the U.S. industry. The Commission applied that specific

additional test in subsequent cases, including the Carbon and Certain Alloy Steel Wire Rod from Trinidad

and Tobago determination that underlies the Mittal Steel litigation.

Mittal Steel clarifies that the Commission’s interpretation of Bratsk was too rigid and makes clear

that the Federal Circuit does not require the Commission to apply an additional test nor any one specific

methodology; instead, the court requires the Commission to have “evidence in the record to show that the

harm occurred ‘by reason of’ the LTFV imports,’” and requires that the Commission not attribute injury

from non-subject imports or other factors to subject imports.60 Accordingly, we do not consider ourselves

required to apply the replacement/benefit test that was included in Commission opinions subsequent to

Bratsk.

The progression of Gerald Metals, Bratsk, and Mittal Steel clarifies that, in cases involving

commodity products where price-competitive non-subject imports are a significant factor in the U.S.

market, the Court will require the Commission to give full consideration, with adequate explanation, to

non-attribution issues when it performs its causation analysis.61 62

The question of whether the material injury threshold for subject imports is satisfied

notwithstanding any injury from other factors is factual, subject to review under the substantial evidence
 63 Mittal Steel, 542 F.3d at 873; Nippon Steel Corp., 458 F.3d at 1350, citing U.S. Steel Group, 96 F.3d at 1357;

S. Rep. 96-249 at 75 (“The determination of the ITC with respect to causation is ... complex and difficult, and is a

matter for the judgment of the ITC.”).

 64 We provide in the discussion of impact in section V.E. below a full analysis of other factors alleged to have

caused any material injury experienced by the domestic industry. 

 65 CR at II-1, PR at II-1.

 66 CR at II-12-13, PR at II-9.

 67 CR at II-8, PR at II-6.

 68 CR/PR at Table IV-4.

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standard. Congress has delegated this factual finding to the Commission because of the agency’s

institutional expertise in resolving injury issues.63 64

B. Conditions of Competition and the Business Cycle

The following conditions of competition inform our analysis of whether there is material injury or

threat of material injury by reason of subject imports from China.

1. Demand Conditions

CSTR is primarily used in commercial construction to suspend electrical conduits, plumbing

pipes, HVAC ductwork, and fire protection sprinkler pipes. It is also used to hang suspended ceilings and

elevated conveyor belts, in joint restraint systems for underground piping, in structural tie downs in

earthquake and hurricane-resistant systems for roofing, as headless screws, for bolting together pipe joints

in waterworks applications, and for basic industrial repair.65 Most questionnaire respondents reported that

there are no substitute products for threaded rod.66 Overall demand for CSTR is derived from demand for

its end-use applications, primarily in commercial construction.67

Apparent U.S. consumption of CSTR (the sum of U.S. shipments by the domestic industry and

imports from subject and non-subject sources) declined slightly from 169,675,000 pounds in 2005 to

169,263,000 pounds in 2006, and then rose to 171,599,000 pounds in 2007. In interim 2008, apparent

U.S. consumption (128,225,000 pounds) was higher than in interim 2007 (122,966,000 pounds). In short,

based on quantity, apparent U.S. consumption rose by 1.1 percent from 2005 to 2007, and was 4.3 percent

higher in interim 2008 than in interim 2007.68

2. Supply Conditions

There are three sources of supply in the U.S. market: imports of the subject merchandise, imports

from non-subject sources, and domestic production.

a. Imports of the Subject Merchandise

The petition listed over 400 firms in China believed to be producing and/or exporting CSTR. In

the final phase of this investigation, the Commission sent foreign producer/exporter questionnaires to

more than 125 firms that accounted for almost all of the production/exports of merchandise shipped to the

United States under HTSUS statistical reporting number 7318.15.5060 (a classification which

encompasses CSTR and other products). Of these 125 firms, in the 2005-2007 period, one firm

accounted for over *** percent of U.S.-bound exports, *** of such exports, and *** percent of such

exports. The Commission did not receive any responses to its foreign producer/exporter questionnaires in
 69 CR at VII-1-VII-2, PR at at VII-1.

 70 CR/PR at Table IV-5.

 71 CR at IV-4, PR at IV-3.

 72 CR/PR at Table IV-5.

 73 CR/PR at Table III-1.

 74 CR at III-1 and Table III-1, PR at III-1 and Table III-1.

 75 The domestic industry’s capacity was *** million pounds in 2005 and 2006 and *** million pounds in 2007. 

CR/PR at Table III-2. 

 76 CR/PR at Table III-1 n. 8.

 77 CR/PR at Table IV-5.

 78 CR at V-1, PR at V-1. Steel costs accounted for an average *** percent of the total cost of goods sold during

the periods for which domestic producers reported data. CR at VI-3, PR at VI-1.

 79 CR/PR at V-1 and Figure V-1.

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the final phase of this investigation; it received responses from only three firms in the preliminary phase.69

The U.S. market share of subject imports rose from 34.8 percent in 2005 to 50.4 percent in 2007.70

b. Non-Subject Imports

Importers reported obtaining non-subject imports from five countries: India, Japan, Belgium,

Germany, and Mexico. Nearly 90 percent of non-subject imports were from India.71 The market share of

non-subject imports declined from 6.4 percent in 2005 to 5.8 percent in 2007, and was lower in interim

2008 (5.3 percent) than in interim 2007 (5.9 percent).72

c. Domestic Shipments

The petition identified the following nine producers of CSTR during the period of investigation:

All-Ohio, Bay Standard, Conklin & Conklin, Interstate Fittings, Inc., Lancaster, Rods Indiana, Threaded

Rod, Vulcan, and Watson. The petitioner, Vulcan, is the largest of these producers, accounting for ***

percent of domestic production in 2007.73 The Commission received responses to its U.S. producer

questionnaire from seven of these firms (***), accounting for *** percent of the quantity of reported U.S.

production of threaded rod in 2007.74

The domestic industry’s capacity to produce CSTR remained stable from 2005 to 2006, and then

declined in 2007.75 There was one plant closure in the United States during the POI.76 As explained

above, many U.S. producers imported subject merchandise during the POI. The domestic industry’s

market share declined from 58.8 percent in 2005 to 43.8 percent in 2007, and was lower in interim 2008

(43.4 percent) than in interim 2007 (45.7 percent).77

3. Raw Material Costs

The main raw material input used to make CSTR is carbon steel wire rod. Approximately 80

percent of CSTR is made from wire rod, and the remaining 20 percent is made from steel bar.78 The price

of steel wire rod decreased in early 2005, but then generally increased from the third quarter of 2005 until

the end of 2007. Prices then increased rapidly until July 2008, after which they declined through the end

of 2008.79
 80 CR/PR at Table II-5. Porteous argued that CSTR is not a single undifferentiated product, and in particular that

Chinese producers do not supply threaded rod that meets the ASTM A36 specification. Porteous’s Prehearing Brief

at 6. The record evidence in the final phase of this investigation , however, does not indicate that there is anything

about the A36 specification that calls into question our conclusion that CSTR is broadly interchangeable regardless

of its source. The ASTM A36 specification is a raw material specification – it relates to the steel that is used to

make CSTR. CR at II-11 n.29, PR at II-8. There was disagreement among the parties as to the significance of this

specification. On the one hand, Porteous contends that the ASTM A36 specification “requires elongation and yield

testing that is not required by other specifications.” Porteous Posthearing Brief at 3. On the other hand,

representatives for the domestic industry testified that this specification is “nothing special” and “kind of the lowest

grade.” Bay Standard testified that it makes all of its threaded rod using A36 steel so that it can satisfy those

customers that request this specification, while not having to carry duplicate inventory, and that it sells this kind of

threaded rod for the same price as other threaded rod. Hearing Tr. at 103 (Iverson, Bay Standard). Regardless of the

significance of the ASTM A36 specification, it is clear that threaded rod meeting this specification accounts for a

small share of the overall market. CR at II-22 n.43, PR at II-15 n.43.

 81 CR at II-15, PR at II-10, and CR/PR at Table II-3.

 82 CR/PR at Table II-6.

 83 CR at II-12, PR at II-9.

 84 CR at II-12 n.31, PR at II-9 n.31.

 85 19 U.S.C. § 1677(7)(C)(i).

 86 CR/PR at Table IV-2.

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4. Substitutability

The record shows that there is a high degree of interchangeability between CSTR produced in the

United States, subject imports from China, and non-subject imports. Most domestic producers, importers,

and purchasers of CSTR reported that the U.S. product, the subject imports, and non-subject imports are

“always” or “frequently” interchangeable.80 When asked to identify the three major factors considered in

purchasing decisions, they identified price most frequently as the most important factor.81 The majority

of domestic producers and importers reported that differences other than price are only sometimes or

never a significant factor in sales of CSTR.82

Most producers and importers reported that there are no substitute products for threaded rod,83

and there is little interchangeability between CSTR and other types of threaded rod, which are made of

materials other than low-carbon steel and are produced to different specifications than CSTR.84

C. Volume of the Subject Imports from China

In evaluating the volume of subject imports, section 771(7)(C)(i) of the Tariff Act provides that

the “Commission shall consider whether the volume of imports of the merchandise, or any increase in that

volume, either in absolute terms or relative to production or consumption in the United States, is

significant.”85

As noted above, demand, as measured by apparent U.S. consumption, rose modestly between

2005 and 2007 (by 1.1 percent) and was higher in interim 2008 as compared with interim 2007 (by 4.3

percent). The volume of subject imports rose at a much higher rate, increasing from 53.5 million pounds

in 2005 to 78.3 million pounds in 2006 and 96.8 million pounds in 2007 (or by 80.9 percent from 2005 to

2007), and was 65.8 million pounds in interim 2007 compared with 80.1 million pounds in interim

2008.86 The market share of subject imports on a quantity basis rose from 34.8 percent in 2005 to 41.8

percent in 2006 and 50.4 percent in 2007, and was 48.4 percent in interim 2007 compared with 51.3
 87 CR/PR at Table IV-5.

 88 CR/PR at Table IV-6.

 89 CR/PR at Table IV-4.

 90 CR/PR at Table IV-5.

 91 CR/PR at Table IV-4.

 92 CR/PR at Table IV-5.

 93 19 U.S.C. § 1677(7)(C)(ii).

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percent in interim 2008.87 The ratio of the quantity of subject imports to U.S. production rose from 55.7

percent in 2005 to 79.9 percent in 2006 and 117.9 percent in 2007, and was 107.7 percent in interim 2007

compared with 110.6 percent in interim 2008.88

The domestic industry’s U.S. shipments declined over the POI, falling from 99.8 million pounds

in 2005 to 87.8 million pounds in 2006 and 75.2 million pounds in 2007, and was 56.2 million pounds in

interim 2007 compared with 55.6 million pounds in interim 2008.89 The domestic industry’s market share

on a quantity basis declined from 58.8 percent in 2005 to 51.9 percent in 2006 and 43.8 percent in 2007,

and was 45.7 percent in interim 2007 compared with 43.4 percent in interim 2008.90

The volume of non-subject imports also declined over the POI, falling from 10.8 million pounds

in 2005 to 10.7 million pounds in 2006 and 9.9 million pounds in 2007, and was 7.2 million pounds in

interim 2007 compared with 6.8 million pounds in interim 2008.91 The market share of non-subject

imports on a quantity basis declined from 6.4 percent in 2005 to 6.3 percent in 2006 and 5.8 percent in

2007, and was 5.9 percent in interim 2007 compared with 5.3 percent in interim 2008.92

It is apparent from these data that, during a period of stable-to-rising apparent U.S. consumption,

subject imports gained market share in the United States almost entirely at the expense of the domestic

industry. From 2005 to 2007, the market share of subject imports rose by 15.6 percentage points, while

that of the domestic industry fell by 15.0 percentage points. This trend is also seen in a comparison of 

the interim periods, with subject imports 1.9 percentage points higher and the domestic industry 2.3

percentage points lower in market share in interim 2008 than in interim 2007.

For all of these reasons, we find that the volume of subject imports and the increase in that

volume are significant, both in absolute terms and relative to consumption and production in the United

States.

D. Price Effects of Subject Imports from China

In evaluating the price effects of the subject imports, section 771(7)(C)(ii) of the Tariff Act

provides that the Commission shall consider whether –

 (I) there has been significant price underselling by the imported merchandise as

compared with the price of domestic like products of the United States, and

 (II) the effect of imports of such merchandise otherwise depresses prices to a significant

degree or prevents price increases, which otherwise would have occurred, to a significant

degree.93

As explained above, the record shows that there is a high degree of substitutability between the

domestic like product and subject imports from China, that purchasers most frequently identified price as

the most important factor in purchasing decisions, and that most domestic producers and importers

reported that non-price factors are only sometimes or never a significant factor in CSTR sales.
 94 These products are as follows: (1) low-carbon steel fully threaded rod, electro-plated with zinc, 3/8 inch in

diameter, and 10 feet in length (Product 1); (2) low-carbon steel fully threaded rod, electro-plated with zinc, 1/4 inch

in diameter, and 10 feet in length (Product 2); (3) low-carbon steel fully threaded rod, hot-dip galvanized, 5/8 inch in

diameter, and 12 feet in length (Product 3); (4) low-carbon steel fully threaded rod, electro-plated with zinc, 3/8 inch

in diameter, and 6 feet in length (Product 4); (5) low-carbon steel fully threaded rod, electro-plated with zinc, 1/2

inch in diameter, and 10 feet in length (Product 5); (6) low-carbon steel fully threaded rod, plain, 3/4 inch in

diameter, and 12 feet in length (Product 6); and (7) low-carbon steel fully threaded rod, plain, 1 1/4 inch in diameter,

and 12 feet in length (Product 7). CR at V-7, PR at V-5.

 95 CR at V-8, PR at V-6. In comparing prices, the Commission's practice is to rely on data for sales made at

arm’s length and at the same level of trade. See, e.g., Tetrahydrofurfuryl Alcohol from China, Inv. No. 731-TA1046 (Final), USITC Pub. 3709 (July 2004) at n. 42 (declining to place significant weight on price comparisons from

differing levels of trade); and Durum and Hard Red Spring Wheat from Canada, Inv. Nos. 701-TA-430A and 430B

and 731-TA-1019A and 1019B (Final), USITC Pub. 3639 (October 2003) at 27, n. 245 (“not directly comparable”). 

Accordingly, ***. CR at V-8 n.20, PR at V-6 n.20. We note that even if *** data had been included, there would

still have been significant underselling by subject imports. See CR/PR at App. F.

 96 Subject imports undersold the domestic like product in all 15 comparisons for product 1, with the margins of

underselling ranging from 6.0 percent to 19.3 percent. CR/PR at Table V-1. For product 2, subject imports

undersold the domestic like product in 14 of 15 comparisons, with the margins of underselling ranging from 5.8 to

28.3 percent. CR/PR at Table V-2. For product 3, subject imports undersold the domestic like product in 14 of 15

comparisons, with the margins of underselling ranging from 2.2 to 34.0 percent. CR/PR at Table V-3. For product

4, subject imports undersold the domestic like product in 14 of 15 comparisons, with the margins of underselling

ranging from 1.0 to 15.1 percent. CR/PR at Table V-4. For product 5, subject imports undersold the domestic like

product in 14 of 15 comparisons, with the margins of underselling ranging from 7.2 to 23.3 percent. CR/PR at Table

V-5. For product 6, subject imports undersold the domestic like product in 13 of 15 comparisons, with the margins

of underselling ranging from 0.0 to 18.4 percent. CR/PR at Table V-6. For product 7, subject imports undersold the

domestic like product in all 15 comparisons, with the margins of underselling ranging from 3.9 to 46.1 percent. 

CR/PR at Table V-7.

 97 CR at V-8, PR at V-6 and CR/PR at Tables V-1 through V-7.

 98 CR at V-9, PR at V-6 and CR/PR at Tables V-1 through V-7.

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The Commission sought quarterly pricing data for seven types of CSTR.94 The Commission

received usable pricing data from seven U.S. producers and 19 importers from China.95 The pricing data

collected for all seven products show widespread underselling (99 of 105 quarterly comparisons) by

subject imports at sometimes large margins throughout the period of investigation.96 In light of these

facts, we find that there has been significant underselling of the domestic like product by subject imports

from China.

We have also considered changes in CSTR prices over the period of investigation. For products 1

through 6, the prices of U.S. produced CSTR generally declined from 2005 through the middle of 2007

(the declines ranged from 1.6 to 24.7 percent), and then increased rapidly from late 2007 through interim

2008, with the greatest increases in the final two quarters of the POI. The prices for product 7 increased

irregularly from 2005 through 2007, and then increased more rapidly in interim 2008.97 The prices of the

subject imports from China showed patterns that were similar to those for the prices of the U.S. products,

except that prices of the subject imports for all seven products declined from 2005 through the third

quarter of 2007 (the declines ranging from 2.0 to 26.4 percent).98 Given that the domestic product and

subject imports are highly substitutable, that price is the most important factor in purchasing decisions,

and that subject imports undersold the domestic product to a significant degree, the price and volume data

provide strong evidence that subject imports depressed domestic prices to a significant degree in the

period from 2005 through the third quarter of 2007. Declining prices during a period in which subject

import levels are rising are particularly significant for a highly substitutable, price-competitive product

such as CSTR.
 99 CR at II-24, PR at II-17.

 100 The domestic industry’s average unit sales value was $0.53 per pound in 2005, $0.52 per pound in 2006, and

$0.53 per pound in 2007. CR/PR at App. G. (As discussed below, we have decided to use the data on the domestic

industry's operations presented in Appendix G of the staff report, rather than the data in Table VI-1.) The domestic

industry’s average unit cost of goods sold (“COGS”) was $0.41 per pound in 2005, $0.41 per pound in 2006, and

$0.44 per pound in 2007. CR/PR at App. G. The domestic industry’s COGS as a share of net sales rose from 78.1

percent in 2005 to 78.2 percent in 2006 and 84.5 percent in 2007. CR/PR at App. G. The industry’s COGS-to-netsales ratio was *** in interim 2008 (*** percent) than in interim 2007 (*** percent). Id. As described below, we

give the data for interim 2008 less weight in our analysis due to the pendency of these investigations.

 101 The Commission confirmed *** of the total *** in alleged lost sales during the period of investigation. CR at

V-24, PR at V-15. The Commission also confirmed *** of the total *** in alleged lost revenues. Id.

 102 See 19 U.S.C. § 1677(7)(I). The statutory provision governing the Commission’s treatment of post-petition

information states as follows:

[T]he Commission shall consider whether any change in the volume, price effects, or impact of imports of

the subject merchandise since the filing of the petition in an investigation ... is related to the pendency of

the investigation and, if so, the Commission may reduce the weight accorded to the data for the period after

the filing of the petition in making its determination of material injury, threat of material injury, or material

retardation of the establishment of an industry in the United States.

 103 *** accounted for almost *** percent of reported imports of the subject merchandise from China in 2007. 

CR/PR at Table IV-1.

 104 Porteous Posthearing Brief at 9. 

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There is also evidence that subject imports suppressed prices of the domestic like product to a

significant degree. Because there are few if any viable substitutes for CSTR in many applications, and

because CSTR accounts for a low cost share in the completion of various construction-related projects,

demand for CSTR has a low sensitivity to changes in price.99 While demand for such a product may still

vary for reasons unrelated to price (such as a drop in construction-related activity), demand in the U.S.

market was stable or slightly increasing from 2005 to 2007. In such a market, we would expect domestic

producers to be able to pass on higher production costs to their purchasers, absent other evidence on the

record reflecting market conditions that restrict price adjustment. In this investigation, the domestic

industry experienced higher production costs, yet was unable to offset its higher costs with an increase in

prices. From 2005 to 2007, while the domestic industry experienced an increase in average unit costs of

goods sold, prices for most pricing products fell and the industry’s average unit sales values remained

essentially unchanged.100 We attribute the industry’s inability to raise costs to competition from a

significant and growing volume of subject imports, which undersold and were highly substitutable with

the domestic product, in an environment in which price is the most important factor in purchasing

decisions. Based on these data, we find that the domestic industry was experiencing a cost-price squeeze

in 2007, that it should have been able to increase prices for CSTR and that subject imports prevented

price increases that otherwise would have occurred to a significant degree.

Finally, the evidence of confirmed lost sales and revenues101 supports our finding that the subject

imports depressed and suppressed prices of the domestic like product to a significant degree.

There is evidence in the record that the pendency of this investigation allowed domestic

producers to regain customers and raise their prices in interim 2008.102 After the petition was filed,

***,103 ***.104 While the suspension of sales was temporary, this action taken by a high-volume importer

had an impact on purchasing decisions. A representative from Bay Standard testified at the hearing that

“[i]mmediately after the case was filed, Porteous ceased doing business in threaded rod . . . [and that]

[d]uring that time, Bay Standard was able to capitalize on their temporary absence from the market and
 105 Hearing Tr. at 28-29 (Iverson).

 106 Hearing Tr. at 64 (Upton).

 107 Porteous Postconference Brief at Attachment 6. This price increase was to go into effect on April 16, 2008. 

Id.

 108 Porteous Posthearing Brief at 9.

 109 E.g., Hearing Tr. at 22 (Ostermueller, Watson Metal Products Corp.) (Watson and importers of Chinese

threaded rod raised their prices after the filing of the petition).

 110 See Memorandum INV-GG-025 (March 25, 2009).

 111 CR/PR at Figure V-1.

 112 Hearing Tr. at 17 (Logan, Vulcan); CR/PR at App. H (statements on anticipated negative effects by ***.

 113 In its final determination, Commerce found a dumping margin of 55.16 percent for all producer/exporter

groupings except one, for which the margin was 206 percent, which is also the country-wide margin. CR/PR at

Table I-1.

 114 19 U.S.C. § 1677(7)(C)(iii); see also SAA at 851 and 885 (“In material injury determinations, 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 also may demonstrate that an

industry is facing difficulties from a variety of sources and is vulnerable to dumped or subsidized imports.”).

 115 19 U.S.C. § 1677(7)(C)(iii); see also SAA at 851, 885; Live Cattle from Canada and Mexico, Invs. Nos. 701-

TA-386, 731-TA-812-813 (Prelim.), USITC Pub. 3155 at 25 n.148 (Feb. 1999).

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recapture additional business.”105 Similarly, a representative from Vulcan testified that Porteous’

temporary withdrawal from the market prompted purchasers to turn to Vulcan.106 The filing of the

petition on March 5, 2008 also led to price increases. Vulcan announced a 25 percent price increase on

March 20, 2008,107 and ***.108 Other domestic producers and importers also raised their prices.109 As

discussed below, the higher prices that the domestic industry was able to realize in interim 2008 led to

improvements in its financial performance.

We recognize that sharply rising prices for steel wire rod (the principal raw material used in

producing CSTR) also played an important role in the rising prices for CSTR in interim 2008, although

CSTR price increases were greater than the increase in raw material costs.110 As noted above, prices for

steel wire rod increased rapidly from the beginning of 2008 until July of that year.111 We also find,

however, that domestic producers would not have been able to implement the price increases without the

pendency of this investigation.112 Consequently, we give less weight to the improvement in domestic

prices in interim 2008 in our assessment of the price effects of subject imports. 

For the foregoing reasons, we find that there has been significant underselling by the subject

imports and that such imports depressed and suppressed domestic prices to a significant degree. 

Accordingly, we find that subject imports have had significant adverse effects on domestic prices. 

E. Impact of the Subject Imports from China on the Domestic Industry113

In examining the impact of subject imports, section 771(7)(C)(iii) of the Tariff Act provides that

the Commission “shall evaluate all relevant economic factors which have a bearing on the state of the

industry.”114 These factors include output, sales, inventories, ability to raise capital, research and

development, and factors affecting domestic prices. No single factor is dispositive and all relevant factors

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

to the affected industry.”115

We have examined the performance indicators in the trade and financial data for the domestic

industry producing CSTR. These data indicate sharp declines in the 2005-2007 period. Production
 116 Production fell from *** million pounds in 2005 to *** million pounds in 2006 and *** million pounds in

2007. CR/PR at Tables III-2 and C-1. 

 117 CR/PR at Table III-2 and C-1.

 118 U.S. shipments were *** million pounds in 2005, *** million pounds in 2006, and *** million pounds in

2007. CR/PR at Tables III-4 and C-1.

 119 The ratio of inventories to total shipments was *** percent in 2005, *** percent in 2006, and *** percent in

2007. CR/PR at Tables III-6 and C-1.

 120 The number of production and related workers declined from *** in 2005 to *** in 2006 and *** in 2007. 

Aggregate hours worked fell from *** in 2005 to *** in 2006 and *** in 2007. Aggregate wages paid were $***

million in 2005, $*** million in 2006, and $*** million in 2007. CR/PR at Tables III-7 and C-1.

 121 Hourly wages rose from $*** in 2005 to $*** in 2006 and $*** in 2007. Productivity (measured in pounds

per hour) declined from *** in 2005 to *** in 2006, before rising to *** in 2007. CR/PR at Tables III-7 and C-1. 

 122 CR/PR at App. G. To analyze the condition of the U.S. industry, Commission practice is to request financial

data for the most recent three full fiscal years as well as the most recent partial year available for each domestic firm.

The data must then be aggregated to reflect the condition of the industry as a whole. When the fiscal years of the

individual reporting companies do not coincide, the Commission must attempt to aggregate data from different time

periods. While the Commission endeavors to base its determinations on the most recent data available to it, it also

seeks to base its determinations on a complete set of trade and financial data that cover the same, or substantially the

same, time periods, for the industry as a whole. In this investigation, not all U.S. producers reported full fiscal year

data for 2008. To address this inconsistency, staff presented industry financial data using two different approaches

(Table VI-I and Appendix G). The Commission has decided to rely on the data in Appendix G (capturing financial

data for fiscal years 2005-2007) because those data cover substantially the same time periods as the trade data in the

report. As such, any developments in any given fiscal year – and trends between fiscal years – are much more

directly comparable to the trade data in Tables III-4 and IV-2 rather than the “blended” data in Table VI-1. In our

view, the data presented in Appendix G are also the most representative of the financial state of the domestic

industry for any given fiscal year. Whereas the data in Appendix G represent fiscal years 2005-2007 for all domestic

producers, Table VI-1 aggregates data for fiscal years 2006-2008 for producers representing most of domestic

production with data for fiscal years 2005-2007 for producers representing the rest of domestic production. The

Appendix G data also are preferable because they permit the Commission to examine three full years of data

preceding the filing of the petition in this case.

