U.S. International Trade Commission

Publication 4489 September 2014

Washington, DC 20436

Certain Oil Country Tubular Goods from 

India, Korea, the Philippines, Taiwan, 

Thailand, Turkey, Ukraine, and Vietnam

Investigation Nos. 701-TA-499-500 and 

731-TA-1215-1217 and 1219-1223 (Final)
U.S. International Trade Commission

COMMISSIONERS 

 

Meredith M. Broadbent, Chairman 

Dean A. Pinkert, Vice Chairman 

Irving A. Williamson 

David S. Johanson 

F. Scott Kieff 

Rhonda K. Schmidtlein

Robert B. Koopman

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Director of Operations

Michael Szustakowski, Investigator 

Alan Treat, Industry Analyst 

Craig Thomsen, Economist 

Charles Yost, Accountant 

Russell Duncan, Statistician 

Peter Sultan, Attorney 

Nataline Viray-Fung, Attorney 

Jonathan Connelly, Intern 

Daniel Hernandez, Intern 

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

Washington, DC 20436 

www.usitc.gov

Publication 4489 September 2014

Certain Oil Country Tubular Goods from 

India, Korea, the Philippines, Taiwan, 

Thailand, Turkey, Ukraine, and Vietnam

Investigation Nos. 701-TA-499-500 and 

731-TA-1215-1217 and 1219-1223 (Final)

  

CONTENTS

Page

i

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

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

  Separate and Dissenting Views of Chairman Meredith M. Broadbent on Negligibility............ 55

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

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

Statutory criteria and organization of the report..................................................................... I‐2

Statutory criteria ................................................................................................................... I‐2

Organization of report........................................................................................................... I‐3

Market summary....................................................................................................................... I‐4

Summary data and data sources............................................................................................... I‐4

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

Antidumping and countervailing duty investigations........................................................... I‐5

Safeguard investigations ....................................................................................................... I‐7

Nature and extent of subsidies and sales at LTFV .................................................................... I‐8

Subsidies................................................................................................................................ I‐8

Sales at LTFV........................................................................................................................ I‐10

The subject merchandise ........................................................................................................ I‐12

Commerce’s scope .............................................................................................................. I‐12

Tariff treatment................................................................................................................... I‐13

The product............................................................................................................................. I‐13

Overview.............................................................................................................................. I‐13

Description and applications............................................................................................... I‐14

Manufacturing processes.................................................................................................... I‐21

Domestic like product issues................................................................................................... I‐28

Intermediate products............................................................................................................ I‐29

Uses ..................................................................................................................................... I‐30

Markets................................................................................................................................ I‐30

Characteristics and functions.............................................................................................. I‐31

Value.................................................................................................................................... I‐31
  

CONTENTS

Page

ii

Transformation process....................................................................................................... I‐31

Part II: Supply and demand information............................................................................... II‐1

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

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

Geographic distribution........................................................................................................ II‐3

Supply and demand considerations......................................................................................... II‐4

Supply ................................................................................................................................... II‐4

Demand .............................................................................................................................. II‐11

Substitutability issues............................................................................................................. II‐18

Purchaser characteristics.................................................................................................... II‐18

Knowledge of country sources........................................................................................... II‐19

Factors affecting purchasing decisions............................................................................... II‐21

Comparisons of domestic products, subject imports, and nonsubject imports................ II‐26

Elasticity Estimates................................................................................................................. II‐47

U.S. supply elasticity........................................................................................................... II‐47

U.S. demand elasticity ........................................................................................................ II‐47

Substitution elasticity ......................................................................................................... II‐47

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

U.S. producers......................................................................................................................... III‐1

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

Overall pipe forming and heat treatment production, capacity, and capacity utilization . III‐3

OCTG production, capacity, and capacity utilization .......................................................... III‐8

Processors’ inclusion in the industry................................................................................. III‐10

U.S. producers’ U.S. shipments and exports......................................................................... III‐11

U.S. producers’ inventories................................................................................................... III‐13

U.S. producers’ imports......................................................................................................... III‐14

U.S. employment, wages, and productivity .......................................................................... III‐14
CONTENTS

Page

iii

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

U.S. importers..........................................................................................................................IV‐1

U.S. imports............................................................................................................................. IV‐4

Critical circumstances..............................................................................................................IV‐7

Negligibility............................................................................................................................IV‐10

Cumulation considerations ...................................................................................................IV‐11

Fungibility ..........................................................................................................................IV‐12

Presence in the market .....................................................................................................IV‐20

Geographical markets .......................................................................................................IV‐21

Apparent U.S. consumption ..................................................................................................IV‐21

U.S. market shares ................................................................................................................IV‐21

Ratio of imports to production ............................................................................................. IV‐24

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

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

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

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

Pricing practices .......................................................................................................................V‐4

Pricing methods....................................................................................................................V‐4

Sales terms and discounts....................................................................................................V‐8

Price data..................................................................................................................................V‐9

Price trends.........................................................................................................................V‐20

Price comparisons ..............................................................................................................V‐21

Lost sales and lost revenues...................................................................................................V‐25

Part VI: Financial experience of U.S. producers....................................................................VI‐1

Background..............................................................................................................................VI‐1

Operations on OCTG................................................................................................................VI‐2

Variance analysis.................................................................................................................VI‐9

Capital expenditures and research and development expenses..........................................VI‐11
CONTENTS

Page

iv

Assets and return on investment..........................................................................................VI‐12

Capital and investment .........................................................................................................VI‐13

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

The industry in India...............................................................................................................VII‐3

Operations on OCTG...........................................................................................................VII‐4

Alternative products...........................................................................................................VII‐5

The industry in Korea .............................................................................................................VII‐5

Operations on OCTG...........................................................................................................VII‐6

Alternative products...........................................................................................................VII‐7

The industry in the Philippines...............................................................................................VII‐8

Operations on OCTG...........................................................................................................VII‐8

Alternative products...........................................................................................................VII‐9

The industry in Saudi Arabia ..................................................................................................VII‐9

Operations on OCTG.........................................................................................................VII‐11

Alternative products.........................................................................................................VII‐12

The industry in Taiwan .........................................................................................................VII‐13

Operations on OCTG.........................................................................................................VII‐14

Alternative products.........................................................................................................VII‐14

The industry in Thailand.......................................................................................................VII‐15

Operations on OCTG.........................................................................................................VII‐15

Alternative products.........................................................................................................VII‐16

The industry in Turkey..........................................................................................................VII‐16

Operations on OCTG.........................................................................................................VII‐17

Alternative products.........................................................................................................VII‐18

The industry in Ukraine ........................................................................................................VII‐18

Operations on OCTG.........................................................................................................VII‐19

Alternative products.........................................................................................................VII‐20

The industry in Vietnam.......................................................................................................VII‐20
CONTENTS

Page

v

Operations on OCTG.........................................................................................................VII‐22

Alternative products.........................................................................................................VII‐22

Subject countries combined ................................................................................................ VII‐23

U.S. inventories of imported merchandise ..........................................................................VII‐24

U.S. importers’ outstanding orders......................................................................................VII‐24

Antidumping or countervailing duty orders in third‐country markets................................VII‐25

Information on nonsubject countries..................................................................................VII‐25

Argentina ..........................................................................................................................VII‐34

Canada..............................................................................................................................VII‐35

Germany ...........................................................................................................................VII‐37

Japan.................................................................................................................................VII‐38

Mexico ..............................................................................................................................VII‐40

Recent OCTG operations in select nonsubject countries.................................................VII‐41

Appendixes

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

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

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

D. U.S. producers’ and U.S. importers’ shipments and imports of OCTG by type ................D‐1

E. Quarterly nonsubject country price data ......................................................................... E‐1

F. Alleged effects of imports on capital and investment ..................................................... F‐1

G. Key tables for post‐Saudi Arabia amended negative determination................................G‐1

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

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

UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation Nos. 701-TA-499-500 and 731-TA-1215-1217 and 1219-1223 (Final)

CERTAIN OIL COUNTRY TUBULAR GOODS FROM INDIA, KOREA, THE PHILIPPINES, TAIWAN, 

THAILAND, TURKEY, UKRAINE, AND VIETNAM

DETERMINATIONS

On the basis of the record1 developed in the subject investigations, the United States 

International Trade Commission (“Commission”) determines, pursuant to sections 705(b) and 

735(b) of the Tariff Act of 1930 (19 U.S.C. ' 1671d(b)) and (19 U.S.C. ' 1673d(b)) (“the Act”), 

that an industry in the United States is materially injured by reason of imports of certain oil 

country tubular goods from India, Korea, Turkey, Ukraine, and Vietnam, provided for in

subheadings 7304.29, 7305.20, and 7306.29 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”) and to be subsidized by the governments of India 

and Turkey.

2 The Commission also determines, pursuant to section 735(b) of the Act, that an 

industry in the United States is threatened with material injury by reason of imports of certain 

oil country tubular goods from Taiwan that have been found by Commerce to be sold in the 

United States at LTFV.3

The Commission further determines that imports of these products from the Philippines 

and Thailand are negligible pursuant to section 771(24) of the Act (19 U.S.C. ' 1677(24)), and its 

investigations with regard to these countries are thereby terminated pursuant to section 735(b) 

of the Act.

BACKGROUND

The Commission instituted these investigations effective July 2, 2013, following receipt 

of a petition filed with the Commission and Commerce by United States Steel Corporation, 

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

CFR ' 207.2(f)).

2 All five participating Commissioners voted in the affirmative (Commissioner F. Scott Kieff did not 

participate in these investigations). The Commission also finds that imports subject to Commerce's 

affirmative critical circumstances determinations are not likely to undermine seriously the remedial 

effect of the countervailing duty orders on certain oil country tubular goods from India or Turkey. The 

Commission further finds that imports subject to Commerce's affirmative critical circumstances 

determinations are not likely to undermine seriously the remedial effect of the antidumping duty orders

on certain oil country tubular goods from Turkey or Vietnam.

3 Chairman Meredith M. Broadbent dissenting with regard to imports from Taiwan, determining 

that subject imports from Taiwan are negligible.

1

 
Pittsburgh, PA; Maverick Tube Corporation, Houston, TX; Boomerang Tube LLC, Chesterfield, 

MO; Energex, a division of JMC Steel Group, Chicago, IL; Northwest Pipe Company, Vancouver, 

WA; Tejas Tubular Products Inc., Houston, TX; TMK IPSCO, Houston, TX; Vallourec Star, L.P., 

Houston, TX; and Welded Tube USA, Inc., Lackawanna, NY. The final phase of the 

investigations was scheduled by the Commission following notification of preliminary 

determinations by Commerce regarding the subsidization of imports of certain oil country 

tubular goods from India and Turkey within the meaning of section 703(b) of the Act (19 U.S.C. 

' 1671b(b)) and sales at less than fair value of imports of certain oil country tubular goods from 

India, Korea, the Philippines, Taiwan, Thailand, Turkey, Ukraine, and Vietnam 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 investigations and of a public hearing to be held in connection 

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

International Trade Commission, Washington, DC, and by publishing the notice in the Federal 

Register on April 7, 2014 (79 FR 19122). The hearing was held in Washington, DC, on July 15, 

2014, and all persons who requested the opportunity were permitted to appear in person or by 

counsel.

2
3

Views of the Commission

Based on the record in the final phase of these investigations, we find that an industry in

the United States is materially injured by reason of imports of certain oil country tubular goods

(“OCTG”) from India, Korea, Turkey, Ukraine, and Vietnam found by the U.S. Department of

Commerce (“Commerce”) to be sold in the United States at less than fair value, and by reason

of imports of the subject merchandise from India and Turkey found by Commerce to have been

subsidized by the governments of India and Turkey.1  We also determine that an industry in the

United States is threatened with material injury by reason of imports of OCTG from Taiwan that

Commerce found to be sold in the United States at less than fair value.2

  We find that critical

circumstances do not exist with respect to the entities exporting the subject merchandise from

India, Turkey, and Vietnam for which Commerce made affirmative critical circumstances

determinations.

We further determine that imports of OCTG from the Philippines and Thailand that

Commerce found to be sold in the United States at less than fair value are negligible.

I. Background

The petitions in these investigations were filed on July 2, 2013 by the United States Steel

Corporation (“U.S. Steel”); Maverick Tube Corporation (“Maverick”); Boomerang Tube LLC;

Energex, a division of JMC Steel Group; Northwest Pipe Company; Tejas Tubular Products Inc.;

TMK IPSCO; Vallourec Star, L.P.; and Welded Tube USA, Inc. (these seven collectively, “Other

Petitioners”) (U.S. Steel, Maverick, and Other Petitioners are collectively the “Petitioners”).  

Evraz Inc., NA, (“Evraz”), a domestic producer, also appeared in these investigations.  

Petitioners and Evraz (collectively, “Domestic Producers”) are domestic producers of OCTG and

accounted for almost all of domestic OCTG production during the January 2011‐March 2013

period of investigation (“POI”).3

  Petitioners appeared at the hearing and submitted prehearing

and posthearing briefs.  Evraz also submitted a prehearing brief.

The following respondents appeared at the Commission’s hearing and submitted

prehearing and posthearing briefs:   

India.  Jindal SAW Ltd. (“Jindal”), Jindal Pipe Ltd., GVN Fuels Limited (“GVN”), and

Maharashtra Seamless Ltd., producer/exporters and importers of subject merchandise.  The

government of India also filed a posthearing statement.

Korea.  AJU Besteel Co., Ltd., Husteel Co., Ltd., Hyundai HYSCO, Nexteel Co., Ltd., SeAH

Steel Corp., producers of subject merchandise; and Husteel USA, Inc., Hyundai USA, Inc.,

                                                       1 Commissioner Kieff did not participate in these investigations. 2 Chairman Broadbent determines that imports of OCTG from Taiwan are negligible.  See

Separate and Dissenting Views of Chairman Broadbent.

3 See Confidential Staff Report, as amended by Memoranda INV‐MM‐075 and INV‐MM‐081

(“CR”) at Table III‐1, Public Report, Certain Oil Country Tubular Goods from India, Korea, Philippines,

Taiwan, Thailand, Turkey, Ukraine, and Vietnam, Inv. Nos. 701‐TA‐499‐500 and 731‐TA‐1215‐1217 and

1219‐1223 (Final), USITC Pub. 4489 (Sept. 2014) (“PR”) at Table III‐1.
4

Hyundai HYSCO USA, Inc., and SeAH Steel America, Inc., U.S. importers of subject merchandise

(“Korean Respondent Group”).  ILJIN Steel Corporation, a producer and exporter of subject

merchandise (“ILJIN”).

The Philippines.  HLD Clark Steel Pipe Co., Ltd., a producer and exporter of subject

merchandise (“Philippine Respondent” or “HLD Clark”).

Thailand.  Boly Pipe Co., Ltd. (“Boly Pipe”), a producer and exporter of subject

merchandise.  

Turkey.  Borusan Mannesmann Boru Sanayi ve Ticaret Anonim Sirketi, Çayirova Boru

Sanayi ve Ticaret A.S., Yücel Boru Ithalat‐Ihracat ve Pazarlama A.S., Tosçelik Profil ve Sac

Endustrisi A.S., and Tosyali Dis Ticaret A.S., producers and exporters of subject merchandise

(collectively “Turkish Respondents”).  A representative of the government of Turkey appeared

at the hearing.

Ukraine.  Interpipe, a producer and exporter of subject merchandise, and North

American Interpipe, Inc., a U.S. importer of subject merchandise (“Ukrainian Respondents”).  A

representative of the government of Ukraine appeared at the hearing.

In addition, C&F International, an importer of OCTG, filed briefs, and Nexgen Metals,

Inc., also an importer of OCTG, filed a posthearing statement.4

U.S. industry data are based on the questionnaire responses from 17 domestic

producers that accounted for the vast majority of domestic production of OCTG during 2013.5

  

U.S. import data are based on official Commerce import statistics, except as noted in the staff

report.6   

The Commission received responses to its questionnaires from 31 foreign

producers/exporters of subject merchandise:   

 eight producers/exporters in India, accounting for approximately *** of all exports of

subject merchandise to the United States from India in 2013;7  

 seven producers/exporters in Korea, accounting for all U.S. imports of subject

merchandise from Korea in 2013;8  

 one producer/exporter in the Philippines, accounting for all U.S. imports of subject

merchandise from the Philippines in 2013;9

  

 five producers/exporters in Taiwan, accounting for all U.S. imports of subject

merchandise from Taiwan in 2013;10  

 one producer/exporter in Thailand, accounting for *** of U.S. imports of subject

merchandise from Thailand in 2013;11

                                                       4 No respondents from Taiwan or Vietnam participated in the final phase investigations. 5 CR at I‐6, PR at I‐4.

6 CR at I‐6, PR at I‐4‐5. 7 CR at VII‐4, PR at VII‐3.

8 CR at VII‐10, PR at VII‐5.

9 CR at VII‐15, PR at VII‐8.

10 CR at VII‐29, PR at VII‐13. 11 CR at VII‐34, PR at VII‐15.
5

 three producers/exporters in Turkey, accounting for *** percent of U.S. imports of

subject merchandise from Turkey in 2013;12

 two producers/exporters in Ukraine, accounting for *** U.S. imports of subject

merchandise from Ukraine in 2013;13 and  

 one producer/exporter in Vietnam, accounting for *** percent of U.S. imports of subject

merchandise from Vietnam in 2013.14

On August 11, 2014, after correcting ministerial errors in its original final determination

of sales at less than fair value with respect to OCTG from Saudi Arabia, Commerce terminated

that investigation.15  The Commission was made aware of this action two days before its

scheduled vote in these investigations.16  On August 13, 2014, the Commission reopened its

record for the limited purpose of receiving Commerce’s amended final determination and

termination with regard to OCTG from Saudi Arabia and comments from parties with regard to

this new factual information.17  U.S. Steel; the United Steel, Paper and Forestry, Rubber,

Manufacturing, Energy, Allied Industrial and Service Workers International Union; Maverick;18

Turkish Respondents; ILJIN; HLD Clark; and Boly Pipe filed comments.  The Commission

terminated its investigation with respect to imports from Saudi Arabia on August 21, 2014.19 20

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 subject merchandise, the Commission

first defines the “domestic like product” and the “industry.”21  Section 771(4)(A) of the Tariff Act

of 1930, as amended (“the Tariff Act”), defines the relevant domestic industry as the

                                                       12 CR at VII‐39, PR at VII‐16‐17.

13 CR at VII‐45, PR at VII‐18‐19. 14 CR at VII‐51, PR at VII‐21.

15 Amended Final Determination and Termination of the Investigation of Sales at Less Than Fair

Value:  Certain Oil Country Tubular Goods From Saudi Arabia, 79 Fed. Reg. 49051 (Aug. 19, 2014).

16 See EDIS Doc. 540196.  The Commission’s vote was originally scheduled for August 14, 2014. 17 Certain Oil Country Tubular Goods from India, Korea, the Philippines, Saudi Arabia, Taiwan,

Thailand, Turkey, Ukraine, and Vietnam, Reopening of the Record and Request for Comments, 79 Fed.

Reg. 49102 (Aug. 19, 2014).

18 Maverick’s additional final comments exceeded the 10‐page limit set by the Commission.  

Accordingly, we have disregarded the material in these comments beyond the first 10 pages.

19 Certain Oil Country Tubular Goods from Saudi Arabia, Termination of Investigation, 79 Fed.

Reg. 51192 (Aug. 27, 2014).

20 We note that these Views would normally have been completed by September 2, 2014, the

date we issued our determinations in these investigations.  However, they were necessarily delayed by

Commerce’s termination of its investigation with respect to Saudi Arabia, and the need to reopen the

record and assess the new information and arguments made by the parties. 21 19 U.S.C. § 1677(4)(A).
6

“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.”22  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.”23

The decision regarding the appropriate domestic like product in an investigation is a

factual determination, and the Commission has applied the statutory standard of “like” or

“most similar in characteristics and uses” on a case‐by‐case basis.24  No single factor is

dispositive, and the Commission may consider other factors it deems relevant based on the

facts of a particular investigation.25  The Commission looks for clear dividing lines among

possible like products and disregards minor variations.26  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,27 the Commission determines what domestic product is like the

imported articles Commerce has identified.28

                                                       22 19 U.S.C. § 1677(4)(A).

23 19 U.S.C. § 1677(10).

24 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’”).  In the semi‐finished products analysis

applicable in these investigations, the Commission examines the following: (1) the significance and

extent of the processes used to transform the upstream into the downstream articles; (2) whether the

upstream article is dedicated to the production of the downstream article or has independent uses; (3)

differences in the physical characteristics and functions of the upstream and downstream articles; (4)

whether there are perceived to be separate markets for the upstream and downstream articles; and (5)

differences in the costs or value of the vertically differentiated articles.  See, e.g., Glycine from India,

Japan, and Korea, Inv. Nos. 731‐TA‐1111‐1113 (Preliminary), USITC Pub. 3921 at 7 (May 2007); Artists'

Canvas from China, Inv. No. 731‐TA‐1091 (Final), USITC Pub. 3853 at 6 (May 2006); Live Swine from

Canada, Inv. No. 731‐TA‐1076 (Final), USITC Pub. 3766 at 8 n.40 (Apr. 2005); Certain Frozen Fish Fillets

from Vietnam, Inv. No. 731‐TA‐1012 (Preliminary), USITC Pub. 3533 at 7 (Aug. 2002).