 123 Id.

 124 Id.

 125 Id.

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declined by 22.9 percent from 2005 to 2007.116 Capacity utilization dropped from *** percent in 2005 to

*** percent in 2006 and *** percent in 2007.117 Domestic producers’ U.S. shipments fell by *** percent

from 2005 to 2007.118 Domestic producers’ inventories as a ratio to shipments declined from 2005 to

2007.119

As to the domestic industry’s employment indicators, the number of production and related

workers, aggregate hours worked, and aggregate wages paid all declined sharply over the 2005-2007

period.120 There were, however, some improvements in hourly wages and productivity in this period.121

The domestic industry’s financial indicators – net sales measured by quantity and value,

operating income, and operating margins – also declined sharply in the 2005-2007 period (especially from

2006 to 2007). The quantity of net sales was *** pounds in 2005, *** pounds in 2006, and *** pounds in

2007.122 The value of net sales was $*** in 2005, $*** in 2006, and $*** in 2007.123 Operating income

declined from $*** in 2005 to $*** in 2006 and $*** in 2007.124 The industry’s ratio of operating

income to net sales fell from *** percent in 2005 to *** percent in 2006 and *** percent in 2007.125 
 126 Production was *** million pounds in interim 2007 compared with *** million pounds in interim 2008. 

CR/PR at Tables III-2 and C-1. 

 127 CR/PR at Table III-2 and C-1.

 128 U.S. shipments were *** million pounds in interim 2007 and *** million pounds in interim 2008. CR/PR at

Tables III-4 and C-1.

 129 The ratio of inventories to total shipments was *** percent in interim 2007 and *** percent in interim 2008. 

CR/PR at Tables III-6 and C-1.

 130 The number of production and related workers was *** in interim 2007 and *** in interim 2008. Aggregate

hours worked were *** in interim 2007 and *** in interim 2008. Aggregate wages paid were $*** million in

interim 2007 and $*** million in interim 2008. Hourly wages were $*** in interim 2007 and $*** in interim 2008. 

Productivity (measured in pounds per hour) was *** in interim 2007 and *** in interim 2008. CR/PR at Tables III-7

and C-1.

 131 Id.

 132 Id.

 133 Id.

 134 CR/PR at App. G.

 135 The effects of the filing of the petition also can be seen in Vulcan’s monthly profit and loss statement for

2008. As noted above, Vulcan announced a price increase on March 20, 2008 that was to take effect on April 16,

2008. The profit and loss statement shows that there was ***. Petitioner’s Posthearing Brief at Exh. 13.

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We recognize that many of the domestic industry’s performance indicators improved in interim

2008 as compared with interim 2007. Production was 17.9 percent higher in interim 2008 as compared

with interim 2007.126 Capacity utilization was *** percent in interim 2008 compared with *** percent in

interim 2007,127 although domestic producers’ U.S. shipments were *** percent lower in interim 2008 as

compared with interim 2007.128 Domestic producers’ inventories as a ratio to shipments, however, were

higher in interim 2008 as compared with interim 2007.129 There also was improvement in some of the

domestic industry’s employment indicators.130 Some of the the domestic industry’s financial indicators

also showed signs of improvement. The value of net sales was $*** in interim 2007 and $*** in interim

2008.131 The industry experienced an operating loss of $*** in interim 2007 and a gain of $*** in interim

2008.132 The industry’s ratio of operating income to net sales was *** percent in interim 2007 and ***

percent in interim 2008.133 However, the quantity of net sales was *** pounds in interim 2007 and ***

pounds in interim 2008.134 We give less weight to the improvements in the domestic industry’s condition

in interim 2008 due to the effect of the pendency of this investigation during that period. As discussed

above, the filing of the petition in this case allowed the domestic industry to raise prices and to regain

customers.135

We conclude that subject imports had an adverse impact on the condition of the domestic industry

during the period of investigation. In particular, we find that both the absolute and relative volumes of

subject imports were significant. In addition, subject imports gained market share at the expense of the

domestic industry, undersold the domestic product to a significant degree, and depressed and suppressed

domestic prices to a significant degree. As the domestic industry’s costs increased and significant

volumes of lower-priced subject imports entered the U.S. market, the domestic industry was caught in a

cost-price squeeze in 2007. The increase in subject imports and their adverse effects on U.S. prices

caused declines in the domestic industry’s trade, employment, and financial performance over the period

of investigation until interim 2008.

We have also examined market trends with respect to non-subject imports. We recognize that the

majority of questionnaire respondents consider domestically produced CSTR and imports from China to
 136 CR/PR at Table II-5.

 137 CR/PR at Table IV-5.

 138 CR at IV-4, PR at IV-3.

 139 Revised Staff Report Tables IV-2 and IV-4.

 140 Importer questionnaire responses showed that the value of imports from India (which accounted for almost 90

percent of non-subject imports) was close to that of imports from China – in 2007, imports from India averaged ***

per pound, while imports from China averaged $*** per pound. On the other hand, importer questionnaire responses

showed that imports from Japan, Belgium and Germany were priced ***. CR at IV-4, PR at IV-3. We recognize

that the quarterly pricing data show that non-subject imports from India and Mexico ***. CR/PR at Tables V-1-V-7.

 141 With respect to the analysis required by the Federal Circuit in Bratsk, Commissioner Pinkert notes that,

although the record indicates that threaded rod is a commodity product for these purposes, it is unclear whether

price-competitive non-subject imports are a significant factor in the U.S. market. Regardless of whether the Bratsk

threshold criteria are satisfied, however, he finds that the record evidence is clear that, had subject imports exited the

U.S. market during the period examined in this investigation, non-subject imports would not have replaced them

without benefit to the domestic industry from their absence. Non-subject imports held only a small and declining

share of the U.S. market during the period. CR/PR at Table IV-5. Nearly 90 percent of those imports were from

India. Non-subject imports from countries other than India during the period had average unit values that were

substantially higher than imports from China and India and thus may have been products outside the scope of the

investigation. CR at IV-4 and VII-5, PR at IV-3 and VII-2. There is no record information with respect to Indian

producers’ capacity and capacity utilization, but the limited information that is available indicates that India is not a

significant enough supplier of threaded rod to have replaced imports from China. Petitioner and respondent Porteous

agree that Bratsk should not have any impact on the Commission’s conclusions in this investigation regarding

causation of material injury. CR at VII-5 to VII-6, PR at VII-2-VII-3 citing Staff Conference Transcript at 49-50

(Waite) and 107 (Magrath).

 142 We have not identified, and no party has claimed that, any factors other than those already discussed have

been injurious to the domestic industry during the period examined.

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be “always” or “frequently” interchangeable with non-subject imports.136 By quantity, non-subject

imports’ share of the U.S. market declined from *** percent in 2005 to *** percent in 2007, and was

lower in interim 2008 (*** percent) compared with interim 2007 (*** percent).137 Importers reported

obtaining non-subject imports from five countries (India, Japan, Belgium, Germany, and Mexico), with

nearly 90 percent of non-subject imports from India.138 There is no information on the record with respect

to Indian producers’ capacity and capacity utilization, but the limited evidence available indicates that

India is not a significant supplier of threaded rod to the U.S. market and that U.S. imports from India have

remained at consistent levels, accounting for a relatively small share of the U.S. market during the period

of investigation.139 Collectively, non-subject imports generally were higher valued than subject imports

from China, although the evidence suggests that non-subject imports, particularly from India and Mexico,

were lower valued than the domestic like product.140 We find that any injury we have found from subject

imports from China cannot be attributed to non-subject imports because of the relatively low and

declining levels of non-subject imports.141 142

Consequently, the record in this investigation indicates a causal nexus between the subject

imports and the condition of the domestic industry and thus demonstrates material injury by reason of

subject imports. We therefore conclude that subject imports have had a significant adverse impact on the

domestic industry.
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CONCLUSION

For the reasons stated above, we find that an industry in the United States is materially injured by

reason of imports of certain steel threaded rod from China that have been found by Commerce to be sold

at less than fair value.

 1

 See the section entitled “The Subject Merchandise” in Part I of this report for a complete description of the

merchandise subject to this investigation.

 2

 Selected Federal Register notices cited in the tabulation are presented in appendix A.

I-1

PART I: INTRODUCTION

BACKGROUND

This investigation results from a petition filed with the U.S. International Trade Commission

(“Commission”) and the U.S. Department of Commerce (“Commerce”) by Vulcan Threaded Products,

Inc. (“Vulcan”), Pelham, AL, on March 5, 2008, alleging that an industry in the United States is

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

certain steel threaded rod (“threaded rod”)1

 from China. Information relating to the background of the

investigation is provided below.2

Effective Date Action

March 5, 2008 Petition filed with Commerce and the Commission; institution of Commission

investigation

April 1, 2008 Commerce’s notice of initiation

April 18, 2008 Commission’s preliminary affirmative determination

October 8, 2008 Commerce’s preliminary antidumping duty determination

October 8, 2008 Commission’s scheduling of the final phase investigations (73 FR 70671,

November 21, 2008)

October 27, 2008 Commerce’s amended preliminary antidumping duty determination and

postponement of final determination (73 FR 63694)

February 27, 2009 Commerce’s final determination (74 FR 8907)

February 25, 2009 Commission’s hearing1

March 26, 2009 Commission’s vote

April 6, 2009 Commission determination to Commerce

 1 A list of the witnesses appearing at the hearing is presented in appendix B.
I-2

STATUTORY CRITERIA AND ORGANIZATION OF THE REPORT

Statutory Criteria

Section 771(7)(B) of the Tariff Act of 1930 (the “Act”) (19 U.S.C. § 1677(7)(B)) provides that in

making its determinations of injury to an industry in the United States, the Commission--

shall consider (I) the volume of imports of the subject merchandise, (II)

the effect of imports of that merchandise on prices in the United States

for domestic like products, and (III) the impact of imports of such

merchandise on domestic producers of domestic like products, but only

in the context of production operations within the United States; and . . .

may consider such other economic factors as are relevant to the

determination regarding whether there is material injury by reason of

imports.

Section 771(7)(C) of the Act (19 U.S.C. § 1677(7)(C)) further provides that--

In evaluating the volume of imports of merchandise, the Commission

shall consider whether the volume of imports of the merchandise, or any

increase in that volume, either in absolute terms or relative to production

or consumption in the United States is significant.

. . .

In evaluating the effect of imports of such merchandise on prices, the

Commission shall consider whether . . . (I) there has been significant

price underselling by the imported merchandise as compared with the

price of domestic like products of the United States, and (II) the effect of

imports of such merchandise otherwise depresses prices to a significant

degree or prevents price increases, which otherwise would have

occurred, to a significant degree.

. . .

In examining the impact required to be considered under subparagraph

(B)(i)(III), the Commission shall evaluate (within the context of the

business cycle and conditions of competition that are distinctive to the

affected industry) all relevant economic factors which have a bearing on

the state of the industry in the United States, including, but not limited to

. . . 

(I) actual and potential declines in output, sales, market share, profits,

productivity, return on investments, and utilization of capacity, (II)

factors affecting domestic prices, (III) actual and potential negative

effects on cash flow, inventories, employment, wages, growth, ability to

raise capital, and investment, (IV) actual and potential negative effects

on the existing development and production efforts of the domestic

industry, including efforts to develop a derivative or more advanced

version of the domestic like product, and (V) in {an antidumping

investigation}, the magnitude of the margin of dumping.
 3

 According to official Commerce statistics for HTS 7318.15.5060, imports from China accounted for 73.1

percent of all threaded rod imports in 2007. HTS statistical reporting number 7318.15.5060 may overstate imports

of subject threaded rod since it also includes a number of nonsubject products such as threaded rods made from alloy

steel, hanger bolts, and rods not threaded along their entire length, etc.

 4

 According to reported U.S. importers’ pricing data from nonsubject countries, the large majority (***) of

nonsubject threaded steel rod in the U.S. market is from India. See Part V: Pricing and Related Information.

 5

 According to official Commerce statistics for HTS 7318.15.5060, imports from China accounted for 73.1

percent of all threaded rod imports in 2007. HTS statistical reporting number 7318.15.5060 may overstate imports

of subject threaded rod since it also includes a number of nonsubject products such as threaded rods made from alloy

steel, hanger bolts, and rods not threaded along their entire length, etc.

I-3

Organization of the Report

Part I of this report presents information on the subject merchandise, dumping margins, and

domestic like product. Part II of this report presents information on conditions of competition and other

relevant economic factors. Part III presents information on the condition of the U.S. industry, including

data on capacity, production, shipments, inventories, and employment. Parts IV and V present the

volume in the market of imports of the subject merchandise and pricing, respectively. Part VI presents

information on the financial experience of U.S. producers. Part VII presents the statutory requirements

and information obtained for use in the Commission’s consideration of the question of threat of material

injury and the judicial requirements and information obtained for use in the Commission’s consideration

of Bratsk issues.

U.S. MARKET SUMMARY

Threaded rod generally is used in commercial construction to suspend electrical conduit, pipes for

plumbing, HVAC ductwork, and sprinkler systems. The leading U.S. producer of threaded rod is Vulcan,

while the petition identified over 400 possible producers of threaded rod from China. The leading U.S.

importers of threaded rod from China are ***. The majority of threaded rod imported into the United

States came from China,3

 with India accounting for nearly 90 percent of nonsubject imports from 2005 to

2007.4

Apparent U.S. consumption of threaded rod totaled approximately *** in the U.S. market in

2007. Currently, eight firms are known to produce threaded rod in the United States. U.S. producers’

U.S. shipments of threaded rod totaled *** in 2007, and accounted for *** percent of apparent U.S.

consumption by quantity and *** percent by value. U.S. shipments of imports from China totaled 86.4

million pounds ($53.3 million) in 2007 and accounted for *** percent of apparent U.S. consumption by

quantity and *** percent by value. U.S. shipments of imports from nonsubject sources totaled 9.9 million

pounds ($9.2 million) in 2007 and accounted for *** percent of apparent U.S. consumption by quantity

and *** percent by value.

SUMMARY DATA AND DATA SOURCES

A summary of data collected in this investigation is presented in appendix C, tables C-1 and C-2. 

Except as noted, U.S. industry data are based on questionnaire responses of seven firms that are believed

to have accounted for the majority of U.S. production of threaded rod during 2007. U.S. imports are

based on importer questionnaire responses.5
 6 Certain Threaded Steel Rod from the People's Republic of China: Final Determination of Sales at Less Than

Fair Value, 74 FR 8907, February 27, 2009.

I-4

PREVIOUS AND RELATED INVESTIGATIONS

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

investigations in the United States.

SALES AT LTFV

On February 27, 2009, the Commission received Commerce’s final determination of sales at

LTFV with respect to imports from China.6

 Table I-1 summarizes Commerce’s final LTFV findings.

Table I-1

Threaded rod: Commerce’s final weighted-average LTFV margins

Exporter Producer

Dumping margin

(percent)

RMB Fasteners Ltd., and IFI & Morgan

Ltd.

Jiaxing Brother Fastener Co., Ltd. 55.16

Ningbo Yinzhou Foreign Trade Co., Ltd. Zhejiang Guorui Industry Co., Ltd.; or Ningbo

Daxie Chuofeng Industrial Development Co.,

Ltd.

206.00

Shanghai Recky International Trading

Co., Ltd.

Shanghai Xiangrong International Trading

Co., Ltd.; Shanghai Xianglong International

Trading Co., Ltd.; Pighu City Zhapu Screw

Cap Factory; or Jiaxing Xinyue Standard Part

Co., Ltd.

55.16

Suntec Industries Co., Ltd. Jiaxing Xinyue Standard Part Co., Ltd.; or

Haiyan County No. 1 Fasteners Factory

55.16

Hangzhou Grand Imp. & Exp. Co., Ltd. Zhapu Creative Standard Parts Material Co.,

Ltd.

55.16

Shanghai Prime Machinery Co. Ltd. Haiyan Yida Fasteners Co., Ltd.; or Jiaxing

Xinyue Standard Part Co., Ltd.

55.16

Jiaxing Xinyue Standard Part Co., Ltd. Jiaxing Xinyue Standard Part Co., Ltd. 55.16

Certified Products International Inc. Jiashan Zhongsheng Metal Products Co.,

Ltd.; or Jiaxing Xinyue Standard Part Co.,

Ltd.

55.16

Zhejiang New Oriental Fastener Co.,

Ltd.

Zhejiang New Oriental Fastener Co., Ltd. 55.16

Jiashan Zhongsheng Metal Products

Co., Ltd.

Jiashan Zhongsheng Metal Products Co.,

Ltd.

55.16

Haiyan Dayu Fasteners Co., Ltd. Haiyan Dayu Fasteners Co., Ltd. 55.16

All other (PRC-Wide) 206.00

Source: 74 FR 8907, February 27, 2009.
 7

 Effective July 1, 2008, a separate HTS subheading 7318.15.5050 was created for “continuously threaded rod”

made of carbon or alloy steel. At the same time, the HTS subheading under which carbon and alloy steel threaded

rod had previously been classified (7318.15.5060) was deleted, and a new HTS subheading 7318.15.5090 for “other”

(continued...)

I-5

THE SUBJECT MERCHANDISE

Commerce’s Scope

Commerce has defined the scope of this investigation as follows:

The merchandise covered by this investigation is steel threaded rod. Steel threaded rod is

certain threaded rod, bar, or studs, of carbon quality steel, having a solid, circular cross

section, of any diameter, in any straight length, that have been forged, turned, colddrawn, cold-rolled, machine straightened, or otherwise cold-finished, and into which

threaded grooves have been applied. In addition, the steel threaded rod, bar, or studs

subject to this investigation are non headed and threaded along greater than 25 percent of

their total length. A variety of finishes or coatings, such as plain oil finish as a temporary

rust protectant, zinc coating (i.e., galvanized, whether by electroplating or hot-dipping),

paint, and other similar finishes and coatings, may be applied to the merchandise. 

Included in the scope of this investigation are steel threaded rod, bar, or studs, in which:

(1) iron predominates, by weight, over each of the other contained elements; (2) the

carbon content is 2 percent or less, by weight; and (3) none of the elements listed below

exceeds the quantity, by weight, respectively indicated: 

1. 1.80 percent of manganese, or

2. 1.50 percent of silicon, or

3. 1.00 percent of copper, or

4. 0.50 percent of aluminum, or

5. 1.25 percent of chromium, or

6. 0.30 percent of cobalt, or

7. 0.40 percent of lead, or

8. 1.25 percent of nickel, or

9. 0.30 percent of tungsten, or

10. 0.012 percent of boron, or

11. 0.10 percent of molybdenum, or

12. 0.10 percent of niobium, or

13. 0.41 percent of titanium, or

14. 0.15 percent of vanadium, or

15. 0.15 percent of zirconium.

Excluded from the scope of the investigation are: (a) threaded rod, bar, or studs which

are threaded only on one or both ends and the threading covers 25 percent or less of the

total length; and (b) threaded rod, bar, or studs made to American Society for Testing and

Materials (“ASTM”) A193 Grade B7, ASTM A193 Grade B7M, ASTM A193 Grade

B16, or ASTM A320 Grade L7.”

Threaded rod is currently imported under statistical reporting number 7318.15.5050 of

the Harmonized Tariff Schedule of the United States (“HTS”).7

 The HTS provision is
 7

 (...continued)

category of products was added. E-mail from Frederick Waite, Counsel for Vulcan, November 14, 2008.

 8 Certain Steel Threaded Rod from the People’s Republic of China: Final Determination of Sales at Less Than

Fair Value, 74 FR 8907, February 27, 2009.

 9

 According to Robert Williams, Owner of RIEX (an importer of subject product), low-carbon rod consists of rod

with a carbon content between 0.2 and 0.3 percent, medium and high carbon rod have a carbon content between 0.3

and 1 percent carbon, and ultra-high carbon rod have a carbon content above 1 percent. Hearing transcript, pp. 124-

125 (Williams)less by weight, the majority of all threaded rod produced in the United States is of low-carbon content

and produced via thread rolling. Some companies, such as RIEX and ***, have the capability to thread

medium-carbon rod for use in applications where strength is an important factor such as in the oil patch, machinery,

or automobile industries. Hearing transcript, pp. 134 and 140 (Williams) and e-mail from ***, March 6, 2009. 

There is no known production of high- or ultra-high carbon rod.

 10 Certain Steel Threaded Rod From China, Investigation No. 731-TA-1145 (Preliminary), USITC Pub. 3996, I-3.

 11 Ibid.

I-6

provided for convenience and customs purposes only; the written description of the scope

of this investigation is dispositive.8

Tariff Treatment

Threaded rod is currently classifiable in the Harmonized Tariff Schedule of the United States

under subheading 7318.15.50 and reported for statistical purposes under statistical reporting number

7318.15.5050 at a general rate of duty of “Free.” Table I-2 presents current tariff rates for threaded rod.

Table I-2

Threaded rod: Tariff treatment, 2009

HTS provision Article description

General Special Column 2

Rates (percent ad valorem)

7318

7318.15

 

 .50

 .50

Screws, bolts, nuts, coach screws, screw hooks, rivets,

cotters, cotter pins, washers (including spring washers) and

similar articles, of iron or steel:

 Threaded articles:

 

 Other screws and bolts, whether or not with their

 nuts or washers

 Studs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

 Of other than stainless steel: continuously threaded rod:

Free 45%

 Source: HTS (2009).

THE SUBJECT PRODUCT

Physical Characteristics and Uses

Threaded rod is fully threaded along its entire length and made from low- and medium-carbon

steel for its strength and ease of cutting.9

 It is especially useful in applications where the rod may be cut

to the needed length on-site.10 Threaded rod is primarily used in commercial construction to suspend the

following: electrical conduit; pipes for plumbing; HVAC-ductwork; and sprinkler systems for fire

protection.11 Normally, one end of the threaded rod is fastened to the ceiling and the other end is fastened

to the support for suspending the pipes, ductwork, or sprinkler system. It is also used in structural tie
 12 Ibid. 

 13 Hearing transcript, p. 15 (Logan).

 14 Scale is the iron oxides which form on the surface of the wire rod during the wire rod manufacturing process. 

This material will lower the quality of the threaded rod and therefore must be removed.

 15 This process is known as “cold-drawing” because no additional heat is supplied during this process.

 16 Hearing transcript, p. 15 (Logan).

 17 Thread rolling “pushes the steel out of the valleys and into peaks, forming the threaded groves.” Because this

process does not involve cutting the steel, there is no scrap or waste material left over. Hearing transcript, p. 15

(Logan).

 18 U.S. producers’ questionnaires, section II-3.

 19 Ibid.

 20 Certain Steel Threaded Rod From China, Investigation No. 731-TA-1145 (Preliminary), USITC Pub. 3996, I-6.

I-7

downs in earthquake- and hurricane-restraint systems for roofing. Threaded rod may also be used as

headless screws in general fastener applications or for bolting pipe joints together.12

Manufacturing Process and Production Employees

The primary raw material for most threaded rod is steel wire rod in coils. However, for largerdiameter threaded rod, the raw material is steel bar.13 The basic production process is the same with

either raw material beginning with cleaning to remove surface scale.14 The rod or bar is then cold-drawn

through a series of dies, each one smaller than the preceding one, to reduce the rod diameter to the

required size.15 Afterwards, the resulting rod is straightened and cut to the desired length, most often to 8-

and 10-foot sections.16 Next, the steel is fed through a threading machine, which forms the threaded

grooves along its entire length by the process of thread rolling17 the rod between grooved dies. Finally,

the threaded rod is either coated with a plain oil finish during the threading process, or is galvanized

either by zinc electroplating or hot-dipping. Most threaded rod is zinc electroplated which imparts

corrosion resistance. After the threaded rod has received its oil finish or galvanizing, it is packed (in

paper tubes or other methods) for shipment. Depending on the rod diameter, several may be packed in the

same tube.

All but one of the responding domestic producers reported that they manufacture other products

using the same equipment and machinery and the same production and related workers that they use to

produce threaded rod. Other such reported products include partially threaded rod, stainless rod, alloy

rod, anchor bolts, and coiled rod.18

Domestic producers reported that threaded rod producers in China use the same basic

manufacturing process, but may have inefficiencies in feeding and offloading their production machinery

and in material movement throughout the plant, thus making their production process more labor

intensive.19 There are also some reports that although the older manufacturing plants in China may be

inefficient “the modern factories in China, fastener factories, are...very similar to Vulcan’s.”20
 21 U.S. producers’ questionnaires, section II-9 and U.S. importers’ questionnaires, section II-5.

 22 ***. U.S. producers’ questionnaires, section IV-19 and U.S. importers’ questionnaires, section III-19.

 23 Respondent Porteous’ prehearing brief, pp. 3-4 and posthearing brief, p. 3.

 24 Respondent Porteous’ prehearing brief, p. 4 and posthearing brief, p. 3.

I-8

Interchangeability and Customer and Producer Perceptions

U.S. producers of threaded rod, as well as importers of threaded rod from China and from

nonsubject countries, generally reported that the U.S.-produced and imported products are “always” or

“frequently” interchangeable. More detailed information on interchangeability can be found in Part II of

this report, Conditions of Competition in the U.S. Market.

Channels of Distribution

During this period of investigation, the vast majority of shipments of threaded rod by U.S.

producers and importers were to distributors.21 In fact, all but one U.S. producer shipped a majority of

their production to distributors.22 More detailed information on channels of distribution can be found in

Part II of this report, Conditions of Competition in the U.S. Market.

Price

Information with regard to prices of threaded rod is presented in Part V of this report, Pricing and

Related Information. 

DOMESTIC LIKE PRODUCT AND THE DOMESTIC INDUSTRY

No issues were raised with respect to either the like product or the domestic industry in the

preliminary phase of this investigation. In the final phase, respondent Porteous advocates excluding ***

from the domestic industry due to ***’s imports of the subject merchandise23 and its production of steel

threaded rod meeting the A-36 specification.24 

Petitioners proposed a domestic like product as:

“a single domestic like product consisting of steel threaded rod, bar, and studs, that are

like the imported STR described in the proposed scope. The domestic like product is

produced using the same types of manufacturing facilities and production processes,

possesses the same general physical characteristics, is sold for the same intended uses,

and is sold through the same channels of distribution (almost exclusively through

distributors). There are no clear dividing lines based on the range of lengths and

diameters to which the products are produced, the surface coatings that may be applied to

the product, or any other characteristics of the products.

Other types of threaded rod are produced to different specifications, are comprised of

different constituent materials, and are used for different and specialized applications. 

There is little interchangeability between STR and other types of threaded rod due to

engineering and design requirements, end-user preferences, and pricing differences. The

like product does not include other kinds of threaded steel rod, such as partially threaded
 25 Certain Steel Threaded Rod From China, Investigation No. 731-TA-1145 (Preliminary), USITC Pub. 3996, I-6.

 26 Ibid.

I-9

rod or threaded rod made of other constituent materials, such as brass, stainless steel, or

other alloy steel.”25

Respondent Porteous, an importer of subject product from China, while not disputing the

petitioners’ description noted that:

“there are significant variances among the individual threaded rod products competing in

the marketplace, which suggest attenuation of competition between the bulk of domestic

like products and imported subject merchandise.”26

 1

 Petition, pp. 8-9.

 2

 Preliminary conference transcript, p. 16 (Upton). Respondents reported that threaded rod is increasingly used in

wood-frame home construction for hurricane- and earthquake-resistant systems. Preliminary conference transcript,

p. 85 (Haggerty).

 3

 Petitioner’s postconference brief, p. 4.

 4

 Hearing transcript, pp. 62-63 (Upton).

 5

 Hearing transcript, pp. 124-128 (Williams).

 6

 According to questionnaire responses, U.S. producers’ shipments to distributors averaged *** percent during the

period for which data were collected. Importers shipped *** percent of their imports of threaded rod from China and

*** percent of their imports from nonsubject countries to distributors during the period.

 7

 Petitioner confirmed that threaded rod is sold almost exclusively through distributors, and that the market has

several “master distributors” that sell to other distributors. Preliminary conference transcript, pp. 25-26 (Logan).

II-1

PART II: CONDITIONS OF COMPETITION IN THE U.S. MARKET

U.S. MARKET SEGMENTS AND CHANNELS OF DISTRIBUTION

There are numerous and varied uses for threaded rod. Primarily, it is used in commercial

construction, where the threaded rods are cut to required lengths and used to suspend electrical conduit,

pipes for plumbing, HVAC ductwork, and sprinkler pipes for fire protection.1

 Additional uses of threaded

rod include: hanging suspended ceilings and elevated conveyor belts; joint restraint systems for

underground piping; structural tie-downs in earthquake- and hurricane-restraint systems for roofing; as

headless screws in general fastener applications; for bolting together pipe joints in the waterworks

industry; and basic industrial repair. Petitioner reported that very little threaded rod is used in residential

construction.2

Threaded rod is manufactured in various diameters and lengths, and can have one of several

different finishes applied. All threaded rod can be used for the bolting applications described above for

which high strength, heat resistance, or special corrosion resistance is not required.3

 It is made of lowquality steel wire rod and bar.4

 During the period studied, it included both low-carbon steel threaded rod

and medium-carbon steel threaded rod.5

The vast majority of threaded rod sold in the United States, whether produced domestically or

imported, is sold to distributors,6

 with only a small percentage sold directly to end users.7

GEOGRAPHIC MARKETS

Two U.S. producers reported selling threaded rod nationwide, whereas the other five reported that

they served regional markets, primarily the Northeast, Mid-Atlantic, Midwest, and the West Coast. 

Sixteen of 24 responding importers reported serving regional markets whereas the other 8 reported

serving the national market (table II-1).
 8

 One end user and the firm that identified itself as a manufacturer also consider themselves to be distributors.

 9

 Some purchasers did not provide data on their annual purchases, so these data are likely understated. Some

purchasers also apparently reported their annual purchases in thousands of pounds instead of pounds. These data

were adjusted to account for this oversight.

II-2

Table II-1

Threaded rod: Geographic market areas in the United States served by domestic producers and

importers of subject product

Region Producers Importers

National 2 8

Hawaii 1 1

Mid-Atlantic 2 3

Midwest 2 4

Northeast 2 7

Northwest 1 6

Rocky Mountains 1 1

Southeast 0 6

Southwest 1 7

West Coast 2 6

Note.–Six producers and 18 importers responded to this question. Firms were not limited to the number of market

areas that they could report.

Source: Compiled from data submitted in response to Commission questionnaires.

PURCHASER CHARACTERISTICS

Purchaser questionnaires were sent to 112 purchasers identified by the producers and importers. 

Thirty-nine purchasers responded to the purchaser questionnaire, with 37 reporting they had purchased

threaded rod since 2005. Of the 37 purchasers, 33 identified themselves as distributors, while three

identified themselves as end users, two identified themselves as retailers, and one identified itself as a

manufacturer.8

 Thirteen of the purchasers that identified themselves as distributors reported selling

threaded rod to other distributors/retailers/supply houses, 21 reported selling to electrical, general,

HVAC, mechanical, plumbing and/or other contractors or consumers, and 3 reported selling to other

entities. Twelve of 34 responding purchasers that re-sell threaded rod indicated that they compete for

sales to their customers with the manufacturers or importers from which they purchase threaded rod.

Responding purchasers reported purchases totaling 22 million pounds of threaded rod in 2007,

accounting for approximately 13.1 percent of the market during that year.9

 Some purchasers only buy

threaded rod sourced from one country, noting factors such as: availability, “Buy American” provisions,

distributors only stocking threaded rod from one source, price, proximity to a domestic producer, quality,

and service as reasons why. 

Thirteen of 36 responding purchasers described at least one change in their purchasing patterns

that were established prior to 2005. Four purchasers reported buying more lower-cost imports, two have
 10 Petition, exh. 2 and preliminary conference transcript, p. 17 (Upton). In its producer questionnaire response,

***. *** also submitted a producer questionnaire response in the preliminary phase of this investigation and

indicated that at that time ***.

 11 Petitioner reported that it imported some threaded rod from China in 2007 in order to evaluate the product’s

quality, as well as to help one of its customers compete with other firms that had imported threaded rod from China. 

Preliminary conference transcript, p. 18 (Upton). Though Vulcan submitted an importer’s questionnaire in this

investigation, tabulations in Parts 2 and 5 of this report referring to the number of importers responding a certain way

to a question do not include Vulcan as an importer. ***.

II-3

added new vendors, and two have increased the inventory they hold. Other changes described by these

purchasers include: buying more; buying less; buying more frequently; buying less frequently; buying

farther in advance; decreasing the inventory they hold; switching to a domestic producer; switching to

buying some items instead of manufacturing them; and changing to buying on an inventory-replacement

system rather than an estimated yearly purchase system.

In addition to those changing their general purchasing patterns, 18 purchasers reported changes in

the relative shares of threaded rod that are attributable to different sources since 2005. Eight firms

reported decreasing their purchases of threaded rod from domestic producers, while four reported an

increase in purchases from domestic sources. Eleven firms reported increasing the share of their

purchases of threaded rod that were imported from China, while three reported a decrease in the share of

their purchases imported from China. With respect to threaded rod from nonsubject countries, two

purchasers increased the relative shares of purchases from India, while three reported decreasing the share

originating in India; one increased its share from Taiwan; and one decreased its share from Germany and

Switzerland.

SUPPLY AND DEMAND CONSIDERATIONS

Supply

There are eight producers of threaded rod in the United States, with Vulcan being the largest

producer. Petitioner reported that ***.10 In addition, most U.S. producers also imported threaded rod

from China during the period of investigation.11

Domestic Production

Based on available information, U.S. producers have the ability to respond to changes in demand

with moderate-to-large changes in the quantity of shipments of U.S.-produced threaded rod to the U.S.

market. The main contributing factors to the moderate-to-high degree of responsiveness of supply are the

availability of unused capacity, moderate levels of inventories, *** export shipments, and the existence of

some production alternatives.

Industry capacity

U.S. producers’ reported capacity utilization decreased steadily, from *** percent in 2005 to ***

percent in 2007 (see table III-2). However, capacity utilization was higher in January-September
 12 According to questionnaire data and official Commerce statistics for HTS 7318.15.5060, imports from China

accounted for 73.1 percent of all threaded rod imports in 2007. Data included in HTS statistical reporting number

7318.15.5060 may be overstated, however, because it includes a number of nonsubject products such as threaded

rods made from alloy steel, hanger bolts, and rods not threaded along their entire lengths, etc.

 13 Petition, exh. 6.

II-4

2008 (*** percent) than it was in the same period of 2007 (*** percent). Accordingly, U.S. producers

have excess capacity with which they could increase production of threaded rod.

Alternative markets

U.S. producers’ export shipments as a percent of total shipments were *** (see table III-4). This

level of exports during the period indicates that domestic producers are constrained in their ability to shift

shipments between the United States and other markets in response to price changes, and in particular, to

the United States from other markets.

Inventory levels

U.S. producers’ inventories, as a share of total shipments, decreased from *** percent in 2005 to

*** percent in 2007 (see table III-6). Comparing interim periods, producers’ inventories were higher in

January-September 2008 (*** percent) than in the same period of 2007 (*** percent on an annualized

basis. These data indicate that U.S. producers have some ability to use inventories to increase shipments

to the U.S. market.

Production alternatives

Six of the seven responding producers reported that they produce other products using the same

equipment and machinery and production and related workers that they use to produce threaded rod. 

Alternative products include: alloy, brass, coil, high-strength, non-ferrous, partially-threaded, and

stainless steel rod; anchor bolts; and custom products.

Foreign Supply

China is the main source of imports of threaded rod in the United States. Imports from China

accounted for 84.5 percent all shipments of imported threaded rod in 2005, increasing to 89.7 percent in

2007 and 90.6 percent in January-September 2008.12

Subject Imports

U.S. shipments of imports of threaded rod from China increased by 46.4 percent between 2005

and 2007 (86.4 million pounds in 2007, compared to 59.0 million pounds in 2005), and were 10.5 percent

higher in interim 2008 than in interim 2007 (see table C-1). The Petitioner reported that there are over

400 Chinese manufacturers of threaded rod.13 However, approximately 40 producers reportedly account

for the vast majority of U.S. imports. There was a limited response by Chinese producers to the

Commission’s foreign producer questionnaire, and information provided from Chinese producers is

included in part VII of this report, Threat Considerations and Information on Nonsubject Countries.
 14 Petition, p. 19.

 15 In fact, over *** percent of quarterly sales of nonsubject product reported by importers were of threaded rod

from India. See Part V: Pricing and Related Information.

 16 The remaining two importers replying affirmatively stated that pricing in the steel market has increased. One

of these importers added that the product range has remained the same, however.

 17 Additionally, in the preliminary phase of the investigation, *** reported that it lost orders to U.S. suppliers due

to increased raw material and transportation costs; this importer did not provide a response in the final phase of this

investigation. *** reported that it imports threaded rod from ***.

 18 Purchasers may have reported more than one change in supply conditions.

II-5

Nonsubject Imports

Although there are other producers of threaded rod in various countries, imports from those

countries have been at relatively low levels since 2005.14 In 2007, the greatest quantity of nonsubject

imports under HTS subheading 7318.15.5060 originated in Taiwan, Japan, and India, respectively. It is

unknown what proportion of nonsubject imports classified under this HTS statistical reporting number is

accounted for by products not subject to this investigation. India, however, was the country which

producers, importers, and purchasers were most familiar, according to their questionnaire responses. 

Further, according to importer questionnaire responses, India is reportedly the largest source of

nonsubject imports of threaded rod.15 U.S. shipments of imports of threaded rod from nonsubject

countries declined from 10.9 million pounds in 2005 to 9.9 million pounds in 2007, and were 6.1 percent

lower in interim 2008 (6.8 million pounds) than in interim 2007 (7.2 million pounds) (see table C-1). 

General Supply Conditions

When asked if there had been any changes in the product range or marketing of threaded rod, two

of the seven producers and the majority (14) of the 23 responding importers reported that there have not

been any significant changes. Among the five producers and nine importers reporting that there have

been changes, a number reported that the product range of imports from China has expanded since 2005. 

Producers *** reported expanding their product lines to include more imports. *** stated that it increased

its imports due to their low prices in order to stay in business. *** reported an increase in its sales via the

Internet. Four of the nine importers replying affirmatively are also producers (***). Among the other

five importers, *** noted the expansion of niche markets which don’t require A36 structural steel instead

of steel with a lower carbon content.16

One producer reported being unable to supply threaded rod at some point during the period of

investigation. *** reported that its production had diminished to the point where it had to import

threaded rod. Three importers reported having been unable to supply threaded rod during the period of

investigation. *** reported that there were container shortages during the Christmas holiday season and a

dock worker strike; *** reported that it could not compete with the product imported from China due to

pricing; and *** had shipments that did not arrive on time, or had its demand exceed the amount it could

supply.17

Twelve of 33 responding purchasers noted changes in factors that have affected the supply of

threaded rod since 2005. More than half (8 of 13) of these purchasers reported increases in the price of

steel used to make threaded rod; three importers reported lengthening lead times and threaded rod being

in short supply from at least one source; two importers reported increased transportation costs and fewer

domestic suppliers; and one noted being on allotment.18 In addition, one purchaser reported that its main

import supplier, ***, stopped selling threaded rod because antidumping tariffs made it uncompetitive. 
 19 In an attachment to its importer questionnaire response in the preliminary phase of this investigation, ***

reported that *** refused to sell it threaded rod on several occasions.

 20 Petition, p. 18 and preliminary conference transcript, p. 16 (Upton).

II-6

Overall, though, 27 of 34 responding purchasers reported not experiencing any short supplies,

unavailability of specific products, or being placed on allocation since 2005.19

 

Demand

U.S. Demand

Demand Characteristics

The overall demand for threaded rod depends upon the demand for end-use applications, most of

which are related to commercial construction. From 2005 to 2007, apparent U.S. consumption of

threaded rod increased by 1.1 percent in terms of quantity. Apparent U.S. consumption of threaded rod

was also 4.3 percent higher in January-September 2008 than in January-September 2007. In the

preliminary phase of the investigation, the Petitioner described the commercial construction market as

being “generally healthy” and “very strong.”20 Statistics from the U.S. Census Bureau show that private,

nonresidential construction spending was relatively flat in early 2005 but then increased steadily through

June 2008 (figure II-1). It then increased irregularly through September 2008 and has been decreasing

since that time. As of January 2009, nonresidential construction has decreased 8.4 percent since the

September 2008 peak.

Figure II-1

Threaded rod: Private, nonresidential construction spending (seasonally-adjusted, annual rate),

January 2005-January 2009

Source: U.S. Census Bureau data at http://www.census.gov/const/www/c30index.html.

0

50

100

150

200

250

300

350

400

450

20052006200720082009

in billions of dollars
 21 Hearing transcript, pp. 17-18 (Logan).

 22 Hearing transcript, p. 70 (Iverson).

 23 Of these three, one purchaser stated that its demand had increased, but that did not necessarily mean demand in

general had increased; another purchaser reported that its demand, not demand for threaded rod in general, decreased

in 2006, increased in 2007, and did not change in 2008; and one stated that demand basically moves with the

economy. 

 24 One purchaser reporting an increase noted that the increase has had only a minimal effect on its purchases of

threaded rod, whereas the other two end users reported a commensurate increase/decrease in their purchases of

threaded rod based on the increase/decrease in sales of their goods that incorporate threaded rod. 

 25 Respondent Porteous’s posthearing brief, p. 15.

 26 Petitioner’s posthearing brief, exh. 10, p. 2.

 27 Three of the five producers actually responded “no,” but in their descriptions of the market, two relayed that the

market depends on the construction market, but this seasonality is not specific to only the threaded rod market. 

II-7

Producers, importers, and purchasers were asked specifically how the demand for threaded rod in

the U.S. market has changed since 2005. Three producers noted an increase in demand since 2005 and

three noted a decrease. Two producers reporting an increase attributed the increase to a growing

commercial construction sector, and one ascribed it to better marketing. The three producers that noted a

decrease described a decrease in their own sales due to less expensive, imported threaded rod, not demand

in general, though one (***) added that the downturn in commercial construction, the housing market

slowdown, and the economy in general has had a depressing effect on demand for steel threaded rod. At

the hearing, domestic producers testified that the decline in general economic activity has led to a sharp

drop in sales.21 Also, one representative testified that purchasers are only buying small orders as they

need threaded rod, upon the assumption that prices will decline due to the declining price of steel.22

Fourteen of 23 responding importers reported an increase in demand since 2005, six reported “no

change,” and three reported a decrease (***. Nine of the 14 importers reporting an increase ascribed it to

growth in construction markets, while others noted availability, the economy, marketing, pricing, and

increased use in final manufactured products as the reason for the increase. Two of the three importers

reporting a decrease further explained that the decrease is due to the housing market slowdown of 2007

and 2008.

 Six of 30 responding purchasers reported an increase in domestic demand for threaded rod since

2005, eight reported a decrease, eight reported that demand did not change, five noted an increase in

demand followed by a decrease in 2007 and/or 2008, and three reported something other than these.23

Twelve of these purchasers attributed the increase, decrease, or fluctuations to commercial or residential

construction activity and five purchasers noted general changes in the U.S. economy as the determinative

factor. For end users of threaded rod, two of the three responding purchasers noted that demand for their

goods containing threaded rod has increased, whereas one reported a decrease.24

The recently passed economic stimulus plan (the American Recovery and Reinvestment Act of

2009) contains language including “Buy American” provisions and includes $29.6 billion for building

repair, renovation, and construction. Respondent Porteous contends the Act will aid the domestic industry

while shutting Chinese threaded rod makers out of this portion of the market.25 Petitioner, however,

contends that these funds will not help since most of the market for threaded rod is in commercial

construction, and commercial structures are excluded from the stimulus plan.26

Producers, importers, and purchasers also were asked if the threaded rod market is subject to

business cycles or conditions of competition that are distinctive to threaded rod. Five of seven producers

responded affirmatively, and they noted that the market is dependent on the construction market, with

increases during good weather, e.g., in the middle of the year.27 Ten of 23 importers also responded

affirmatively, while 13 responded negatively. Eight of the ten importers responding affirmatively agreed

with the majority of producers; i.e., the threaded rod market is dependent on the commercial construction

market, with six importers further describing the seasonality of the construction market, when sales are
 28 The other importer described the availability of threaded rod to be a condition of competition distinctive to the

threaded rod market. 

 29 ASTM specification A36 is a raw material specification that is “almost interchangeable with the other products

made by the companies that do purchase A36 grade wire rod,” is seldom requested by purchasers, and is priced the

same as non-A36 material (i.e., “1018” material). Hearing transcript, p. 102 (Iverson and Waite). Producer Bay

Standard manufactures all of its threaded rod using A36 material so that it will meet the specifications of those

customers that request it, and so that Bay Standard does not have to carry duplicate inventory. Hearing transcript,

pp. 102-103 (Iverson). Other witnesses described A36 material as “nothing special,” “the most common spec out

there,” “kind of the lowest grade,” and that “no difference between it and just common low carbon grades” exists. 

Hearing transcript, p. 103 (Magrath and Logan). Respondent Porteous disagrees with this assessment, noting there

are special qualities of material meeting the A36 specification, including requiring elongation and yield testing not

required by other specifications. Respondent Porteous’s posthearing brief, p. 3. At the hearing, Mr. Iverson of Bay

Standard stated that, though imports from China cannot be certified as meeting the A36 specification, when tested,

sometimes threaded rod labelled “A36” from China will meet the required mechanical properties. Hearing

transcript, p. 28 (Iverson). Mr. Williams of Riex testified that he has been told by his suppliers of Chinese threaded

rod that they can meet the A36 specification. Hearing transcript, p. 131 (Williams). 

 30 *** purchaser questionnaire response.

II-8

greater in the warmer months when construction activity is heaviest. One of the other importers described

a shift to the ASTM A36 specification in some construction projects, which it believes is a standard that

China is reportedly unable to meet.28 29 Ten of 36 responding purchasers reported seasonality or

conditions of competition distinctive to the threaded rod market. Five purchasers reported that

construction market cycles play a role in the business cycle for threaded rod; two reported seasonality as

influencing the threaded rod market’s business cycle; one noted the influence of the economy in general;

and one stated the business cycle of the metalworking industry has an impact on the threaded rod market.

With respect to the business cycle or conditions of competition for threaded rod, three producers

and five importers reported that there have been changes since 2005. The changes noted by producers

and importers include increased costs for transportation and raw materials, the emergence of master

distributors, and a downturn in the market starting in second half of 2008, during which purchasers began

to worry about being able to finance their projects. In addition, four purchasers described changes in the

conditions of competition specific to the threaded rod market. Two purchasers reported that pricing has

become more competitive since 2005, and as a result, domestic firms have had to reduce prices. As a

result, one of these purchasers stopped buying imports and started buying from Vulcan because it was

relatively less expensive. One other purchaser described how the preliminary antidumping duties

lengthened lead times to unjustifiable levels and made the market non-competitive. The remaining

purchaser reported that end users have now found out that threaded rod from China is “excellent” and is a

great value, which it termed the “Wal-Mart effect.”30
 31 Petitioner reported that other types of threaded rod exist which are produced to different specifications,

comprised of different constituent materials, and used for different and specialized applications. Therefore, there is

little interchangeability between low-carbon threaded rod and other types of threaded rod. Petition, p. 13. In

addition, the ability of an end user to cut the threaded rod to length on site is an advantage of this specific product

that limits substitutability. Preliminary conference transcript, pp. 23-24 (Logan) and Petitioner’s postconference

brief, pp. 5-6.

 32 Despite answering “no,” *** reported that specially-produced double-ended rods could be made to order,

adding that usually these products are not used as substitutes.

 33 Purchaser *** stated that there is a direct relationship between the prices of different grades of threaded rod,

once a 90-180 day time lag is taken into account.

 34 ***.

 35 In the preliminary phase of the investigation, producers also reported that threaded rod accounts for 15 to 20

percent of the total cost of anchoring systems and ductwork for heat and air. 

II-9

Alternative Products

Six of seven producers, 17 of 22 responding importers, and 29 of 34 responding purchasers

reported that there are no substitute products for threaded rod.31 Two producers,32 five importers, and five

purchasers reported that A193-B7 threaded rod, anchor bolts and wedge anchors, double-ended studs used

in bracing applications, headed bolts, jack chain, long bolts with plate washers used in concrete

applications, single- or double-ended rod, specially produced double-ended rods, steel strapping, pipe,

wire rope, and different grades of steel threaded rod are products that may be substituted for threaded rod

and that these products can be used in some similar applications. Purchasers were asked if changes in the

prices of the alternative products affect the price of threaded rod. Only one of the five purchasers which

noted the existence of possible substitutes responded affirmatively.33

***.34

Cost Share

Producers, importers, and purchasers were asked to provide information on the cost share of

threaded rod relative to the end products in which it is used. Producers reported that threaded rod

accounts for 30 to 40 percent of the total cost of access flooring, hanging electrical conduit, hanging

mechanical systems, hanging pipes for plumbing and sprinklers, and seismic systems.35 Importers

generally were not able to report information about cost share, but importer *** estimated that threaded

rod accounts for less than 10 percent of the total cost of hanging plumbing pipe, electrical conduit, and

HVAC duct equipment; importer *** estimated that threaded rod makes up 20 percent of the cost of all

thread studs; and importer *** estimated that steel threaded rod accounts for 2 to 5 percent of the cost for

hanging light fixtures or cable tray, 15 percent of the cost of hanging plumbing, fire protection, or HVAC

systems, and 20 percent of the cost of hanging strut trapezes. Three purchasers responded to this

question, with responses of 1 to 5 percent, 10 percent, and 60 percent for the end uses they cited.

Global Demand

Producers, importers, and purchasers were asked how the demand for threaded rod outside the

United States has changed since 2005. Two producers, four importers, and six purchasers reported that

demand has increased in the rest of the world, with most citing the global increase in commercial

construction and infrastructure requirements. Two of the six purchasers specifically cited increased

demand in China, and one importer specified that Europe and the Middle East were the reason for

increased demand. One producer, seven importers, and one purchaser reported that the demand for
II-10

threaded rod outside of the United States had not changed since 2005, and one purchaser reported that

demand has decreased, but did not specify a reason or a region.

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported products depends upon such factors as

relative prices, quality, and conditions of sale (e.g., price discounts/rebates, lead times between order and

delivery dates, payment terms, product services, etc.). Based on producer, importer, and purchaser

responses, staff believes that overall, there is likely to be a high degree of substitution between threaded

rod produced in the United States and threaded rod produced in China.

Knowledge of Country Sources

Thirty-four of the 37 responding purchasers were familiar with the source of the threaded rod that

they purchase. Of these 34 purchasers, 29 were familiar with domestically produced threaded rod, 26

were familiar with that from China, nine were familiar with threaded rod from India, two were familiar

with threaded rod from Taiwan, and one each was familiar with threaded rod from Mexico, and

Germany/Switzerland. Purchasers were also asked if they were aware whether the threaded rod they

purchased was imported or produced in the United States, how often they knew the manufacturer of the

threaded rod, and how often their customers were aware of or interested in the country of origin of the

threaded rod. Responses to these questions are presented in table II-2. 

Table II-2

Threaded rod: Certain purchaser responses to questions regarding the origin of their purchases

Purchaser/customer decision Always Usually Sometimes

Rarel

y Never

Purchaser aware of whether U.S.-produced or imported 12 18 3 1 2

Purchaser knows the manufacturer 6 7 12 4 7

Purchaser’s customer is aware of, or interested in the

country of origin

4 7 11 11 3

Source: Compiled from data submitted in response to Commission questionnaires.

Factors Affecting Purchasing Decisions

Major Factors in Purchasing

Purchasers were asked to identify the three major factors considered by their firm in deciding

from whom to purchase threaded rod (table II-3). Price was most frequently reported to be the most

important factor, and was cited by 15 of 35 responding purchasers. For the second and third most

important factors, availability and quality, respectively, were the most common responses (13 purchasers

each). Additionally, 15 of 24 responding purchasers stated that their customers will specifically order

threaded rod from one country over another, with 13 of the 15 referencing the need to buy domestically

produced threaded rod for some applications, mostly due to “Buy American” provisions. One purchaser

reported that it will buy from China or the United States, but not India, for quality reasons, whereas

another purchaser noted that his customers will specify imported product because it costs less. Also,

when purchasers were asked how frequently they purchased the lowest-priced threaded rod, 4 purchasers

replied “always,” 17 replied “usually,” 7 replied “sometimes,” 4 replied “rarely” and 3 replied “never.” 
II-11

Table II-3

Threaded rod: Ranking factors used in purchasing decisions, as reported by U.S. purchasers

Factor

Number of firms reporting

First Second Third Total

Price 15 9 8 32

Availability 7 13 5 25

Quality (including meeting or exceeding

specifications and exceeding competition) 7 5 13 25

Reliability 1 1 2 4

Traditional supplier 2 0 1 3

Product range 1 1 1 3

Extension of credit 0 1 2 3

Delivery and delivery terms 2 0 0 2

Lead times 0 2 0 2

Packaging 0 1 1 2

Specification 0 1 1 2

Prepaid freight 0 1 0 1

Minimum order 0 1 0 1

Service 0 0 1 1

Note.–Some purchasers listed more than three factors. Among those factors deemed important enough to rank, but

not in the top three are: availability, buying group participation, buying domestically, lead times, service, and terms.

Note.–Two purchasers stated that all of their listed factors are treated equally or are equally important. These

purchasers listed delivery and quality as the first factor, price and availability second, and quality and price third. 