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

26 Nippon, 19 CIT at 455; Torrington, 747 F. Supp. at 748‐49; see also S. Rep. No. 96‐249 at 90‐91

(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.”).

27 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).

28 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);

(Continued...)
7

B. Product Description

Commerce defined the scope of the imported merchandise under investigation as

follows:

The merchandise covered by the investigation is certain oil

country tubular goods (“OCTG”), which are hollow steel products

of circular cross‐section, including oil well casing and tubing, of

iron (other than cast iron) or steel (both carbon and alloy),

whether seamless or welded, regardless of end finish (e.g.,

whether or not plain end, threaded, or threaded and coupled)

whether or not conforming to American Petroleum Institute

(“API”) or non‐API specifications, whether finished (including

limited service OCTG products) or unfinished (including green

tubes and limited service OCTG products), whether or not thread

protectors are attached. The scope of the investigation also

covers OCTG coupling stock.

Excluded from the scope of the investigation are: casing or tubing

containing 10.5 percent or more by weight of chromium; drill

pipe; unattached couplings; and unattached thread protectors.29

                                                                                                                                                                              

(...Continued)

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 in which Commerce found five classes or

kinds).

29 E.g., Final Determination of Sales at Less Than Fair Value and Final Negative Determination of

Critical Circumstances: Certain Oil Country Tubular Goods from India, 79 Fed. Reg. 41981, 41983 (July

18, 2014).  According to Commerce, the merchandise subject to the investigation is currently classified

in the Harmonized Tariff Schedule of the United States (“HTSUS”) under item numbers:  7304.29.10.10,

7304.29.10.20, 7304.29.10.30, 7304.29.10.40, 7304.29.10.50, 7304.29.10.60, 7304.29.10.80,

7304.29.20.10, 7304.29.20.20, 7304.29.20.30, 7304.29.20.40, 7304.29.20.50, 7304.29.20.60,

7304.29.20.80, 7304.29.31.10, 7304.29.31.20, 7304.29.31.30, 7304.29.31.40, 7304.29.31.50,

7304.29.31.60, 7304.29.31.80, 7304.29.41.10, 7304.29.41.20, 7304.29.41.30, 7304.29.41.40,

7304.29.41.50, 7304.29.41.60, 7304.29.41.80, 7304.29.50.15, 7304.29.50.30, 7304.29.50.45,

7304.29.50.60, 7304.29.50.75, 7304.29.61.15, 7304.29.61.30, 7304.29.61.45, 7304.29.61.60,

7304.29.61.75, 7305.20.20.00, 7305.20.40.00, 7305.20.60.00, 7305.20.80.00, 7306.29.10.30,

7306.29.10.90, 7306.29.20.00, 7306.29.31.00, 7306.29.41.00, 7306.29.60.10, 7306.29.60.50,

7306.29.81.10, and 7306.29.81.50.

The merchandise subject to the investigations may also enter under the following HTSUS item

numbers:  7304.39.00.24, 7304.39.00.28, 7304.39.00.32, 7304.39.00.36, 7304.39.00.40, 7304.39.00.44,

7304.39.00.48, 7304.39.00.52, 7304.39.00.56, 7304.39.00.62, 7304.39.00.68, 7304.39.00.72,

7304.39.00.76, 7304.39.00.80, 7304.59.60.00, 7304.59.80.15, 7304.59.80.20, 7304.59.80.25,

(Continued...)
8

OCTG includes casing, tubing, and coupling stock of carbon and alloy steel used in oil

and gas wells.30  Casing is a circular pipe that serves as a structural retainer for the walls of the

well.  It typically has an outside diameter (OD) ranging from 4.5 inches to 20 inches and a length

ranging from 34 feet to 48 feet.  Casing provides a firm foundation for the drill string by

supporting the walls of the hole to prevent caving in or wall collapse both during drilling and

after the well is completed.31  Casing also serves as a surface pipe designed to prevent

contamination of the recoverable oil and gas by surface water, gas, sand, or limestone.32  

Tubing is a smaller‐diameter pipe (between 1.050 and 4.5 inches OD) installed inside the larger‐

diameter casing that is used to conduct the oil or gas to the surface, either through natural flow

or through pumping.33  Coupling stock is a thick‐walled, seamless tubular product used to

manufacture coupling blanks.  Coupling blanks, in turn, are unthreaded tube blanks used to

make individual couplings. Couplings are thick‐walled and internally threaded seamless

cylinders that are used for joining two lengths of threaded OCTG.34  Casing and tubing are

usually produced in accordance with specification 5CT of the American Petroleum Institute

(“API”).35

C. Arguments of the Parties

Petitioners argue that the Commission should find a single domestic like product which

is coextensive with the scope of Commerce’s investigations, as it did in the preliminary

determinations.36  More specifically, Petitioners argue that there is no clear dividing line

between green tubes and finished OCTG.37   

                                                                                                                                                                              

(...Continued)

7304.59.80.30, 7304.59.80.35, 7304.59.80.40, 7304.59.80.45, 7304.59.80.50, 7304.59.80.55,

7304.59.80.60, 7304.59.80.65, 7304.59.80.70, 7304.59.80.80, 7305.31.40.00, 7305.31.60.90,

7306.30.50.55, 7306.30.50.90, 7306.50.50.50, and 7306.50.50.70.  Id.

30 CR at I‐17, PR at I‐14.

31 CR at I‐20, PR at I‐17.

32 CR at I‐22, PR at I‐18.

33 CR at I‐22, PR at I‐19.

34 CR at I‐25, PR at I‐19.

35 CR at I‐22, PR at I‐19.

36 U.S. Steel Prehearing Brief at Exh. 1, 1; Other Petitioners’ Prehearing Brief at 3, Maverick

Prehearing Brief at 2‐3.

37 U.S. Steel adopts the definition of green tubes in the prehearing report, namely, “a term that

can apply to unfinished, non‐heat‐treated tube bodies intended for casing and tubing.”  U.S. Steel

Prehearing Brief at Exh. 1, 4 n.21.  Maverick states that the industry defines green tubes as “pipe that

has not been tested and is therefore incapable of achieving an API certification,” but acknowledges that

other parties use different definitions.  Maverick Prehearing Brief at 3‐4.  Maverick further asserts that

only the category identified by Commission staff as “unfinished OCTG not at API grade” should be

considered green tube.  Maverick Prehearing Brief at 4.  Other Petitioners define green tubes as

“circular welded or seamless steel tube intended and suited for production into OCTG, that has not yet

been heat treated, upset, threaded, or otherwise processed.”  Other Petitioners’ Prehearing Brief at 4.  
9

    ILJIN’s arguments regarding the definition of the domestic like product have evolved in

the course of these final phase investigations.  It argued in its prehearing brief that “green

tubes subject to heat treatment in the United States prior to sale to the merchant market”

should be treated as a separate domestic like product.38  In its posthearing brief, ILJIN argued

that “{a}t the very least, the Commission should find a separate domestic like product for those

green tubes that must be heat treated subsequent to importation and prior to sale.”39  In

addition, ILJIN submitted that “entries of unfinished upgradeable seamless OCTG should be

considered ‘green tubes’ falling into the same category as ‘Not API/proprietary grade’ inasmuch

as unheat‐treated, unfinished seamless OCTG would not have any other use other than to be

upgraded by a U.S. processor.”40  ILJIN also argued that it would be “appropriate” for the

Commission to include in the separate domestic like product upgradeable J‐55 welded OCTG

that is in fact heat treated after importation.41  In its final comments, ILJIN acknowledged that

the term “green tubes” does not have a single, accepted definition, and that it was itself

partially responsible for any confusion over the meaning of the term.42  ILJIN urged the

Commission to define “U.S. heat‐treated semi‐finished OCTG” as a separate domestic like

product.43  ILJIN also noted that there are, in its view, more narrow definitions of semifinished

OCTG that would qualify for separate domestic like‐product treatment, namely (i) all

semifinished OCTG not at API grade, and (ii) semifinished seamless OCTG that has not been

heat treated prior to importation, but is imported at API grade (upgradeable seamless OCTG).44

D. Domestic Like Product Analysis

We consider whether “U.S. heat‐treated semi‐finished OCTG” should be treated as a

separate domestic like product.  As we understand ILJIN’s argument, this category of products

encompasses (i) tubular products that require further processing to comply fully with the API

5CT specifications for casing and tubing, and (ii) tubular products – whether seamless or welded

– that meet the minimum specifications for lower‐grade API 5CT casing and tubing (i.e., H40

and J55) and can be upgraded from one API grade to a more demanding API grade through heat

treatment (“upgradeable” product).  For the sake of convenience, we refer to these products as

“green tubes.”45  We have not considered ILJIN’s “alternative” domestic like product

formulations, as they were not raised in a timely fashion.46

                                                       38 ILJIN Prehearing Brief at 9.  We note that neither ILJIN nor any other party asked the

Commission to collect additional separate information for green tubes, however defined, when

commenting on the draft questionnaires in these final phase investigations.  CR at I‐36 n.46, PR at I‐29

n.46.   39 ILJIN Posthearing Brief at Appdx. 1, 44.

40 ILJIN Posthearing Brief at Appdx. 1, 44‐45. 41 ILJIN Posthearing Brief at Appdx. 1, 45.

42 ILJIN Final Comments (Aug. 8, 2014) at 8.

43 ILJIN Final Comments (Aug. 8, 2014) at 9. 44 ILJIN Final Comments (Aug. 8, 2014) at 10.

45 We note that a number of parties apply an incorrect domestic like product inquiry when they

argue that the Commission should treat certain imported products as a separate like product.  E.g., ILJIN

(Continued...)
10

Because the question of whether green tubes should be treated as a separate domestic

like product from finished OCTG involves a comparison of articles at different stages of

processing, we use our semi‐finished product analysis to resolve this issue.

Dedication for Use.   ILJIN concedes that all green tubes are dedicated to the production

of finished OCTG.47  Green tubes have no practical use other than to be further processed.  As a

representative of a distributor stated at the hearing (presumably referring to OCTG not at API

grade), without being finished, green tube is “either a very expensive fence post or it’s a cattle

guard.”48  With regard to seamless, upgradeable product, ILJIN explains that, while it is

conceivable that it could be used without heat treatment, the price premium associated with

that product makes that economically and commercially unrealistic.49  To the extent that

upgradeable product could be used without being further heat treated, it would be used for the

same use (i.e., as OCTG) as if it were heat treated.

Separate Markets.  ILJIN’s assertion that there are completely separate markets for

green tubes and finished OCTG – with the former being sold to processers and the latter being

sold to distributors50 – is not supported by the record.  Several U.S. OCTG producers reported

selling green tubes to distributors.  In the preliminary phase of these investigations, U.S. Steel

reported selling green tubes to processors and to distributors ***.51  ***, the largest domestic

producer of unfinished OCTG not at API/proprietary grade, accounting for *** percent of U.S.

producers’ shipments of this product in 2013,52 only shipped this product to distributors and

not to end users or processors.53  *** also reported selling unfinished OCTG not at

API/proprietary grade to a distributor.54  Thus, the record shows that green tubes are not only

sold to processors, but some are sold to distributors which can then arrange for the green tubes

to be heat treated and/or finished.  

                                                                                                                                                                              

(...Continued)

Posthearing Brief, Appdx. 1, 41 (arguing that the “unfinished seamless OCTG ILJIN sells to the United

States” should be treated as a separate domestic like product); U.S. Steel Prehearing Brief at Exh. 1, 5

(noting that green tubes from both U.S. producers and importers go through distribution); Maverick

Prehearing Brief at 4 (noting that most imported OCTG is already at API grade).    46 ILJIN proposed these formulations for the first time in its final comments.  Under both the

Commission’s regulations and the statute, such comments should “only concern such information” as to

which the parties have not previously had an opportunity to comment.  19 C.F.R. § 207.30(b); see also

19 U.S.C. § 1677m(g).  Consequently, final comments are not to be a vehicle for asserting new legal

arguments.  This is particularly true concerning arguments that would require collection or analysis of

new data, such as domestic like product arguments, insofar as the statute states that the Commission

“shall cease collecting information” before the filing of such comments.  19 U.S.C. § 1677m(g). 47 ILJIN Prehearing Brief at 11.

48 Hearing Tr. at 153 (Shoaff).

49 ILJIN Final Comments (Aug. 8, 2014) at 10.

50 ILJIN Prehearing Brief at 11‐12.

51 CR at I‐39 n.58, PR at I‐31 n.58.

52 Calculated from *** response to Question II‐17 in the Commission’s domestic producer

questionnaire and aggregate U.S. shipment data from CR at Table IV‐9.

53 Email from *** to Commission staff, dated July 29, 2014.

54 Other Petitioners’ Posthearing Brief at ***.
11

Differences in Physical Characteristics and Functions of the Upstream and Downstream

Articles.   Green tubes intended for specific OCTG applications are produced to chemical and

dimensional specifications for those applications.55  Thus, the specific characteristics of green

tubes impart characteristics essential to the functionality of the finished OCTG.  The various

forms of heat treatment (annealing, normalizing, and quenching and tempering) do not change

the physical appearance of the tubes, but they may change their microstructure and

mechanical properties.56  The further steps of the finishing process (upsetting pipe ends and

threading them) do change the physical characteristics of the tubes to some extent.57  In sum,

green tubes and finished OCTG share some physical characteristics, but are different in other

respects.  Their functions are the same, in that green tubes have no practical function other

than to be processed into finished OCTG.

Differences in Value.  There is some evidence in the record that prices for green tubes

may be substantially lower than prices for finished OCTG.  For example, in 2013 U.S. producers’

U.S. shipments of finished OCTG had an average unit value (“AUV”) of $1,568, whereas

shipments of unfinished OCTG not at API had an AUV of $*** and shipments of OCTG at API but

upgradeable had an AUV of $***.58  We treat these AUV data with caution, however, given that

they are derived from categories with vastly different aggregate quantities and given the

potential for variations in product mix.  Other data in the record show that the value added by

processors (both tollers and non‐tollers) ranged from *** percent to *** percent.59

Extent of Processes Used to Transform Downstream Product into Upstream Product.  The

processes involved in the heat treatment and other finishing (upsetting, in some cases, and

threading and coupling) of green tubes can be substantial.60  As discussed below, we find that

processors that perform heat treatment engage in sufficient production‐related activity to

qualify as domestic producers of OCTG.  

Conclusion.  All green tubes are dedicated to the production of finished OCTG,

suggesting a single domestic like product.  The two products are not sold in completely

different markets.  Although some green tube is sold to processors, some is also sold to

distributors, to whom finished OCTG is also sold.  Green tubes and finished OCTG share many

basic physical characteristics, but not others.  Their functions are essentially the same.  There is

a significant difference in the value of green tubes and finished OCTG, although the magnitude

of this difference is unclear.  The extent of the processes involved in transforming green tubes

into finished OCTG can be substantial.  On balance, we find that there is not a clear dividing line

                                                       55 CR at I‐38, PR at I‐30.

56 CR at I‐30‐31, PR at I‐24. 57 CR at I‐32, PR at I‐25.

58 CR/PR at Table IV‐9.

59 CR at III‐17 and VI‐20‐21, PR at III‐11 and VI‐8.  These percentages were derived from  (1) a

ratio of the sum of direct factory labor and factory overhead costs (conversion costs) to cost of goods

sold (“COGS”); and (2) a ratio of conversion costs plus selling, general, and administrative (“SG&A”)

expenses  to the sum of COGS and SG&A expenses.    We note that a substantial portion of the green

tube finished by U.S. processors was imported.  CR/PR at Table III‐7 (toll processing); CR at III‐23 and 24,

PR at III‐14 (non‐toll processing).

60 CR at I‐30‐32, PR at I‐24‐26.
12

between green tubes and finished OCTG and we do not find them to be separate domestic like

products.  Accordingly, we define the domestic like product in these investigations as all OCTG,

a category that is coextensive with the scope of Commerce’s investigations.

III. Domestic Industry  

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.”61  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.  

A. Sufficient Production‐Related Activities

In deciding whether a firm qualifies as a domestic producer of the domestic like product,

the Commission generally analyzes the overall nature of a firm’s U.S. production‐related

activities, although production‐related activity at minimum levels could be insufficient to

constitute domestic production.62

Maverick argues that the domestic industry should only include U.S. mills that produce

OCTG and that processors should not be included in the Commission’s definition because

processors do not engage in sufficient production‐related activity to be deemed domestic

producers.63  ILJIN argues that the Commission should continue to include processors in its

definition of the domestic industry because processors engage in sufficient production‐related

activities to qualify as part of the domestic industry.64

Capital Investments.  Five processors that provided data reported aggregate capital

expenditures of $*** during the POI.  Four firms reported their sources of funding, including

private capital and credit lines.65  Processors that reported construction of new facilities spent

an average of $*** each.66  We note that these amounts do not take into account capital

investments that were made before the POI, which would also be relevant to an assessment of

the extent of the processors’ overall capital investments.

                                                       61 19 U.S.C. § 1677(4)(A).

62 The Commission generally considers six factors:  (1) source and extent of the firm’s capital

investment; (2) technical expertise involved in U.S. production activities; (3) value added to the product

in the United States; (4) employment levels; (5) quantity and type of parts sourced in the United States;

and (6) any other costs and activities in the United States directly leading to production of the like

product.  No single factor is determinative and the Commission may consider any other factors it deems

relevant in light of the specific facts of any investigation.  Diamond Sawblades and Parts Thereof from

China and Korea, Inv. Nos. 731‐TA‐1092‐93 (Final), USITC Pub. 3862 at 8‐11 (July 2006).

63 Maverick Prehearing Brief at 8.

64 ILJIN Prehearing Brief at 7‐8.

65 CR at III‐16, PR at III‐10.

66 Maverick Prehearing Brief at 10 n.30.
13

Technical Expertise.  The various forms of heat treatment and other finishing activities

require considerable technical expertise.  OCTG processor *** reported that it employs

metallurgical personnel and a heat treatment equipment operator.  *** reported technical

expertise in heat treating, inspection, and threading.  *** reported having a heat treatment

production director and an API 5CT quality director.67  

Value Added.  The value added by processors (both tollers and non‐tollers) ranged from

*** percent to *** percent.68  We disagree with Maverick’s argument that these percentages

are overstated because they may include finishing operations other than heat treatment.  We

have appropriately considered the full range of a processor’s production‐related activities,

including, but not limited to, heat treatment, when assessing the value added by the processor.  

Indeed, because Maverick did not advocate the collection of value added data for heat

treatment alone when it commented on the Commission’s draft questionnaires, the value‐

added data in the staff report are the information available to the Commission in these

proceedings.

Employment.  Processors employed a total of 2,019 production and related workers in

2013.69

Quantity and Type of Parts Sourced in the United States.  In 2013, non‐toll processors

sourced *** percent of their purchased green tubes from U.S. mills.70  Toll processors do not

source green tubes because they do not take title to the product; however, in 2013, ***

percent of their processing was performed for the account of U.S. mills.71   

In sum, the record indicates that processors have made significant capital investments,

use substantial technical expertise to engage in heat treatment and other finishing activities,

add significant value, employ a substantial number of personnel, and source some green tube

in the United States.72  In light of these considerations, we find that processors that provide

heat treatment engage in sufficient production‐related activities in the United States to be

treated as domestic producers.73 74

                                                       67 CR at III‐16, PR at III‐11.

68 CR at III‐17 and VI‐20‐21, PR at III‐11 and VI‐8.

69 CR at III‐18, PR at III‐11.

70 U.S. producers’ questionnaire responses of ***. 71 CR/PR at Table III‐7.

72 There is no information in the record on any other costs processors incur or other activities in

the United States directly leading to production of OCTG.