Source: Compiled from data submitted in response to Commission questionnaires.

Twenty-one purchasers stated that they have bought a higher-priced threaded rod even though a

lower-priced threaded rod was available. The reasons listed by purchasers include availability, “Buy

American” provisions, delivery history, freight costs, maintaining multiple suppliers, minimum order

requirements, product range, proximity, quality, service, and supply history.

Importance of Specified Purchase Factors

Purchasers were asked to rate the importance of 18 factors when making their purchasing

decisions (table II-4). The factors listed as “very important” by at least three-quarters of the 35

responding firms were: quality meets standards (32 firms), availability and product consistency (31 firms

each), reliability of supply (30 firms), and price (28 firms). The next factor listed most frequently as

“very important” was delivery time (20 firms). The availability of consigned inventory was listed as “not

important” by a large majority (27 of 33) of these purchasers.
II-12

Table II-4

Threaded rod: Importance of factors as reported by U.S. purchasers

Factor1

Very important

Somewhat

important Not important

Number of firms responding 

Availability 31 4 0

Availability of consigned inventory 1 5 27

Delivery terms 18 17 0

Delivery time 20 15 0

Discounts offered 12 19 4

Extension of credit 14 11 10

Minimum quantity requirements 8 20 7

Packaging 15 13 7

Price 28 7 0

Product consistency 31 3 1

Product range 15 15 5

Quality meets standards 32 3 0

Quality exceeds standards 10 15 10

Reliability of supply 30 5 0

Technical support/service 10 19 6

U.S. transportation costs 14 16 5

Willingness to negotiate price/terms 17 17 1

Willingness of supplier to accept raw

material cost increase risk 8 19 8

 1 One purchaser also added that “communication” is a “very important” factor.

Source: Compiled from data submitted in response to Commission questionnaires.

Factors Determining Quality

Purchasers were asked to identify the factors that determine the quality of threaded rod. 

Purchasers reported numerous specific factors: meeting standards, codes, and claimed specifications; 

clean, functional, and/or uniform threads; appearance; good plating; strength; durability; each rod being

useable; product consistency; packaging; material traceability; and the ability to bend.

Certification/Qualification Issues

Purchasers were asked if they require certification or prequalification of their suppliers. Eighteen

of 35 responding purchasers reported that they required prequalification, with 16 requiring it for all of the

firms’ purchases. Qualification can range from a visual inspection of the material to financial, material

quality, and delivery performance data checks. One purchaser reported the qualification process could

last up to 6 weeks, whereas another purchaser only requires verbal confirmation that the threaded rod

meets building code specifications. 

Only two of 32 responding purchasers reported that any firms had failed to qualify: *** failed at

one purchaser because it would not provide material certifications, and *** failed to qualify at a purchaser

because of a poor service and delivery record. 
 36 *** reported that it ships *** percent from inventory and *** percent is produced to order, and *** reported

that it ships *** percent from inventory and *** percent is produced to order.

 37 One importer, however, reported a lead time of one week.

II-13

Purchasers were asked how often domestic, imported Chinese, and imported nonsubject threaded

rod met minimum quality specifications since January 2005. All responding purchasers reported that

domestic producers were either “always” (19 purchasers) or “usually” (11 purchasers) able to meet

minimum specifications. All responding purchasers reported that imported Chinese threaded rod

“always” (14 purchasers) or “usually” (14 purchasers) met minimum specifications. In addition, four

purchasers reported that threaded rod from India “always” meets specifications, three reported that it

“usually” meets specifications, and one reported that threaded rod from India “rarely” meets

specifications. Among other responses, Germany, Japan, Mexico, Russia, and Taiwan were reported by

one purchaser each to “usually” meet specifications. 

Thirty-one purchasers reported the factors they consider when choosing a supplier. Factors

identified by purchasers include: quality, service, price, availability, reliability, dependable delivery

times, lead times, financial stability of the vendor, shipping, location, packaging, the quality control

process employed, technical support, reputation, participation in a buying group, and vendor relationship.

Supply Sources

Purchasers reported contacting between 1 and 7 suppliers for their threaded rod needs, though

most contact very few. At least 10 purchasers only contact one supplier or have set supply agreements

with one supplier. Twenty-one purchasers have not changed suppliers since 2005, whereas 15 have. 

Availability, low minimum amounts, payment terms, pricing, and unsatisfactory delivery performance all

contributed to these purchasers changing supply sources. Ten of 34 responding purchasers became aware

of new suppliers since 2005. The suppliers that these purchasers listed are: Ameri-bolt, Cavalier, EGW

Utilities, Heads and Threads, J and D Industrial Products, Inc., Master Distribution, Petrom Pacific,

Porteous, Prime Source, Taylor Threaded Products, and Worldwide Construction Products.

Lead Times

Five of the seven producers reported that 60 percent (***) to 98 percent (***) of their threaded

rod was sold out of inventory and all noted lead times between zero and seven days, with an average lead

time of 3.3 days.36 Lead times for those producers who reported selling some threaded rod produced-toorder ranged from “1 to 10” days to three weeks and averaged just less than two weeks.

Eleven of the 22 responding importers reported only selling from inventory, and four reported

only selling on a produced-to-order basis. The remaining importers sell the majority (between 60 and 90

percent) of their threaded rod out of inventory. Reported lead times for importers’ sales from inventory

ranged between one day and two weeks, but averaged 3.6 days. For importers’ sales that are produced to

order, lead times ranged between two and five months37 and averaged slightly more than three-and-a-half 

months.

Comparisons of Domestic Products, Subject Imports, and Nonsubject Imports

Producers, importers, and purchasers were asked to assess how interchangeable threaded rod

produced in the United States, China, and nonsubject countries is; responses are presented in table II-5. 

The majority of producers, importers, and purchasers that reported familiarity with imported threaded rod

reported that U.S.-produced threaded rod is always or frequently interchangeable with threaded rod

imported from China and nonsubject countries. Two producers, three importers, and five purchasers
 38 Two of the importers that reported non-price factors are “always” or “frequently” significant did not explain

their answers as requested.

II-14

reported reasons that limit or preclude interchangeable use. One producer and one importer stated that the

use of the metric system in other countries affects interchangeability. Producer *** reported that if

customers require the material to meet certain specifications, only domestic threaded rod can be used, and

importer *** reported that the U.S. product with certain zinc plating cannot be used in Europe. Importer

*** noted that the quality of the material and manufacture may play a role in limiting interchangeability. 

Four purchasers noted that federal or state projects can require the use of domestically produced threaded

rod, while the other reported that domestic and Chinese threaded rod are only sometimes interchangeable

due to the need for a mill certificate.

Table II-5

Threaded rod: U.S. producers’ and importers’ perceived degree of interchangeability of products

produced in the United States and in other countries1

Country comparison

U.S. producers U.S. importers U.S. purchasers

AF S N A F S N A F SN

U.S. vs. China 4 3 0 0 12 7 0 0 19 5 3 0

U.S. vs. other countries2 32 1 0 8 5 0 0 6 4 10

China vs. other countries2 32 0 0 6 4 0 0 5 2 00

 1 Producers and importers were asked if threaded rod produced in the United States and in other countries are

used interchangeably and to what degree.

 2

 All producers and importers which identified the “other countries” referred to India as the other country. 

Purchasers used Germany, India, Indonesia, Mexico, South Korea, Switzerland, and Taiwan for comparisons. 

Note.--“A” = Always, “F” = Frequently, “S” = Sometimes, and “N” = Never.

Source: Compiled from data submitted in response to Commission questionnaires.

In addition, producers and importers were asked to assess how often differences other than price

were significant in sales of threaded rod from the United States, China, and nonsubject countries (table II6). Producers reported a varying degree of differences, and importers most often reported that differences

other than price are “sometimes” a significant factor in their sales of threaded rod.38 Among producers,

*** reported there are “always” differences because availability is very important; *** reported that there

are “frequently” differences between threaded rod from the United States and that from nonsubject

countries because of floating exchange rates; and *** reported that there are “sometimes” differences

among all three comparisons due to variations in product range. Importers that noted non-price factors

are “always” or “frequently” significant factors described availability, differences among producers, lead

times, order fulfillment, product range, quality, and transportation as factors leading to those non-price

differences between countries’ products. Only one of 34 (***) responding purchasers reported that a

certain grade, size, or type of threaded rod is only available from one source; specifically, A36 grade steel

threaded rod is only available domestically. 
 39 Preliminary conference transcript, p. 18 (Upton) and p. 104 (Haggerty).

 40 Hearing transcript, p. 6 (Waite) and pp. 16-17 (Logan)

 41 Industrial Threaded Products’ and Fastenal’s postconference brief, pp. 1-3.

 42 Hearing transcript, p. 28 (Iverson).

 43 ***. Staff telephone interview with ***. According to testimony presented at the hearing, the West Coast is

the only place where the A36 specification is an issue. Hearing transcript, p. 101 (Magrath). Bay Standard reported

that all of the raw materials it buys meet the ASTM A36 specification, in an effort to reduce the duplication of

inventories. Hearing transcript, pp. 102-103 (Iverson). In all, less than five percent of his customers specify A36

when they place orders for threaded rod. Hearing transcript, p. 28 (Iverson).

 44 Porteous’s postconference brief, pp. 5-6.

 45 Preliminary conference transcript, pp. 78-79 (Buckner) and pp. 80-81 (Logan).

 46 Preliminary conference transcript, pp. 85-87 (Haggerty).

II-15

Table II-6

Threaded rod: U.S. producers’ and importers’ perceived importance of factors other than price in

sales of product produced in the United States and in other countries1

Country comparison

U.S. producers U.S. importers

AFSNAFSN

U.S. vs. China 1 1 3 2 4 2 9 3

U.S. vs. other countries 11311152

China vs. other countries 00131142

 1 Producers and importers were asked if differences other than price between threaded rod produced in the

United States and that produced in other countries were a significant factor in sales of the threaded rod.

Note.--“A” = Always, “F” = Frequently, “S” = Sometimes, and “N” = Never.

Source: Compiled from data submitted in response to Commission questionnaires.

Petitioner Vulcan and respondent Porteous agreed that there are no significant quality differences

between U.S.-produced threaded rod and threaded rod that is imported from China.39 Vulcan reported

that threaded rod is a commodity product, and that price is the primary factor that customers consider

when making their purchasing decisions.40 However, importers Industrial Threaded Products (“ITP”) and

Fastenal reported that the threaded rod imported from China is not identical to the product produced by

Vulcan, and that the imported and domestic products do not meet the same technical specifications and

thus often do not compete for the same applications.41 Some end users specify that the threaded rod they

purchase must meet ASTM A36 specifications, which imports of threaded rod from China inconsistently

meet.42 However, U.S. producers reported that end users that request threaded rod that meets A36

specifications are a small part of the market.43

Porteous reported that it disagrees that threaded rod is a commodity product and added that

imports from China do not compete with all of the specifications and sizes of threaded rod that are

produced in the United States.44

Both the petitioner and respondents reported that service issues are an important factor in the

threaded rod market. Petitioner reported that its product inventory, raw material inventory, and

independent warehouses help it to service the entire U.S. market with short lead times.45 Respondent

Porteous reported that it has invested in coast-to-coast trucking and stocking warehouses, thus giving it an

advantage in lead times, and that it has a unique way of bundling threaded rod so that it is easier to

handle.46 It also reported that it sells a large variety of fastener products that can be packaged together
 47 Porteous reported that by bundling products, its customers get an advantage in terms of pre-paid shipping. 

Preliminary conference transcript, pp. 99-100 (Haggerty).

II-16

with threaded rod,47 and that all of these factors allow it to compete for customers on a basis other than

price.

Country Comparisons

Purchasers were asked to compare threaded rod produced in the United States to that made in

China and nonsubject countries with respect to 18 different attributes. Twenty-five purchasers provided

responses; details are provided in table II-7.

Table II-7

Threaded rod: Comparisons of U.S. product, product from China, and product from other

countries, as reported by U.S. purchasers

Factor

U.S. vs China U.S. vs India

US vs other

nonsubject1

SC I SC I SC I

Number of firms responding 

Availability 12 11 2340030

Availability of consigned inventory 1 19 3160020

Delivery terms 7 15 3 3 4 0 0 3 0

Delivery time 14 8 3 3 4 0 1 2 0

Discounts offered 0 19 5061020

Extension of credit 2 19 4 1 5 1 0 2 1

Minimum quantity requirements 9 15 1340030

Packaging 4 18 3 2 5 0 0 3 0

Price2 0 7 18 0 5 2 0 2 1

Product consistency 3 21 1160030

Product range 6 17 2160021

Quality meets standards 1 22 1 0 7 0 0 3 0

Quality exceeds standards 4 20 1 0 7 0 0 3 0

Reliability of supply 5 18 1 1 6 0 0 3 0

Technical support/service 7 17 1 2 5 0 0 3 0

U.S. transportation costs2 4 17 2 1 6 0 0 3 0

Willingness to negotiate price/terms 0 18 7070030

Willingness of supplier to accept raw material

cost increase risk 0 18 7 0 6 0 0 2 1

 1 Other nonsubject includes Germany, Switzerland, and Taiwan. 2 A rating of superior means that the price/U.S. transportation cost is generally lower. For example, if a firm reported “U.S.

superior”, it meant that the price of U.S. product is generally lower than the price of the imported product.

Note.--S=first listed country’s product is superior; C=both countries’ products are comparable; I=first listed country’s product is

inferior. 

Source: Compiled from data submitted in response to Commission questionnaires.
 48 Parties were invited to submit comments regarding this section in their prehearing briefs. Neither petitioner nor

respondents did so.

 49 A supply function is not defined in the case of a non-competitive market.

 50 The substitution elasticity measures the responsiveness of the relative U.S. consumption levels of the subject

imports and the domestic like product to changes in their relative prices. This reflects how easily purchasers switch

from the U.S. product to the subject product (or vice versa) when prices change.

II-17

ELASTICITY ESTIMATES48

U.S. Supply Elasticity49

The domestic supply elasticity for threaded rod measures the sensitivity of the quantity supplied

to changes in the U.S. market price of threaded rod. The elasticity of domestic supply depends on several

factors including the level of excess capacity, the ease with which producers can alter capacity,

producers’ ability to shift to and from production of other products, the existence of inventories, and the

availability of alternative markets for U.S.-produced threaded rod. 

In the short term, the domestic industry has a moderate-to-high degree of responsiveness to

changes in prices. Supply responsiveness is enhanced by possible available capacity, the ability to switch

to producing threaded rod instead of other products, and the quantity of inventory on hand, but is limited

by ***. Domestic supply elasticity is likely in the range of 3 to 5.

U.S. Demand Elasticity

The U.S. demand elasticity for threaded rod measures the sensitivity of the overall quantity

demanded to a change in the U.S. market price of threaded rod, and is likely to be low, and in the range of

-.25 to -.5. This estimate is driven by factors discussed earlier, such as the low cost share of threaded rod

in the production of various construction-related products, and a lack of viable substitute products in large

portions of the market.

Substitution Elasticity

The elasticity of substitution depends upon the extent of product differentiation between the

domestic and imported products.50 Product differentiation, in turn, depends upon such factors as quality

(both perceived and actual), specs, availability, and conditions of sale. Many of the producers, importers,

and purchasers noted the similarities of threaded rod produced domestically and imported from China

with respect to most factors. Based on the above data, substitution elasticity between domestic and

imported Chinese threaded rod is high, and is likely to be in the range of 4 to 6.

 1

 Eight producers submitted U.S. producer questionnaires in the preliminary phase of this investigation. ***. 

 2

 ***. 

 3

 Effective October 10, 2008, TRC, Inc., a wholly owned subsidiary of Acme Manufacturing Company, Inc.

located in Denver, CO, purchased the assets of Threaded Rod. The company is now Indianapolis Threaded Rod

Company. E-mail from ***, January 25, 2009. 

 4

 RIEX, an importer of the subject product, testified at the hearing of this investigation that it has threading

operations and that might qualify it as a producer of the subject product. Hearing transcript, pp. 122-123 and 141-

142. ***.

 5

 ***.

III-1

PART III: U.S. PRODUCERS’ PRODUCTION, SHIPMENTS, AND

EMPLOYMENT

The Commission analyzes a number of factors in making injury determinations (see 19 U.S.C. §§

1677(7)(B) and 1677(7)(C)). Information on the alleged margins of dumping were presented earlier in

this report and information on the volume of imports of the subject merchandise and pricing is presented

in Parts IV and V, respectively. Information on the other factors specified is presented in this section

and/or Part VI and (except as noted) is based on the questionnaire responses of seven firms that accounted

for the vast majority of U.S. production of threaded rod from 2005 to 2007.1

U.S. PRODUCERS

The Commission sent U.S. producer’s questionnaires to the nine firms cited in the petition: 

Vulcan, All Ohio, Bay Standard,2

 Conklin, Interstate Fittings, Inc. (“Interstate”), Lancaster, Rods Indiana,

Threaded Rod Company, Inc.,3

 and Watson.4 Responses were received from seven of the nine firms.5

Producers of threaded rod, their position with respect to the petition, and information on their production

of threaded rod are shown in table III-1.
III-2

Table III-1

Threaded rod: U.S. producers, locations, position on the petition, and production and shares of

production in 2007

Firm Plant location(s) Position

Reported production of threaded

rod in 2007

Quantity

(1,000 pounds)

Share

 (percent)

***1 *** *** *** ***

Bay Standard2 Phoenix, AZ

Brentwood, CA

Fontana, CA

Kapolei, HI

Las Vegas, NV

Tigard, OR

Supports *** ***

Conklin Union City, CA Supports *** ***

Lancaster3 Lancaster, PA Supports *** ***

Rods Indiana4 5 Butler, IN Supports ***5 ***5

Threaded Rod6 Indianapolis, IN Supports *** ***

Vulcan7 Pelham, AL Petitioner *** ***

Watson8 Kenilworth, NJ

Petersburg, VA

Supports *** ***

 1

 ***.

 2

 ***.

 3

 ***.

 4

 ***. 

 5

 ***. 

 6

 ***.

 7

 ***.

 8

 ***.

 Note--Because of rounding, figures may not add to the totals shown.

 Source: Compiled from data submitted in response to Commission questionnaires.
 6

 The decline in capacity to produce threaded rod is attributable to ***. 

III-3

U.S. CAPACITY, PRODUCTION, AND CAPACITY UTILIZATION

U.S. producers’ capacity, production, and capacity utilization data for threaded rod are presented

in table III-2. Total U.S. capacity for threaded rod decreased by *** percent from 2005 to 2007 and

experienced no change when comparing data from interim 2007 to interim 2008.6

 Total U.S. production

of threaded rod declined by *** percent from 2005 to 2007, but was *** percent higher in interim 2008

compared with interim 2007. Capacity utilization declined from *** percent in 2005 to *** percent in

2007. Capacity utilization stood at *** percent in interim 2008 compared with *** percent in interim

2007.

Table III-2

Threaded rod: U.S. capacity, production, and capacity utilization, 2005-07, January-September

2007, and January-September 2008

* * * * * * *

In the Commission’s questionnaire, U.S. producers were asked if they had experienced any plant

openings, relocations, expansions, acquisitions, consolidations, closures, or prolonged shutdowns because

of strikes or equipment failure; curtailment of production because of shortages of materials; or any other

change in the character of their operations or organization relating to the production of threaded rod since

January 1, 2005. Five firms reported such changes; their responses to this question are presented in table

III-3.

Table III-3

Threaded rod: U.S. producers’ comments concerning plant openings, relocations, expansions,

acquisitions, consolidations, closures, or prolonged shutdowns

Firm Changes in the character of operations

*** ***.

*** ***.

*** ***.

*** ***. 

*** ***. 

Source: Compiled from data submitted in response to Commission questionnaires.
 7

 Appendix D presents data on U.S. producers’ total shipments of the subject product by diameter in 2007.

 8

 *** stated that it purchased subject threaded rod from ***. ***’s producer questionnaire response, section II12.

 9

 ***’s producer questionnaire response, section II-12.

 10 *** asserts that the “substantial increases in both U.S. producer inventories and inventory-to-shipment ratios

clearly show the continued threat of Chinese imports in the marketplace,” Petitioner’s posthearing brief, p. 10.

III-4

U.S. PRODUCERS’ SHIPMENTS7

Data on domestic producers’ shipments of threaded rod are presented in table III-4. Domestic

commercial sales accounted for *** of U.S. producers’ shipments of threaded rod during the period of

investigation. U.S. producers’ commercial shipments decreased by *** percent from 2005 to 2007 and

was *** percent lower in interim 2008 than in interim 2007. No firm reported internal consumption,

transfers to related firms, or export shipments during the period of investigation.

Table III-4

Threaded rod: U.S. producers’ shipments, by types, 2005-07, January-September 2007, and

January-September 2008

* * * * * * *

U.S. PRODUCERS’ IMPORTS AND PURCHASES

Five U.S. producers, ***, reported direct imports of threaded rod from China during the period

for which data were collected. Data concerning U.S. producers’ purchases of imported and domestically

produced threaded rod are shown in table III-5. Two producers, ***8

 and ***,9 reported purchases from

importers of threaded rod from China. *** also reported purchases from importers of threaded rod from

India. *** purchased threaded rod from domestic producers, stating that it could not meet customer

demands with its own production so it purchased domestically produced threaded rod from *** to fill

inventory. 

Table III-5

Threaded rod: U.S. producers’ imports and purchases of imports, 2005-07, January-September

2007, and January-September 2008

* * * * * * *

U.S. PRODUCERS’ INVENTORIES

Data on end-of-period inventories of threaded rod are presented in table III-6. All responding

U.S. producers held inventory of threaded rod. *** accounted for the vast majority of inventory during

the period of investigation.10 

Table III-6

Threaded rod: U.S. producers’ end-of-period inventories, 2005-07, January-September 2007, and

January-September 2008

* * * * * * *
III-5

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

U.S. producers’ aggregate employment data for threaded rod are presented in table III-7. In the

aggregate, U.S. threaded rod producers reported an overall decline of *** percent in the number of

production and related workers employed in the manufacture of threaded rod during 2005-07. 

Table III-7

Threaded rod: U.S. producers’ employment-related indicators, 2005-07, January-September 2007,

and January-September 2008

* * * * * * *

 1

 Twenty-eight firms submitted a U.S. importer questionnaire response in the preliminary phase of this

investigation. Five firms, ***, did not submit a U.S. importer questionnaire for the final phase of the investigation. 

Two of these six firms, ***, are also U.S. producers of the subject product. ***. Four additional firms, ***,

provided U.S. importer questionnaire responses in the final phase only. 

 2

 HTS statistical reporting number 7318.15.5060 also includes a number of items outside the product scope such

as threaded rods made from alloy steel (e.g., stainless steel), hanger bolts, and rods which are not threaded along

their entire length, etc. As noted in Part I, effective July 1, 2008, a separate HTS subheading 7318.15.5050 was

created for “continuously threaded rod” made of carbon or alloy steel. At the same time, the HTS subheading under

which carbon and alloy steel threaded rod had previously been classified (7318.15.5060) was deleted, and a new

HTS subheading 7318.15.5090 for “other” products was added. E-mail from Frederick Waite, counsel for Vulcan, 

November 14, 2008.

 3

 As noted earlier in this report, HTS statistical reporting number 7318.15.5060 also includes a number of items

outside the product scope such as threaded rods made from alloy steel (i.e., stainless steel), hanger bolts, and rods

which are not threaded along their entire length, etc. Hence, use of official Commerce statistics in examining import

data would lead to an overstatement of imports of subject product and, in turn, lead to an overstatement of the import

presence in apparent consumption figures.

IV-1

PART IV: U.S. IMPORTS, APPARENT CONSUMPTION, AND

MARKET SHARES

U.S. IMPORTERS

The Commission sent questionnaires to 90 firms believed to be importers of threaded rod based

on information provided in the petition and information provided by U.S. Customs and Border Protection. 

In addition, importer questionnaires were sent to the nine firms that received producer questionnaires. 

Useable questionnaire responses were received from 27 firms.1

 As a share of official statistics (HTS

7318.15.5060), questionnaire responses were received from importers that in 2007 accounted for more

than 52.4 percent of U.S. imports from China.2

 Table IV-1 presents a list of the firms that provided

useable responses to the Commission’s questionnaire in the final phase of this investigation, the countries

from which they imported during 2005-07, and their shares of reported imports from China in 2007. 

Table IV-1

Threaded rod: U.S. importers and sources of their imports, 2005-07, and share of reported

imports from China in 2007

* * * * * * *

U.S. IMPORTS

Subject Imports from China

Table IV-2 presents U.S. imports of threaded rod based on data reported in response to

Commission questionnaires.3

 The quantity of U.S. imports from China increased 63.3 percent from 2005

to 2007 while the value of U.S. imports from China increased 64.0 percent. During the interim periods,

U.S. imports from China also increased 21.1 percent by quantity and increased 63.3 percent by value. 
IV-2

Table IV-2

Threaded rod: Imports, by sources, 2005-07, January-September 2007, and January-September 2008 

Source

Calendar year January-September

2005 2006 2007 2007 2008

Quantity (1,000 pounds)

China 53,496 68,157 87,339 59,091 71,537

Nonsubject sources 9,865 10,125 9,466 6,710 8,529

Total 63,362 78,282 96,805 65,801 80,066

Value (1,000 dollars)

1

China 17,237 20,610 28,273 18,666 30,485

Nonsubject sources 9,475 9,191 8,815 6,084 8,584

Total 26,712 29,802 37,088 24,750 39,069

Unit value (per pound)

1

China $0.32 $0.30 $0.32 $0.32 $0.43

Nonsubject sources 0.96 0.91 0.93 0.91 1.01

Average 0.42 0.38 0.38 0.38 0.49

Share of quantity (percent)

China 84.4 87.1 90.2 89.8 89.3

Nonsubject sources 15.6 12.9 9.8 10.2 10.7

Total 100.0 100.0 100.0 100.0 100.0

Share of value (percent)

China 64.5 69.2 76.2 75.4 78.0

Nonsubject sources 35.5 30.8 23.8 24.6 22.0

Total 100.0 100.0 100.0 100.0 100.0

1

 Landed, duty-paid.

Note.–Because of rounding, figures may not add to the totals shown.

Source: Compiled from data submitted in response to Commission questionnaires.
IV-3

Nonsubject Sources of Imports

In addition to firms reporting imports from China, seven firms reported imports from nonsubject

sources (three from India, two from Japan, one from Belgium and Germany, and one from Mexico), with

an overall decline in volume from nonsubject countries from 2005 to 2007.

Nearly 90 percent of imports from nonsubject sources were from India and were valued

comparably with imports from China (***). Imports from Japan ranged from ***; imports from Belgium

and Germany ranged from ***; and imports from Mexico ranged from ***.

NEGLIGIBILITY

The Tariff Act provides for the termination of an investigation if imports of the subject product

from a country are less than 3 percent of total imports, or, if there is more than one such country, their

combined share is less than or equal to 7 percent of total imports, during the most recent 12 months for

which data are available preceding the filing of the petition – in this case March 2007 to February 2008. 

Table IV-3 presents the shares according to official statistics (HTS 7318.15.5060). 

Table IV-3

Threaded rod: U.S. imports, by sources, based on official Commerce statistics, and shares of

total imports (in percent), March 2007-February 2008

Source Imports 

(1,000 pounds)

Share of total imports

(percent)

China 166,489 73.6

Nonsubject sources 59,727 26.4

Total 226,216 100.0

Note.–Because of rounding, figures may not add to the totals shown.

Source: Compiled from official Commerce statistics (HTS 7318.15.5060), the 7318.15.5050 supercedes

7318.15.5060 starting in July 1, 2008.
IV-4

APPARENT U.S. CONSUMPTION

Table IV-4 shows data on total apparent U.S. consumption for threaded rod using data compiled

from responses to Commission questionnaires. Apparent U.S. consumption of threaded rod increased by 

1.1 percent from 2005 to 2007 in quantity, and was 4.3 percent higher in interim 2008 than in interim

2007. The value of apparent U.S. consumption increased by 0.7 percent from 2005 to 2007, and was 

36.2 percent higher in interim 2008 than in interim 2007.

Table IV-4

Threaded rod: U.S. producers’ U.S. shipments, U.S. shipments of imports, by sources, and

apparent U.S. consumption, 2005-07, January-September 2007, and January-September 2008

Item

Calendar year January-September 

2005 2006 2007 2007 2008

Quantity (1,000 pounds)

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

U.S. shipments of imports from--

China 59,045 70,683 86,436 59,531 65,780

Nonsubject countries 10,861 10,696 9,943 7,244 6,799

Total 69,906 81,379 96,379 66,775 72,579

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

Value (1,000 dollars)

1

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

U.S. shipments of imports from--

China 38,163 44,775 53,323 36,656 50,561

Nonsubject countries 10,431 9,660 9,170 6,496 7,973

Total 48,593 54,435 62,493 43,152 58,534

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

 1 Landed, duty-paid.

Note.–Because of rounding, figures may not add to the totals shown.

Source: Compiled from data submitted in response to Commission questionnaires.
IV-5

U.S. MARKET SHARES

Table IV-5 shows data on total U.S. market share for threaded rod using data compiled from

responses to Commission questionnaires. From 2005 to 2007, U.S. producers lost 15.0 percentage points

of market share based on quantity and 13.3 percentage points based on value. Comparing interim 2008

with interim 2007, U.S. producers lost 2.3 percentage points of market share based on quantity, but

gained 0.2 percentage points based on value. U.S. imports from China gained 15.6 percentage points

based on quantity and 14.6 percentage points based on value from 2005 to 2007. Comparing interim

2008 with interim 2007, U.S. imports from China gained 2.9 percentage points of market share in terms

of quantity and experienced a 0.7 percentage point increase in terms of value. Nonsubject imports lost

market shares in both value and quantity during 2005-07. 

Table IV-5

Threaded rod: U.S. consumption and market shares, 2005-07, January-September 2007, and

January-September 2008

* * * * * * *

RATIO OF IMPORTS TO U.S. PRODUCTION

Information concerning the ratio of imports to U.S. production of threaded rod is presented in

table IV-6.

Table IV-6

Threaded rod: Ratio of U.S. imports to U.S. production, by sources, 2005-07, January-September

2007, and January-September 2008

Item

Calendar year January-September 

2005 2006 2007 2007 2008

Quantity (1,000 pounds)

U.S. production *** *** *** *** ***

U.S. imports from--

China 53,496 68,157 87,339 59,091 71,537

Nonsubject countries 9,865 10,125 9,466 6,710 8,529

 All countries 63,362 78,282 96,805 65,801 80,066

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

U.S. imports from--

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

Nonsubject countries *** *** *** *** ***

 All countries *** *** *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires.

 1

 Respondents reported that prices of steel wire rod have increased dramatically in China, beginning in late 2007

and continuing into early 2008. Preliminary conference transcript, p. 10 (McGrath) and Porteous’ postconference

brief, pp. 19-22. In addition, Porteous reported that there has been a strong correlation between threaded rod prices

and prices of steel wire rod. Porteous’ postconference brief, pp. 18-20.

 2

 Approximately 80 percent of threaded rod is made from steel wire rod and 20 percent from steel bar. Hearing

transcript, pp. 61-62 (Logan and Iverson).

V-1

PART V: PRICING AND RELATED INFORMATION

FACTORS AFFECTING PRICES

Raw Materials

The main raw material used in the production of threaded rod is carbon steel wire rod; the wire

rod is cold-drawn, straightened, cut to length, threaded, and then galvanized. It accounted for 67 percent

of total cost of goods sold during the financial data reporting period (see Part VI: Financial Condition of

U.S. Producers). The price of carbon steel wire rod decreased in early 2005 before generally increasing

until the end of 2007 (figure V-1).1

 Prices then increased rapidly until July 2008 and then declined

through the end of 2008. For larger diameter threaded rod, steel bar is used as an input.2

Figure V-1

Low-carbon steel wire rod: Average monthly U.S. spot price in dollars per ton, January 2005-

January 2009

Source: Compiled from data published in Purchasing, Steel Price Transaction Report.

0

200

400

600

800

1000

1200

2005

2006

2007

2008

Dollars per ton
 3

 Respondents reported that Chinese producers have an advantage in the galvanized products because of the

production process, as well as because they generally have their own coating operations rather than having to

contract out for it, as some U.S. producers do. Preliminary conference transcript, pp. 103-104 (Levinson and

Haggerty).

 4

 Petitioner estimated that galvanized threaded rod, including both electro-plated and hot-dipped, is approximately

75 to 80 percent of the total market. Preliminary conference transcript, p. 63 (Logan). Simlarly, respondents

estimated that galvanized threaded rod makes up approximately 70 percent of the total market. Preliminary

conference transcript, p. 89 (Haggerty). 

 5 See, e.g., “OECD sees slowdown affecting steel demand and outlook,” January 28, 2009, found at

http://steelguru.com/news/index/2009/01/02/NzcxMjA%3D/Recession_reports_-_OECD_sees_slowdown_affecting

_steel_demand_and_outlook.html, downloaded January 28, 2009, and “Down economic reports set the stage for

weak steel prices,” January 9, 2009, found at http://www.purchasing.com/blog/1570000357/post/1660038966.html,

downloaded January 28, 2009.

 6

 These estimates are based on HTS subheading 7318.15.5060 which, at that time was the heading for threaded

rod.

 7

 *** reported inland transportation costs of 20 and 30 percent, respectively, and may have been referring to total

transportation costs from overseas.

 8

 Porteous reported that, ***. Porteous’ postconference brief, pp. 6-9.

V-2

Most threaded rod is galvanized using either a zinc plating or a hot-dip process;3

 other coatings

for threaded rod include a plain oil finish, paint, black oxide, or plating with other elements.4

Producers and importers were asked to describe any trends in the prices of raw materials used to

produce threaded rod and whether they expect these trends to continue. Six of seven responding

producers and 18 of the 27 responding importers described the fluctuations of raw material prices that are

shown in figure V-1. As the economy has sunk into recession, demand for steel in general has declined

leading to lower prices.5

 Producer *** reported the threat of increasing steel prices in 2009, however, and

importer *** noted that it believes the price decline is over. Importers *** expect prices to decline

further, and importer *** stated that it is difficult to know how long the current decline in steel and fuel

costs will last, or how much farther prices will drop. 

Transportation Costs to the U.S. Market

Transportation costs for threaded rod to the United States (excluding U.S. inland transportation

costs) from China were estimated to be 14.9 percent in 2007. These estimates are derived from official

import data and represent the transportation and other charges on imports valued on a c.i.f. basis, as

compared with customs value.6

U.S. Inland Transportation Costs

U.S. producers reported that, generally, U.S. inland transportation costs ranged from 1 to 8

percent of the total delivered cost of threaded rod, and averaged 4.2 percent. Sixteen of 21 responding

importers reported that inland transportation costs ranged between 3 and 10 percent (averaging 6.2

percent)7

 of the total delivered cost of threaded rod.8

Six of seven U.S. producers reported that they arranged delivery, with four reporting that they

shipped 50 to 80 percent of their threaded rod less than 100 miles and the other two reporting that they

shipped 80 percent of their threaded rod between 101 and 1,000 miles. Twenty of the 24 responding

importers reported that they arranged delivery. Based on a simple average, the 18 responding importers

noted shipping 50.6 percent of their threaded rod less than 100 miles, 34.6 percent between 101 and 1,000

miles, and 14.8 percent more than 1,000 miles.
 9

 Real values of the Chinese yuan are not available.

V-3

Exchange Rates

Quarterly data reported by the International Monetary Fund indicate that the nominal value of the

Chinese yuan appreciated relative to the U.S. dollar beginning in the third quarter of 2005 and continued

to do so through the entire period under review (figure V-2).9

 In all, the yuan appreciated 21.0 percent

over the period.

Figure V-2

Exchange rates: Indices of the nominal exchange rate of the Chinese currency relative to the U.S.

dollar, by quarters, January 2005-September 2008

Source: International Monetary Fund, International Financial Statistics, retrieved from http://www.imfstatistics.org/imf/

on January 15, 2009.

PRICING PRACTICES

Pricing Methods

The seven responding U.S. producers of threaded rod reported that they use a variety of methods

in determining prices. Two producers (***) reported that they use some form of a cost-plus markup, and

three others (***) remarked that they have set price lists. In addition to their use of set price lists, ***

also contract for multiple shipments and *** will negotiate on a transaction-by-transaction basis, which is

the way *** sets its pricing. *** reported that it considers the customer, the volume, and competitor’s

price, and arrives at a negotiated price for each customer. *** reported that it also has contracts for

multiple shipments and annualized contracts with conditions attached.

0

20

40

60

80

100

120

140

160

2005200620072008

Jan.-Mar. 2005 = 100
 10 Two importers offer net 60 and net 90 days payment terms.

 11 ***.

 12 Additionally, *** reported that *** percent of its 2007 sales were via short-term contracts.

 13 *** reported a portion of its sales subject to long-term contracts, but these contracts were for a period of up to

one year, which means they should be classified as short-term contracts. However, these longer short-term contracts

can have prices renegotiated and have a fixed price with an approximate quantity. With *** other short-term

contracts, both quantity and price are fixed and prices cannot be renegotiated. 

 14 *** sells exclusively on a long-term contract basis; its contract is ***. 

 15 Importers *** reported selling on a long-term contract basis, but the details provided reference short-term

contracts. 

 16 Among the five importers whose contracts do not generally fit this description, three importers reported that

prices were renegotiable, and two importers each reported that only prices were fixed and that meet-or-release

clauses were included.

 17 Additionally, three purchasers noted that they only purchase from one source. Therefore, their responses are

excluded in these totals.

V-4

Among importers, 14 reported that they set prices on a transaction-by-transaction basis; seven

importers reported that they use price lists; four reported that they use contracts for multiple shipments;

four reported that they use some form of a cost-plus markup, and three reported using market pricing as a

guide.

Sales Terms and Discounts

Six of the seven producers and the vast majority of importers reported that sales terms for

threaded rod are generally net 30 days.10 Four of the seven producers and six of 23 importers stated that

they give discounts for early payment. Three producers reported that prices are generally quoted on a

f.o.b. warehouse basis; three reported that they generally quote delivered prices; and *** reported that it

negotiates freight terms on a customer-by-customer basis.11 Among responding importers, 11 reported

that they quote delivered prices, nine reported that they quote f.o.b. prices, and two quote on both a

delivered and f.o.b. basis.

Six of seven responding producers reported that the majority of their sales of threaded rod are on

a spot basis (*** percent, based on a simple average); only *** reported that a significant percent are

sales by long-term and short-term contracts:12 ***, *** sells *** percent to *** on a short-term contract

basis, and *** sells *** percent on a short-term basis, respectively.13 Ten importers sell threaded rod

exclusively on a spot basis, two sell exclusively on a short-term contract basis, and one sells exclusively

on a long-term contract basis.14 The other nine responding importers sold about 68.1 percent on the spot

market and about 31.9 percent via short-term contracts (up to 12 months in length).15

Four producers reported that short-term contracts are *** in length, with ***. ***. Ten importers

reported that short-term contracts are generally 3 to 9 months in length, with both price and quantity

fixed, no price renegotiations, and no meet-or-release provisions included.16

Purchasers were asked if sales terms differ between U.S. producers of threaded rod and importers

of Chinese threaded rod. Twenty of 27 responding purchasers replied “no.”17 Of the seven purchasers

responding “yes,” two stated that imported material is at least sometimes less expensive than threaded rod

produced domestically; two noted that importers are more willing to enter into longer contracts; one

stated that some importers will offer special payment terms; one indicated that imports have to meet

certain specifications; and one reported shorter domestic producer lead times, which has the effect of

bringing about quicker changes in the market price.
 18 These discounts are in addition to those previously mentioned for early payment.

 19 Ten other suppliers were identified by purchasers, however none of these suppliers was identified by more than

one purchaser.

V-5

With respect to discounts, six of seven producers reported offering some type of discount on their

sales of threaded rod,18 with five producers reporting that the discounts depend on the quantity purchased. 

Additionally, *** reported that it offers ***. Nine importers reporting giving quantity discounts; one

gives discounts based on the frequency of purchases; one gives a rebate based on total volume of

purchases that include products other than threaded rod; and 10 do not offer discounts. 

Price Leadership

Purchasers were asked if there have been any firms that they would consider price leaders in the

market since 2005. Responding purchasers identified the following suppliers as price leaders: Vulcan

(identified by 7 purchasers); Heads and Threads (4); Porteous and PrimeSource (3); Bay Standard,

Conklin & Conklin, Industrial Threaded Products, and Western States (2).19

PRICE DATA

The Commission requested U.S. producers and importers of threaded rod to provide quarterly

data for the total quantity and f.o.b. value of threaded rod that was shipped to unrelated customers in the

U.S. market. Data were requested for the period January 2005 to September 2008. The products for

which pricing data were requested are as follows:

Product 1.–Low-carbon steel fully threaded rod, electro-plated with zinc, 3/8" diameter (as

measured from the top of the thread), 10 feet in length, in cardboard tubes

Product 2.–Low-carbon steel fully threaded rod, electro-plated with zinc, 1/4" diameter (as

measured from the top of the thread), 10 feet in length, in cardboard tubes

Product 3.–Low-carbon steel fully threaded rod, hot-dip galvanized, 5/8" diameter (as

measured from the top of the thread), 12 feet in length, in cardboard tubes

Product 4.—Low-carbon steel fully threaded rod, electro-plated with zinc, 3/8-inch diameter

(as measured from the top of the thread), 6 feet in length, in cardboard tubes

Product 5.—Low-carbon steel fully threaded rod, electro-plated with zinc, 1/2-inch diameter

(as measured from the top of the thread), 10 feet in length, in cardboard tubes

Product 6.—Low-carbon steel fully threaded rod, plain, 3/4 inch diameter (as measured

from the top of the thread), 12 feet in length, in cardboard tubes

Product 7.—Low-carbon steel fully threaded rod, plain, 11⁄4 inch diameter (as measured

from the top of the thread), 12 feet in length, in cardboard tubes
 20 ***. 

 21 Quarterly pricing data excluding Bay Standard is presented in app. E. All of Bay Standard’s shipments would

meet the A36 specification, whether requested by the customer or not. Respondent Porteous alleges that A36 is a

specialty product that commands a premium price. Respondent Porteous’s prehearing brief, pp. 4-5. At the hearing,

a representative for Bay Standard reported with respect to A36-compliant threaded rod, “We sell it for the same price

as we do regular threaded rod.” Hearing transcript, p. 103 (Iverson). 

 22 Including *** import data presented in app. F, the percentage of import shipments would rise to *** percent.

 23 The large majority (over *** percent) of these sales were imported from India. 

 24 Petitioner reported that the price increases in the fourth quarter of 2007 were forced by the increase in raw

material costs, specifically that of carbon steel wire rod. Preliminary conference transcript, p. 40 (Magrath).

V-6

All U.S. producers provided usable pricing data for sales of the requested products, and 19

importers from China20 provided usable pricing data for sales of the requested products, although not all

firms reported pricing for all products for all quarters.21 In addition, four importers reported usable

pricing data for their imports from India and Mexico, nonsubject countries. Pricing data for the seven

products reported by these firms, shown in tables V-1 to V-7 and figures V-3 to V-9, accounted for 37.7

percent of U.S. producers’ shipments of threaded rod and 28.5 percent of U.S. shipments of imports from

China in 2007.22 Pricing data reported by importers of threaded rod from nonsubject countries accounted

for *** percent of U.S. shipments of imports from nonsubject countries in 2007.23

Price Trends

Prices of U.S.-produced threaded rod for products 1 through 6 generally decreased from 2005

through the middle of 2007, before rapidly increasing in late 2007 through 2008.24 Prices of product 7

irregularly increased through 2007, and began to increase more rapidly in 2008. For products 1 through

6, prices of U.S.-produced threaded rod decreased from the first quarter of 2005 to the third quarter of

2007. The decrease in prices ranged between 1.6 and 24.7 percent. Overall, prices were between 32.4

percent (product 3) and 83.5 percent (product 7) higher in the third quarter of 2008 than the first quarter

of 2005. 

In general, prices of products imported from China show a similar pattern to the prices of the U.S. 

Prices of all products imported from China declined from the first quarter of 2005 to the third quarter of

2007, with decreases ranging from 2.0 to 26.4 percent. All products, however, had large price increases

in 2008. A summary of price trends is shown in tables V-1 through V-7 and figures V-3 through V-9.
V-7

Table V-1

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

and importers of product 1,1

 and margins of underselling, by quarters, January 2005-September

2008

Period

United States China Nonsubject2

Price

(per pound)

Quantity

(pounds)

Price

(per pound)

Quantity

(pounds)

Margin

(percent)

Price

(per

pound)

Quantity

(pounds)

2005:

 Jan.-Mar. $*** *** $0.45 1,276,168 *** $*** ***

 Apr.-June *** *** 0.43 1,894,638 *** *** ***

 July-Sept. *** *** 0.42 2,153,878 *** *** ***

 Oct.-Dec. *** *** 0.42 1,776,693 *** *** ***

2006:

 Jan.-Mar. *** *** 0.45 2,159,355 *** *** ***

 Apr.-June *** *** 0.44 2,375,281 *** *** ***

 July-Sept. *** *** 0.44 2,745,524 *** *** ***

 Oct.-Dec. *** *** 0.42 2,314,064 *** *** ***

2007:

 Jan.-Mar. *** *** 0.41 2,679,148 *** *** ***

 Apr.-June *** *** 0.42 2,878,362 *** *** ***

 July-Sept. *** *** 0.41 3,309,037 *** *** ***

 Oct.-Dec. *** *** 0.43 3,478,609 *** *** ***

2008:

 Jan.-Mar. *** *** 0.49 3,538,787 *** *** ***

 Apr.-June *** *** 0.61 3,520,713 *** *** ***

 July-Sept. *** *** 0.69 3,638,697 *** *** ***

 1 Product 1.–Low-carbon steel fully threaded rod, electro-plated with zinc, 3/8" diameter (as measured from the top

of the thread), 10 feet in length, in cardboard tubes.

 2 Nonsubject data were reported for India and Mexico.

Source: Compiled from data submitted in response to Commission questionnaires.
V-8

Table V-2

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

and importers of product 2,1

 and margins of underselling/(overselling), by quarters, January 2005-

September 2008

Period

United States China Nonsubject2

Price

(per pound)

Quantity

(pounds)

Price

(per pound)

Quantity

(pounds)

Margin

(percent)

Price

(per pound)

Quantity

(pounds)

2005:

 Jan.-Mar. $*** *** $0.65 94,727 *** $*** ***

 Apr.-June *** *** 0.56 105,090 *** 0.54 13,294

 July-Sept. *** *** 0.52 94,137 *** *** ***

 Oct.-Dec. *** *** 0.57 88,157 *** *** ***

2006:

 Jan.-Mar. *** *** 0.64 126,689 *** *** ***

 Apr.-June *** *** 0.53 140,845 *** *** ***

 July-Sept. *** *** 0.48 139,543 *** *** ***

 Oct.-Dec. *** *** 0.42 243,908 *** *** ***

2007:

 Jan.-Mar. *** *** 0.44 215,211 *** *** ***

 Apr.-June *** *** 0.47 356,950 *** *** ***

 July-Sept. *** *** 0.50 252,451 *** *** ***

 Oct.-Dec. *** *** 0.53 260,495 *** *** ***

2008:

 Jan.-Mar. *** *** 0.59 248,258 *** *** ***

 Apr.-June *** *** 0.68 369,455 *** *** ***

 July-Sept. *** *** 0.83 290,268 *** *** ***

 1 Product 2.–Low-carbon steel fully threaded rod, electro-plated with zinc, 1/4" diameter (as measured from the top

of the thread), 10 feet in length, in cardboard tubes.

 2 Nonsubject data were reported for India and Mexico.

Source: Compiled from information submitted in response to Commission questionnaires.
V-9

Table V-3

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

and importers of product 3,1

 and margins of underselling/(overselling), by quarters, January 2005-

September 2008

Period

United States China Nonsubject2

Price

(per pound)

Quantity

(pounds)

Price

(per pound)

Quantity

(pounds)

Margin

(percent)

Price

(per pound)

Quantity

(pounds)

2005:

 Jan.-Mar. $*** *** $*** *** 27.5 $*** ***

 Apr.-June *** *** *** *** 34.0 *** ***

 July-Sept. *** *** *** *** 15.2 *** ***

 Oct.-Dec. *** *** *** *** 32.5 *** ***

2006:

 Jan.-Mar. *** *** *** *** 30.5 *** ***

 Apr.-June *** *** 0.60 77,893 31.8 *** ***

 July-Sept. *** *** 0.62 43,153 29.0 *** ***

 Oct.-Dec. *** *** *** *** 28.5 *** ***

2007:

 Jan.-Mar. *** *** *** *** 12.0 -- 0

 Apr.-June *** *** 0.73 97,222 7.4 *** ***

 July-Sept. *** *** 0.67 112,856 5.6 *** ***

 Oct.-Dec. *** *** 0.72 106,686 9.7 -- 0

2008:

 Jan.-Mar. *** *** 0.80 77,773 2.2 *** ***

 Apr.-June *** *** 1.09 81,648 (14.1) *** ***

 July-Sept. *** *** 1.15 61,541 8.0 *** ***

 1 Product 3.–Low-carbon steel fully threaded rod, hot-dip galvanized, 5/8" diameter (as measured from the top of

the thread), 12 feet in length, in cardboard tubes.

 2 Nonsubject data were reported for India and Mexico.

Source: Compiled from information submitted in response to Commission questionnaires.
V-10

Table V-4

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

and importers of product 4,1

 and margins of underselling/(overselling), by quarters, January 2005-

September 2008

Period

United States China Nonsubject2

Price

(per pound)

Quantity

(pounds)

Price

(per pound)

Quantity

(pounds)

Margin

(percent)

Price

(per pound)

Quantity

(pounds)

2005:

 Jan.-Mar. $*** *** $0.53 402,231 *** $*** ***

 Apr.-June *** *** *** *** *** *** ***

 July-Sept. *** *** 0.50 482,608 *** *** ***

 Oct.-Dec. *** *** 0.50 441,807 *** *** ***

2006:

 Jan.-Mar. *** *** 0.48 595,997 *** *** ***

 Apr.-June *** *** 0.45 977,831 *** *** ***

 July-Sept. *** *** 0.43 1,029,141 *** *** ***

 Oct.-Dec. *** *** 0.43 881,790 *** *** ***

2007:

 Jan.-Mar. *** *** 0.44 1,314,313 *** *** ***

 Apr.-June *** *** 0.45 1,333,295 *** *** ***

 July-Sept. *** *** 0.46 1,279,985 *** *** ***

 Oct.-Dec. *** *** 0.48 950,695 *** *** ***

2008:

 Jan.-Mar. *** *** 0.53 1,092,543 *** *** ***

 Apr.-June *** *** 0.66 1,068,833 *** *** ***

 July-Sept. *** *** 0.74 1,316,927 *** *** ***

 1 Product 4.-Low-carbon steel fully threaded rod, electro-plated with zinc, 3/8-inch diameter (as measured from the

top of the thread), 6 feet in length, in cardboard tubes.

 2 Nonsubject data were reported for India.

Source: Compiled from information submitted in response to Commission questionnaires.
V-11

Table V-5

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

and importers of product 5,1

 and margins of underselling/(overselling), by quarters, January 2005-

September 2008

Period

United States China Nonsubject2

Price

(per pound)

Quantity

(pounds)

Price

(per pound)

Quantity

(pounds)

Margin

(percent)

Price

(per pound)

Quantity

(pounds)

2005:

 Jan.-Mar. $*** *** $0.57 411,478 *** $*** ***

 Apr.-June *** *** 0.45 714,680 *** *** ***

 July-Sept. *** *** 0.40 767,769 *** *** ***

 Oct.-Dec. *** *** 0.44 565,192 *** *** ***

2006:

 Jan.-Mar. *** *** 0.43 624,435 *** *** ***

 Apr.-June *** *** 0.43 897,173 *** *** ***

 July-Sept. *** *** 0.43 904,586 *** *** ***

 Oct.-Dec. *** *** 0.45 790,427 *** *** ***

2007:

 Jan.-Mar. *** *** 0.44 1,047,561 *** *** ***

 Apr.-June *** *** 0.41 1,093,558 *** *** ***

 July-Sept. *** *** 0.45 1,169,943 *** *** ***

 Oct.-Dec. *** *** 0.45 1,353,309 *** *** ***

2008:

 Jan.-Mar. *** *** 0.50 1,141,191 *** *** ***

 Apr.-June *** *** 0.61 1,513,738 *** *** ***

 July-Sept. *** *** 0.74 1,364,068 *** *** ***

 1 Product 5.-Low-carbon steel fully threaded rod, electro-plated with zinc, 1/2-inch diameter (as measured from the

top of the thread), 10 feet in length, in cardboard tubes.