73 Without identifying the firms involved or providing any further information, ILJIN argues that

some of its customers that contract with tollers to provide heat treatment services should also be

treated as domestic producers.  ILJIN Prehearing Brief at 9.  ILJIN has not provided enough information

to enable us to identify these entities or to assess their activities.  In any event, the Commission has

generally treated the toller, and not the tollee, as the domestic producer in these situations.  See, e.g.,

Certain Welded Large Diameter Line Pipe from Japan, Inv. No. 731‐TA‐919 (Final), USITC Pub. 3464

(November 2001) at 10, n. 53 (while toll producers that engage in sufficient production related activity

are included, tollees “that merely supply raw materials and pay a fabrication fee” are not).   See also,

e.g., Certain Potassium Phosphate Salts from China, Inv. Nos. 701‐TA‐473 and 473‐TA‐1173 (Final), USITC

Pub. 4171 (July 2010) at 7, n. 30 (“In accordance with our standard practice, we do not consider the

(Continued...)
14

For the foregoing reasons, we define the domestic industry to include all U.S. producers

of OCTG, including both mills that produce OCTG and processors that engage in heat

treatment.75

IV. Negligible Imports

A. Legal Standard

Pursuant to Section 771(24) of the Tariff Act, imports from a subject country of

merchandise corresponding to a domestic like product that account for less than 3 percent of

all such merchandise imported into the United States during the most recent 12 months for

which data are available preceding the filing of the petition shall be deemed negligible.76  The

statute further provides that subject imports from a single country that account for less than 3

percent of such total imports of the product may not be considered negligible if there are

several countries subject to investigation with negligible imports and the sum of such imports

from all such countries accounts for more than 7 percent of all such merchandise imported into

the United States.77   

                                                                                                                                                                              

(...Continued)

tollee . . .to be part of the domestic industry because it does not engage in production of the like

product.”).    74 Maverick argues that, if the Commission includes processors in the domestic industry, it

should follow its decision in DRAMs and DRAM Modules from Korea (“DRAMs”), Inv. No. 701‐TA‐431

(Final), USITC Pub. 3616 (Aug. 2003), and exclude processors and tollers of subject imports from the

domestic industry.  Maverick characterizes such processors and tollers as being merely a “conduit for . . .

unfairly traded imports.”  Maverick contends that in DRAMs, the Commission generally included

assemblers of uncased DRAMs into cased DRAMs in the domestic industry, but excluded assemblers of

subject imports.  Maverick Posthearing Brief, Exh. 1, 34.  Maverick misreads the DRAMs decision.  There

is no evidence in that decision that the Commission excluded assemblers of subject imports from the

domestic industry.  The Commission considered an argument that DRAMs assembled in the United

States that had been fabricated in third countries should be treated as nonsubject imports.  The

Commission rejected this argument.  It noted that “{i}n effect, what respondents request is for the

Commission to give determinative weight to the ‘quantity and type of parts sourced in the United

States’ factor on a transaction‐by‐transaction basis.”  Pub. 3616 at 10.  In effect, Maverick is doing the

same thing here; it is asking the Commission to give determinative weight to only one of the five factors

that the Commission considers in deciding whether firms engage in sufficient production‐related activity

to be treated as domestic producers.   75 We find no basis to exclude any producer from the domestic industry under the statute’s

related party provision, 19 U.S.C. § 1677(4)(A), and no party has argued that any producer should be

excluded.

76 19 U.S.C. §§ 1671b(a), 1673b(a), 1677(24)(A)(i), 1677(24)(B);  see also 15 C.F.R. § 2013.1

(identifying certain developing countries for purposes of 19 U.S.C. § 1677(24) for which the relevant

negligibility threshold is different in countervailing duty investigations). 77 19 U.S.C. § 1677(24)(A)(ii).  For the purpose of countervailing duty investigations, the

threshold is 9 percent for designated developing countries.  19 U.S.C. § 1677(24)(B).
15

The statute further provides that, even if subject imports are found to be negligible for

purposes of present material injury, they shall not be treated as negligible for purposes of a

threat analysis should the Commission determine that there is a potential that subject imports

from the country concerned will imminently account for more than 3 percent of all such

merchandise imported into the United States, or that there is a potential that the aggregate

volumes of subject imports from all countries with currently negligible imports will imminently

exceed 7 percent of all such merchandise imported into the United States.78

B. Arguments of the Parties

U.S. Steel, the United Steelworkers, and Maverick argue that subject imports from the

Philippines, Taiwan, and Thailand individually will imminently account for more than 3 percent

of total imports, and that the aggregate volume of imports from these countries will imminently

exceed 7 percent of total imports.  Addressing the three countries individually, U.S. Steel and

the United Steelworkers argue that each country is on pace to imminently exceed the 3 percent

level.79

Philippine respondent HLD Clark argues that subject imports from the Philippines are

unlikely to exceed 3 percent of total imports.80  Thai respondent Boly Pipe argues that subject

imports from Thailand are unlikely to exceed 3 percent of total imports and that the aggregate

volume of subject imports from Taiwan, Thailand, and the Philippines is unlikely to exceed 7

percent.81  

C. Analysis

   

During the pertinent 12‐month period for determining negligibility (July 2012‐June

2013), imports from the following five subject countries were above the 3 percent negligibility

threshold:  India (*** percent of total imports), Korea (*** percent), Turkey (*** percent),

Ukraine (*** percent), and Vietnam (5.5 percent).82  We consequently find that imports from

these five subject countries are not negligible.83

Imports from the following three subject countries were below the applicable 3 percent

statutory threshold:  the Philippines (2.2 percent of total imports), Taiwan (*** percent), and

Thailand (0.8 percent).84  The aggregate volume of imports from these countries (*** percent)

                                                       78 19 U.S.C. § 1677(24)(A)(iv).

79 U.S. Steel Prehearing Brief at Exh. 2, 2‐3 and Final Comments (Aug. 18, 2014) at 2‐4.  Maverick

Final Comments (Aug. 18, 2014) at 9‐10.

80 HLD Clark Final Comments (Aug. 18, 2014) at 2‐4.   81 Boly Pipe Final Comments (Aug. 18, 2014) at 3‐5.

82 CR/PR at Table IV‐8.

83 For purposes of countervailing duty investigations, India is among the countries classified as

“developing countries” under 15 C.F.R . § 2013.1, so the negligibility threshold for the countervailing

duty investigation of subject imports from India is 4 percent.  19 U.S.C. § 1677(24)(B).  Subject imports

from India (at *** percent) are above that threshold.  CR/PR at Table IV‐8.

84 CR/PR at Table IV‐8.
16

is below the statutory aggregate 7 percent level during the relevant 12‐month period.  We

therefore determine that imports from these three countries are negligible for purposes of

present material injury.   

We next consider, for purposes of a threat analysis, whether there is a potential that

subject imports from the Philippines, Taiwan, and Thailand will imminently exceed the statutory

negligibility thresholds.  For the reasons provided in the paragraphs below, we find that there is

a potential that subject imports from Taiwan will exceed the 3 percent negligibility threshold,85

but there is not a potential that subject imports from the Philippines and Thailand will exceed

the 3 percent negligibility threshold individually or exceed the 7 percent negligibility threshold

when considered in the aggregate with subject imports from Taiwan.  In reaching these

determinations, we have made reasonable estimates on the basis of available statistics, as we

are permitted to do by the statute.86

Taiwan.  The production capacity of subject producers in Taiwan expanded during the

POI, *** from 2011 to 2012, as one of the subject producers brought a new mill online.87  The

capacity utilization of these producers *** in 2012 (***), and utilization remained at *** levels

throughout the rest of the POI.88  Over the period of investigation, subject imports from Taiwan

were increasing steadily as a share of all imports, from *** percent in 2011 to *** percent in

2012 and then to *** percent in 2013.89  The producer with the ***.90  In the aggregate, subject

producers in Taiwan project that their export shipments to the United States will reach ***

short tons in 2014, increasing from *** short tons in 2013.

To estimate the share of total imports that would be accounted for by subject imports

from Taiwan in the imminent future, we assumed that subject imports from Taiwan would be

*** short tons, the amount projected by subject producers for 2014.  We estimated that total

imports in 2014 would fall in a range between *** short tons and *** short tons.91  Using these

                                                       85 Chairman Broadbent determines that there is not a potential that subject imports from

Taiwan will imminently exceed 3 percent of total imports, and does not join the discussion concerning

Taiwan below, except as it pertains to the estimation of total U.S. imports in 2014. See Separate and

Dissenting Views of Chairman Broadbent.

86 19 U.S.C. §1677(24)(C).

87 The capacity of subject producers in Taiwan increased from *** short tons in 2011 to *** tons

in 2012 and *** in 2013.  Capacity was *** short tons in both January‐March (“interim”) 2013 and

interim 2014.  CR/PR at Table VII‐9.

88 Production of subject producers in Taiwan increased from *** short tons in 2011 to *** short

tons in 2012, and then declined to *** short tons in 2013.  Production was *** short tons in interim

2013 and *** short tons in interim 2014.  CR/PR at Table VII‐9.  Capacity utilization declined from ***

percent in 2011 to *** percent in 2012 and *** percent in 2013.  Capacity utilization was *** percent in

interim 2013 and *** percent in interim 2014. Id.

89 CR/PR at Table IV‐2.

90 CR at VII‐30, PR at VII‐13.

91 We arrived at these estimates of total imports in the following manner.   The lower end of the

range was calculated by annualizing total imports in the first quarter of 2014 (***).  The upper end of

the range was calculated by calculating the ratio of total imports in the first quarter of 2013 to total

imports in all of 2013 (i.e., ***), and then multiplying total imports in the first quarter of 2014 by the

(Continued...)
17

figures, we estimate that subject imports from Taiwan would range between *** percent and

*** percent of total imports in 2014.92  On the basis of these estimates, the increased capacity

and low capacity utilization rates among subject producers in Taiwan, and the steady increase

in subject imports from Taiwan over the POI, we determine that there is a potential that subject

imports from Taiwan will imminently surpass 3 percent of total imports.

The Philippines.  The production capacity of the subject producer in the Philippines

fluctuated in a stable range throughout the POI, except in interim 2014 when it was lower than

in interim 2013.93  The capacity utilization of this producer *** in all parts of the POI ***.94

To estimate the share of total imports that would be accounted for by subject imports

from the Philippines in the imminent future, we assumed that subject imports from the

Philippines would be at their highest annual level during the POI, which was 73,969 short tons

in 2013.95  Using this amount and the estimated range of total imports described above, we

estimate that subject imports from the Philippines would fall in a range between *** percent

and *** percent of total imports in 2014.96  On the basis of these estimates, and the stable

capacity and high capacity utilization rate of the subject producer in the Philippines, we

determine that there is not a potential that subject imports from the Philippines will

imminently surpass 3 percent of total imports.

Thailand.  The Commission received a questionnaire response in the final phase of these

investigations from one subject producer in Thailand, Boly Pipe.  There is one other known

producer of OCTG in Thailand, WSP Pipe Co., Ltd. (“WSP”), and there is evidence in the record

                                                                                                                                                                              

(...Continued)

inverse of that ratio (i.e., ***).  CR/PR at Table IV‐2.  That the annualized Q1 2014 data is “reasonable” is

supported by its use by petitioner U.S. Steel.  U.S. Steel Final Comments (Aug. 18, 2014) at 7 n.35.

92 These estimates were calculated as follows, using the methodology described in footnote 91

above:  ***.

93 The capacity of the subject producer in the Philippines was *** short tons in 2011, *** short

tons in 2012, *** short tons in 2013, *** short tons in interim 2013 and *** short tons in interim 2014.  

CR/PR at Table VII‐5.   U.S. Steel argued that the producer in the Philippines *** to make pipe product.  

U.S. Steel Final Comments (Aug. 18, 2014) at 5.  We note that U.S. Steel relies solely on a Dow Jones

news story that primarily concerns port facilities (U.S. Steel Prehearing Brief at Exh. 68), and we do not

find that this evidence contradicts the reported capacity of the subject producer in the Philippines.  We

note that even if capacity in the Philippines were higher than reported, it would not affect our analysis

because our projections are based on actual import levels and demonstrated production ability, not

capacity.  

94 Capacity utilization rose from *** percent in 2011 to *** percent in 2012 and *** percent in

2013.  Capacity utilization was *** percent in interim 2013 and *** percent in interim 2014.  CR/PR at

Table VII‐4.  The *** in 2011 reflected the fact that the subject producer in the Philippines began OCTG

production in that year.  CR at VII‐15, PR at VII‐8.  The following factors indicate a relatively low ability of

the subject producer in the Philippines to increase shipments to the United States:  the producer’s

relatively small capacity, its high capacity utilization, the fact that the vast majority of its sales are

already exports to the United States, and the absence of inventories.  CR/PR at Table II‐4.

95 CR/PR at Table C‐1.

96 These estimates were calculated as follows, using the methodology described in footnote 91

above:  ***.  
18

that that firm has idled its plant.97 98  The production capacity of Boly Pipe was *** short tons in

2013, the first year in which it was producing OCTG, and is projected to rise to *** short tons in

2014 and *** short tons in 2015.99  Boly’s capacity utilization rate was *** percent in 2013 and

*** percent in interim 2014.100

To estimate the share of total imports that would be accounted for by subject imports

from Thailand in the imminent future, we first estimated what Boly Pipe’s production would be

in 2014.  We did this by assuming that it would reach its projected capacity of *** short tons in

2014 and that it would operate at the same capacity utilization rate in 2014 as it did in 2013

(*** percent).  This would result in production of *** short tons.  We then assumed that all the

increased production in 2014 (*** short tons) would be exported to the United States.  We

added these increased exports to the level of its imports to the United States in 2013 (33,741 +

***) to arrive at an estimate for subject exports to the United States of *** short tons.  Using

that amount and the estimated range of total imports described above, we estimate that

subject imports from Thailand would fall between *** percent and *** percent of total imports

                                                       97 CR at VII‐34, PR at VII‐15.  Boly Pipe, which has its facilities located in the same industrial park

in Thailand as those of WSP, states that WSP idled its plant in November 2013 and that it would take

many months to bring that plant back online, should WSP wish to do so.  Boly Pipe Final Comments

(Aug. 18, 2013) at 7‐8.  U.S. Steel described recent significant financial losses reported by WSP’s Chinese

parent and uncertainty as to the parent’s ability to continue as a going concern.  U.S. Steel Prehearing

Brief at 86. The idling of WSP’s plant in Thailand in November 2013 would be consistent with these

developments.     98 U.S. Steel contends that there are two other mills in Thailand in addition to Boly Pipe and

WSP.  U.S. Steel Final Comments (Aug. 18, 2014) at 6.  One of these “other” mills appears in fact to be

Boly Pipe.  Exhibit 93 to U.S. Steel’s Prehearing Brief describes this new producer, owned by Baosteel  

(Boly Pipe’s parent) and another Chinese partner, called “Baoli Steel Pipe,” which began production in

2013 (the same year that Boly Pipe began production).   

With respect to the issue of a second additional mill in Thailand, we note that the Commission

sent questionnaires in both the preliminary and final phase investigations to all entities named in the

petition as producers of subject merchandise from Thailand, and only Boly Pipe and WSP provided

responses.   There are no publicly available sources identifying other sources of exports to the United

States.  Consequently, the information submitted by reporting Thai producers is the information

available with respect to the OCTG industry in Thailand.  We aIso note that, to the extent that there

were other exporters of subject merchandise from Thailand, their data would be reflected in the official

U.S. import statistics.  The share of total imports represented by subject imports from Thailand

increased by only *** percentage point from 2012 to 2013, and we have projected greater growth

based on data from the foreign producers’ questionnaires than would be reflected by looking at

available full‐year data from all importers.

99 CR/PR at Table VII‐11.  U.S. Steel argued that Boly Pipe *** to make OCTG by over *** metric

tons.  U.S. Steel Final Comments (Aug. 18, 2014) at 6.  We note that U.S. Steel relies solely on an

undated brochure which may or may not reflect Boly Pipe’s true capacity (U.S. Steel Prehearing Brief at

Exh. 98).  We note that even if capacity in Thailand were higher than reported, it would not affect our

analysis because our projections are based on actual import levels, and demonstrated production ability,

not capacity.

100 CR/PR at Table VII‐11.
19

in 2014.101  On the basis of these estimates, we determine that there is not a potential that

subject imports from Thailand will imminently surpass 3 percent of total imports.

Aggregate Analysis.

102  To determine whether there is a potential that subject imports

from the Philippines, Taiwan, and Thailand in the aggregate will imminently exceed 7 percent of

total imports, we added together the numbers for each country, as detailed above.  The sum of

these numbers ranges from *** to *** percent. Thus, even using assumptions that are most

favorable to petitioners, there is not a potential that subject imports from the Philippines,

Taiwan, and Thailand will imminently exceed 7 percent.

For the foregoing reasons, we determine that subject imports from the Philippines and

Thailand are negligible for purposes of both our present material injury analysis and our threat

of material injury analysis and that subject imports from Taiwan are negligible for purposes of

our present material injury analysis, but not for purposes of our threat of material injury

analysis.103

V. Cumulation

A. Background

For purposes of evaluating the volume and price effects for a determination of material

injury by reason of subject imports, section 771(7)(G)(i) of the Tariff Act requires the

Commission to cumulate subject imports from all countries as to which petitions were filed

and/or investigations self‐initiated by Commerce on the same day, if such imports compete

with each other and with the domestic like product in the U.S. market.  In assessing whether

subject imports compete with each other and with the domestic like product, the Commission

generally has considered four factors:

(1) the degree of fungibility between subject imports from different

countries and between subject imports and the domestic like product,

including consideration of specific customer requirements and other  

quality related questions;

(2) the presence of sales or offers to sell in the same geographic markets of

subject imports from different countries and the domestic like product;

                                                       101 These estimates were calculated as follows, using the methodology described in footnote 91

above:  ***.   102 Chairman Broadbent determines that there is not a potential that subject imports from the

Philippines, Taiwan, and Thailand will imminently exceed 7 percent of total imports. See Separate and

Dissenting Views of Chairman Broadbent.

103 Chairman Broadbent determines that subject imports from Taiwan are negligible for

purposes of both the Commission’s present material injury analysis and its threat of material injury

analysis. See Separate and Dissenting Views of Chairman Broadbent.
20

(3) the existence of common or similar channels of distribution for subject

imports from different countries and the domestic like product; and

(4) whether the subject imports are simultaneously present in the market.104

   

While no single factor is necessarily determinative, and the list of factors is not

exclusive, these factors are intended to provide the Commission with a framework for

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

product.105  Only a “reasonable overlap” of competition is required.106

B. Arguments of the Parties

Petitioners argue that the Commission should cumulate subject imports from all

countries.107  The government of India argues that it would be inconsistent with Article 15 of

the WTO Agreement on Subsidies and Countervailing Measures (“SCM Agreement”) for the

Commission to cumulate the effects of imports from countries subject only to antidumping duty

investigations with those of imports subject to countervailing duty investigations, i.e., India and

Turkey.108  The Philippine Respondent argues that subject imports from the Philippines should

not be cumulated with those from other subject countries.109

C. Analysis

With respect to the government of India’s argument, we believe that the Commission’s

long‐standing practice of “cross‐cumulating” imports subject to Commerce’s affirmative subsidy

determinations with imports subject to Commerce’s affirmative dumping determinations, when

the conditions for cumulation are otherwise met, is consistent with U.S. law.110  We recognize

                                                       104 See Certain Cast‐Iron Pipe Fittings from Brazil, the Republic of Korea, and Taiwan, Inv. Nos.

731‐TA‐278‐280 (Final), USITC Pub. 1845 (May 1986), aff’d, Fundicao Tupy, S.A. v. United States, 678 F.

Supp. 898 (Ct. Int’l Trade), aff’d, 859 F.2d 915 (Fed. Cir. 1988).

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

106 The Statement of Administrative Action (SAA) to the Uruguay Round Agreements Act (URAA),

expressly states that “the new section will not affect current Commission practice under which the

statutory requirement is satisfied if there is a reasonable overlap of competition.”  H.R. Rep. No. 103‐

316, Vol. I at 848 (1994) (citing Fundicao Tupy, S.A. v. United States, 678 F. Supp. at 902); see Goss

Graphic Sys., Inc. v. United States, 33 F. Supp. 2d 1082, 1087 (Ct. Int’l Trade 1998) (“cumulation does not

require two products to be highly fungible”); Wieland Werke, AG, 718 F. Supp. at 52 (“Completely

overlapping markets are not required.”).

107 U.S. Steel Prehearing Brief at Exh. 3, 2‐3, Maverick Prehearing Brief at 39.

108 Posthearing Comments from the government of India.

109 Philippine Respondent’s Posthearing Brief at 2‐4.

110 19 U.S.C. § 1677(7)(G).  E.g., Circular Welded Carbon‐Quality Steel Pipe from India, Oman, the

United Arab Emirates, and Vietnam, Inv. Nos. 701‐TA‐482‐484 and 731‐TA‐1191‐1194 (Final), USITC Pub.

4362 at 12 n.59 (Dec. 2012); Softwood Lumber from Canada, Inv. Nos. 701‐TA‐414 and 731‐TA‐928

(Continued...)
21

that a WTO dispute resolution panel recently found this practice to be inconsistent with Article

15 of the SCM Agreement, but this panel report has not been adopted by the WTO Dispute

Settlement Body, and the United States has appealed the panel report.111

The statutory threshold for cumulation is satisfied in these investigations because

Petitioners filed the antidumping/countervailing duty petitions with respect to all nine

countries on the same day, July 2, 2013.112  As explained above, we have found that imports

from the Philippines, Taiwan, and Thailand are negligible for purposes of our analysis of

material injury by reason of subject imports.  Thus, we consider whether to cumulate subject

imports from the remaining five subject countries – India, Korea, Turkey, Ukraine, and Vietnam

– for purposes of this analysis.113  As discussed below, we find that there is a reasonable overlap

of competition among subject imports from these five countries and between subject imports

from each source and the domestic like product.