 2 Nonsubject data were reported for India.

Source: Compiled from information submitted in response to Commission questionnaires.
V-12

Table V-6

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

and importers of product 6,1

 and margins of underselling/(overselling), by quarters, January 2005-

September 2008

Period

United States China Nonsubject2

Price

(per pound)

Quantity

(pounds)

Price

(per pound)

Quantity

(pounds)

Margin

(percent)

Price

(per pound)

Quantity

(pounds)

2005:

 Jan.-Mar. $*** *** $*** *** *** $*** ***

 Apr.-June *** *** 0.47 82,511 *** -- 0

 July-Sept. *** *** *** *** *** *** ***

 Oct.-Dec. *** *** *** *** *** *** ***

2006:

 Jan.-Mar. 0.49 165,567 *** *** *** *** ***

 Apr.-June *** *** 0.44 118,496 *** *** ***

 July-Sept. *** *** *** *** *** *** ***

 Oct.-Dec. *** *** *** *** *** *** ***

2007:

 Jan.-Mar. 0.48 129,568 0.42 166,299 12.1 *** ***

 Apr.-June 0.48 135,482 0.39 192,690 18.4 *** ***

 July-Sept. *** *** 0.42 213,446 *** *** ***

 Oct.-Dec. *** *** 0.43 184,302 *** *** ***

2008:

 Jan.-Mar. *** *** 0.51 137,480 *** *** ***

 Apr.-June *** *** 0.63 187,627 *** *** ***

 July-Sept. *** *** 0.69 147,586 *** -- 0

 1 Product 6.-Low-carbon steel fully threaded rod, plain, 3/4 inch diameter (as measured from the top of the thread),

12 feet in length, in cardboard tubes. .

 2 Nonsubject data were reported for India.

Source: Compiled from information submitted in response to Commission questionnaires.
V-13

Table V-7

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

and importers of product 7,1

 and margins of underselling, by quarters, January 2005-September

2008

Period

United States China Nonsubject2

Price

(per pound)

Quantity

(pounds)

Price

(per pound)

Quantity

(pounds)

Margin

(percent)

Price

(per pound)

Quantity

(pounds)

2005:

 Jan.-Mar. $0.53 122,441 $*** *** *** $*** ***

 Apr.-June 0.52 125,476 *** *** *** *** ***

 July-Sept. 0.58 94,890 *** *** *** -- 0

 Oct.-Dec. 0.54 137,468 *** *** *** *** ***

2006:

 Jan.-Mar. *** *** *** *** *** -- 0

 Apr.-June *** *** *** *** *** *** ***

 July-Sept. 0.56 107,239 0.47 70,840 16.5 *** ***

 Oct.-Dec. 0.61 60,167 *** *** *** -- 0

2007:

 Jan.-Mar. 0.56 90,457 *** *** *** -- 0

 Apr.-June 0.60 92,947 0.43 122,969 28.5 *** ***

 July-Sept. 0.63 97,426 *** *** *** -- 0

 Oct.-Dec. 0.59 143,501 0.32 138,909 46.1 *** ***

2008:

 Jan.-Mar. 0.66 69,402 *** *** *** *** ***

 Apr.-June 0.82 72,909 0.50 156,138 38.5 *** ***

 July-Sept. 0.96 60,082 0.64 119,491 33.3 -- 0

 1 Product 7.-Low-carbon steel fully threaded rod, plain, 11⁄4 inch diameter (as measured from the top of the thread),

12 feet in length, in cardboard tubes. 2 Nonsubject data were reported for India.

Source: Compiled from information submitted in response to Commission questionnaires.

Figure V-3

Threaded rod: Weighted-average f.o.b. selling prices and quantities, as reported by U.S. producers

and importers of product 1, by quarters, January 2005-September 2008

* * * * * * *

Figure V-4

Threaded rod: Weighted-average f.o.b. selling prices and quantities, as reported by U.S. producers

and importers of product 2, by quarters, January 2005-September 2008

* * * * * * *
 25 ***.

V-14

Figure V-5

Threaded rod: Weighted-average f.o.b. selling prices and quantities, as reported by U.S. producers

and importers of product 3, by quarters, January 2005-September 2008

* * * * * * *

Figure V-6

Threaded rod: Weighted-average f.o.b. selling prices and quantities, as reported by U.S. producers

and importers of product 4, by quarters, January 2005-September 2008

* * * * * * *

Figure V-7

Threaded rod: Weighted-average f.o.b. selling prices and quantities, as reported by U.S. producers

and importers of product 5, by quarters, January 2005-September 2008

* * * * * * *

Figure V-8

Threaded rod: Weighted-average f.o.b. selling prices and quantities, as reported by U.S. producers

and importers of product 6, by quarters, January 2005-September 2008

* * * * * * *

Figure V-9

Threaded rod: Weighted-average f.o.b. selling prices and quantities, as reported by U.S. producers

and importers of product 7, by quarters, January 2005-September 2008

* * * * * * *

Price Comparisons

Imports of threaded rod from China undersold the U.S. product in 99 of 105 quarterly

comparisons, with margins of underselling ranging from 0.002 to 46.1 percent.25 Conversely, the

remaining six quarters of imports of threaded rod from China oversold the U.S. product, with margins of

overselling ranging from 2.2 to 14.1 percent. A summary of margins of underselling and overselling is

presented in table V-8. 
 26 Petitioner reported that it has lost some significant customers who are now buying 100 percent of their supply

of threaded rod from China. Preliminary conference transcript, p. 26 (Logan). However, it included *** in its lost

sales allegations.

 27 All of the lost sales allegations were made by ***. The lost revenue allegations were submitted by ***. 

Producer *** reported that it had neither lost sales nor revenues since January 1, 2005. Producer *** did not provide

details regarding its lost sales, just a statement of how its volume had decreased.

V-15

Table V-8

Threaded rod: Number of quarters of underselling and overselling and highest and lowest margins

of underselling and (overselling) by product number

Product Number of

quarters of

underselling

Number of

quarters of

(overselling)

Average

margin of

underselling

(percent) 

Range of

margins of 

underselling

(percent)

Average

margin of

(overselling)

(percent)

Range of

margins of

(overselling)

(percent)

1 15 0 11.9 6.0 to 19.3 -- --

2 14 1 15.1 5.8 to 28.3 5.4 --

3 14 1 19.6 2.2 to 34.0 14.1 --

4 14 1 7.7 1.0 to 15.1 8.7 --

5 14 1 13.2 7.2 to 23.3 2.8 --

6 13 2 8.9 0.0 to 18.4 7.6 2.2 to 13.1

7 15 0 31.1 3.9 to 46.1 -- --

Source: Compiled from data submitted in response to Commission questionnaires.

LOST SALES AND LOST REVENUES

The Commission requested that U.S. producers of threaded rod report any instances of lost sales

and lost revenues experienced due to competition from imports from China since January 1, 2005. Six of

the seven producers reported that they had reduced prices and four had rolled back announced price

increases, allegedly due to imports from China. Five of six responding producers alleged that they had

lost sales due to low-priced imports from China.26 All of the lost sales and lost revenue allegations are

presented in tables V-9 and V-10 and are discussed in more detail below. There were *** lost sales

allegations totaling $*** and *** lost revenue allegations totaling $***.27 Staff was able to contact all of

the listed purchasers. *** of the lost sales allegations were confirmed totaling $***, and *** of the lost

revenue allegations, totaling $*** were confirmed. Additional information, where relevant, is

summarized in the individual responses below.

Table V-9

Threaded rod: U.S. producers’ lost sales allegations

* * * * * * *

Table V-10

Threaded rod: U.S. producers’ lost revenue allegations

* * * * * * *
V-16

***

***.

***

***.

***

***.

***

***.

Purchasers responding to lost sales and lost revenue allegations in the preliminary phase of the

investigation also were asked whether they shifted their purchases of threaded rod from U.S. producers

to suppliers of threaded rod from China since January 2005. In addition, they were asked whether U.S.

producers reduced their prices in order to compete with suppliers of threaded rod from China (table V11). Five of the nine responding purchasers reported that they had shifted purchases of threaded rod

from U.S. producers to subject imports since January 1, 2005; all five of these purchasers reported that

price was the reason for the shift. In addition, five of nine purchasers reported that since January 1,

2005, U.S. producers reduced their prices in order to compete with the prices of subject imports.

Table V-11

Threaded rod: Purchaser responses regarding purchase shifting

Purchaser Shift from

U.S. to

imports1

Was

price

the

reason2

If not, list reasons3 Did U.S.

producers reduce

price to compete

with imports4

Comments

*** Yes Yes *** n/a ***

*** Yes Yes n/a Yes n/a

*** Yes Yes n/a Yes n/a

*** Yes Yes n/a Yes n/a

*** No n/a n/a No ***

*** n/a n/a *** n/a ***

*** No n/a n/a Yes (5

)

*** Yes Yes n/a Yes ***

*** No n/a n/a No6 n/a

 1 “Since January 1, 2005, did your firm switch purchases of threaded rod from U.S. producers to suppliers of threaded rod

imported from China?”

 2

 “If yes, was price the reason for the shift?”

 3

 “If price was not the reason for the shift, please list the reason(s) for the shift.”

 4

 “Since January 1, 2005, did U.S. producers reduce their prices of threaded rod in order to compete with prices of threaded rod

imported from China?”

 5

 ***. Staff telephone interview with ***.

 6

 ***.

Source: Compiled from data submitted in response to Commission questionnaires.
 1

 The firms (and their fiscal year ends if other than December 31) are: ***. In accordance with standard

Commission practice, financial data were collected for each firm’s three most recently completed fiscal years. Full

year financial data in this section of the report are presented for fiscal years 2006 to 2008 because firms accounting

for 85 percent of 2008 net sales reported data for these fiscal years. Full year financial data for fiscal years 2005 to

2007 are presented in app. G. 

 2

 Commission staff verified the U.S. producers’ questionnaire response of ***, and the results of the verification

are incorporated in this report.

VI-1

PART VI: FINANCIAL CONDITION OF THE U.S. PRODUCERS

BACKGROUND

Seven U.S. producers of threaded rod provided usable financial data on their operations on

threaded rod.1 2

 These data are believed to account for the large majority of U.S. production of threaded

rod in 2008. ***. 

OPERATIONS ON THREADED ROD

Income-and-loss data for U.S. producers of threaded rod are presented in table VI-1. Selected

company-specific financial data are presented in table VI-2. The reported financial condition of the U.S.

industry irregularly *** from 2006 to 2008, and *** during the comparable interim periods. The reported

aggregate net sales quantities *** from 2006 to 2008, while aggregate net sales values *** during this

time. Collectively, the aggregate cost of goods sold (“COGS”) and selling, general, and administrative

(“SG&A”) expenses *** during this time. As a result of the *** in operating costs and expenses as

compared to revenue, aggregate operating income *** from 2006 to 2008.

While the data show an overall *** in operating income from 2006 to 2008, year-to-year changes

in aggregate revenue and costs led to *** in the U.S. industry’s financial condition during this time. 

From 2006 to 2007, the ***, while from 2007 to 2008, as well as during the comparable interim periods,

operating income ***.

For U.S. producers of threaded rod, per-pound net sales values *** from 2006 to 2007, while

combined per-pound operating costs and expenses ***, which led to ***. From 2007 to 2008, as well as

during the comparable interim periods, per-pound net sales values ***, respectively, while per-pound

operating costs and expenses ***, respectively.

While not all components of operating costs and expenses *** on a per-pound basis during the

period for which data were collected, raw material costs *** during this time. Steel costs accounted for

an average of *** percent of total COGS for the reporting period, ***. From 2006 to 2008, as well as

during the comparable interim periods, per-pound steel costs ***, respectively.

Table VI-1

Threaded rod: Results of operations of U.S. producers, fiscal years 2006-08, January-September

2007, and January-September 2008

* * * * * * *

Table VI-2

Threaded rod: Selected results of operations of U.S. producers, by firm, fiscal years 2006-08,

January-September 2007, and January-September 2008

* * * * * * *
 3

 ***.

 4

 ***.

 5

 ***.

 6

 ***.

VI-2

While the aggregate data on threaded rod operations reveal an industry that experienced an *** in

profitability from 2006 to 2008, individual firm data reveal some variation in profitability during this

time. ***.3

 In contrast, ***.4 ***.5 

A variance analysis for the operations of U.S. producers of threaded rod is presented in table VI3. The information for this variance analysis is derived from table VI-1. The analysis shows that the ***. 

During the comparable interim periods, the ***.

Table VI-3

Threaded rod: Variance analysis on the operations of U.S. producers, fiscal years 2006-08, and

January-September 2007-08

* * * * * * *

CAPITAL EXPENDITURES

Capital expenditures are shown in table VI-4. Only three firms (***) reported capital

expenditures, and no firms reported R&D expenses. *** accounted for the majority of reported capital

expenditures. According to ***, its capital expenditures reflect ***.6

 During the first two fiscal years for

which data were requested, as well as the January-September 2007 time frame, total reported capital

expenditures were less than total reported depreciation expense, which suggests the industry was not

replacing its productive assets during that time. 

Table VI-4

Threaded rod: Capital expenditures of U.S. producers, fiscal years 2006-08, January-September

2007, and January-September 2008

* * * * * * *

ASSETS AND RETURN ON INVESTMENT

Data on the U.S. producers’ total assets and their return on investment (“ROI”) are presented in

table VI-5. For U.S. producers of threaded rod, the total assets utilized in the production, warehousing,

and sale of such products ***. The ROI ***. The trend in the ROI was similar to the trend in the

operating income margin.

Table VI-5

Threaded rod: U.S. producers’ total assets and return on investment, fiscal years 2006-08

* * * * * * *
VI-3

CAPITAL AND INVESTMENT

The Commission requested U.S. producers of threaded rod to describe any actual or potential

negative effects of imports of threaded rod from China on their firms’ growth, investment, ability to raise

capital, development and production efforts, or the scale of capital investments. Their responses are

shown in appendix H.

 1

 As noted earlier, the HTS classification (statistical reporting number 7318.15.5060) also includes items outside

the product scope such as threaded rods made from alloy steel (i.e., stainless steel), hanger bolts, and rods which are

not threaded along their entire length, etc. Hence, a portion of product shipped by Chinese producer/exporters may

be outside the scope of the investigation.

 2

 According to ***.

 3

 From January to October 2008, Customs data show that *** accounted for *** percent of total exports of

threaded rod classified under HTS 7318.15.5060 for January-June 2008 and HTS 7318.15.5050 and 7318.15.5090

for July-October 2008.

 4

 One firm, ***, submitted a final phase foreign producer/exporter questionnaire with the same data from its

response in the preliminary phase. Responses to the additional questions and January-September 2007 and JanuarySeptember 2008 data were left blank.

 5

 ***. U.S. Customs data.

VII-1

PART VII: THREAT CONSIDERATIONS AND INFORMATION ON

NONSUBJECT COUNTRIES

The Commission analyzes a number of factors in making threat determinations (see 19 U.S.C. §

1677(7)(F)(i)). Information on the volume of imports of the subject merchandise and pricing is presented

in Parts IV and V, respectively; and information on the effects of imports of the subject merchandise on

U.S. producers’ existing development and production efforts is presented in Part VI. Information on

inventories of the subject merchandise; foreign producers’ operations, including the potential for

“product-shifting;” any other threat indicators, if applicable; and any dumping in third-country markets,

follows. Also presented in this section of the report is information obtained for consideration by the

Commission on nonsubject countries and the global market.

THE INDUSTRY IN CHINA

The petition listed over 400 Chinese firms believed to be producing and/or exporting threaded

rod. Foreign producer/exporter questionnaires were sent via fax and/or e-mail to more than 125 firms that

accounted for nearly all of production/exports of product shipped to the United States under HTS

7318.15.5060.1

 Of those firms, Customs data show that ***. One firm, ***,2 accounted for more than

*** percent of U.S.-bound exports from 2005 to 2007.3

 No foreign producer/exporter in China submitted

a questionnaire response in the final investigation.4

 Three firms (one producer and two exporters)5

provided useable responses in the preliminary phase of this investigation. Their data are presented in

table VII-1. The exports to the United States of these firms were equivalent to *** percent of threaded

rod U.S. imports from China in 2007 as reported in Commission importer questionnaires. None of the

firms reported any shipments going to the home market. From 2005 to 2007, the share of Chinese

shipments going to the United States dropped from *** to *** percent while the share of shipments going

to all other export markets rose from *** to *** percent. Third country markets included Asia, Australia,

and Europe.

Table VII-1

Threaded rod: China’s production capacity, production, shipments, and inventories, 2005-07, and

projected 2008-09

* * * * * * *
 6

 Mittal Steel Point Lisas Ltd. v. United States, Slip Op. 2007-1552 at 17 (Fed. Cir., Sept. 18, 2008), quoting

from Statement of Administrative Action on Uruguay Round Agreements Act, H.R. Rep. 103-316, Vol. I at 851-52;

see also Bratsk Aluminum Smelter v. United States, 444 F.3d 1369 (Fed. Cir. 2006).

 7 Certain Steel Threaded Rod from China, Inv. No. 731-TA-1145 (Preliminary), USITC Publication 3996, April

2008, p. VII-3.

 8

 *** reported imports from *** during 2005–07.

 9

 HTS 7318.15.5060.

VII-2

U.S. IMPORTERS’ INVENTORIES

Inventories of threaded rod as reported by U.S. importers are presented in table VII-2.

Table VII-2

Threaded rod: U.S. importers’ end-of-period inventories of imports, 2005-07, January-September

2007, and January-September 2008

* * * * * * *

U.S. IMPORTERS’ IMPORTS SUBSEQUENT TO SEPTEMBER 30, 2008

Importer questionnaire respondents reported there were approximately 10.2 million pounds of

Chinese threaded rod scheduled for delivery after September 30, 2008. 

ANTIDUMPING DUTY ORDERS IN THIRD-COUNTRY MARKETS

None of the parties to this investigation is aware of any dumping findings or antidumping

remedies imposed on threaded rod in third-country markets.

INFORMATION ON NONSUBJECT COUNTRIES

In assessing whether the domestic industry is materially injured or threatened with material injury

“by reason of subject imports,” the legislative history states “that the Commission must examine all

relevant evidence, including any known factors, other than the dumped or subsidized imports, that may be

injuring the domestic industry, and that the Commission must examine those other factors (including nonsubject imports) ‘to ensure that it is not attributing injury from other sources to the subject imports.’”6

Global Market

According to respondents, virtually all of the U.S. imports of threaded rod from nonsubject

sources were from India.7

 Nearly 90 percent of imports from nonsubject sources were from India and

were valued comparably with imports from China, while values of imports from other nonsubject sources

were somewhat higher and, therefore, may have been materials outside the scope of this investigation.8

As a share of imports from India reported in official Commerce data,9

 responding importers’ accounted

for *** percent in 2005, 2006, and 2007 respectively.

In response to a question posed by staff during the staff conference, both Petitioner and 

respondent Porteous indicated they did not believe this investigation involved Bratsk issues. In this

regard, counsel for Petitioner stated:
 10 Conference transcript, pp. 49-50 (Waite).

 11 Conference transcript, p. 107 (Magrath).

 12 ***, retrieved January 21, 2009.

 13 ***, retrieved January 21, 2009. 

VII-3

 “ . . . Bratsk . . .would not apply to the facts of this case. Bratsk holds not only a

commodity product as an indicator, which is the first threshold test I know that a number

of Commissioners use, but it must also be available from other sources and it must be

priced below the U.S. product . . . it’s very clear that, first of all, there are no other

sources of the product in this harmonized tariff schedule that even begins to compare

with the volume of China, so you have an issue of availability. You have an issue of

pricing because, . . . the average unit price of the next lowest product or the next lowest

country rather in that period was India, but it was twice the price average unit value of

China, and of course the Indian average unit value is much higher than the domestic price

of subject merchandise so Bratsk doesn’t really apply here.”10

Counsel for Porteous stated:

“In looking at it in the context of a potential Bratsk analysis, as was raised this morning,

probably we would find that India is not a sufficient supplier of a pricing level

historically to have replaced the Chinese product. That would be if we assume that we're

dealing with a commodity product to start with; and I’m not sure that I want to concede

that point that it’s purely commodity.”11 

India

Table VII-3 presents data on India’s exports and U.S. imports of threaded rod from India. The

U.S. accounted for about 30 percent of India’s export shipment volume in 2005, 23 percent in 2006, and

20 percent in 2007. During the 2005-07 period, importers reported imports from *** Indian firms, ***. 

***.12 ***.13

Table VII-3

India’s threaded rod exports and imports, 2005–07

Item

Calendar year

2005 2006 2007

Quantity (1,000 pounds)

Exports 189,190 144,548 113,454

Imports 23,297 24,501 41,410

Net exports 165,892 120,047 72,044

Note.--Export and import figures are quantities reported at the 6-digit level for HTS subheading 7318.15 and may

include nonsubject products such as certain screws and bolts, threaded rod made from alloy steel, threaded rod

with threads covering 25 percent or less of the surface, and other miscellaneous threaded articles made from iron or

steel.

 

Source: Compiled from the Global Trade Atlas database.

A-1

APPENDIX A

FEDERAL REGISTER NOTICES

Federal Register / Vol. 73, No. 226 / Friday, November 21, 2008 / Notices 70671 

1For purposes of this investigation, the 

Department of Commerce has defined the subject 

merchandise as ‘‘steel threaded rod. Steel threaded 

rod is certain threaded rod, bar, or studs, of carbon 

quality steel, having a solid, circular cross section, 

of any diameter, in any straight length, that have 

been forged, turned, cold-drawn, cold-rolled, 

machine straightened, or otherwise cold-finished, 

and into which threaded grooves have been 

applied. In addition, the steel threaded rod, bar, or 

studs subject to this investigation are non-headed 

and threaded along greater than 25 percent of their 

total length. A variety of finishes or coatings, such 

as plain oil finish as a temporary rust protectant, 

zinc coating (i.e., galvanized, whether by 

electroplating or hot-dipping), paint, and other 

similar finishes and coatings, may be applied to the 

merchandise.’’ 

ACTION: Notice. 

SUMMARY: Notice is hereby given that 

the U.S. International Trade 

Commission has determined not to 

review the presiding administrative law 

judge’s (‘‘ALJ’’) initial determination 

(‘‘ID’’) (Order No. 11), granting 

complainant’s motion to amend the 

Complaint and Notice of Investigation 

and extending the target date for 

completion of the investigation to 

December 7, 2009. 

FOR FURTHER INFORMATION CONTACT: 

Megan M. Valentine, Office of the 

General Counsel, U.S. International 

Trade Commission, 500 E Street, SW., 

Washington, DC 20436, telephone (202) 

708–2301. Copies of non-confidential 

documents filed in connection with this 

investigation are or will be available for 

inspection during official business 

hours (8:45 a.m. to 5:15 p.m.) in the 

Office of the Secretary, U.S. 

International Trade Commission, 500 E 

Street, SW., Washington, DC 20436, 

telephone (202) 205–2000. General 

information concerning the Commission 

may also be obtained by accessing its 

Internet server at http://www.usitc.gov. 

The public record for this investigation 

may be viewed on the Commission’s 

electronic docket (EDIS) at http:// 

edis.usitc.gov. Hearing-impaired 

persons are advised that information on 

this matter can be obtained by 

contacting the Commission’s TDD 

terminal on (202) 205–1810. 

SUPPLEMENTARY INFORMATION: On May 

28, 2008, the Commission instituted an 

investigation under section 337 of the 

Tariff Act of 1930, 19 U.S.C. 1337, based 

on a complaint filed by Tessera, Inc. of 

San Jose, California (‘‘Tessera’’), alleging 

a violation of section 337 in the 

importation, sale for importation, and 

sale within the United States after 

importation of certain semiconductor 

chips with minimized chip package size 

and products containing same that 

infringe certain claims of U.S. Patents 

Nos. 5,852,326; 6,433,419; and 

5,679,977. 73 FR 30628 (May 28, 2008). 

The complainant named as respondents 

Siliconware Precision Industries Co, 

Ltd. of Tachung, Taiwan and 

Siliconware U.S.A., Inc. of San Jose, 

California (collectively ‘‘Siliconware’’); 

ChipMOS Technologies (Bermuda) Ltd. 

of Hsinchu, Taiwan and ChipMOS 

U.S.A., Inc. of San Jose, California 

(collectively ‘‘ChipMOS’’); ASE, Inc. of 

Kaohsiung, Taiwan, ASE Test Limited 

of Kaohsiung, Taiwan, and ASE (U.S.), 

Inc. of Santa Clara, California 

(collectively ‘‘ASE’’); and STATS 

ChipPAC Ltd. of Techpoint, Singapore, 

STATS ChipPAC (BVI) Limited of 

Tortola, British Virgin Islands, and 

STATS ChipPAC, Inc. of Freemont, 

California (collectively ‘‘STATS’’). 

On October 8, 2008, Tessera filed an 

emergency motion to amend the 

Complaint and Notice of Investigation to 

add U.S. Patent No. 5,663,106. On 

October 20, 2008, Siliconware and 

ChipMOS filed a response opposing the 

motion, ASE filed a separate response 

opposing the motion, and STATS filed 

a response joining Siliconware and 

ChipMOS’s opposition. The 

Commission investigative attorney filed 

a response, also on October 20, 2008, in 

support of the motion. 

On October 29, 2008, the ALJ issued 

the subject ID, granting Tessera’s motion 

to amend the Complaint and Notice of 

Investigation, and extending the target 

date for completion of the investigation 

to December 7, 2009. No petitions for 

review of this ID were filed. 

The Commission has determined not 

to review the ID. 

The authority for the Commission’s 

determination is contained in section 

337 of the Tariff Act of 1930, as 

amended (19 U.S.C. 1337), and in 

section 210.42 of the Commission’s 

Rules of Practice and Procedure (19 CFR 

210.42). 

Issued: November 18, 2008. 

By order of the Commission. 

William R. Bishop, 

Acting Secretary to the Commission. 

[FR Doc. E8–27733 Filed 11–20–08; 8:45 am] 

BILLING CODE 7020–02–P 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation No. 731–TA–1145 (Final)] 

Certain Steel Threaded Rod From 

China 

AGENCY: United States International 

Trade Commission. 

ACTION: Scheduling of the final phase of 

an antidumping investigation. 

SUMMARY: The Commission hereby gives 

notice of the scheduling of the final 

phase of antidumping investigation No. 

731–TA–1145 (Final) under section 

735(b) of the Tariff Act of 1930 (19 

U.S.C. 1673d(b)) (the Act) to determine 

whether an industry in the United 

States is materially injured or 

threatened with material injury, or the 

establishment of an industry in the 

United States is materially retarded, by 

reason of less-than-fair-value imports 

from China of certain steel threaded rod, 

provided for in subheading 7318.15.50 

of the Harmonized Tariff Schedule of 

the United States.1

For further information concerning 

the conduct of this phase of the 

investigation, hearing procedures, and 

rules of general application, consult the 

Commission’s Rules of Practice and 

Procedure, part 201, subparts A through 

E (19 CFR part 201), and part 207, 

subparts A and C (19 CFR part 207). 

EFFECTIVE DATE: October 8, 2008. 

FOR FURTHER INFORMATION CONTACT: 

Joanna Lo (202–205–1888), Office of 

Investigations, U.S. International Trade 

Commission, 500 E Street, SW., 

Washington, DC 20436. Hearingimpaired persons can obtain 

information on this matter by contacting 

the Commission’s TDD terminal on 202– 

205–1810. Persons with mobility 

impairments who will need special 

assistance in gaining access to the 

Commission should contact the Office 

of the Secretary at 202–205–2000. 

General information concerning the 

Commission may also be obtained by 

accessing its Internet server (http:// 

www.usitc.gov). The public record for 

this investigation may be viewed on the 

Commission’s electronic docket (EDIS) 

at http://edis.usitc.gov. 

SUPPLEMENTARY INFORMATION: 

Background.—The final phase of this 

investigation is being scheduled as a 

result of an affirmative preliminary 

determination by the Department of 

Commerce that imports of certain steel 

threaded rod from China are being sold 

in the United States at less than fair 

value within the meaning of section 733 

of the Act (19 U.S.C. 1673b). The 

investigation was requested in a petition 

filed on March 5, 2008, by Vulcan 

Threaded Products, Inc., Pelham, AL. 

Participation in the investigation and 

public service list.—Persons, including 

industrial users of the subject 

merchandise and, if the merchandise is 

sold at the retail level, representative 

consumer organizations, wishing to 

participate in the final phase of this 

investigation as parties must file an 

entry of appearance with the Secretary 


dwashington3 on PRODPC61 with NOTICES
70672 Federal Register / Vol. 73, No. 226 / Friday, November 21, 2008 / Notices 

1Commerce defined the subject merchandise in 

its notice of preliminary determination (73 FR 

62952, October 22, 2008).

to the Commission, as provided in 

section 201.11 of the Commission’s 

rules, no later than 21 days prior to the 

hearing date specified in this notice. A 

party that filed a notice of appearance 

during the preliminary phase of the 

investigation need not file an additional 

notice of appearance during this final 

phase. The Secretary will maintain a 

public service list containing the names 

and addresses of all persons, or their 

representatives, who are parties to the 

investigation. 

Limited disclosure of business 

proprietary information (BPI) under an 

administrative protective order (APO) 

and BPI service list.—Pursuant to 

section 207.7(a) of the Commission’s 

rules, the Secretary will make BPI 

gathered in the final phase of this 

investigation available to authorized 

applicants under the APO issued in the 

investigation, provided that the 

application is made no later than 21 

days prior to the hearing date specified 

in this notice. Authorized applicants 

must represent interested parties, as 

defined by 19 U.S.C. 1677(9), who are 

parties to the investigation. A party 

granted access to BPI in the preliminary 

phase of the investigation need not 

reapply for such access. A separate 

service list will be maintained by the 

Secretary for those parties authorized to 

receive BPI under the APO. 

Staff report.—The prehearing staff 

report in the final phase of this 

investigation will be placed in the 

nonpublic record on February 5, 2009, 

and a public version will be issued 

thereafter, pursuant to section 207.22 of 

the Commission’s rules. 

Hearing.—The Commission will hold 

a hearing in connection with the final 

phase of this investigation beginning at 

9:30 a.m. on February 25, 2009, at the 

U.S. International Trade Commission 

Building. Requests to appear at the 

hearing should be filed in writing with 

the Secretary to the Commission on or 

before February 16, 2009. A nonparty 

who has testimony that may aid the 

Commission’s deliberations may request 

permission to present a short statement 

at the hearing. All parties and 

nonparties desiring to appear at the 

hearing and make oral presentations 

should attend a prehearing conference 

to be held at 9:30 a.m. on February 18, 

2009, at the U.S. International Trade 

Commission Building. Oral testimony 

and written materials to be submitted at 

the public hearing are governed by 

sections 201.6(b)(2), 201.13(f), and 

207.24 of the Commission’s rules. 

Parties must submit any request to 

present a portion of their hearing 

testimony in camera no later than 7 

business days prior to the date of the 

hearing. 

Written submissions.—Each party 

who is an interested party shall submit 

a prehearing brief to the Commission. 

Prehearing briefs must conform with the 

provisions of section 207.23 of the 

Commission’s rules; the deadline for 

filing is February 12, 2009. Parties may 

also file written testimony in connection 

with their presentation at the hearing, as 

provided in section 207.24 of the 

Commission’s rules, and posthearing 

briefs, which must conform with the 

provisions of section 207.25 of the 

Commission’s rules. The deadline for 

filing posthearing briefs is March 4, 

2009; witness testimony must be filed 

no later than three days before the 

hearing. In addition, any person who 

has not entered an appearance as a party 

to the investigation may submit a 

written statement of information 

pertinent to the subject of the 

investigation, including statements of 

support or opposition to the petition, on 

or before March 4, 2009. On March 18, 

2009, the Commission will make 

available to parties all information on 

which they have not had an opportunity 

to comment. Parties may submit final 

comments on this information on or 

before March 20, 2009, but such final 

comments must not contain new factual 

information and must otherwise comply 

with section 207.30 of the Commission’s 

rules. All written submissions must 

conform with the provisions of section 

201.8 of the Commission’s rules; any 

submissions that contain BPI must also 

conform with the requirements of 

sections 201.6, 207.3, and 207.7 of the 

Commission’s rules. The Commission’s 

rules do not authorize filing of 

submissions with the Secretary by 

facsimile or electronic means, except to 

the extent permitted by section 201.8 of 

the Commission’s rules, as amended, 67 

FR 68036 (November 8, 2002). Even 

where electronic filing of a document is 

permitted, certain documents must also 

be filed in paper form, as specified in II 

(C) of the Commission’s Handbook on 

Electronic Filing Procedures, 67 FR 

68168, 68173 (November 8, 2002). 

Additional written submissions to the 

Commission, including requests 

pursuant to section 201.12 of the 

Commission’s rules, shall not be 

accepted unless good cause is shown for 

accepting such submissions, or unless 

the submission is pursuant to a specific 

request by a Commissioner or 

Commission staff. 

In accordance with sections 201.16(c) 

and 207.3 of the Commission’s rules, 

each document filed by a party to the 

investigation must be served on all other 

parties to the investigation (as identified 

by either the public or BPI service list), 

and a certificate of service must be 

timely filed. The Secretary will not 

accept a document for filing without a 

certificate of service. 

Authority: This investigation is being 

conducted under authority of title VII of the 

Tariff Act of 1930; this notice is published 

pursuant to section 207.21 of the 

Commission’s rules. 

Issued: November 18, 2008. 

By order of the Commission. 

William R. Bishop, 

Acting Secretary to the Commission. 

[FR Doc. E8–27750 Filed 11–20–08; 8:45 am] 

BILLING CODE 7020–02–P 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation No. 731–TA–1148 (Final)] 

Frontseating Valves From China 

AGENCY: United States International 

Trade Commission. 

ACTION: Scheduling of the final phase of 

an antidumping investigation. 
Federal Register / Vol. 74, No. 38 / Friday, February 27, 2009 / Notices 8907 

1 In the Amended Preliminary Determination, the 

Department amended the Preliminary 

Determination to correct certain ministerial errors 

with respect to the antidumping duty margin 

calculation for RMB Fasteners Ltd. and IFI and 

Morgan Ltd. 2See Memorandum to the File from Scot T. 

Fullerton, Program Manager, and Toni Dach, 

International Trade Compliance Analyst, regarding: 

‘‘Verification of the Sales Response of RMB 

Fasteners Ltd. and IFI & Morgan Ltd. in the 

Antidumping Duty Investigation of Certain Steel 

Threaded Rod from the People’s Republic of 

China,’’ dated January 6, 2009 (‘‘RMB & IFI 

Verification Report’’). 

3See Memorandum to the File from Scot T. 

Fullerton, Program Manager, and Toni Dach, 

International Trade Compliance Analyst, regarding: 

‘‘Verification of the Factors of Production Response 

of Jiaxing Brother Standard Part Co. in the 

Antidumping Duty Investigation of Certain Steel 

Threaded Rod from the People’s Republic of 

China,’’ dated January 6, 2009 (‘‘Brother Fastener 

Verification Report’’). 

4See Memorandum to the File from Scot T. 

Fullerton, Program Manager, and Toni Dach, 

International Trade Compliance Analyst, regarding: 

‘‘Verification of the Sales Response of Ningbo 

Yinzhou Foreign Trade Co., Ltd. in the 

Antidumping Duty Investigation of Certain Steel 

Threaded Rod from the People’s Republic of 

China,’’ dated January 6, 2009 (‘‘Ningbo Yinzhou 

Verification Report’’). 

5See Memorandum to the File from Scot T. 

Fullerton, Program Manager, and Toni Dach, 

International Trade Compliance Analyst, regarding: 

‘‘Verification of the Factors of Production Response 

of Haiyan Zhonguan Fastener Factory and Zhejiang 

Guorui Industry Co., Ltd. in the Antidumping Duty 

Investigation of Certain Steel Threaded Rod from 

the People’s Republic of China,’’ dated January 6, 

2009 (‘‘Zhonghuan & Guorui Verification Report’’). 

6See Memorandum to the File from Scot T. 

Fullerton, Program Manager, and Toni Dach, 

International Trade Compliance Analyst, regarding: 

‘‘Verification of the Separate Rate Response of 

Shanghai Prime Machinery Co., Ltd. in the 

Antidumping Duty Investigation of Certain Steel 

Threaded Rod from the People’s Republic of 

China,’’ dated January 6, 2009 (‘‘Shanghai Prime 

Separate Rate Verification Report’’). 

Dated: February 20, 2009. 

John M. Andersen, 

Acting Deputy Assistant Secretary for Import 

Administration. 

[FR Doc. E9–4244 Filed 2–26–09; 8:45 am] 

BILLING CODE 3510–DS–S 

DEPARTMENT OF COMMERCE 

International Trade Administration 

(A–570–932) 

Certain Steel Threaded Rod from the 

People’s Republic of China: Final 

Determination of Sales at Less Than 

Fair Value 

AGENCY: Import Administration, 

International Trade Administration, 

Department of Commerce. 

EFFECTIVE DATE: February 27, 2009. 

SUMMARY: The Department of Commerce 

(‘‘Department’’) has determined that 

certain steel threaded rod (‘‘STR’’) from 

the People’s Republic of China (‘‘PRC’’) 

is being, or is likely to be, sold in the 

United States at less than fair value 

(‘‘LTFV’’) as provided in section 735 of 

the Tariff Act of 1930, as amended 

(‘‘Act’’). The final dumping margins for 

this investigation are listed in the ‘‘Final 

Determination Margins’’ section below. 

FOR FURTHER INFORMATION CONTACT: 

Bobby Wong or Toni Dach, Import 

Administration, International Trade 

Administration, U.S. Department of 

Commerce, 14th Street and Constitution 

Avenue, NW, Washington, DC 20230; 

telephone (202) 482–0409 or (202) 482– 

1655, respectively. 

SUPPLEMENTARY INFORMATION: 

Case History 

On October 8, 2008, the Department 

published in the Federal Register its 

preliminary determination. See Certain 

Steel Threaded Rod from the People’s 

Republic of China: Preliminary 

Determination of Sales at Less Than 

Fair Value, 73 FR 58931 (October 8, 

2008) (‘‘Preliminary Determination’’). 

On October 27, 2008, the Department 

published in the Federal Register its 

amended preliminary determination 

that STR from the PRC are being, or are 

likely to be, sold in the United States at 

LTFV. See Certain Steel Threaded Rod 

from the People’s Republic of China: 

Amended Preliminary Determination of 

Sales at Less Than Fair Value and 

Postponement of Final Determination, 

73 FR 63693 (October 27, 2008) 

(‘‘Amended Preliminary 

Determination’’).1 As provided in 

section 782(i) of the Act, we verified the 

information submitted by: 1) RMB 

Fasteners Ltd. and IFI & Morgan Ltd.2

(the ‘‘RMB/IFI Group’’) from November 

3–4, 2008, and Jiaxing Brother Standard 

Part Co.3 (‘‘Jiaxing Brother’’), its 

affiliated producer from November 6–7, 

2008; 2) Ningbo Yinzhou Foreign Trade 

Co., Ltd.4 (‘‘Ningbo Yinzhou’’) from 

November 13–14, 2008, and Haiyan 

Zhonghuan Fastener Factory 

(‘‘Zhonghuan’’), one of Ningbo 

Yingzhou’s manufacturers, and Zhejiang 

Guorui Industry Co., Ltd.5 (‘‘Guorui’’), 

one of Ningbo Yinzhou’s suppliers from 

November 10–12, 2008; and 3) Shanghai 

Prime Machinery Co., Ltd.6 (‘‘Shanghai 

Prime’’), a separate rate respondent, on 

November 17, 2008. On December 12, 

2008, Vulcan Threaded Products 

(‘‘Petitioner’’) and the RMB/IFI Group 

placed new factual information on the 

record regarding surrogate valuation, 

and submitted rebuttal comments on 

December 22, 2008. In accordance with 

19 CFR 351.309(c)(i), we invited parties 

to comment on our Preliminary 

Determination. On January 16, 2009, the 

Department received case briefs from 

the RMB/IFI Group, Ningbo Yinzhou, 

and Petitioner. On January 23, 2009, we 

received rebuttal briefs from Petitioner 

and the RMB/IFI Group. On November 

6 and 7, 2008, Petitioner and the RMB/ 

IFI Group submitted requests for a 

hearing, respectively. On January 22, 

2009, Petitioner and the RMB/IFI Group 

withdrew their requests for a hearing. 

Analysis of Comments Received 

All issues raised in the case and 

rebuttal briefs by the parties to this 

investigation are addressed in the 

‘‘Certain Steel Threaded Rod from the 

People’s Republic of China: Issues and 

Decision Memorandum for the Final 

Determination of Sales at Less than Fair 

Value,’’ dated concurrently with this 

notice, which is hereby adopted by this 

notice in its entirety (‘‘Issues and 

Decision Memorandum’’). A list of the 

issues which parties raised and to 

which we respond in the Issues and 

Decision Memorandum is attached to 

this notice as an Appendix. The Issues 

and Decision Memorandum is a public 

document and is on file in the Central 

Records Unit in the main Commerce 

building, Room 1117, and is accessible 

on the Web at http://www.trade.gov/ia. 

The paper copy and electronic version 

of the Issues and Decision 

Memorandum are identical in content. 

Period of Investigation 

The period of investigation (‘‘POI’’) is 

July 1, 2007, through December 31, 

2007. 

Scope of Investigation 

The merchandise covered by this 

investigation is steel threaded rod. Steel 

threaded rod is certain threaded rod, 

bar, or studs, of carbon quality steel, 

having a solid, circular cross section, of 

any diameter, in any straight length, that 

have been forged, turned, cold drawn, 

cold rolled, machine straightened, or 

otherwise cold finished, and into which 

threaded grooves have been applied. In 

addition, the steel threaded rod, bar, or 

studs subject to this investigation are 

non headed and threaded along greater 

than 25 percent of their total length. A 

variety of finishes or coatings, such as 

plain oil finish as a temporary rust 

protectant, zinc coating (i.e., galvanized, 

whether by electroplating or hot– 

dipping), paint, and other similar 

finishes and coatings, may be applied to 

the merchandise. 

Included in the scope of this 

investigation are steel threaded rod, bar, 

or studs, in which: (1) iron 

predominates, by weight, over each of 

the other contained elements; (2) the 

carbon content is 2 percent or less, by 

weight; and (3) none of the elements 


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7For example, the Department specifically asked 

Ningbo Yinzhou in its August 21, 2008, 

supplemental questionnaire whether any FOPs 

other than those reported were consumed by 

Zhonghuan in production of the subject 

merchandise. Ningbo Yinzhou reported in its 

September 8, 2008, response that all factors 

consumed by Zhonghuan in the production of the 

subject merchandise were reported. We discovered 

at verification that this statement was not correct, 

and unreported factors were consumed in the 

production of the subject merchandise. 

Additionally, Ningbo Yinzhou provided a sales 

reconciliation to the Department on August 8, 2008, 

that they claimed reconciled its U.S. sales database 

to its financial statements. At verification, we 

discovered that the sales reconciliation did not tie 

the U.S. sales database to Ningbo Yinzhou’s 

financial statements. For additional information 

and examples of situations where verification 

findings contradicted Ningbo Yinzhou’s 

questionnaire responses, see Issues and Decision 

Memorandum at Comment 5. 

listed below exceeds the quantity, by 

weight, respectively indicated: 

• 1.80 percent of manganese, or 

• 1.50 percent of silicon, or 

• 1.00 percent of copper, or 

• 0.50 percent of aluminum, or 

• 1.25 percent of chromium, or 

• 0.30 percent of cobalt, or 

• 0.40 percent of lead, or 

• 1.25 percent of nickel, or 

• 0.30 percent of tungsten, or 

• 0.012 percent of boron, or 

• 0.10 percent of molybdenum, or 

• 0.10 percent of niobium, or 

• 0.41 percent of titanium, or 

• 0.15 percent of vanadium, or 

• 0.15 percent of zirconium. 

Steel threaded rod is currently 

classifiable under subheading 

7318.15.5050 and 7318.15.5090 of the 

HTSUS. Although the HTSUS 

subheading is provided for convenience 

and customs purposes, the written 

description of the merchandise is 

dispositive. 

Excluded from the scope of the 

investigation are: (a) threaded rod, bar, 

or studs which are threaded only on one 

or both ends and the threading covers 

25 percent or less of the total length; 

and (b) threaded rod, bar, or studs made 

to American Society for Testing and 

Materials (‘‘ASTM’’) A193 Grade B7, 

ASTM A193 Grade B7M, ASTM A193 

Grade B16, or ASTM A320 Grade L7. 

Scope–HTSUS Modification 

On September 22, 2008, U.S. Customs 

and Border Protection (‘‘CBP’’) informed 

the Department that on July 1, 2008, it 

amended the United States Harmonized 

Tariff Schedule (‘‘HTSUS’’) category 

7318.15.5060, and replaced the category 

with two new HTSUS categories: 

7318.15.5050 and 7318.15.5090. 

Therefore, the Department has modified 

the scope to reflect the new HTSUS 

categories. 

Changes Since the Preliminary 

Determination 

Based on our findings at verification, 

and additional information placed on 

the record of this investigation, we have 

made changes since the Amended 

Preliminary Determination. As 

discussed further below, we have 

applied total adverse facts available 

(‘‘AFA’’) to Ningbo Yinzhou for 

purposes of this final determination. See 

Issues and Decision Memorandum at 

Comment 5. 

Based on our analysis of information 

on the record of this investigation, and 

comments received from the interested 

parties, we have made changes to the 

margin calculations for the RMB/IFI 

Group. We have revalued certain 

surrogate values used in the Amended 

Preliminary Determination. The values 

that were modified for this final 

determination are those for surrogate 

financial ratios, packing strips, buckles, 

and coal. For further details see I&D 

Memo at Comment 6, and Memorandum 

to the File from Bobby Wong, through 

Scot T. Fullerton, Program Manager, 

AD/CVD Operations, Office 9, and 

James C. Doyle, Director, AD/CVD 

Operations, Office 9; Certain Steel 

Threaded Rod from the People’s 

Republic of China: Surrogate Values for 

the Final Determination, dated February 

20, 2009 (‘‘Final Surrogate Value 

Memo’’). 

In addition, we have made certain 

company–specific changes since the 

Amended Preliminary Determination. 

Specifically, we have incorporated, 

where applicable, post–preliminary 

clarifications based on a post– 

preliminary supplemental questionnaire 

and verification for the RMB/IFI Group. 

For further details on these company– 

specific changes, see Memorandum to 

the File, through Scot T. Fullerton, 

Program Manager, AD/CVD Operations, 

Office 9, from Bobby Wong, Senior 

International Trade Analyst, AD/CVD 

Operations, Office 9, regarding 

‘‘Program Analysis for the Final 

Determination of Antidumping Duty 

Investigation of Certain Steel Threaded 

Rod from the People’s Republic of 

China,’’ dated February 20, 2009 (‘‘The 

RMB/IFI Group Analysis 

Memorandum’’). 

Adverse Facts Available 

Section 776(a)(2) of the Act provides 

that the Department shall apply ‘‘facts 

otherwise available’’ if, inter alia, an 

interested party or any other person (A) 

withholds information that has been 

requested, (B) fails to provide 

information within the deadlines 

established, or in the form or manner 

requested by the Department, subject to 

subsections (c)(1) and (e) of section 782 

of the Act, (C) significantly impedes a 

proceeding, or (D) provides information 

that cannot be verified as provided by 

section 782(i) of the Act. Section 776(b) 

of the Act provides further that the 

Department may use an adverse 

inference when a party has failed to 

cooperate by not acting to the best of its 

ability to comply with a request for 

information. 

Pursuant to sections 776(a)(2)(A), (B), 

(C), and (D) of the Act, we are applying 

facts otherwise available to Ningbo 

Yinzhou because it withheld certain 

information that had been requested by 

the Department which significantly 

impeded the Department’s investigation. 

Ningbo Yinzhou failed to provide 

information regarding certain factors of 

production (‘‘FOP’’) in the form and 

manner requested by the Department. 

Ningbo Yinzhou withheld certain 

information that was specifically 

requested by the Department and 

significantly impeded the proceeding by 

not providing accurate or complete 

responses to the Department’s questions 

regarding certain FOPs and the sales 

reconciliation. See Verification of the 

Sales Response of Ningbo Yinzhou 

Foreign Trade Co., Ltd. in the 

Antidumping Duty Investigation of 

Certain Steel Threaded Rod from the 

People’s Republic of China, dated 

January 6, 2009 at 2, 6–8, and 10–11; 

and Ningbo Yinzhou’s response to the 

Department’s First Supplemental 

Sections C and D Questionnaire, dated 

September 8, 2008, at 19. Additionally, 

information discovered at verification 

directly contradicted information 

contained in Ningbo Yinzhou’s 

questionnaire responses.7 Significant 

delays were experienced by the 

Department in completing verification 

procedures, which prevented the 

completion of some verification 

procedures. Due to the insufficiency of 

the respondent’s record keeping, 

numerous verification procedures could 

not be completed. For these reasons, the 

Department was unable to verify certain 

statements in Ningbo Yinzhou’s 

questionnaire responses for which the 

Department sought verification. See 

Ningbo Yinzhou Verification Report and 

Zhonghuan/Guorui Verification Report. 

Furthermore, based on the record 

evidence and pursuant to section 776(b) 

of the Act, the Department has 

determined that Ningbo Yinzhou did 

not cooperate to the best of its ability to 

comply with the Department’s requests 

for information. In particular, the 

Department gave specific instructions in 

our questionnaires and the verification 

outline as to the purpose of and 

directions for submission and 


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verification of the reconciliation of 

Ningbo Yinzhou’s U.S. sales database to 

Ningbo Yinzhou’s accounting records, 

and proper reporting of all FOPs for all 

models. Despite these extensive 

instructions, provided numerous times 

over the course of the investigation, 

Ningbo Yinzhou failed to provide the 

Department with adequate information 

and supporting documentation to fully 

verify its responses to the Department’s 

questionnaires. In addition, despite 

multiple opportunities presented by the 

Department, Ningbo Yinzhou failed to 

report certain FOPs and failed to report 

FOPs for each model in the U.S. sales 

database. For a detailed description of 

each of the deficiencies, see Issues and 

Decision Memorandum at Comment 5. 

Surrogate Country 

In the Preliminary Determination and 

unchanged in the Amended Preliminary 

Determination, we stated that we had 

selected India as the appropriate 

surrogate country to use in this 

investigation for the following reasons: 

(1) it is a significant producer of 

comparable merchandise; (2) it is at a 

level of economic development 

comparable to that of the PRC; and (3) 

we have reliable data from India that we 

can use to value FOPs. See Preliminary 

Determination. We received no 

comments on our surrogate country 

selection. Accordingly, for the final 

determination, we made no changes to 

our finding with respect to the selection 

of India as a surrogate country. 

Separate Rates 

In proceedings involving non–market 

economy (‘‘NME’’) countries, the 

Department begins with a rebuttable 

presumption that all companies within 

the country are subject to government 

control and, thus, should be assigned a 

single antidumping duty deposit rate. It 

is the Department’s policy to assign all 

exporters of merchandise subject to an 

investigation in an NME country this 

single rate unless an exporter can 

demonstrate that it is sufficiently 

independent so as to be entitled to a 

separate rate. See Final Determination of 

Sales at Less Than Fair Value: Sparklers 

from the People’s Republic of China, 56 

FR 20588, 20589 (May 6, 1991), as 

amplified by Notice of Final 

Determination of Sales at Less Than 

Fair Value: Silicon Carbide from the 

People’s Republic of China, 59 FR at 

22585, 22587 (May 2, 1994), and 19 CFR 

351.107(d). 

In the Preliminary Determination and 

unchanged in the Amended Preliminary 

Determination, we found that Shanghai 

Recky, Suntec Industries, Hangzhou 

Grand, Shanghai Prime, Jianxing 

Xinyue, CPII, Jiashan Zhongsheng, 

Haiyan Dayu, and New Oriental 

(hereinafter referred to as ‘‘Separate Rate 

Companies’’), and Ningbo Yinzhou, a 

mandatory respondent, have provided 

company–specific information to 

demonstrate that they operate 

independently of de jure and de facto 

government control, and therefore 

satisfy the standards for the assignment 

of a separate rate. 

No party has commented on the 

eligibility of these companies for 

separate rate status. For the final 

determination, we continue to find that 

the evidence placed on the record of 

this investigation by these companies 

demonstrates both a de jure and de facto 

absence of government control with 

respect to their exports of the 

merchandise under investigation. Thus, 

we continue to find that they are eligible 

for separate rate status. Normally, the 

separate rate is determined based on the 

estimated weighted–average dumping 

margins established for exporters and 

producers individually investigated, 

excluding de minimis margins or 

margins based entirely on AFA. See 

section 735(c)(5)(A) of the Act. 

In the Preliminary Determination and 

unchanged in the Amended Preliminary 

Determination, the Department stated 

that it could not deny the RMB/IFI 

Group separate rate status because the 

Department did not ask specifically for 

information relating to the RMB/IFI 

Group’s separate rate eligibility. 