Fungibility.  Casing and tubing products, regardless of source, are generally produced in

accordance with standards set by the API.114  All responding domestic producers and a majority

of importers and purchasers reported that subject OCTG from the subject countries are always

or frequently used interchangeably with each other and with the domestic like product.  The

remaining domestic producers and importers indicated that subject imports from the subject

countries are sometimes used interchangeably with each other and with the domestic like

product.  No domestic producers or importers reported that subject imports are never used

interchangeably with each other and with the domestic like product.  Most of the remaining

purchasers also reported that subject imports are sometimes used interchangeably with each

other and with the domestic like product; very few of them reported that subject imports are

never used interchangeably with each other and with the domestic like product.115

We recognize that there are several factors that may limit the fungibility between and

among subject imports from each source and the domestic like product.  First, welded and

seamless OCTG are not interchangeable in all applications.  Imports from the subject countries

tended to be concentrated in one product or the other:  imports from Korea, Turkey, and

Vietnam were almost exclusively welded OCTG; imports from Ukraine were exclusively

seamless OCTG; and imports from India were predominantly seamless OCTG.116  Although

seamless OCTG can be used in any application which requires welded OCTG, the reverse is not

true.  Certain high stress applications require seamless OCTG, and the seamless product may

also be preferred in some applications to reduce risk.117  However, a witness for petitioners

                                                                                                                                                                              

(...Continued)

(Final), USITC Pub. 3509 at 29‐31 (May 2009); Bingham & Taylor v. United States, 815 F.2d 1482 (Fed.

Cir. 1987). 111 www.wto.org/english/tratop_e/dispu_e/cases_e/ds436_e.htm. 112 Because the investigation on OCTG from Saudi Arabia has been terminated, those imports

are not eligible for cumulation.  19 U.S.C. § 1677(7)(G)(ii)(II).

113 See 19 U.S.C. § 1677(24)(B)(iv). 114 CR at I‐16‐17, PR at I‐14.

115 CR/PR at Table II‐12.

116 CR at II‐39‐40, PR at II‐29. 117 CR at II‐39, PR at II‐29.
22

estimated that welded OCTG could be used for 70 percent of seamless applications, and a

witness for respondents noted that they are interchangeable in many cases from an

engineering perspective.118   

Fungibility may also be somewhat limited by requirements for proprietary or premium

connections. OCTG producers are unable to offer particular proprietary connections if they do

not have access to the intellectual property rights required to produce those connections,

although these producers would have the option of developing their own proprietary

connections.119  Purchasers reported that for seamless OCTG, 37.4 percent of purchases

required proprietary connections, 8.3 percent preferred proprietary connections, and 54.2

percent were unrestricted.  For welded OCTG, 14.4 percent of purchases required proprietary

connections, 4.2 percent preferred them, and 81.4 percent were unrestricted.120  The record

contains data on shipments broken down by end finish.  Subject imports had little presence in

the “threaded and coupled, proprietary” category.  In 2013, only *** percent of subject import

shipments were in this category, compared to *** percent of domestic producers’

shipments.121  On the other hand, there was substantial overlap in 2013 between shipments of

the domestic product and subject imports in the categories of “threaded and coupled, not

proprietary” and “plain end.”122  

Fungibility may also be somewhat limited by the domestic product and subject imports

being concentrated in different grades.  Whereas there was substantial overlap in 2013

between the domestic product and subject imports in the three grades with the highest

volumes, J‐55, L‐80, and P‐110, the highest volume product for the domestic industry was

higher alloy P‐110, whereas subject imports were concentrated in the more commodity‐like J‐

55 grade.123   

Another factor that may limit fungibility somewhat is the extent to which subject

countries and the domestic industry ship semi‐finished or finished OCTG.  Although a large

proportion of responding purchasers reported buying finished OCTG from both domestic

sources and the subject countries, a relatively larger proportion of the purchasers reported

buying “unfinished at API but upgradable” product from subject countries than from domestic

sources.124

On balance, we find that the record indicates a sufficient degree of substitutability

between and among subject imports and the domestic like product to establish that products

from the different sources are fungible for purposes of a cumulation analysis.

                                                       118 CR at II‐39, PR at II‐29.

119 Hearing Tr. at 297 (Hraibi).

120 CR at II‐41‐42, PR at II‐30. 121 See CR/PR at Table IV‐13 and derived from Table G‐15. 122 See CR/PR at Table IV‐13 and derived from Table G‐15.

123 In 2013, the quantities of U.S. producers’ U.S. shipments and U.S. importers’ U.S. shipments

of subject imports, respectively,  for the three grades with the highest volumes were as follows:  (i) J‐55

– 806,818 shorts tons and *** short tons; (ii) L‐80 – 553,466 short tons and *** short tons; and (iii)

1,727,521 short tons and *** short tons.  CR/PR at Tables IV‐12 and G‐15.    124 CR/PR at Table II‐10.
23

Channels of Distribution.  Subject imports and the domestic like product shared the

same channels of distribution.  During the POI, all domestically produced and most subject

imports from each source were shipped to distributors.

Geographic Overlap.  The majority of imports from each subject country are

concentrated in the Central Southwest.125  The Pacific Coast received the second greatest

coverage by subject imports, with imports from all subject countries serving that region.  All

responding U.S. producers reported making sales to the Central Southwest, and eight of 13

reported making sales to the Pacific Coast region.126

Simultaneous Presence in Market.  Subject imports from each subject country were

present in the United States in each year of the POI and in interim 2014.127  Subject imports

from each subject country were present in the majority of the 39 months of the POI.128

Conclusion.  In sum, because the relevant antidumping duty petitions and countervailing

duty petitions were filed on the same day, and the record indicates that there is a reasonable

overlap of competition between and among subject imports and the domestic like product, we

analyze subject imports from India, Korea, Turkey, Ukraine, and Vietnam on a cumulated basis

for our analysis of material injury by reason of subject imports.

VI. Material Injury by Reason of Subject Imports from India, Korea, Turkey,

Ukraine, and Vietnam  

Based on the record in the final phase of these investigations, we find that an industry in

the United States is materially injured by reason of imports of OCTG from India, Korea, Turkey,

Ukraine, and Vietnam found by Commerce to be sold in the United States at less than fair value

and imports of the subject merchandise from India and Turkey found by Commerce to have

been subsidized by the governments of India and Turkey.

A. Legal Standards

In the final phase of antidumping and 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.129  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 operations.130  The statute defines

                                                       125 CR at II‐3, PR at II‐3, and CR/PR at Table II‐2.

126 CR at II‐3, PR at II‐3, and CR/PR at Table II‐2.

127 CR/PR at Table IV‐14.

128 CR/PR at Table IV‐14.

129 19 U.S.C. §§ 1671d(b), 1673d(b).

130 19 U.S.C. § 1677(7)(B).  The Commission “may consider such other economic factors as are

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

the determination.”  19 U.S.C. § 1677(7)(B).
24

“material injury” as “harm which is not inconsequential, immaterial, or unimportant.”131  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.132  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.”133

Although the statute requires the Commission to determine whether the domestic

industry is “materially injured or threatened with material injury by reason of” unfairly traded

imports,134 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.135  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.136

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 nonsubject 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.137  In performing its examination, however, the Commission need not isolate

                                                       131 19 U.S.C. § 1677(7)(A).

132 19 U.S.C. § 1677(7)(C)(iii).

133 19 U.S.C. § 1677(7)(C)(iii).

134 19 U.S.C. §§ 1671d(a), 1673d(a).

135 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).

136 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).

137 SAA at 851‐52 (“{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‐

(Continued...)
25

the injury caused by other factors from injury caused by unfairly traded imports.138  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 nonsubject imports, which may be contributing to overall injury to an industry.139  It is

clear that the existence of injury caused by other factors does not compel a negative

determination.140

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.”141 142  Indeed, the Federal Circuit has examined and affirmed various

Commission methodologies and has disavowed “rigid adherence to a specific formula.”143

                                                                                                                                                                              

(...Continued)

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

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.

138 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, 266 F.3d at 1345 (“{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, 132 F.3d at 722 (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.”).

139 S. Rep. 96‐249 at 74‐75; H.R. Rep. 96‐317 at 47.    140 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.”). 141 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.  
26

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 price‐competitive nonsubject 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 nonsubject imports.144  The additional “replacement/benefit”

test looked at whether nonsubject 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 nonsubject imports or other factors to

subject imports.145  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 nonsubject imports are a significant

                                                                                                                                                                              

(...Continued)

142 Vice Chairman Pinkert does not join this paragraph or the following three paragraphs.  He

points out that the Federal Circuit, in Bratsk, 444 F.3d 1369, and Mittal Steel, held that the Commission

is required, in certain circumstances when considering present material injury, to undertake a particular

kind of analysis of non‐subject imports, albeit without reliance upon presumptions or rigid formulas.  

Mittal Steel explains as follows:

What Bratsk held is that “where commodity products are at issue and fairly traded, price

competitive, non‐subject 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.   

542 F.3d at 878.   143 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.”). 144 Mittal Steel, 542 F.3d at 875‐79.

145 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).
27

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.146

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 standard.147  Congress has delegated this factual finding to the Commission because

of the agency’s institutional expertise in resolving injury issues.148

B. Conditions of Competition and the Business Cycle  

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

injury by reason of subject imports.149  

1. Demand Considerations

Demand for OCTG is cyclical, is largely driven by the level of activity in the U.S. economy,

and is derived from the demand for oil and natural gas exploration and drilling.150  Because oil

and natural gas prices partly influence drilling activity, these prices also drive the demand for

OCTG.151  The quantity of OCTG used in oil and natural gas exploration and extraction is

determined by the number of rigs that are operating as well as the length and depth of the

wells being drilled.152

OCTG demand rose during the POI, especially from 2011 to 2012.  Apparent U.S.

consumption of OCTG increased from 6.0 million short tons in 2011 to 7.0 million short tons in

2012 and remained at 7.0 million short tons in 2013.153 154  Other measures of OCTG demand

                                                       146 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 nonsubject countries that accounted for substantial shares of U.S. imports of subject

merchandise (if, in fact, there were large nonsubject 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 nonsubject imports. 147 We provide in our respective discussions of volume, price effects, and impact a full analysis of

other factors alleged to have caused any material injury experienced by the domestic industry.

148 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.”).    149 These conditions of competition also inform our analysis, discussed below, of whether the

U.S. industry is threatened with material injury by reason of subject imports from Taiwan.   150 CR at II‐15, PR at II‐11.   151 CR at II‐15, PR at II‐11.

152 CR at II‐18, PR at II‐13.

153 CR/PR at Table IV‐16.  Apparent consumption was 1.6 million short tons in interim 2013 and   

1.8 million short tons in interim 2014.     
28

increased over the POI, particularly in the early part.155  Specifically, rig count increased

between 2011 and 2012, then declined in late 2012, before stabilizing in 2013.156  Operator

consumption figures, which track OCTG used by well operators, increased from 2011 to 2012,

declined irregularly until the first quarter of 2013, and then rose steadily after that.157   

Most responding producers, importers, and purchasers reported that OCTG demand in

the United States has increased since 2011.158  Respondents generally agreed with this

assessment.159  The reasons given by market participants for this increase in demand mostly

focused on the development of shale plays, increased drilling, and increased OCTG

requirements per rig due to horizontal drilling.160  Horizontal drilling and hydraulic fracturing

(“fracking”) have played an increasing role in oil and gas exploration.161  Because both

techniques allow wells to reach greater distances, the footage of OCTG used in fracking and/or

horizontal drilling can be greater on a per well basis than the footage used in traditional vertical

wells.162   

2. Supply Considerations

The 17 domestic producers that responded to the Commission’s U.S. producers’

questionnaire accounted for the vast majority of OCTG produced in the United States.163  The

                                                                                                                                                                              

(...Continued)

154 As explained in Section III above, we have defined the domestic industry producing OCTG to

include not only mills that roll OCTG, but also processors that engage in heat treatment.  In measuring

apparent U.S. consumption by volume, however, we have included the U.S. shipments of only the mills

and not the processors.  CR/PR at Table IV‐15.  We have done this because including all U.S. shipments

of processors would lead to double counting on a quantity basis because all OCTG shipped by processors

has already been counted as a shipment by a U.S. mill or as an import.   155 CR/PR at Figures II‐3, II‐4, and II‐5.

156 CR/PR at Figure II‐3.  The number of rigs in the United States was around 1,700 at the

beginning of 2011, rose to around 2,000 in late 2011 and early 2012, remained at that level until mid‐ 

2012, declined to about 1,750 by early 2013, and remained roughly at that level through the first

quarter of 2014.

157 CR/PR at Figure II‐4.  Operator consumption levels were about 430,000 net tons at the

beginning of 2011, rose to about 550,000 net tons in late 2011, declined to about 470,000 net tons in

the first quarter of 2013, and then rose to about 570,000 net tons by the end of the first quarter of

2014.

158 CR/PR at Table II‐5.

159 Korean Respondent Group Prehearing Brief at 7‐10, Borusan Prehearing Brief at 8‐10,

Ukrainian Respondents’ Prehearing Brief at 6‐9, and Saudi Respondents’ Prehearing Brief at 8‐14

160 CR at II‐20, PR at II‐16.

161 CR at II‐1, PR at II‐1.  The proportion of rigs that employ horizontal drilling has

increased substantially in recent years, rising from 20 percent of total rigs at the beginning of 2007 to

more than 56 percent at the beginning of 2010 and reaching 67 percent in March 2014.  CR at II‐19, PR

at II‐15 and CR/PR at Figure II‐8.

162 CR at II‐1, PR at II‐1.     163 CR at III‐1, PR at III‐1.
29

capacity of U.S. mills producing OCTG increased from 5.0 million short tons in 2011 to 5.2

million short tons in 2012 and 5.8 million short tons in 2013.164  The capacity of U.S. processors

producing OCTG increased from 674,376 short tons in 2011 to 996,876 short tons in 2012 and

1.1 million short tons in 2013.165  Capacity utilization of U.S. mills increased from 67.6 percent in

2011 to 69.2 percent in 2012 and 70.8 percent in 2013.166  The capacity utilization of U.S.

processors producing OCTG decreased from 76.0 percent in 2011 to 69.6 percent in 2012

before increasing to 71.6 percent in 2013.167  U.S. producers have planned further expansions

and additional plant openings in 2014, but have also shut down and idled some facilities.168

The 31 subject producers/exporters of OCTG that responded to the Commission’s

questionnaires accounted for all or virtually all imports of OCTG in 2013 from seven of the eight

subject countries in these investigations.169  Combined capacity in the five subject countries

which we cumulated for our analysis of material injury by reason of subject imports (India,

Korea, Turkey, Ukraine, and Vietnam) rose from *** short tons in 2011 to *** short tons in

2012 and *** short tons in 2013.170 171 172  Total capacity utilization for the industries in these

five subject countries rose from *** percent in 2011 to *** percent in 2012 and then declined

to *** percent in 2013.173 174  

Imports from nonsubject countries were present in the U.S. market throughout the

POI.175  They originated from a variety of countries, including Argentina, Austria, Canada,

                                                       164 CR/PR at Table III‐4.  The capacity of these mills was 1.4 million short tons in interim 2013 and

1.5 million short tons in interim 2014.

165 CR/PR at Table III‐4.  The capacity of these processors was 257,642 short tons in interim 2013

and 320,084 short tons in interim 2014.  Id.

166 CR/PR at Table III‐4.  Capacity utilization of U.S. mills was 72.4 percent in interim 2013 and

72.0 percent in interim 2014.  Id.

167 CR/PR at Table III‐4.  The capacity utilization of these processors was 67.9 percent in interim

2013 and 73.5 percent in interim 2014. Id.

168 CR/PR at Table III‐2b.    169 CR at VII‐4, 10, 15, 29, 34, 39, and 45; PR at VII‐3, 5, 8, 13, 15, 17, and 19.  Responding

producers/exporters from Vietnam accounted for only *** percent of imports of OCTG from Vietnam in

2013. CR at VII‐51, PR at VII‐21.

170 CR/PR at Table G‐12.  Capacity in these five countries was *** short tons in interim 2013 and

*** short tons in interim 2014. 171 Capacity of the subject producers in Taiwan rose from *** short tons in 2011 to *** short

tons in 2012, remained at that level in 2013, and was *** short tons in both interim 2013 and interim

2014.  CR/PR at Table VII‐9.   Chairman Broadbent does not join in this footnote.   172 As noted above, Chairman Broadbent determines that subject imports from Taiwan are

negligible for purposes of both the Commission’s present material injury analysis and its threat of

material injury analysis. As such, she does not join any analysis of subject imports from Taiwan within

this section.

173 CR/PR at Table G‐12.  Capacity utilization for the industries in these five subject countries was

*** percent in interim 2013 and *** percent in interim 2014. 174 Capacity utilization in Taiwan fell from *** percent in 2011 to *** percent in 2012 and ***

percent in 2013; it was *** percent in interim 2013 and *** percent in interim 2014.  CR at Table VII‐9.

175 CR/PR at Table IV‐3.
30

Germany, Japan, and Mexico.  Several domestic producers have affiliates that produce OCTG in

nonsubject countries such as ***.176  OCTG imports from China have all but disappeared from

the U.S. market after antidumping and countervailing duty orders were imposed on OCTG from

China in 2010.177

A sizable portion of imports from subject and, to some degree, nonsubject sources

consists of OCTG products that are further processed in the United States, such as green tubes

that may not have been heat treated or threaded, as well as plain‐end pipe that may have been

heat treated but not threaded.178

Inventories of U.S.‐produced OCTG and OCTG from subject and nonsubject countries

held by purchasers are also a source of current supply.  U.S. inventory levels expressed in

months of supply on hand reached a trough of 4.2 months in January 2012, but then increased

until October 2012.  After dipping slightly at the end of 2012, U.S. inventories increased until

the fourth quarter of 2013 and then dropped again in the first quarter of 2014.179

3. Substitutability

OCTG is produced according to standards and specifications published by a number of

organizations, including the API.180  Once a mill passes inspection and obtains API certification,

it may begin marketing its OCTG as API grade.181  OCTG is usually produced in accordance with

API specification 5CT, which encompasses 11 separate grades of casing and tubing.182  OCTG is

produced in two forms:  seamless and welded.183

There is a moderate to high degree of substitutability between U.S.‐produced OCTG and

imported OCTG that is of the same API grade and type.184  All responding domestic producers

and a majority of importers and purchasers reported that subject imports of OCTG from the

subject countries are always or frequently used interchangeably with each other and with the

domestic like product. The remaining domestic producers and importers indicated that subject

imports from the subject countries are sometimes used interchangeably with each other and

with the domestic like product.  No domestic producers or importers reported that subject

imports are never used interchangeably with each other and with the domestic like product.  

Most of the remaining purchasers also reported that subject imports are sometimes used

interchangeably with each other and with the domestic like product; very few of them reported

                                                       176 CR/PR at Table III‐1 notes 5, 6, 7, 8, 12, 14, 15, and 16. 177 Exhibit to Testimony by U.S. Steel entitled “Trade Relief Against Chinese Imports Has Been

Extremely Effective.”

178 CR/PR at Tables G‐4 and IV‐11.

179 CR/PR at Figure II‐1.

180 CR at I‐16‐17, PR at I‐13.  While other organizations and standards exist, for the purposes of

these investigations, we will identify different grades of OCTG using API standards and specifications.   181 CR at II‐13, PR at II‐24.

182 CR at I‐22, PR at I‐19.   183 CR at I‐16, PR at I‐13.

184 CR at II‐24, PR at II‐18.  
31

that subject imports are never used interchangeably with each other and with the domestic like

product.185

We recognize that substitutability between subject imports and the domestic like

product may be somewhat limited by a number of factors, including differences between

seamless and welded OCTG, differences between “upgradeable” and finished OCTG, the

concentration of subject imports and the domestic like product in different grades, the

limitation of proprietary connections mostly to the domestic like product, and the use of

program sales.  We discuss each of these in turn below.

Seamless and Welded OCTG.  Imports from each of the subject countries tended to be

concentrated in either welded or seamless OCTG.   Imports from Korea, Turkey, and Vietnam

were almost exclusively welded OCTG; imports from Ukraine were exclusively seamless OCTG;

and imports from India were predominantly seamless OCTG.186  Production by the domestic

industry was more equally divided, with a small preponderance of seamless product.187  

Regardless of whether a subject country’s imports were concentrated in one or the other type

of OCTG, they compete at least with the domestic industry’s production of that type of product.  