However, subsequent to the Preliminary 

Determination, on October 22, 2008, in 

response to the Department’s inquiry, 

the RMB/IFI Group reported that it is a 

wholly foreign–owned company, and at 

verification the Department found no 

discrepancies in the RMB/IFI Group’s 

responses to the Department’s separate 

rate questions. As the RMB/IFI Group is 

wholly foreign–owned, a separate rate 

analysis is not necessary to determine 

whether it is independent from 

government control. See Notice of Final 

Determination of Sales at Less Than 

Fair Value: Creatine Monohydrate From 

the People’s Republic of China, 64 FR 

71104, 71105 (December 20, 1999) (the 

respondent was wholly foreign–owned, 

and thus, qualified for a separate rate). 

Consequently, for the final 

determination we find that the evidence 

placed on the record of this 

investigation by the RMB/IFI Group 

demonstrates that it is eligible for a 

separate rate. 

In the Preliminary Determination and 

unchanged in the Amended Preliminary 

Determination, the Department assigned 

to nine exporter/producer combinations 

that qualified for a separate rate a 

weighted–average margin based on the 

experience of the mandatory 

respondents, excluding any de minimis 

or zero rates or rates based on total AFA. 

See Preliminary Determination. For the 

final determination, because the 

Department based the rate for Ningbo 

Yinzhou on total AFA, the Department 

has applied the RMB/IFI Group’s 

calculated rate for purposes of 

establishing a separate rate. See section 

735(c)(5)(A) of the Act. Therefore, the 

Department will assign the RMB/IFI 

Group’s calculated rate as the separate 

rate for the nine exporter/producer 

combinations. This rate is corroborated, 

to the extent practicable, for the reasons 

stated below. See ‘‘Corroboration’’ 

section below. 

The PRC–Wide Rate 

In the Preliminary Determination and 

unchanged in the Amended Preliminary 

Determination, the Department found 

that certain companies did not respond 

to our requests for information. See 

Preliminary Determination, 73 FR at 

58936. In the Preliminary Determination 

we treated these PRC producers/ 

exporters as part of the PRC–wide entity 

because they did not demonstrate that 

they operate free of government control 

over their export activities. Because 

these producers/exporters did not 

provide information regarding their 

export activities, the Department has 

determined that application of facts 

available (‘‘FA’’) is warranted. No 

additional information was placed on 

the record with respect to these 

companies after the Preliminary 

Determination. Therefore, pursuant to 

section 776(a)(2)(A) of the Act, the 

Department continues to find that the 

use of FA is appropriate to determine 

the PRC–wide rate. 

Section 776(b) of the Act provides 

that, in selecting from among the facts 

otherwise available, the Department 

may employ an adverse inference if an 

interested party fails to cooperate by not 

acting to the best of its ability to comply 

with requests for information. See 

Notice of Final Determination of Sales 

at Less Than Fair Value: Certain Cold– 

Rolled Flat–Rolled Carbon–Quality Steel 

Products From the Russian Federation, 

65 FR 5510, 5518 (February 4, 2000). 

See also Statement of Administrative 

Action accompanying the URAA, H.R. 

Rep. No. 103–316, vol. 1, at 870 (1994) 

(‘‘SAA’’). We determined that, because 

the PRC–wide entity did not respond to 

our request for information, it has failed 

to cooperate to the best of its ability. 

Therefore, the Department finds that, in 

selecting from among the facts 

otherwise available, an adverse 

inference is appropriate for the PRC– 

wide entity. 


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Because we begin with the 

presumption that all companies within 

an NME country are subject to 

government control and because only 

the companies listed under the ‘‘Final 

Determination Margins’’ section below 

have overcome that presumption, we are 

applying a single antidumping rate (i.e., 

the PRC–wide entity rate) to all other 

exporters of subject merchandise from 

the PRC. Such companies did not 

demonstrate entitlement to a separate 

rate. See, e.g., Synthetic Indigo From the 

People’s Republic of China; Notice of 

Final Determination of Sales at Less 

Than Fair Value, 65 FR 25706 (May 3, 

2000). The PRC–wide entity rate applies 

to all entries of subject merchandise 

except for entries from the respondents 

which are listed in the ‘‘Final 

Determination Margins’’ section below. 

In the Preliminary Determination and 

unchanged in the Amended Preliminary 

Determination, we assigned to the PRC– 

wide entity the highest rate calculated 

from the petition, 206.00 percent. See 

Preliminary Determination, 73 FR at 

58936. We received no comments on 

this rate. Therefore, for the final 

determination, we have continued to 

assign to the PRC–wide entity the rate 

of 206.00 percent. 

Corroboration 

Section 776(c) of the Act provides 

that, when the Department relies on 

secondary information in using the facts 

otherwise available, it must, to the 

extent practicable, corroborate that 

information from independent sources 

that are reasonably at its disposal. We 

have interpreted ‘‘corroborate’’ to mean 

that we will, to the extent practicable, 

examine the reliability and relevance of 

the information submitted. See Tapered 

Roller Bearings and Parts Thereof, 

Finished and Unfinished, From Japan, 

and Tapered Roller Bearings, Four 

Inches or Less in Outside Diameter, and 

Components Thereof, From Japan; 

Preliminary Results of Antidumping 

Duty Administrative Reviews and 

Partial Termination of Administrative 

Reviews, 61 FR 57391, 57392 (November 

6, 1996), unchanged in Notice of Final 

Determination of Sales at Less Than 

Fair Value: Certain Cold–Rolled Flat– 

Rolled Carbon–Quality Steel Products 

From Brazil, 65 FR 5554, 5568 (February 

4, 2000); see, e.g., Tapered Roller 

Bearings and Parts Thereof, Finished 

and Unfinished, From Japan, and 

Tapered Roller Bearings, Four Inches or 

Less in Outside Diameter, and 

Components Thereof, From Japan; Final 

Results of Antidumping Duty 

Administrative Reviews and 

Termination in Part, 62 FR 11825 

(March 13, 1997). 

To corroborate the AFA margin we 

have selected, we compared that margin 

to the margins calculated for the RMB/ 

IFI Group. We found that the margin of 

206.00 percent has probative value 

because it is in the range of margins 

calculated for the RMB/IFI Group. See 

October 1, 2008, Memorandum to the 

File, From Bobby Wong, Through Scot 

T. Fullerton, regarding: Antidumping 

Duty Investigation of Certain Steel 

Threaded Rod from the People’s 

Republic of China: RMB/IFI Program 

Analysis for the Preliminary 

Determination, at 1. Accordingly, we 

find that the rate of 206.00 percent is 

corroborated within the meaning of 

section 776(c) of the Act. 

Combination Rates 

In the Preliminary Determination, the 

Department stated that it would 

calculate combination rates for the 

respondents that are eligible for a 

separate rate in this investigation. See 

Preliminary Determination, 73 FR at 

58931. This change in practice is 

described in Policy Bulletin 05.1, 

available at http://ia.ita.doc.gov/. Policy 

Bulletin 05.1, states: 

{w}hile continuing the practice of 

assigning separate rates only to 

exporters, all separate rates that the 

Department will now assign in its 

NME investigations will be specific 

to those producers that supplied the 

exporter during the period of 

investigation. Note, however, that 

one rate is calculated for the 

exporter and all of the producers 

which supplied subject 

merchandise to it during the period 

of investigation. This practice 

applies both to mandatory 

respondents receiving an 

individually calculated separate 

rate as well as the pool of non– 

investigated firms receiving the 

weighted–average of the 

individually calculated rates. This 

practice is referred to as the 

application of ‘‘combination rates’’ 

because such rates apply to specific 

combinations of exporters and one 

or more producers. The cash– 

deposit rate assigned to an exporter 

will apply only to merchandise 

both exported by the firm in 

question and produced by a firm 

that supplied the exporter during 

the period of investigation. 

See Policy Bulletin 05.1, ‘‘Separate 

Rates Practice and Application of 

Combination Rates in Antidumping 

Investigations Involving Non–Market 

Economy Countries.’’ 

Final Determination Margins 

We determine that the following 

percentage weighted–average margins 

exist for the POI: 

CERTAIN STEEL THREADED ROD FROM THE PRC 

Exporter Producer Weighted–Average 

Margin 

RMB Fasteners Ltd., and IFI & Morgan Ltd. (‘‘RMB/IFI Group’’) Jiaxing Brother Fastener Co., Ltd. (aka Jiaxing Brother 

Standard Parts Co., Ltd.) 

55.16 

Ningbo Yinzhou Foreign Trade Co. Ltd. ..................................... Zhejiang Guorui Industry Co., Ltd.; or Ningbo Daxie 

Chuofeng Industrial Development Co. Ltd. 

206.00% 

Separate Rates Entities: Exporter Producer Margin 

Shanghai Recky International Trading Co., Ltd. ......................... Shanghai Xiangrong International Trading Co., Ltd.; 

Shanghai Xianglong International Trading Co., Ltd.; 

Pighu City Zhapu Screw Cap Factory; or Jiaxing Xinyue 

Standard Part Co., Ltd. 

55.16 

Suntec Industries Co., Ltd. .......................................................... Jiaxing Xinyue Standard Part Co., Ltd.; or Haiyan 

County No. 1 Fasteners Factory 

55.16 

Hangzhou Grand Imp. & Exp. Co., Ltd. ...................................... Zhapu Creative Standard Parts Material Co., Ltd. 55.16 

Shanghai Prime Machinery Co. Ltd. ........................................... Haiyan Yida Fasteners Co., Ltd.; or Jiaxing Xinyue 

Standard Part Co., Ltd. 

55.16 

Jiaxing Xinyue Standard Part Co., Ltd. ....................................... Jiaxing Xinyue Standard Part Co., Ltd. 55.16 


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Separate Rates Entities: Exporter Producer Margin 

Certified Products International Inc. ............................................ Jiashan Zhongsheng Metal Products Co., Ltd.; or Jiaxing 

Xinyue Standard Part Co., Ltd. 

55.16 

Zhejiang New Oriental Fastener Co., Ltd. ................................... Zhejiang New Oriental Fastener Co., Ltd. 55.16 

Jiashan Zhongsheng Metal Products Co., Ltd. ........................... Jiashan Zhongsheng Metal Products Co., Ltd. 55.16 

Haiyan Dayu Fasteners Co., Ltd. ................................................ Haiyan Dayu Fasteners Co., Ltd. 55.16 

PRC–wide Entity .......................................................................... ............................................................................................ 206.00% 

Disclosure 

We will disclose the calculations 

performed within five days of the date 

of publication of this notice to parties in 

this proceeding in accordance with 19 

CFR 351.224(b). 

Continuation of Suspension of 

Liquidation 

We will instruct U.S. Customs and 

Border Protection (‘‘CBP’’) to continue 

the suspension of liquidation required 

by section 735(c)(1)(B) of the Act, of all 

entries of subject merchandise from the 

RMB/IFI Group, Ningbo Yinzhou, the 

Separate Rate Companies, and the PRC– 

wide entity entered, or withdrawn from 

warehouse, for consumption on or after 

October 8, 2008, the date of publication 

of the Preliminary Determination. CBP 

shall continue to require a cash deposit 

or the posting of a bond equal to the 

estimated amount by which the NV 

exceeds the U.S. price as shown above. 

See section 735(c)(1)(B)(ii) of the Act. 

The suspension of liquidation 

instructions will remain in effect until 

further notice. 

International Trade Commission 

Notification 

In accordance with section 735(d) of 

the Act, we have notified the 

International Trade Commission (‘‘ITC’’) 

of our final determination of sales at 

LTFV. As our final determination is 

affirmative, in accordance with section 

735(b)(2) of the Act, within 45 days the 

ITC will determine whether the 

domestic industry in the United States 

is materially injured, or threatened with 

material injury, by reason of imports or 

sales (or the likelihood of sales) for 

importation of the subject merchandise. 

If the ITC determines that material 

injury or threat of material injury does 

not exist, the proceeding will be 

terminated and all securities posted will 

be refunded or canceled. If the ITC 

determines that such injury does exist, 

the Department will issue an 

antidumping duty order directing CBP 

to assess, upon further instruction by 

the Department, antidumping duties on 

all imports of the subject merchandise 

entered, or withdrawn from warehouse, 

for consumption on or after the effective 

date of the suspension of liquidation. 

Notification Regarding APO 

This notice also serves as a reminder 

to the parties subject to administrative 

protective order (‘‘APO’’) of their 

responsibility concerning the 

disposition of proprietary information 

disclosed under APO in accordance 

with 19 CFR 351.305. Timely 

notification of return or destruction of 

APO materials or conversion to judicial 

protective order is hereby requested. 

Failure to comply with the regulations 

and the terms of an APO is a 

sanctionable violation. 

This determination is issued and 

published in accordance with sections 

735(d) and 777(i)(1) of the Act. 

Dated: February 20, 2009. 

Ronald K. Lorentzen, 

Acting Assistant Secretary for Import 

Administration. 

Appendix 

I. General Issues: 

Comment 1: Surrogate Financial Ratios 

Comment 2: Treatment of Drawing 

Power as a Direct Material Input 

Comment 3: Wire Rod & Round Bar 

Comment 4: Hydrochloric Acid and 

Trisodium Phosphate 

II. Ningbo Yinzhou Issues 

Comment 5: Application of Facts 

Available for Ningbo Yinzhou 

Comment 6: Ningbo Yinzhou and 

Zhonghuan/Guorui Verification Report 

Comment 7: Surrogate Value Selection 

Galvanizing Surrogate Value 

III. RMB/IFI Issues 

Comment 8: Surrogate Values Packing 

Strips, Buckles, and Coal 

Comment 9: Limits to By–Product Offset 

Comment 10: Minor Corrections for the 

RMB/IFI Group 

[FR Doc. E9–4248 Filed 2–26–09; 8:45 am] 

BILLING CODE 3510–DS–S 

DEPARTMENT OF COMMERCE 

National Institute of Standards and 

Technology 

Advisory Committee on Earthquake 

Hazards Reduction Meeting 

AGENCY: National Institute of Standards 

and Technology, Department of 

Commerce. 

ACTION: Notice of open meeting. 

SUMMARY: The Advisory Committee on 

Earthquake Hazards Reduction (ACEHR 

or Committee), will hold a meeting on 

Wednesday, March 25, 2009 from 2 p.m. 

to 4 p.m. Eastern Standard Time (EST). 

The primary purpose of this meeting is 

to review and finalize the Committee’s 

draft reauthorization letter to the 

Interagency Coordinating Committee 

(ICC). The draft letter will be posted on 

the NEHRP Web site at 

http://nehrp.gov/. Interested members of 

the public will be able to participate in 

the meeting from remote locations by 

calling into a central phone number. 

DATES: The ACEHR will hold a meeting 

on Wednesday, March 25, 2009, from 2 

p.m. until 4 p.m. Eastern Standard Time 

(EST). The meeting will be open to the 

public. Interested parties may 

participate in the meeting from their 

remote location. 

ADDRESSES: Questions regarding the 

meeting should be sent to National 

Earthquake Hazards Reduction Program 

Director, National Institute of Standards 

and Technology, 100 Bureau Drive, Mail 

Stop 8630, Gaithersburg, Maryland 

20899–8630. For instructions on how to 

participate in the meeting, please see 

the SUPPLEMENTARY INFORMATION section 

of this notice. 

FOR FURTHER INFORMATION CONTACT: Dr. 

Jack Hayes, National Earthquake 

Hazards Reduction Program Director, 

National Institute of Standards and 

Technology, 100 Bureau Drive, Mail 

Stop 8630, Gaithersburg, Maryland 

20899–8630. Dr. Hayes’ e-mail address 

is jack.hayes@nist.gov and his phone 

number is (301) 975–5640. 

SUPPLEMENTARY INFORMATION: The 

Committee was established in 

accordance with the requirements of 

Section 103 of the NEHRP 

Reauthorization Act of 2004 (Pub. L. 


rwilkins on PROD1PC63 with NOTICES2

B-1

APPENDIX B

HEARING WITNESSES

B-3

CALENDAR OF PUBLIC HEARING

Those listed below appeared as witnesses at the United States International Trade

Commission’s hearing:

Subject: Certain Steel Threaded Rod from China

Inv. No.: 731-TA-1145 (Final)

Date and Time: February 25, 2009 - 9:30 a.m.

Sessions were held in connection with this investigation in the Main Hearing Room (room

101), 500 E Street, S.W., Washington, D.C.

In Support of the Imposition of Antidumping Duty Order:

Vorys, Sater, Seymour and Pease LLP

Washington, D.C.

on behalf of

Vulcan Threaded Products, Inc. (“Vulcan”)

William D. Upton, Jr., President, Vulcan

Alan D. Logan, Vice President, Operations, Vulcan

Gary Ostermueller, President and CEO, Watson Metal Products Corporation

Greg Iverson, President, Bay Standard Mfg., Inc.

Robert Rodgers, Vice President of Sales and Marketing, Bay Standard Mfg., Inc.

Dr. Patrick Magrath, Managing Director,

Georgetown Economic Consulting Services

Frederick P. Waite )

) – OF COUNSEL

Kimberly R. Young )
B-4

In Opposition to the Imposition of Antidumping Duty Order:

Kelly Hart & Hallman LLP

Fort Worth, TX

on behalf of

RIEX Co., LP (“RIEX”)

Robert Williams, Owner

John T. Wilson ) – OF COUNSEL
C-1

APPENDIX C

SUMMARY DATA

Table C-1

Threaded rod: Summary data concerning the U.S. market, 2005-07, January-September 2007, and January-September 2008

(Quantity=1,000 pounds, value=1,000 dollars, unit values, unit labor costs, and unit expenses are per pound; period changes=percent, except where noted)

Reported data Period changes

January-September Jan.-Sept.

Item 2005 2006 2007 2007 2008 2005-07 2005-06 2006-07 2007-08

U.S. consumption quantity:

 Amount . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Producers' share (1) . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Importers' share (1):

 China . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Other sources . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Total imports . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

U.S. consumption value:

 Amount . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Producers' share (1) . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Importers' share (1):

 China . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Other sources . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Total imports . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

U.S. shipments of imports from:

 China:

 Quantity . . . . . . . . . . . . . . . . . . 59,045 70,683 86,436 59,531 65,780 46.4 19.7 22.3 10.5

 Value . . . . . . . . . . . . . . . . . . . . 38,163 44,775 53,323 36,656 50,561 39.7 17.3 19.1 37.9

 Unit value . . . . . . . . . . . . . . . . . $0.65 $0.63 $0.62 $0.62 $0.77 -4.6 -2.0 -2.6 24.8

 Ending inventory quantity . . . . 21,856 21,295 21,678 20,790 23,410 -0.8 -2.6 1.8 12.6

 All other sources:

 Quantity . . . . . . . . . . . . . . . . . . 10,861 10,696 9,943 7,244 6,799 -8.5 -1.5 -7.0 -6.1

 Value . . . . . . . . . . . . . . . . . . . . 10,431 9,660 9,170 6,496 7,973 -12.1 -7.4 -5.1 22.7

 Unit value . . . . . . . . . . . . . . . . . $0.96 $0.90 $0.92 $0.90 $1.17 -4.0 -6.0 2.1 30.8

 Ending inventory quantity . . . . 854 586 378 55 2,107 -55.7 -31.4 -35.5 3730.9

 All sources:

 Quantity . . . . . . . . . . . . . . . . . . 69,906 81,379 96,379 66,775 72,579 37.9 16.4 18.4 8.7

 Value . . . . . . . . . . . . . . . . . . . . 48,593 54,435 62,493 43,152 58,534 28.6 12.0 14.8 35.6

 Unit value . . . . . . . . . . . . . . . . . $0.70 $0.67 $0.65 $0.65 $0.81 -6.7 -3.8 -3.1 24.8

 Ending inventory quantity . . . . 22,710 21,881 22,056 20,845 25,517 -2.9 -3.7 0.8 22.4

U.S. producers':

 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 ($1,000) . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Hourly wages . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 Productivity (pounds 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) . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** ***

 (1) "Reported data" are in percent and "period changes" are in percentage points.

 (2) Not applicable.

 (3) Undefined.

Note.--Financial data are reported on a fiscal year basis for 2006-08 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.

C-3
C-4

Table C-2

Threaded rod: Summary data concerning the U.S. market (excluding Bay Standard from U.S.

producer data), 2005-07, January-September 2007, and January-September 2008

* * * * * * *
D-1

APPENDIX D

U.S. PRODUCERS’ AND IMPORTERS’ 

TOTAL SHIPMENTS OF THREADED ROD BY DIAMETER

D-3

Table D-1

Threaded rod: U.S. producers’ shipments by diameter, 2007, in percent

Diameter Pounds Linear feet Value

Share of quantity Share of value

1/4-inch 2.9 9.5 3.3

5/16-inch 0.7 1.3 0.9

3/8-inch 46.6 64.7 41.8

7/16-inch 0.2 0.1 0.2

1/2-inch 19.1 14.8 18.4

9/16-inch 0.0 0.0 0.0

5/8-inch 7.8 3.7 8.4

3/4-inch 11.9 3.9 13.0

7/8-inch 3.2 0.8 4.0

1-inch 3.2 0.6 4.0

1 1/8-inch 0.8 0.1 1.0

1 1/4-inch 1.7 0.2 2.2

1 3/8-inch 0.2 0.0 0.2

1 1/2-inch 1.0 0.1 1.4

1 3/4-inch 0.4 0.0 0.5

2-inch 0.3 0.0 0.5

2 1/4-inch 0.1 0.0 0.1

2 1/2-inch 0.1 0.0 0.1

Other1 0.1 0.1 0.2

 Total (all diameters) 100.0 100.0 100.0

 1 Accounted for by *** reported shipments of screw diameter rod.

Note.--Reported shipments include all lengths and finishes.

Source: Compiled from data submitted in response to Commission questionnaires.
D-4

Table D-2

Threaded rod: U.S. importers’ shipments by diameter, 2007, in percent

Diameter Pounds Linear feet Value

Share of quantity Share of value

1/4-inch 2.5 12.8 2.9

5/16-inch 0.8 1.4 1.1

3/8-inch 38.0 60.9 32.3

7/16-inch 0.2 0.1 0.3

1/2-inch 15.8 11.9 16.8

9/16-inch 0.0 0.0 0.0

5/8-inch 11.8 5.6 12.4

3/4-inch 14.3 4.2 16.2

7/8-inch 5.2 1.3 5.4

1-inch 6.3 1.1 7.0

1 1/8-inch 1.6 0.2 1.3

1 1/4-inch 2.1 0.2 2.5

1 3/8-inch 0.1 0.0 0.1

1 1/2-inch 0.9 0.1 1.1

1 3/4-inch 0.2 0.0 0.2

2-inch 0.2 0.0 0.3

2 1/4-inch 0.0 0.0 0.0

2 1/2-inch 0.0 0.0 0.0

Other 0.1 0.2 0.2

 Total (all diameters) 100.0 100.0 100.0

Note.--Reported shipments include all lengths and finishes.

Source: Compiled from data submitted in response to Commission questionnaires.
E-1

APPENDIX E

ADDITIONAL QUARTERLY PRICE DATA

EXCLUDING BAY STANDARD

E-3

Table E-1

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

excluding Bay Standard, and importers excluding Bay Standard, of product 1,1

 and margins of

underselling, by quarters, January 2005-September 2008

* * * * * * *

Table E-2

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

excluding Bay Standard, and importers excluding Bay Standard, of product 2,1

 and margins of

underselling/(overselling), by quarters, January 2005-September 2008

* * * * * * *

Table E-3

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

excluding Bay Standard, and importers excluding Bay Standard, of product 3,1

 and margins of

underselling/(overselling), by quarters, January 2005-September 2008

* * * * * * *

Table E-4

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

excluding Bay Standard, and importers excluding Bay Standard, of product 4,1

 and margins of

underselling/(overselling), by quarters, January 2005-September 2008

* * * * * * *

Table E-5

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

excluding Bay Standard, and importers excluding Bay Standard, of product 5,1

 and margins of

underselling/(overselling), by quarters, January 2005-September 2008

* * * * * * *

Table E-6

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

excluding Bay Standard, and importers excluding Bay Standard, of product 6,1

 and margins of

underselling/(overselling), by quarters, January 2005-September 2008

* * * * * * *

Table E-7

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers

excluding Bay Standard, and importers excluding Bay Standard, of product 7,1

 and margins of

underselling, by quarters, January 2005-September 2008

* * * * * * *

F-1

APPENDIX F

ADDITIONAL QUARTERLY PRICE DATA

INCLUDING ***

F-3

Table F-1

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers,

including ***, and importers of product 1,1

 and margins of underselling, by quarters, January 2005-

September 2008

* * * * * * *

Table F-2

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers, 

including ***, and importers of product 2,1

 and margins of underselling/(overselling), by quarters,

January 2005-September 2008

* * * * * * *

Table F-3

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers, 

including ***, and importers of product 3,1

 and margins of underselling/(overselling), by quarters,

January 2005-September 2008

* * * * * * *

Table F-4

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers, 

including ***, and importers of product 4,1

 and margins of underselling/(overselling), by quarters,

January 2005-September 2008

* * * * * * *

Table F-5

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers, 

including ***, and importers of product 5,1

 and margins of underselling/(overselling), by quarters,

January 2005-September 2008

* * * * * * *

Table F-6

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers, 

including ***, and importers of product 6,1

 and margins of underselling/(overselling), by quarters,

January 2005-September 2008

* * * * * * *

Table F-7

Threaded rod: Weighted-average f.o.b. selling prices and quantities as reported by U.S. producers, 

including ***, and importers of product 7,1

 and margins of underselling, by quarters, January 2005-

September 2008

* * * * * * *

G-1

APPENDIX G

U.S. PRODUCERS’ AGGREGATE FINANCIAL DATA

FISCAL YEARS 2005 THROUGH 2007,

 JANUARY-SEPTEMBER 2007, AND JANUARY-SEPTEMBER 2008
G-2
G-3

Appendix G-1

Threaded Rod: Results of operations of U.S. producers, fiscal years 2005-07, January-September

2007, and January-September 2008

* * * * * * *

Appendix G-2

Threaded Rod: Results of operations of U.S. producers excluding ***, fiscal years 2005-07,

January-September 2007, and January-September 2008

* * * * * * *

H-1

APPENDIX H

ALLEGED EFFECTS OF SUBJECT IMPORTS ON U.S. PRODUCERS’ 

EXISTING DEVELOPMENT AND PRODUCTION EFFORTS,

GROWTH, INVESTMENT, AND ABILITY TO RAISE CAPITAL
H-2
H-3

The Commission requested U.S. producers to describe any actual or potential negative effects since

January 1, 2005, on their return on investment, growth, investment, ability to raise capital, existing

development and production efforts, or the scale of capital investments as a result of imports of

threaded rod from China. Their responses are as follows:

Actual Negative Effects

* * * * * * *

Anticipated Negative Effects

* * * * * * *