Moreover, there is a significant degree of interchangeability between welded and seamless

OCTG, notwithstanding that welded and seamless OCTG are not interchangeable in all

applications.  Seamless OCTG can be used in any welded OCTG application.  The reverse is not

true, however, because certain high‐stress applications require seamless OCTG, and the

seamless product may also be preferred in some applications to reduce risk.188  In short,

differences between seamless and welded OCTG do not significantly limit competition between

cumulated subject imports and the domestic like product.

“Upgradeable” and Finished OCTG.  We recognize that some subject imports are

imported in the condition of “at API but upgradeable” and that a larger proportion of subject

imports than U.S. producers’ U.S. shipments are in this condition.189  Nonetheless, a large and

increasing proportion of subject imports were either “at final API but needs end finishing” or

“finished OCTG” – the two categories in which most U.S. producers’ U.S. shipments were

concentrated.190  OCTG that is “at final API but needs end finishing” requires relatively little

                                                       185 CR/PR at Table II‐12.

186 CR at IV‐17, PR at IV‐12.  Additionally, imports from Taiwan were almost exclusively welded

OCTG.

187 CR at IV‐17, PR at IV‐12.

188 CR at II‐39, PR at II‐29.   A witness for petitioners estimated that welded OCTG could be used

for 70 percent of seamless applications, and a witness for respondents noted that they are

interchangeable in many cases from an engineering perspective.  Conference Tr. pp. 109 (Matthews)

and 261 (Brewer).

189 For example, in 2013, *** percent of U.S. importers’ U.S. imports from India, Korea, Turkey,

Ukraine, and Vietnam consisted of “at API but upgradeable” product (See CR/PR at Table G‐5), whereas

only *** percent of U.S. producers’ U.S. shipments were in this category.  See CR/PR at Table IV‐9.

190 For example, in 2013, *** percent of U.S. importers’ U.S. imports from India, Korea, Turkey,

Ukraine, and Vietnam were in these two product categories (See CR/PR at Table G‐5), as were ***

percent of U.S. producers’ U.S. shipments.  See CR/PR at Table IV‐9.
32

further processing before becoming a finished product.191  Thus, the fact that some subject

imports are imported in the condition of “at API but upgradeable” does not alter our conclusion

that there is a moderate to high degree of substitutability between U.S.‐produced OCTG and

imported OCTG that is of the same API grade and type.   

Different Grades of OCTG.  We recognize that particular OCTG grades constitute

different percentages of subject imports from India, Korea, Turkey, Ukraine, and Vietnam on

the one hand, and the domestic like product on the other.  For example, in 2013, the individual

grade with the largest volume for subject imports was J‐55, while it was P‐110 for the

domestically produced product.192  Nonetheless, for both the subject imports and the domestic

like product, substantial volumes of shipments were concentrated in the same three OCTG

grades:  J‐55, L‐80, and P‐110.193  The largest volume of U.S. importers’ U.S. shipments from

subject sources in 2013 was in the J‐55 grade, at *** short tons, compared to the 806,818 short

tons of U.S. shipments from U.S. producers.194  Thus, the varying percentages that individual

grades represent of the subject imports and the domestic like product do not indicate

significantly limited competition between subject imports and the domestic like product.  

The evidence in the record as to trends in the types of OCTG consumed in the United

States during the POI is mixed.  Petitioners maintain that changes in technology, specifically a

shift to horizontal oil drilling and pad drilling, have altered the type of OCTG consumed by wells,

and that because horizontal rigs generally are onshore in nonhostile environments, they do not

generally require premium or proprietary connections.  This and the standardization of drilling

patterns have led to increased use of standard, API‐grade OCTG products that constitute the

bulk of subject imports, according to Petitioners.  Petitioners estimate that about 80 percent of

U.S. demand is for standard, API‐grade OCTG.195  Respondents, on the other hand, maintain

that the recent increased use of horizontal drilling and of hydraulic fracturing has, in fact,

shifted the composition of U.S. OCTG demand away from basic API grades and toward

increased use of high grade and specialty OCTG products, including those with proprietary

premium connections – products that are not available from subject imports, but are available

from domestic producers and nonsubject import sources affiliated with domestic producers.196  

The majority of producers and importers responding to the Commission’s questionnaires

reported that the increase in demand for OCTG used in horizontal drilling has led to greater

                                                       191 See CR at I‐32, PR at I‐25.

192 CR/PR at Tables G‐15 and IV‐12.

193 In 2013, 91.8 percent of shipments of subject imports from India, Korea, Turkey, Ukraine, and

Vietnam were in these three grades (See CR/PR at Table G‐5), as were 79.2 percent of U.S. producers’

U.S. shipments.   See CR/PR at Table IV‐12.  In 2013, the quantities of U.S. producers’ U.S. shipments and

U.S. importers’ U.S. shipments of subject imports, respectively,  for these three grades were :  (i) J‐55 –

806,818 shorts tons and *** short tons; (ii) L‐80 – 553,466 short tons and *** short tons; and (iii)

1,727,521 short tons and *** short tons.  CR/PR at Tables IV‐12 and G‐9.

194 CR/PR at Tables G‐15 and IV‐12.

195 E.g., Maverick Prehearing Brief at 19‐23.

196 Korean Respondent Group Prehearing Brief at 7‐10, Borusan Prehearing Brief at 8‐10,

Ukrainian Respondents’ Prehearing Brief at 6‐9, Saudi Respondents’ Prehearing Brief at 8‐14,
33

demand for higher‐grade OCTG, such as more heat‐treated or alloy grade OCTG.197  We

conclude that, regardless of the nature of trends in the types of OCTG consumed in the United

States during the POI, the record shows that subject imports and the domestic like product

were both represented in the major types of OCTG.

Proprietary Connections.  As discussed above in connection with cumulation, the

requirement to supply proprietary connections limits substitutability for certain sales.  We note,

however, that most of the domestic industry’s shipments do not involve OCTG with proprietary

connections.198  Moreover, subject imports were also present in this part of the market.199  

Thus, the demand for proprietary connections does not significantly limit competition between

subject imports and the domestic like product.

Program Sales.  Program sales are non‐contractual obligations between mills,

distributors, and end users which encompass what type of OCTG is to be supplied, when it will

be supplied, and at what price it will be supplied.200  We recognize that program sales are an

important means for making sales for the domestic industry201 and that subject imports

participate in these types of sales arrangements to a considerably lesser degree.202  This does

not mean, however, that domestically produced OCTG sold pursuant to these arrangements is

insulated from price competition from subject imports.  Many market participants reported

that the terms of program sales are not legally binding.203  Thus, the pricing terms of these

program sales could be subject to renegotiation to reflect pricing pressure brought by subject

imports or any other source of supply.  Moreover, even to the extent that pricing terms in

program sales are legally binding, these terms are affected by published price indexes,204 which

in turn are affected by external pricing pressure.  In short, the domestic industry’s use of

program sales does not significantly limit competition between subject imports and the

domestic like product.

We have also considered the foregoing factors in the aggregate and we conclude that,

even when considered in such a manner, they do not significantly attenuate competition

between the subject imports and the domestic like product.  At most, the factors cited by the

respondents focus on product characteristics, or, in the case of program sales, the nature of the

sales process.  They indicate – both individually and in the aggregate – that there is not a

perfect overlap between the cumulated subject imports and the domestic like product.  

Nevertheless, respondents do not explain how these factors operate in the aggregate to shield

the domestic industry from competition by the subject imports, and the record does not

                                                       197 CR at II‐21, PR at II‐16.

198 For example, in 2013 only *** percent of U.S. producers’ U.S. shipments had such

connections.  CR/PR at Table IV‐13.

199 For example, in 2013, U.S. importers reported shipping *** short tons from India, Korea,

Turkey, Ukraine, and Vietnam with proprietary connections.  CR/PR at Table G‐15.

200 CR at II‐42, PR at II‐31.

201 In 2013, *** percent of the domestic industry’s sales were program sales.  CR/PR at Table V‐

3.   202 See CR/PR at Table V‐3.

203 CR/PR at Table V‐5.

204 See, e.g., U.S. Purchasers’ Questionnaire Responses of ***, at III‐25(i).
34

indicate that there is a lack of competition between the domestic like product and the subject

imports in any significant and discrete segment of the market.  To the contrary, the record

indicates significant competition between the domestic like product and the cumulated subject

imports.

4. Other Conditions

The primary raw materials used to make OCTG are hot‐rolled steel and billets (and

associated inputs such as coke, scrap, pig iron, and hot‐briquetted iron).  Raw materials as a

share of the cost of goods sold for domestic OCTG mills decreased from 59.3 percent in 2011 to

58.3 percent in 2012 and increased to 59.0 percent in 2013; they were 58.1 percent in interim

2014 and 59.3 percent in interim 2013.205  

C. 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.”206

Cumulated subject imports from India, Korea, Turkey, Ukraine, and Vietnam had a

substantial presence in the U.S. market throughout the POI.  Cumulated subject imports

increased from *** short tons in 2011 to *** short tons in 2012, and remained at that level in

2013.207  The absolute volume of cumulated subject imports had increased sharply since 2010,

when Commerce issued antidumping and countervailing duty orders on OCTG from China.208  

As explained above, apparent U.S. consumption rose during the POI, increasing by 16.4 percent

between 2011 and 2012 and by 0.3 percent between 2012 and 2013, for an overall increase of

16.8 percent between 2011 and 2013.209  The volume of cumulated subject imports rose much

faster, increasing by *** percent between 2011 and 2012 but decreasing by *** percent

between 2012 and 2013, for an overall increase of *** percent between 2011 and 2013.210

The market share (by quantity) of cumulated subject imports from India, Korea, Turkey,

Ukraine, and Vietnam increased from *** percent in 2011 to *** percent in 2012 and then

                                                       205 CR/PR at V‐1.

206 19 U.S.C. § 1677(7)(C)(i).

207 CR/PR at Table G‐8.  Cumulated subject imports were *** short tons in interim 2013 and ***

short tons in interim 2014.   208 CR/PR at Table G‐1; Certain Oil Country Tubular Goods From the People’s Republic of China:  

Amended Final Affirmative Countervailing Duty Determination and Countervailing Duty Order, 75 Fed.

Reg. 3203 (Jan. 20, 2010); Certain Oil Country Tubular Goods From the People’s Republic of China:  

Amended Final Determination of Sales at Less Than Fair Value and Antidumping Duty Order, 75 Fed. Reg.

28551 (May 21, 2010).

209 CR/PR at Table C‐1.  Apparent U.S. consumption in interim 2014 was 14.7 percent higher than

in interim 2013.  Id.

210 CR/PR at Table G‐8.  The volume of cumulated subject imports in interim 2014 was ***

percent higher than in interim 2013.  Id.  
35

declined slightly to *** percent in 2013.211 212  The gain in market share by subject imports

between 2011 and 2012 came mostly at the expense of the domestic industry, whose market

share decreased from 52.5 percent in 2011 to 48.7 percent in 2012.  Between 2012 and 2013,

the domestic industry’s market share rose from 48.7 percent to 53.5 percent, and this gain

came at the expense of nonsubject imports.213  Nonsubject imports’ market share decreased

*** percentage points from *** percent in 2011 to *** percent in 2013.214  

We find that the cumulated volume of subject imports, and the increase in that volume,

are significant in absolute terms.215

                                                       211 CR/PR at Table G‐9.  Cumulated subject imports held *** percent of U.S. market share (by

quantity) in interim 2013 and *** percent in interim 2014.    212 As explained above, in measuring apparent U.S. consumption by volume, in order to avoid

double‐counting, we have included the U.S. shipments of only the OCTG mills and not the processors.   213 For purposes of this section, “nonsubject imports” are those from sources not subject to

these investigations.  CR/PR at Table IV‐8.  The domestic industry’s market share was 51.6 percent in

interim 2012 and 54.2 percent in interim 2013.  Id.

214 CR/PR at Table G‐9.  The market share of nonsubject imports was *** percent in interim

2014, higher than the *** in interim 2013.  Id.

215 ILJIN argues that the Commission should exclude from its volume and price effects analysis all

imports of green tubes that are, after importation, processed by heat treating as well as by other

processes (such as threading and coupling, upsetting and quality testing) before being sold in the U.S.

merchant OCTG market.  ILJIN argues that this result is compelled by the Commission’s decisions in

Certain Wax and Wax/Resin Thermal Transfer Ribbons from France and Japan, Inv. Nos. 731‐TA‐1039‐

1040, and Certain Lightweight Thermal Paper from China and Germany, Inv. Nos. 701‐TA‐451 and 731‐

TA‐1126‐1127.  ILJIN Prehearing Brief at 13‐18.

We disagree with ILJIN’s argument.  ILJIN reads too much into the Commission’s decisions in

Thermal Transfer Ribbons and Lightweight Thermal Paper.  Thermal Transfer Ribbons involved a

situation where imports consisted entirely of semi‐finished products (jumbo rolls) processed by

slitters/converters (which were deemed part of the domestic industry) into finished products (TTR).  The

Commission rejected an argument by petitioners in those investigations that the Commission should

measure shipments and market share of the subject imports on the basis of shipments of finished TTR

(USITC Pub. 3683 at 23), and it discounted price comparisons that included finished TTR in the import

data (USITC Pub. 3683 at 24).  On remand, the Commission adopted its conclusion from the original

views that price trends for sales of TTR produced by slitters/converters from imported jumbo rolls

“could not have resulted from subject import competition because the reported pricing data {for two of

the pricing products} reflect competition among domestic producers.”  USITC Pub. 3854 at 7.

In Lightweight Thermal Paper the Commission declined to cumulate imports of finished slit rolls

from China with imports of unslit jumbo rolls from Germany because it found that the imports were not

functionally interchangeable upon importation.  USITC Pub. 4043 at 14.   

Although in these investigations the Commission considered how to avoid double‐counting

imported merchandise subsequently processed in the United States, they do not support ILJIN’s

proposition that the Commission should entirely exclude semifinished imported products that are within

the scope definition from the volume and price effects analyses.

We agree with ILJIN only insofar as it would be inappropriate to treat sales of imported green

tube that have been heat treated in the United States as sales of subject imports for purposes of price

(Continued...)
36

D. Price Effects of the Subject Imports

Section 771(7)(C)(ii) of the Tariff Act provides that evaluating the price effects of the

subject imports, 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.216

As explained in Section VI.B.3. above, the record indicates that there is a moderate to

high degree of substitutability between subject imports and domestically produced OCTG made

to the same specifications and that price is an important factor in purchasing decisions.  We

recognize that price is not the only important factor in pricing decisions.  In a ranking of factors

used in purchasing decisions as reported by U.S. purchasers, quality was the most frequently

cited most important factor (cited by 31 purchasers), followed by price (19 purchasers); price

was the most frequently reported second‐ and third‐most important factor (16 and 18

purchasers, respectively).217  The importance of quality as a purchasing factor is mitigated

somewhat by the fact that OCTG, regardless of source, is produced to API specifications.

The Commission collected quarterly pricing data on six OCTG products.218  Ten U.S.

producers and 18 importers219 provided usable pricing data for sales of the requested products,

although not all firms reported pricing for all products and all quarters.220

                                                                                                                                                                              

(...Continued)

comparisons.  No such sales are included in the Commission’s price data.  CR at V‐15‐16 n.11, PR at V‐9

n.11.

216 19 U.S.C. § 1677(7)(C)(ii).

217 CR at II‐28, PR at II‐21, CR/PR at Table II‐8.  Lead times and availability were also noted as

important factors determining purchasers’ sourcing decisions.  Id.

218 The pricing products were:  Product 1 ‐‐ Tubing, Grade L‐80, 2 7/8" O.D., 6.5 lbs./ft., threaded

and coupled, range 2, seamless; Product 2 ‐‐ Tubing, Grade J‐55, 2 3/8" O.D., 4.7 lbs./ft., threaded and

coupled, range 2, welded; Product 3 ‐‐ Casing, Grade J‐55, 5 1⁄2" O.D., 17.0 lbs./ft., threaded and coupled,

range 3, welded; Product 4 ‐‐ Casing, Grade P‐110, 5 1⁄2" O.D., 17.0 lbs./ft., threaded and coupled, range

3, seamless; Product 5 ‐‐ Casing, Grade J‐55, 8 5/8" O.D., 32.0 lbs./ft., threaded and coupled, range 3,

welded; and Product 6 ‐‐ Casing, Grade J‐55, 9 5/8" O.D., 36.0 lbs./ft., threaded and coupled, range 3,

welded.   CR at V‐15, PR at V‐9.   Firms that had supplied pricing data for seamless products 1 and 4 were

asked to divide their sales for those products among OCTG that had API‐standard threading and OCTG

that had non‐API standard threading.  CR at V‐15‐16, PR at V‐9.   We did not use data for pipe with

non‐API standard threading in our analysis of quarterly pricing data.

219 These were importers of subject merchandise from the five subject countries which we

cumulated for our analysis of material injury.

220 CR at V‐15, PR at V‐9.  Reported pricing products represented 11.6 percent of U.S. shipments

of U.S.‐produced products during the POI and *** percent of shipments of imported product from India,

(Continued...)
37

The quarterly pricing data show that the subject imports undersold the domestic like

product in 165 of 189 possible comparisons and oversold the domestic like product in the

remaining 24 instances.221  The margins of underselling ranged from *** percent to ***

percent, and the average margin of underselling was *** percent.222  Given the high frequency

of underselling and the fact that price is an important consideration in purchasing decisions, we

find the underselling to be significant.223

We are not persuaded by respondents’ contention that the observed underselling can

be attributed to price premiums commanded by the domestic like product.224  Almost an equal

number of purchasers reported that they were not willing to pay a price premium for

domestically produced OCTG as reported that they were willing to pay such a premium.225  

Moreover, a representative from a major distributor of OCTG testified that “for like products,

for like quality from mills that make commensurate products, there is not a serious or a real

measureable increase or premium for domestic product.”226  Because price is important to

purchasing decisions, the fact that some purchasers may be willing to pay a higher price for a

domestically produced product does not mean that domestic producers can establish price only

with such purchasers in mind.  They must price for purchasers generally, including the

substantial numbers who will not pay higher prices, as a purchaser presumably will not be

willing to pay a higher price for the same product than a competitor pays.227  This is particularly

true given the prevalence of short‐term and spot sales in the market.228  We also note that for

the largest individual source of subject imports, Korea, a substantial majority of purchasers

                                                                                                                                                                              

(...Continued)

*** percent of shipments of imported product from Korea, *** percent of shipments of imported

product from Turkey, *** percent of shipments of imported product from Ukraine, and *** percent of

shipments of imported product from Vietnam.  CR at V‐16, PR at V‐9‐10.    221 CR/PR at Table G‐10.    222 CR/PR at Table G‐10.

223 While we typically rely on AUV data with caution because differences in AUVs can reflect

differences in product mix, we note that AUV data for U.S. producers’ U.S. shipments and subject

imports from India, Korea, Turkey, Ukraine, and Vietnam in 2013 corroborate the underselling observed

in the quarterly price comparisons.  We collected AUV data for U.S. producers’ U.S. shipments and U.S.

importers’ U.S. shipments of subject imports for 14 grades of OCTG in 2013.  Subject imports were

present in 10 of these grades.  The AUV of subject imports was less than that of the domestic like

product for each of these grades.  In the aggregate, the AUV of U.S. producers’ U.S. shipments in 2013

was $*** per short ton, and the AUV for U.S. importers’ U.S. shipments of cumulated subject imports

was $*** per short ton.  CR/PR at Tables IV‐12 and G‐15.

224 E.g., Korean Respondent Group Prehearing Brief at 22‐23.

225 When comparing OCTG from the five subject countries individually with OCTG produced

domestically, 119 purchaser responses indicated that they were not willing to pay more for the domestic

like product, and 121 responses indicated that they were willing to pay a premium.  CR/PR at Table II‐16.

226 Hearing Tr. at 194 (Miller).

227 As noted by a representative of a major OCTG distributor, market participants are able to see

the latest pricing data from across the country in publications like Preston Pipe or PipeLogix.  Hearing Tr.

at 106‐107 (Shoaff).

228 See CR/PR at Table V‐3.
38

stated that they would not pay a price premium.229  Nevertheless, subject imports from Korea

undersold the domestic like product in the vast majority of comparisons at an average 7.3

margin,230 which was higher than the premium suggested by some purchasers.231

We find that the subject imports, because of their pervasive underselling, depressed

prices for the domestic like product to a significant degree.  In general, prices for the domestic

like product increased during 2011, began to decline around the beginning of 2012, fell

throughout the rest of 2012 and in the first quarter of 2013, and then leveled off or slightly

increased in the second half of 2013 and the first quarter of 2014.232  Thus, these declines in the

prices of the domestic like product began to occur at a time of robust increases in demand.  As

noted above, apparent U.S. consumption of OCTG increased from 6.0 million short tons in 2011

to 7.0 million short tons in 2012 and remained at 7.0 million short tons in 2013.233  Prices for

the domestic like product were highest in either the third or fourth quarter of 2011 for five of

the six pricing products, and lowest in the first through third quarters of 2013 for five of the six

pricing products.  Prices for the domestic like product were lower by 1.2 to 19.3 percent for five

of the six products in the first quarter of 2014 compared with the first quarter of 2011.234   

Respondents argue that subject imports did not depress domestic prices because

changes in domestic prices do not correlate with trends in subject import volume.  They assert

that prices for the domestic product rose during the period when the largest increase in subject

imports occurred, from 2011 to 2012.235  The evidence on the record does not support this

assertion.  The year 2012, when subject imports rose by *** percent,236 also saw sharp price

declines for the domestic like product.237

Respondents’ argument that declining OCTG prices were caused by falling raw material

costs238 also is not borne out by information in the record regarding trends in raw material

costs and the magnitude of declines in those costs.  In 2011, trends in raw material costs for

both scrap and hot‐rolled sheet diverged from the price trends for all six products for which the

Commission requested quarterly data.239  Although trends in the six pricing products moved in a

manner more similar to these raw material costs from 2012 through the first quarter of 2014,

                                                       229 For OCTG from Korea 30 out of 49 purchasers reported that they were not willing to pay

more for the domestic product.   CR/PR at Table II‐16.

230 Subject imports from Korea undersold the domestic like product in 42 of 46 quarterly

comparisons.  CR/PR at Table V‐14.

231 The 19 purchasers who reported that they were willing to pay more for the domestic like

product than for subject imports from Korea reported being willing to pay an average of between 6 and

16 percent more for the domestic product.  CR/PR at Table II‐16.

232 CR at V‐32, PR at V‐20, and CR/PR at Figure V‐10.  These price trends are also reflected in

OCTG prices reported in an industry publication, ***.   U.S. Steel Posthearing Brief at Exhibit 16.   233 CR/PR at Table C‐1.

234 CR at V‐32, PR at V‐20.

235 E.g., Korean Respondents’ Prehearing Brief at 26.

236 CR/PR at Table G‐8.

237 CR/PR at Figure V‐10 and U.S. Steel Posthearing Brief at Exhibit 16.

238 E.g., Korean Respondents’ Prehearing Brief at 26‐27.

239 Compare CR/PR at Figure V‐1 with CR/PR at Figures V‐4‐V‐9.
39

raw material cost changes cannot account fully for the change in the six products’ price

movements.  Between the first quarter of 2012 and the first quarter of 2014, hot‐rolled steel

sheet prices declined by $68 per short ton, and scrap prices declined by $27 per short ton.240  In

contrast, prices for the six pricing products declined by between $149 and $349 (or a simple

average of $231) over the same period.241    

We are unpersuaded by respondents’ argument that the declines in domestic OCTG

prices are attributable to the domestic industry’s capacity expansions during the POI.  The

growth in production capacity of U.S. OCTG mills was not appreciably greater than the growth

in demand.242  Moreover, most of the new capacity was added in 2013,243 whereas the prices of

the domestic like product began to fall in late 2011 and early 2012.

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

the subject imports and that subject imports depressed domestic prices to a significant

degree.244  

E. Impact of the Subject Imports245

Section 771(7)(C)(iii) of the Tariff Act provides that in examining the impact of subject

imports, the Commission “shall evaluate all relevant economic factors which have a bearing on

                                                       240 CR/PR at Figures V‐2 and V‐3.   241 CR/PR at Tables V‐6‐V‐11.  We also note that the net sales unit value for U.S. mills declined by

$178, or 10.3 percent, between 2012 and 2013, while the unit raw material cost of goods sold fell by

only $35, or 4.3 percent.  CR/PR at Table VI‐1.

242 From 2011 to 2013, the average capacity of U.S. mills grew by 17.9 percent, while the

quantity of U.S. apparent consumption grew by 16.8 percent.  While there was also growth in processing

capacity during this period, the overwhelming percentage of domestic industry capacity is mill capacity.

243 Capacity rose by 12.0 percent in 2013, compared to an increase of only 5.2 percent in 2012.  

CR/PR at Table C‐1.

244 Petitioners made 84 lost sales allegations involving $285 million and 167,079 short tons and

15 lost revenue allegations involving $11.2 million and 19,197 short tons.  Purchasers agreed with

allegations totaling 42,501 short tons of lost sales, accounting for $68.2 million, as well as 9,905 short

tons of lost revenue accounting for $935,287.  CR at V‐38, PR at V‐25.  These confirmed lost sales and

lost revenue allegations provide further support for our finding that subject imports had significant price

effects on prices for the domestic like product.

245 The statute instructs the Commission to consider the “magnitude of the dumping margin” in

an antidumping proceeding as part of its consideration of the impact of imports.  19 U.S.C. §

1677(7)(C)(iii)(V).  In its final determination of sales at less than fair value, Commerce found the

following antidumping duty margins:  India ‐‐ 2.05 percent to 9.91 percent for individually investigated

respondents, 5.79 percent for all others; Korea ‐‐ 9.89 percent to 15.75 percent for individually

investigated respondents, 12.82 percent for all others; Turkey ‐‐ 0.00 percent for Borusan (which did not

receive a non‐de minimis subsidy rate); 35.86 percent for the other individually investigated

respondents and all others; Ukraine ‐‐ 6.73 percent for the individually investigated respondents and for

all others; and Vietnam ‐‐ 24.22 percent for the individually investigated respondent, 111.47 percent for

all others.  CR/PR at Table I‐3.
40

the state of the industry.”246  These factors include output, sales, inventories, capacity

utilization, market share, employment, wages, productivity, profits, cash flow, return on

investment, 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.”

We find that subject imports of OCTG from India, Korea, Turkey, Ukraine, and Vietnam

had a significant impact on the domestic industry during the POI.  This was a period of strong

demand, and the domestic industry’s trade and employment indicators reflected this expansion

in the market.  However, the significant and increasing volume of subject imports, which

undersold the domestic like product and depressed domestic prices to a significant degree, led

to a substantial erosion of the domestic industry’s financial performance despite favorable

market conditions.

    The capacity of domestic OCTG mills increased from 4.9 million short tons in 2011 to 5.2

million short tons in 2012 and 5.8 million short tons in 2013, for an overall increase of 17.9

percent.247  Processors’ capacity increased from 674,376 short tons in 2011 to 996,876 short

tons in 2012 and 1.0 million short tons in 2013, for an overall increase of 62.1 percent.248  

Production at mills increased from 3.3 million short tons in 2011 to 3.6 million short tons in

2012 and 4.1 million short tons in 2013, for an overall increase of 23.4 percent.249  Processors’

production was 512,674 short tons in 2011, 693,525 short tons in 2012, and 783,266 short tons

in 2013, for an overall increase of 52.8 percent.250  Capacity utilization at mills was 67.6 percent

in 2011, 69.2 percent in 2012, and 70.8 percent in 2013, increasing overall by 3.2 percentage

points.251  Capacity utilization at processors was 76.0 percent in 2011, 69.6 percent in 2012, and

71.6 percent in 2013, for an overall decrease of 4.4 percentage points.252

                                                       246 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.”).

247  CR/PR at Table C‐1.  The capacity of the mills was 1.5 million short tons in interim 2014, up

from 1.4 million short tons in interim 2013.  Id.

248 CR/PR at Table C‐1.  The capacity of processors was 320,084 short tons in interim 2014, up

from 257,642 short tons in interim 2013.  Id.

249 CR/PR at Table C‐1.  The production of the mills was 1.0 million short tons in both interim

2014 and interim 2013.  Id.

250 CR/PR at Table C‐1.  The production of processors was 235,359 short tons in interim 2014, up

from 175,046 short tons in interim 2013.  Id.

251 CR/PR at Table C‐1.  The capacity utilization of the mills was 72.0 percent in interim 2014,

down slightly from 72.4 percent in interim 2013.  Id.

252 CR/PR at Table Table C‐1.  The capacity utilization of the processors was 73.5 percent in

interim 2014, up from 67.9 percent in interim 2013.  Id.
41

The mills’ U.S. shipments increased from 3.1 million short tons in 2011 to 3.4 million

short tons in 2012 and 3.7 million short tons in 2013, for an overall increase of 19.1 percent.253  

The market share of the mills fell from 52.5 percent in 2011 to 48.7 percent in 2012, but then

increased to 53.5 percent in 2013.254  Processors’ U.S. shipments increased from 499,623 short

tons in 2011 to 681,109 short tons in 2012 and 789,499 short tons in 2013, for an overall

increase of 58.0 percent.255    

  The mills’ end of period inventories decreased from 10.8 percent of total shipments in

2011 to 8.9 percent in 2012, and then increased to 9.1 percent in 2013.256  Processors’ end of

period inventories increased from *** percent of total shipments in 2011 to *** percent in

2012, and then decreased to *** percent in 2013.257   

The number of production workers, hours worked, and wages paid at mills all increased

from 2011 to 2013, by 15.3 percent, 23.0 percent, and 37.4 percent respectively.258  The

number of production workers, hours worked, and wages paid at processors combined also

increased from 2011 to 2013, by 33.7 percent, 45.6 percent, and 60.1 percent respectively.259

The mills’ net sales value increased from $5.6 billion in 2011 to $6.2 billion in 2012 and

$6.2 billion in 2013, for an overall increase of 11.4 percent.260  However, as the significant and

increasing volume of subject imports depressed domestic prices, the financial performance of

the mills deteriorated.  Although the net sales value for mills increased by 11.4 percent in the

2011‐2013 period, the cost of goods sold (“COGS”) increased to a much greater extent, by 19.3

percent,261 resulting in declining operating income.  The COGS/net sales ratio for mills rose from

81.1 percent in 2011 to 82.7 percent in 2012 and 86.9 percent in 2013.262  Therefore, despite

increased sales, the mills’ operating income fell from $641 million in 2011 to $613 million in

                                                       253 CR/PR at Table C‐1.  The mills’ U.S. shipments were 950,579 short tons in interim 2014, up

from 870,703 short tons in interim 2013.  Id.

254 CR/PR at Table C‐1.  The mills’ market share was 51.6 percent in interim 2014, down from

54.2 percent in interim 2013.  Id.

255 CR/PR at Table C‐1.  The processors’ U.S. shipments were 222,560 short tons in interim 2014,

up from 176,275 short tons in interim 2013. Id.

256 CR/PR at Table C‐1.  End of period inventories of the mills were 9.1 percent of total

shipments in interim 2014, down from 10.4 percent in interim 2013.  Id.

257 CR/PR at Table C‐1.  Processors’ end of period inventories were *** percent of total

shipments in interim 2014, down from *** percent in interim 2013.  Id.

258 CR/PR at Table C‐1.  The number of production workers, hours worked, and wages paid at

mills were  higher ‐‐ by 4.9 percent, 1.5 percent, and 17.2 percent respectively – in interim 2014 than in

interim 2013.  Id.

259 CR/PR at Table C‐1.  The number of production workers, hours worked, and wages paid at

processors were higher ‐‐ by 17.2 percent, 21.9 percent, and 16.1 percent respectively – in interim 2014

than in interim 2013.  Id.

260 CR/PR at Table C‐1.  The mills’ net sales value was $1.6 billion in interim 2014, up from $1.5

billion in interim 2013.  Id.

261 CR/PR at Table C‐1.    262 CR/PR at Table C‐1.  The COGS/net sales ratio for mills was 89.3 percent in interim 2014, up

from 86.0 percent in interim 2013.  Id.
42

2012 and $312 million in 2013.263  The mills’ operating income ratio declined from 11.5 percent

in 2011 to 9.8 percent in 2012 and 5.0 percent in 2013.264  The mills’ capital expenditures

declined from $705.2 million in 2011 to $632.8 million in 2012 and then $370.7 million in

2013.265

Before discussing the effect of subject imports on the financial performance of

processors, we emphasize that OCTG mills constitute a much larger part of the domestic

industry than processors.  For example, the value of U.S. mills’ U.S. shipments in 2013 ($5.8

billion) was more than 10 times that of U.S. processors ($485 million).266  

    The effect of subject imports on the financial performance of processors was less

discernible than that on mills.  The processors’ net sales value increased from $333.4 million in

2011 to $460.7 million in 2012 and $493.4 million in 2013, for an overall increase of 48.0

percent.267  Although the net sales values for processors increased by 48.0 percent in the 2011‐

2013 period, the cost of goods sold or tolled (“COGST”) increased by 52.5 percent.268 The

COGST/net sales ratio for processors rose from 75.4 percent in 2011 to 79.7 percent in 2012

but then fell to 77.6 percent in 2013.269  The operating income of processors rose from $43.0

million in 2011 to $44.4 million in 2012 and to $58.9 million in 2013.270  The processors’

operating income ratio declined from 12.9 percent in 2011 to 9.6 percent in 2012, but then rose

to 11.9 percent in 2013.271  The processors’ capital expenditures declined from $79.0 million in

2011 to $45.5 million in 2012 and $44.3 million in 2013.272

    Notwithstanding that the domestic industry was able to maintain and increase output

and employment during a period of increasing demand, the significant and increasing volume of

low‐priced subject imports caused domestic producers to significantly lower their prices.  As a

result, the domestic industry’s revenues did not increase commensurately with either output or

costs, and the domestic industry exhibited significant declines in operating performance.  In

                                                       263 CR/PR at Table C‐1.  The mills’ operating income was $47 million in interim 2014, down from

$87 million in interim 2013.  Id.

264 CR/PR at Table C‐1.  The mills’ operating income ratio was 2.9 percent in interim 2014, down

from 6.0 percent in interim 2013.  Id.

265 CR/PR at Table C‐1.  The mills’ capital expenditures were $41.2 million in interim 2014, down

from $86.7 million in interim 2013.  Id.

266 CR/PR at Table C‐1.

267 CR/PR at Table C‐1.  The processors’ net sales value was $129.5 million in interim 2014, up

from $113.9 million in interim 2013.  Id.

268 CR/PR at Table C‐1.    269 CR/PR at Table C‐1.  The COGST/net sales ratio for processors was 74.9 percent in interim

2014, down from 78.4 percent in interim 2013.  Id.

270 CR/PR at Table C‐1.  The processors’ operating income was $19.5 million in interim 2014, up

from $13.7 million in interim 2013.  Id.

271 CR/PR at Table C‐1.  The processors’ operating income ratio was 15.1 percent in interim 2014,

up from 12.0 percent in interim 2013.  Id.

272 CR/PR at Table C‐1.  The processors’ capital expenditures were $5.1 million in interim 2014,

down from $11.7 million in interim 2013.  Id.
43

light of the foregoing, we find that the cumulated subject imports had a significant adverse

impact on the domestic industry.

    We have considered whether there are other factors that may have had an adverse

impact on the domestic industry during the POI to ensure that we are not attributing injury

from such other factors to subject imports.  Nonsubject imports273 had a declining presence in

the U.S. market during most of the POI.274  Moreover, the pricing data collected by the

Commission show that nonsubject imports undersold the domestic product less frequently than

subject imports (and when they did so, at a lower average margin) and that prices of

nonsubject imports were most frequently higher than prices of subject imports.275  The pricing

data obtained for nonsubject imports (from 15 importers, involving imports from six such

countries and from the nonsubject producer in Taiwan) show that these imports were priced

lower than the domestic like product in 75 of 126 quarterly comparisons, with an average

margin of underselling of *** percent.276  These nonsubject imports were priced higher than

the domestic like product in 51 of 126 quarterly comparisons, with an average margin of

overselling of *** percent.277  OCTG imported from subject sources was priced lower than

OCTG imported from nonsubject sources in 260 of 361 possible comparisons.278  Because

nonsubject imports were typically priced higher than subject imports, and were priced lower

than the domestic like product less frequently than were subject imports, they do not explain

the significant depression of domestic prices and consequent decline in the domestic industry’s

financial indicators over the POI.

    Respondents argue that the domestic industry was injured by nonsubject imports

brought into the U.S. market by U.S. producers from affiliated mills in nonsubject countries,

because such nonsubject imports obtained by one domestic producer from a foreign affiliate

injure other domestic producers.279  We find this argument unpersuasive.  It is premised on the

notion that an adverse impact on the domestic industry was manifested in declines in

                                                       273 For purposes of this section, “nonsubject imports” are those from sources not subject to

these investigations.

274 Nonsubject imports’ share of apparent U.S. consumption declined from *** percent in 2011

to *** percent in 2012 and *** percent in 2013.  The share was *** percent in interim 2014, as

compared to *** percent in interim 2013.  See CR at Table G‐9.  As we found in Section IV above, subject

imports from the Philippines, Taiwan, and Thailand are negligible for purposes of our analysis of material

injury by reason of subject imports.  Negligible imports cannot, by definition, be injurious.

275 Based on the evidence in these investigations, Vice Chairman Pinkert finds that price‐

competitive nonsubject imports were a significant factor in the U.S. market during the period of

investigation.  Regardless of whether OCTG is considered a commodity product, however, nonsubject

imports would not have replaced the subject imports during the period, without benefit to the domestic

industry, had the subject imports exited the market.  As discussed in the text, OCTG imported from

subject sources was priced at less than OCTG from nonsubject sources in 260 of 361 possible

comparisons.  CR/PR at Table G‐19.

276 CR/PR at Table G‐18.

277 CR/PR at Table G‐18.

278 CR/PR at Table G‐19.

279 E.g., Hearing Tr. at 310‐311 (McConnell).
44

production and shipments, which is neither what the record shows nor what we have found.  

Moreover, imports from nonsubject sources had a declining presence in the U.S. market during

most of the POI, undersold the domestic product less frequently than subject imports, and

were priced mostly higher than subject imports.

    Respondents argue that the domestic industry’s profitability was adversely impacted by

the start‐up operations of new domestic mills.  They contend that declines in domestic industry

operating profit are not correlated with subject import volume trends, given that the bulk of

the subject import volume increase was from 2011 to 2012 and that most of the decline in

profitability occurred in 2012 and 2013, when new domestic capacity was coming online.  

Domestic producers had strong incentives to ramp up production and shipments to "fill the

mill,” according to respondents.280  We are not persuaded that new domestic capacity explains

the material injury experienced by the industry.  As detailed above, the domestic industry’s

addition of new mill capacity was commensurate with rising demand for OCTG.  Moreover, the

bulk of the domestic industry’s capacity expansions occurred in 2013, well after subject imports

had caused significant depression of domestic prices in 2012.  Even if additional supply from

domestic producers added to competitive pressure in the market, it cannot explain the

magnitude of the observed price declines in a growing market and in light of the significant

volumes of lower‐priced subject imports.  We also reject the argument that the deterioration in

the domestic industry’s financial performance was attributable to start‐up costs associated with

new domestic production facilities.281  The incremental costs of mills’ new capacity were

equivalent to only *** percent of total COGS in 2011, *** percent in 2012, and *** percent in

2013.282  These cannot account for the sharp deterioration in the domestic industry’s financial

condition.

In sum, we find that the significant and increasing volume of subject imports, at prices

which undersold the domestic like product and depressed domestic prices, adversely impacted

the domestic industry, leading to significant declines in that industry’s financial performance.  

We consequently determine that the domestic industry is materially injured by reason of

cumulated subject imports from India, Korea, Turkey, Ukraine, and Vietnam.

VII. Critical Circumstances

A. Legal Standards and Party Arguments

In its final antidumping duty determinations concerning OCTG from Turkey and

Vietnam283 and its final countervailing duty determinations concerning OCTG from India284 and

                                                       280 E.g., Korean Respondent Group Prehearing Brief at 29‐44 and ILJIN Prehearing Brief at 19‐23.

281 E.g., Korean Respondent Group Prehearing Brief at 34‐35.

282 CR at VI‐16, PR at VI‐5.

283 In its antidumping duty investigation, Commerce determined that critical circumstances

existed with regard to the Vietnam‐wide entity, excluding SeAH Steel VINA Corp.   Certain Oil Country

Tubular Goods from the Socialist Republic of Vietnam, 79 Fed. Reg. 41971 (final determination of sales at

less than fair value and final affirmative determination of critical circumstances) (July 18, 2014).
45

Turkey,285 Commerce found that critical circumstances exist with respect to certain subject

producers/exporters.  Because we have determined that the domestic industry is materially

injured by reason of subject imports from, inter alia, India, Turkey, and Vietnam, we must

further determine “whether the imports subject to the affirmative {Commerce critical

circumstances} determination . . . are likely to undermine seriously the remedial effect of the

antidumping {and/or countervailing duty} order{s} to be issued.”286   

The SAA indicates that the Commission is to determine “whether, by massively

increasing imports prior to the effective date of relief, the importers have seriously undermined

the remedial effect of the order” and specifically “whether the surge in imports prior to the

suspension of liquidation, rather than the failure to provide retroactive relief, is likely to

seriously undermine the remedial effect of the order.”287  The legislative history for the critical

circumstances provision indicates that the provision was designed “to deter exporters whose

merchandise is subject to an investigation from circumventing the intent of the law by

increasing their exports to the United States during the period between initiation of an

investigation and a preliminary determination by {Commerce}.”288  An affirmative critical

circumstances determination by the Commission, in conjunction with an affirmative

determination of material injury by reason of subject imports, would normally result in the

retroactive imposition of duties for those imports subject to the affirmative Commerce critical

circumstances determination for a period 90 days prior to the suspension of liquidation.

The statute provides that, in making this determination, the Commission shall consider,

among other factors it considers relevant,  

(I) the timing and the volume of the imports,

(II) a rapid increase in inventories of the imports, and

                                                                                                                                                                              

(...Continued)

284 In its countervailing duty investigation, Commerce determined that critical circumstances

existed with regard to OCTG from Jindal SAW and all other producers other than GVN Fuels Ltd. and its

cross‐owned producers, Maharashtra Seamless Ltd. and Jindal Pipes Ltd.  Certain Oil Country Tubular

Goods from India, 79 Fed. Reg. 41967 (final affirmative countervailing duty determination and partial

final affirmative determination of critical circumstances) (July 18, 2014).

285 In its countervailing duty investigation, Commerce determined that critical circumstances

existed with regard to all producers and exporters in Turkey.  In its antidumping duty investigation,

Commerce determined that critical circumstances existed with regard to all producers and exporters in

Turkey other than Borusan and Yucel.  Certain Oil Country Tubular Goods from Turkey, 79 Fed. Reg.

41964 (final affirmative countervailing duty determination and final affirmative critical circumstances

determination) (July 18, 2014); Certain Oil Country Tubular Goods from Turkey, 79 Fed. Reg. 41961 (final

determination of sales at less than fair value and affirmative final determination of critical

circumstances) (July 18, 2014).

286 19 U.S.C. §§ 1671d(b)(4)(A)(ii), 1673d(b)(4)(A)(ii).

287 SAA at 877.

288 ICC Industries, Inc. v United States, 812 F.2d 694, 700 (Fed. Cir. 1987), quoting H.R. Rep. No.

96‐317 at 63 (1979), aff’g 632 F. Supp. 36 (Ct. Int’l Trade 1986). See 19 U.S.C. §§ 1671b(e)(2),

1673b(e)(2).
46

(III) any other circumstances indicating that the remedial effect of

the {order} will be seriously undermined.289

In considering the timing and volume of subject imports, the Commission's practice is to

consider import quantities prior to the filing of the petition with those subsequent to the filing

of the petition using monthly statistics on the record regarding those firms for which Commerce

has made an affirmative critical circumstances determination.290

Consistent with Commission practice, in these investigations we have considered data

for the six months prior to and including the month in which the petition was filed (July 2013)

and data for the six months following that month.

B. Analysis

1. India

Maverick argues that according to Commerce, certain subject imports from India surged

massively after the filing of the petition. It asserts that, without a finding of critical

circumstances, these imports will seriously undermine the remedial effects of any future

orders.291

Jindal SAW characterizes the increase in imports from Jindal SAW as being “relatively

normal” and consistent with the "demand of the purchasing cycles of its customers.”  Jindal

SAW notes that its 2013 end‐of‐period (“EOP”) inventories were significantly less than its 2012

end‐of‐period inventories.  Jindal SAW also argues that there was no surge in its imports just

before Commerce’s preliminary antidumping duty determination.292

The monthly data for subject import volume from India (excluding the entities that were

excluded from Commerce’s affirmative critical circumstances determination, i.e., GVN,

Maharashtra, and Jindal Pipes Ltd.) for the six‐month periods before and after the filing of the

petition in July 2013 show only a minor increase in imports from India subject to Commerce’s

affirmative critical circumstances determination. 293  These subject imports were *** short tons

in the six months preceding the filing of the petition and *** short tons in the six months

following the filing of the petition.294  EOP inventories of imports from India subject to

Commerce’s affirmative critical circumstances determination were *** short tons in 2012 and

*** short tons in 2013.295   Notwithstanding the increase in these inventories from 2012 to

                                                      

289 19 U.S.C. §§ 1671d(b)(4)(A)(ii), 1673d(b)(4)(A)(ii).

290 See Lined Paper School Supplies from China, India, and Indonesia, Inv. Nos. 701‐TA‐442‐43,

731‐TA‐1095‐97,  USITC Pub. 3884 at 46‐48 (Sept. 2006); Carbazole Violet Pigment from China and India,

Inv. Nos. 701‐TA‐437 and 731‐TA‐1060‐61 (Final), USITC Pub. 3744 at 26 (Dec. 2004); Certain Frozen Fish

Fillets from Vietnam, Inv. No. 731‐TA‐1012 (Final), USITC Pub. 3617 at 20‐22 (Aug. 2003).

291 Maverick Posthearing Brief at Exh. 1, 50‐52.

292 Jindal Prehearing Brief at 43‐45.

293 The periods considered are January‐June 2013 and July‐December 2013.  CR/PR at Table IV‐4.

294 CR/PR at Table IV‐4.

295 CR/PR at Table IV‐4.
47

2013, the quantity of inventories in 2013 subject to Commerce’s affirmative critical

circumstances determination represents only a small percentage of the *** short tons of

subject imports that entered the United States in 2013 that were cumulated for purposes of our

material injury determination and therefore cannot seriously undermine the effectiveness of

the order.296   

Taken as a whole, the data on record do not show a sudden and significant increase in

imports from India subject to Commerce’s affirmative critical circumstances determination

subsequent to the filing of the petition that would seriously undermine the remedial effect of

the countervailing duty order to be issued on OCTG from India.  We therefore make a negative

critical circumstances determination with regard to subject imports from India.

2. Turkey

Maverick argues that according to Commerce, subject imports from Turkey surged

massively after the filing of the petition.  It asserts that, without a finding of critical

circumstances, subject imports from Turkey will seriously undermine the remedial effects of

future orders.297

With regard to the countervailing duty investigation, in which Commerce made an

affirmative critical circumstances determination with respect to all subject imports from Turkey,  

imports from Turkey were 59,173 short tons in the six‐month period preceding the filing of the

petition and 74,599 short tons in the six‐month period following the filing of the petition.298  

We do not find that this 26 percent increase, for an absolute volume of only 15,426 short tons,

was massive or sufficient to seriously undermine the remedial effect of the CVD order.  

Importers’ EOP inventories declined from *** short tons in 2012 to *** short tons in 2013.299   

Taken as a whole, the data on record do not show a sudden and significant increase in

subject imports subsequent to the filing of the petition that would seriously undermine the

remedial effect of the CVD order to be issued on OCTG from Turkey.  We therefore make a

negative critical circumstances determination with regard to subsidized imports from Turkey

subject to Commerce’s affirmative critical circumstances determination.

Commerce’s affirmative critical circumstances determination in the antidumping duty

investigation concerning Turkey excluded imports from Borusan and Yucel.  The relevant

imports were *** short tons in the six month period preceding the filing of the petition and ***

short tons in the six month period following the filing of the petition.300  Although the

percentage increase in such imports between the pre‐ and post‐petition periods  was ***

percentage points, the absolute volume was only *** short tons.  Importers’ EOP inventories of

OCTG from Turkey, excluding Borusan and Yucel , were minimal ‐‐ *** short tons in 2012 and

                                                       296 See CR/PR at Table G‐8.

297 Maverick Posthearing Brief at Exh. 1, 50‐52.

298 CR/PR at Table IV‐5.

299 CR/PR at Table IV‐5.

300 CR/PR at Table IV‐6.
48

2013.301  Therefore, we find that such subject imports cannot seriously undermine the

effectiveness of the order.   

Taken as a whole, the data on record do not show a sudden and significant increase in

imports from Turkey subject to Commerce’s affirmative critical circumstances determination

subsequent to the filing of the petition that would seriously undermine the remedial effect of

the antidumping duty order to be issued on OCTG from Turkey.  We therefore make a negative

critical circumstances determination with regard to subject imports from Turkey.

3. Vietnam

Maverick argues that according to Commerce, subject imports from Vietnam surged

massively after the filing of the petition.  It asserts that, without a finding of critical

circumstances, subject imports from Vietnam will seriously undermine the remedial effects of

future orders.302

C&F International and Nexgen Metals argue that subject imports from Vietnam

increased only modestly from the pre‐petition period to the post‐petition period and that this

small increase does not support the claim that there was a massive surge of subject imports

after the petition was filed or that the remedial effect of the order would be “seriously

undermined” unless critical circumstances are found.  They also argue that there was no

increase in inventories of subject imports from Vietnam.303

Subject import volume from Vietnam (excluding SeAH, which was excluded from

Commerce’s affirmative critical circumstances determination) was *** short tons in the six‐

month period preceding the filing of the petition and *** short tons in the six‐month period

following the filing of the petition.304  The increase was only *** percent, or *** short tons.  

EOP inventories of imports from Vietnam subject to Commerce’s affirmative critical

circumstances determination increased by only *** short tons, from *** short tons in 2012 to

*** short tons in 2013.305   

Taken as a whole, the data on record do not show a sudden and significant increase in

imports from Vietnam subject to Commerce’s affirmative critical circumstances determination

subsequent to the filing of the petition that would seriously undermine the remedial effect of

the antidumping duty order to be issued on OCTG from Vietnam.  We therefore make a

negative critical circumstances determination with regard to subject imports from Vietnam.306

                                                       301 CR/PR at Table IV‐6.

302 Maverick Posthearing Brief at Exh. 1, 50‐52.

303 C&F International Prehearing Brief at 3‐5; Nexgen Metals Posthearing Brief at 2‐5.

304 CR/PR at Table IV‐7.

305 CR/PR at Table IV‐7.

306 Chairman Broadbent does not join the remainder of this opinion.
49

VIII. Threat of Material Injury by Reason of Subject Imports

As discussed earlier, we determined that subject imports from Taiwan would

imminently account for more than three percent of all subject merchandise imported into the

United States.  Therefore we proceed to determine whether the U.S. industry is threatened

with material injury by reason of subject imports from Taiwan.   

A. Legal Standard

Section 771(7)(F) of the Tariff Act directs the Commission to determine whether the U.S.

industry is threatened with material injury by reason of the subject imports by analyzing

whether “further dumped or subsidized imports are imminent and whether material injury by

reason of imports would occur unless an order is issued or a suspension agreement is

accepted.”307  The Commission may not make such a determination “on the basis of mere

conjecture or supposition,” and considers the threat factors “as a whole” in making its

determination whether dumped or subsidized imports are imminent and whether material

injury by reason of subject imports would occur unless an order is issued.308  In making our

determination, we consider all statutory threat factors that are relevant to these

investigations.309

                                                       307 19 U.S.C. § 1677(7)(F)(ii).

308 19 U.S.C. § 1677(7)(F)(ii).

309 These factors are as follows:

(I) if a countervailable subsidy is involved, such information as may be presented to it by the

administering authority as to the nature of the subsidy (particularly as to whether the countervailable

subsidy is a subsidy described in Article 3 or 6.1 of the Subsidies Agreement) and whether imports of the

subject merchandise are likely to increase,

(II) any existing unused production capacity or imminent, substantial increase in production

capacity in the exporting country indicating the likelihood of substantially increased imports of the

subject merchandise into the United States, taking into account the availability of other export markets

to absorb any additional exports,

(III) a significant rate of increase of the volume or market penetration of imports of the subject

merchandise indicating the likelihood of substantially increased imports,

(IV) whether imports of the subject merchandise are entering at prices that are likely to have a

significant depressing or suppressing effect on domestic prices and are likely to increase demand for

further imports,

(V) inventories of the subject merchandise,

(VI) the potential for product‐shifting if production facilities in the foreign country, which can be

used to produce the subject merchandise, are currently being used to produce other products,

...

(VIII) the 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

(Continued...)
50

B. Cumulation for Threat

Under Section 771(7)(H) of the Tariff Act, the Commission may “to the extent

practicable” cumulatively assess the volume and price effects of subject imports from all

countries as to which petitions were filed on the same day if the requirements for cumulation in

the material injury context are satisfied.310   Accordingly, for purposes of our analysis of threat

of material injury by reason of subject imports from Taiwan, subject imports from Taiwan are

eligible for cumulation with subject imports from India, Korea, Ukraine, Turkey, and Vietnam.311

Petitioners contend that the Commission should cumulate all subject imports for

purposes of the threat analysis.312  Although respondents from India, Turkey, and Ukraine

respectively argued that the Commission should not cumulate imports from any other subject

country in making any threat determination concerning subject imports from those countries,

no respondent specifically directed arguments concerning cumulation for a threat

determination concerning subject imports from Taiwan.

We found in Section V above that there is a reasonable overlap of competition between

subject imports from India, Korea, Turkey, Ukraine, and Vietnam and between imports from

each of the subject countries and the domestic like product.  The considerations discussed

above concerning reasonable overlap of competition apply equally to subject imports from

Taiwan.313   

The record does not indicate that there would likely be any significant difference in the

conditions of competition between subject imports from India, Korea, Taiwan, Turkey, Vietnam,

and Ukraine.  We recognize that some potential differences exist between the industries in

these subject countries and, after examining these differences, find that they are not significant

enough to warrant not cumulating subject imports from Taiwan with those from other subject

countries eligible for cumulation.  For these reasons, we conclude that it is appropriate to

                                                                                                                                                                              

(...Continued)

(IX) any other demonstrable adverse trends that indicate the probability that there is likely to be

material injury by reason of imports (or sale for importation) of the subject merchandise (whether or

not it is actually being imported at the time).   

19 U.S.C. § 1677(7)(F)(i).  To organize our analysis, we discuss the applicable statutory threat

factors using the same volume/price/impact framework that applies to our material injury analysis.  

Statutory threat factors (I), (II), (III), (V), and (VI) are discussed in the analysis of subject import volume.  

Statutory threat factor (IV) is discussed in the analysis of subject import price effects.  Statutory factors

(VIII) and (IX) are discussed in the analysis of impact.  Statutory factor (VII) concerning agricultural

products is inapplicable to this investigation.   310 19 U.S.C. § 1677(7)(H).

311  As stated in Section V above, the investigation from OCTG from Saudi Arabia was

terminated, so these imports are not eligible for cumulation.  Subject imports from the Philippines and

Thailand are also not eligible for cumulation in light of our negligibility findings in Section IV. above.

312  U.S. Steel Prehearing Brief, Ex. 3 at 6; Other Petitioners’ Posthearing Brief at 13, 27; Maverick

Posthearing Brief at 15.

313 See generally, e.g., CR/PR at Tables II‐1‐2, II‐10, IV‐12, IV‐13, IV‐14.
51

exercise our discretion to cumulate subject imports from India, Korea, Taiwan, Turkey, Ukraine,

and Vietnam for the purposes of our threat analysis.  

C. Analysis   

1. Likely Volume

We found in Section VI.C. above that the absolute volume of cumulated subject imports

from India, Korea, Turkey, Ukraine, and Vietnam and the increase in the volume of these

imports over the POI is significant in absolute terms.  Including subject imports from Taiwan

does not change these findings.  The volume of cumulated subject imports from India, Korea,

Taiwan, Turkey, Ukraine, and Vietnam increased from *** short tons in 2011 to *** short tons

in 2012 and remained at *** short tons in 2013, for an overall increase of *** percent.314  This

increase in volume was far greater than the *** percent increase in apparent U.S. consumption

over the same period.315  Subject imports captured an increasing share of the U.S. market over

the POI, from *** percent in 2011 to *** percent in 2013.316

The significant increase in cumulated subject import volume observed during the POI is

likely to persist in the imminent future.  The subject industries increased their capacity and

production during the POI, and these increases will likely continue.  Subject producers’

cumulated capacity increased from *** short tons in 2011 to *** short tons in 2012 and ***

short tons in 2013.317  Subject producers produced *** short tons of OCTG in 2011, *** short

tons in 2012, and *** short tons in 2013.318  Subject producers’ capacity utilization fluctuated

within a fairly narrow range, increasing from *** percent in 2011 to *** percent in 2012, and

then decreasing to *** percent in 2013.319  These data indicate that there is substantial unused

capacity in the subject industries.   

Subject producers are export‐oriented and demonstrated a substantial and increasing

focus on the U.S. market during the POI.  The record shows that virtually all of the additional

production of OCTG produced in the subject countries over the POI was absorbed by the U.S.

market.  Shipments of cumulated subject merchandise to the United States increased from ***

short tons in 2011 to *** short tons in 2012 and *** short tons in 2013.320  U.S. shipments of

cumulated subject imports as a share of total shipments also increased over the POI, from ***

                                                       314 Derived from CR/PR Table C‐1.  Findings in the remainder of this section on cumulated

subject imports refer to imports from India, Korea, Taiwan, Turkey, Ukraine, and Vietnam.

315 Derived from CR/PR Table C‐1.

316 Derived from CR/PR Table C‐1.

317 Derived from CR/PR at Tables VII‐1a, VII‐3, VII‐9, VII‐13, VII‐15, and VII‐17.  Subject capacity

was *** short tons in interim 2013 and *** short tons in interim 2014. Id.

318 CR/PR at Table Supp‐10.  Production was *** short tons in interim 2013 and *** short tons in

interim 2014.  Id.

319 CR/PR at Table Supp‐10.  Capacity utilization was *** percent in interim 2013 and ***

percent in interim 2014.  Id.

320 CR/PR at Table Supp‐10.  Shipments of cumulated subject merchandise to the United States

were *** short tons in interim 2013 and *** short tons in interim 2014.  Id.
52

percent in 2011 to *** percent in 2013.  Meanwhile, shipments of subject merchandise to

third‐country markets decreased from *** percent in 2011 to *** percent in 2013.321 322

In light of the increases in subject import volume and market penetration observed

during the POI, the growing capacity and substantial excess capacity of the subject industries,

and the subject industries’ focus on supplying export markets generally and the United States in

particular, we find that the significant increase in cumulated subject import volume that

occurred during the POI will likely continue in the imminent future.

                                                       321 CR/PR at Table Supp‐10.

322 Inventories of cumulated subject merchandise also increased over the POI, rising from ***

short tons in 2011 to *** short tons in 2012, then decreasing slightly to *** short tons in 2013, for an

overall increase of *** percent.  Derived from CR/PR Table C‐1.

OCTG producers in the cumulated subject countries also produce other welded tubular products

on the same equipment that they use to produce the subject merchandise.   CR/PR at Section VII.  Some,

but not all subject producers indicated that there were constraints on their ability to shift production

from other tubular products to OCTG.  CR/PR at Section VII , n.13, 17, 23, 69, 81, 115, and 130.  Given

the substantial excess capacity in the subject countries, while we acknowledge that there is some

potential for product shifting, we do not place reliance on it for our analysis of likely subject import

volume.

We also observe that the EU and Russia have imposed antidumping duties on imports of certain

OCTG from Ukraine.  Furthermore, Canada recently initiated a preliminary injury inquiry on allegedly

dumped and/or subsidized imports of certain OCTG from Taiwan, India, Indonesia, the Philippines,

Korea, Thailand, Turkey, Ukraine, and Vietnam.  CR at VII‐62, PR at VII‐25.   

We have also considered the nature of the countervailable subsidies.  In its final determinations,

Commerce found that 11 programs in India and ten programs in Turkey were countervailable.  CR at I‐

10‐11, PR at I‐8‐9 .  Commerce’s Issues and Decision Memorandum in the countervailing duty

investigation on OCTG from India characterizes four programs as “countervailable export subsidies.”  

Those are the Advance License/Advance Authorization Program, the Export Promotion Capital Goods

Program, Pre‐Shipment and Post‐Shipment Export Financing, and the State Government of

Maharashtra’s Sales Tax Program.   Memorandum from Christian Marsh to Ronald K. Lorentzen: Issues

and Decision Memorandum for the Final Determination in the Countervailing Duty Investigation of

Certain Oil Country Tubular Goods from India at 18, 23, 25, 29 (July 10, 2014).  Commerce’s Issues and

Decision Memorandum in the countervailing duty investigation on OCTG from Turkey indicates that

three of the programs it found to be countervailable specifically concerned export activities.  These

include the Deductions from Taxable Income for Export Revenue, the Rediscount Program (which

Commerce states is “designed to provide financial support to Turkish exporters, manufacturer‐exporters

and manufacturers supplying exporters” and “is contingent upon an export commitment”) and the Pre‐

Export Credit Program (which Commerce described in the same manner as it described the Rediscount

Program).   Memorandum from Christian Marsh to Ronald K. Lorentzen: Issues and Decisions

Memorandum for the Final Determination in the Countervailing Duty Investigation of Certain Oil Country

Tubular Goods from the Republic of Turkey at 13‐15 (July 10, 2014).  Commerce did not make any

express findings that any of the programs discussed above were the types of programs described in

Articles 3 or 6.1 of the WTO Subsidies Agreement.   
53

2. Likely Price Effects

As explained in Section VI. D. above, the domestic like product and subject imports are

moderately to highly substitutable, and price is an important consideration in purchasing

decisions.  We found significant underselling by subject imports, which caused significant price

depression of the domestic like product.  The inclusion of subject imports from Taiwan does not

change the nature of our underselling findings.323    

Significant underselling of the domestic like product by subject imports will likely

continue in the immediate future absent the issuance of any orders.  Cumulated subject

imports from India, Korea, Taiwan, Turkey, Ukraine, and Vietnam undersold the domestic like

product in 195 out of 225 quarterly comparisons, with underselling margins ranging from ***

percent to *** percent.  The significant and increasing volumes of subject imports that will

likely enter the U.S. market in the imminent future will likely continue predominantly to

undersell the domestic like product at significant rates, as they did during the POI.  The likely

low prices of the subject imports, in turn, are likely to place significant downward pressure on

domestic prices in the imminent future, as they did during the POI.  Accordingly, we find that

subject imports are likely to enter the U.S. market in the imminent future at prices that are

likely to have significant price‐depressing effects and are likely to increase demand for further

imports.

3. Likely Impact324

We found in Section VI.E. above that the domestic industry’s financial performance

indicators declined over the POI due to the presence of significant volumes of cumulated

subject imports which undersold the domestic like product at significant margins.  We have also

found that cumulated subject imports, including subject imports from Taiwan, are likely to

continue to enter the U.S. market in increasing and significant volumes and engage in

significant underselling of the domestic like product in the imminent future.  We conclude that

cumulated subject imports will likely have the same type of adverse impact on the domestic

industry in the imminent future as they did during the POI.  The significant volumes of low‐

priced subject imports will likely continue to cause significant price depression, which will lead

to adverse effects on the domestic industry’s revenues and financial performance.

We have already considered in Section VI.E. above other factors, including nonsubject

imports, and concluded that we have not attributed any likely injury from nonsubject imports

                                                       323 Pricing data collected by the Commission accounted for *** percent of subject imports from

Taiwan.  CR at V‐16, PR at V‐10.  Sales of subject imports from Taiwan were reported for 3 of the 6

pricing products, with the highest volume of subject merchandise from Taiwan concentrated in Product

5 (welded J‐55 casing, 8 5/8” OD, threaded and coupled).  CR/PR at Table V‐10.  Subject imports from

Taiwan undersold the domestic like product in 30 out of 36 quarterly comparisons, with underselling

margins ranging from *** percent to *** percent.  CR/PR at Table V‐14.

324 In its antidumping duty investigation concerning imports from Taiwan, Commerce found that

imports from Taiwan were being sold at LTFV at the following margins:  2.52 percent for Tension Steel

Industries, Co. and 2.52 percent for the all others rate.  CR/PR at Table I‐3.
54

to subject imports.  We accordingly find that further subject imports are imminent and that

material injury by reason of subject imports would occur unless an antidumping duty order is

issued on subject imports from Taiwan.  Accordingly, we have made an affirmative

determination of threat of material injury in the investigation of OCTG from Taiwan.325

IX. Conclusion

For the forgoing reasons, we conclude that a domestic industry in the United States is

materially injured by reason of imports of OCTG from India, Korea, Turkey, Ukraine, and

Vietnam, that critical circumstances do not exist with respect to subject imports from India,

Turkey, and Vietnam covered by Commerce’s affirmative critical circumstances determinations,

and that a domestic industry in the United States is threatened with material injury by reason

of imports of OCTG from Taiwan.326  We also conclude that imports of OCTG from the

Philippines and Thailand are negligible.  

                                                       325 We further determine, pursuant to 19 U.S.C. §1671d(b)(4)(B), that we would have not found

material injury but for the suspension of liquidation of subject imports because we were unable to find

material injury by reason of subject imports from Taiwan because we found they were currently

negligible.   326 Chairman Broadbent dissents from our findings with respect to OCTG from Taiwan.
Separate and Dissenting Views of Chairman Meredith M. Broadbent on Negligibility

Based on the record in these investigations, I find that an industry in the United States is 

materially injured by reason of imports of certain oil country tubular goods (“OCTG”) from 

India, Korea, Turkey, Ukraine, and Vietnam. I also find that imports of OCTG from the 

Philippines, Taiwan, and Thailand are negligible.

In reaching these determinations, I join and adopt all sections of the Views of the 

Commission, with the exception of section IV.C as it pertains to the Commission’s analysis of 

the negligibility of subject imports from Taiwan for purposes of threat of material injury, and 

section VIII, which concerns threat of material injury by reason of subject imports. I write 

separately with respect to the negligibility of subject imports from Taiwan for purposes of 

threat of material injury.

I. Negligible Imports from Taiwan for Purposes of Threat of Material Injury

I determine that there is not a potential that subject imports from Taiwan will 

imminently exceed the 3 percent negligibility threshold. As I discuss in more detail below, I find 

that the subject producers in Taiwan have not exhibited a pattern of substantial growth in 

production nor have the subject imports from Taiwan increased at a rate that it is likely that 

they will surpass 3 percent of total imports in the imminent future. In addition, I determine 

that there is not a potential that the combined subject imports from the Philippines, Taiwan, 

and Thailand will imminently exceed the 7 percent aggregate negligibility threshold. 

In these investigations, the Commission received questionnaire responses from all four 

subject producers of OCTG in Taiwan.1 *** reported investing in a new OCTG-producing mill

during the POI, with the ***.

2 As a result of this new investment, the industry in Taiwan’s 

capacity increased from *** short tons in 2011 to *** short tons in 2012, where it remained in 

2013.3 Despite this sizable increase in the industry’s capacity, the industry’s production only 

increased from *** short tons in 2011 to *** short tons in 2012, and then decreased to ***

short tons in 2013.4 While the industry reported a projected increase in production of ***

short tons between 2013 and 2014, production during the first quarter of 2014 was in fact ***

1 CR at VII-29-30; PR at VII-13. The four responding subject producers in Taiwan are Far East 

Machinery Co. Ltd. (“Far East Machinery”), Kao Hsing Chang Iron & Steel Corp. (“Kao Hsing”), Shin Yang 

Steel Co., Ltd. (“Shin Yang”), and Tension Steel Industries Co., Ltd. (“Tension Steel”). Id. In addition, 

Commerce calculated a final weighted-average margin of 0.00 percent for a fifth producer in Taiwan, 

Chung Hung Steel Corp. (“Chung Hung”), and that producer is not therefore a subject producer. CR at 

VII-30 n. 71; PR at VII-13 n. 71. 2 CR at VII-30; PR at VII-13; *** Foreign Producer Questionnaire at II-10.

3 CR/PR at Table VII-9. 4 Id.

55

 
short tons lower than during the first quarter of 2013.5 Given these stable trends in the 

industry’s production and shipments since the inception of new capacity in 2012, I have 

concluded that it is not likely that the subject industry in Taiwan will substantially increase its 

overall level of shipments in the imminent future. Accordingly, since exports to the United 

States made up nearly *** percent of the Taiwan’s total shipments in 2013,6 I find that it is also 

unlikely that Taiwan will substantially increase its exports to the United States in 2014.7

To estimate the share of total imports that subject imports from Taiwan would account 

for in the imminent future, I assume that subject imports from Taiwan would continue to 

increase at the *** percent rate of growth that occurred between 2012 and 2013, thereby 

rising to *** short tons in 2014.8 Using this amount and the estimated range of total imports in 

2014 described in the Views of the Commission,9 I estimate that subject imports from Taiwan 

would fall in the range between *** percent and *** percent of total imports in 2014.10 On the 

basis of these estimates, I determine that there is not a potential that subject imports from 

Taiwan will imminently exceed 3 percent of total imports.11

5 Id. Similarly, while the industry reported a projected increase in shipments of *** short tons 

between 2013 and 2014, total shipments during the first quarter of 2014 were *** short tons lower 

than during the first quarter of 2013.

6 CR/PR at Table VII-9. 7 I note that the subject producers in Taiwan projected production of *** short tons in 2014, 

with exports to the United States of *** short tons in that year. This projected production would be ***

short tons higher than in 2013, with exports to the United States being *** short tons higher. CR/PR at 

Table VII-9. The industry’s projected increase in production, however, is entirely driven by the 

projections of ***, which projected that it would increase production to *** short tons in 2014, reaching 

a capacity utilization rate of ***. However, *** capacity utilization rate peaked at *** percent in 2013, 

even though it had the same capacity to produce OCTG in both 2012 and 2013. *** does not project any 

increase in capacity in 2014, and its production was *** short tons in the first quarter of 2014, 

compared to *** short tons in the first quarter of 2013. CR/PR at Table VII-9; *** Foreign Producer 

Questionnaire at II-10. Because of the sustained *** of *** unchanged capacity throughout the entire 

period of investigation, I do not find the production and export projections of *** to be indicative of 

future increased exports from Taiwan to the United States. 8 CR/PR at Table C-1. I note that this rate of growth is a high estimate, given that a volume of 

U.S. subject imports from Taiwan that totaled *** short tons would surpass the highest volume of total 

exports from Taiwan and total production from Taiwan in any year during the POI. As stated above, I do 

not find it likely that Taiwan will substantially increase its production and total shipments in the 

imminent future.

9 In the Views of the Commission, the Commission estimated that total imports in 2014 would 

fall in a range between *** short tons and *** short tons. See Views of the Commission at section IV.C. 10 These estimates were calculated as follows, using the methodology described in footnote 91

of the Views of the Commission: ***. 11 I note that in the 12 months before the filing of the petitions in these investigations (July 2012 

through June 2013), subject imports from Taiwan only reached or exceeded 3 percent of total U.S. 

imports in *** months, and at no time were these higher levels sustained for more than *** months at a 

time. CR/PR at Table G-3. This trend reinforces my conclusion that subject imports from Taiwan will not 

exceed 3 percent of total imports for any sustained period of time in the imminent future.

56

 
Aggregate Analysis. Consistent with the discussion above and my findings that imports 

from the Philippines and Thailand are not likely to exceed the 3 percent negligibility threshold 

in the imminent future, I also determine there is not a potential that subject imports from the 

Philippines, Taiwan, and Thailand will imminently exceed the 7 percent aggregate negligibility 

threshold. In reaching this conclusion, I added together my estimated shares of total U.S. 

imports for each of the three subject sources in the imminent future. These shares range 

between *** and *** percent for the Philippines, between *** and *** percent for Taiwan,

and between *** and *** percent for Thailand.

12 Summing these ranges, I find that the 

aggregate level of the subject imports from these three sources will be between *** and ***

percent in the imminent future. Thus, I find that there is not a potential that subject imports 

from the Philippines, Taiwan, and Thailand will imminently exceed 7 percent of total imports.

Conclusion. For the foregoing reasons, I determine that subject imports from the 

Philippines, Taiwan, and Thailand are negligible for purposes of both my present material injury 

analysis and my threat of material injury analysis.

12 See Views of the Commission at section IV.C. 

57

 

PART I: INTRODUCTION

BACKGROUND

These investigations result from a petition filed with the U.S. Department of Commerce 

(“Commerce”) and the U.S. International Trade Commission (“USITC” or “Commission”) by 

United States Steel Corporation (“U.S. Steel”), Pittsburgh, PA; Maverick Tube Corporation 

(“Maverick”), Houston, TX; Boomerang Tube LLC (“Boomerang”), Chesterfield, MO; EnergeX, a 

division of JMC Steel Group (“EnergeX”), Chicago, IL; Northwest Pipe Company (“Northwest”), 

Vancouver, WA; Tejas Tubular Products Inc. (“Tejas”), Houston, TX; TMK IPSCO, Houston, TX; 

Vallourec Star (“Vallourec”), L.P., Houston, TX; and Welded Tube USA (“Welded Tube”), Inc.; 

Lackawanna, NY, on July 2, 2013, alleging that an industry in the United States is materially 

injured and threatened with material injury by reason of subsidized imports of certain oil 

country tubular goods (“OCTG”)1 from India and Turkey, and less-than-fair-value (“LTFV”) 

imports of OCTG from India, Korea, Philippines, Saudi Arabia,2 Taiwan, Thailand, Turkey, 

Ukraine, and Vietnam. The following tabulation provides information relating to the 

background of these investigations.3 4

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

description of the merchandise subject to these investigations. 2 Maverick and Vallourec took no position with regard to the petition for the imposition of 

antidumping duties on OCTG from Saudi Arabia.On August 11, 2014, after correcting ministerial errors in 

its original final determination of sales at less than fair value with respect to OCTG from Saudi Arabia, 

Commerce terminated that investigation. DOC, ITA, Amended Final Determination and Termination of 

the Investigation of Sales at Less Than Fair Value: Certain Oil Country Tubular Goods From Saudi Arabia, 

Ronald K. Lorentzen, Acting Assistant Secretary for Enforcement and Compliance, August 11, 2014. The

Commission consequently terminated its investigation regarding Saudi Arabia. The report presented 

herein maintains references to Saudi Arabia. Appendix G presents key tables excluding Saudi Arabia 

from subject merchandise.

3 Pertinent Federal Register notices are referenced in app. A, and may be found at the Commission’s 

website (www.usitc.gov). 4 Appendix B presents the hearing witness list.

I-1

 
Effective date Action

July 2, 2013 Petition filed with Commerce and the Commission; 

institution of Commission’s investigations (78 FR 41421, 

July 10, 2013)

July 29, 2013 Commerce’s notice of initiation of countervailing duty and 

antidumping duty investigations (78 FR 45502 and 

45505, July 29, 2013)

August 16, 2013 Commission’s preliminary determination (78 FR 52213, 

August 22, 2103)

December 23, 2013 Commerce’s preliminary determinations: India CVD (78 

FR 77421, December 23, 2013) and Turkey CVD (78 FR 

77420, December 23, 2013)

February 25, 2014 Commerce’s preliminary determinations: India LTFV (79

FR 10493, February 25, 2014), Korea LTFV (79 FR 

10480, February 25, 2014), Philippines LTFV (79 FR 

10491, February 25, 2014); Saudi Arabia LTFV (79 FR 

10489, February 25, 2014), Taiwan (amended) LTFV (79 

FR 18667, April 3, 2104), Thailand LTFV (79 FR 10487, 

February 25, 2014), Turkey LTFV (79 FR 10484, 

February 25, 2014), Ukraine LTFV (79 FR 10482, 

February 25, 2014), and Vietnam LTFV (79 FR 10478, 

February 25, 2014);

Scheduling of final phase of Commission’s investigations

(78 FR 19122, April 7, 2014)

July 10, 2014 Commerce’s suspension of Ukraine antidumping 

investigation (79 FR 41959, July 18, 2014)

July 15, 2014 Commission’s hearing

July 18, 2014 Commerce’s final determinations: India CVD (79 FR 

41959, July 18, 2014); Turkey CVD (79 FR 41964, July 

18, 2014); India LTFV (79 FR 41981, July 18, 2014), 

Korea LTFV (79 FR 41983, July 18, 2014), Philippines 

LTFV (79 FR 41976, July 18, 2014); Saudi Arabia LTFV 

(79 FR 41986, July 18, 2014), Taiwan LTFV (79 FR 

41979, July 18, 2014), Thailand LTFV (79 FR 41978, July 

18, 2014), Turkey LTFV (79 FR 41971, July 18, 2014), 

Ukraine LTFV (79 FR 41969, July 18, 2014), and 

Vietnam LTFV (79 FR 41973, July 18, 2014)

August 22, 2014 Commission’s vote

September 2, 2014 Commission’s determinations

September 9, 2014 Commission’s views 

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--

I-2
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 decline 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.

Organization of report

Part I of this report presents information on the subject merchandise, subsidy/dumping 

margins, and domestic like product. Part II of this report presents information on conditions of 

I-3
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 of subject imports and pricing of domestic and 

imported products, 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 as well as 

information regarding nonsubject countries.

MARKET SUMMARY

OCTG generally is used in oil and gas wells, and consists primarily of casing and tubing. 

The leading U.S. mills producing OCTG are U.S. Steel and TMK IPSCO, both of which produce 

OCTG in multiple U.S. facilities and manufacture both seamless and welded OCTG. Several 

independent processors, led by Texas Steel Conversion and Tubular Services, provide additional 

heat treating capabilities. The leading producers of OCTG in subject countries include 

Maharashtra of India (“Maharashtra”), Hyundai HYSCO and AJU Besteel of Korea, HLD Clark of 

the Philippines, Jubail Energy Services Company (“JESCO”) of Saudi Arabia, Tension Steel 

Industries (“Tension Steel”) of Taiwan, Boly Pipe of Thailand, Borusan of Turkey, Interpipe of 

Ukraine, and SeAH Steel Vina of Vietnam. Leading producers of OCTG in nonsubject countries 

include the following: Tenaris in Argentina; Tenaris, Evraz, and Vallourec in Canada; Vallourec 

and Benteler Steel/Tube in Germany; Nippon Steel Sumitomo Metals (NSSM), JFE Steel, Tenaris 

NKKTubes, and Maruichi Steel Tube in Japan; and Tenaris TAMSA in Mexico. The leading U.S. 

importers of OCTG from subject countries are ***. Leading importers of OCTG from nonsubject 

countries (primarily Argentina, Canada, Germany, Japan, and Mexico) include ***. U.S. 

purchasers of OCTG include distributors - which typically purchase directly from U.S. mills and 

U.S. importers - as well as production and exploration companies that purchase from the 

distributors.

Apparent U.S. consumption of OCTG totaled approximately 7.0 million short tons ($10.1

billion) in 2013. Currently, 18 firms are known to produce OCTG in the United States, all but one 

of which provided usable data to the Commission. U.S. mills’ U.S. shipments of OCTG totaled 

3.7 million short tons ($5.8 billion) in 2013, and accounted for 53.5 percent of apparent U.S. 

consumption by quantity and 57.8 percent by value (60.4 percent with the inclusion of revenue 

generated by U.S. processors). U.S. imports from subject sources totaled *** short tons (***) in 

2013 and accounted for *** percent of apparent U.S. consumption by quantity and *** percent 

by value. U.S. imports from nonsubject sources totaled *** short tons ($***) in 2013 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 these investigations is presented in appendix C, table C1. Except as noted, U.S. industry data are based on questionnaire responses of 17 mills and 

processors that accounted for the vast majority of U.S. production of OCTG during 2013

(including both pipe forming and heat treatment). U.S. imports are based on official Commerce 

I-4
statistics except as noted. Additional information regarding nonsubject price data appears in 

appendix E.

PREVIOUS AND RELATED INVESTIGATIONS

Antidumping and countervailing duty investigations

OCTG has been the subject of several Commission investigations. Table I-1 presents a

listing of these investigations.

Table I-1

OCTG: Previous and related investigations, since 1984

Original investigation Commission reviews Current status

Date Number Country Outcome Dates1 Outcomes

1984 701-TA-215 Brazil Affirmative - - ITA revoked 8/21/85

1984 701-TA-216 Korea Negative - - -

1984 701-TA-217 Spain Affirmative - - ITA revoked 7/31/85

1984 731-TA-191 Argentina Negative - - -

1984 731-TA-192 Brazil Affirmative2 - - Petition withdrawn

1984 731-TA-193 Korea Affirmative2 - - Petition withdrawn

1984 731-TA-194 Mexico Affirmative2 - - Petition withdrawn

1984 731-TA-195 Spain Affirmative - - ITA revoked 6/30/85

1985 701-TA-240 Austria Affirmative2 - - Petition withdrawn

1985 701-TA-241 Venezuela Affirmative2 - - Petition withdrawn

1985 701-TA-255 Canada Affirmative - - ITA revoked 7/10/91

1985 701-TA-256 Taiwan Negative - - -

1985 731-TA-249 Austria Affirmative2 - - Petition withdrawn

1985 731-TA-251 Venezuela Affirmative2 - - Petition withdrawn

1985 731-TA-275 Argentina Affirmative2 - - Terminated

1985 731-TA-276 Canada Affirmative 1999 / - Negative / - Revoked

1985 731-TA-277 Taiwan Affirmative 1999 / - Negative / - Revoked

1986 701-TA-271 Israel Affirmative - - ITA revoked 3/1/93

1986 731-TA-318 Israel Affirmative - - ITA revoked 7/27/99

Table continued on next page.

I-5
Table I-1--Continued

OCTG: Previous and related investigations, since 1984

Original investigation Commission reviews Current status

Date Number Country Outcome Dates1 Outcomes

1995 701-TA-363 Austria Negative - - -

1995 701-TA-364 Italy Affirmative 2001 / - Affirmative / - ITA revoked 12/26/06

1995 731-TA-711 Argentina Affirmative 2001 / 2006 Affirmative/Negative Revoked

1995 731-TA-712 Austria Negative - - -

1995 731-TA-713 Italy Affirmative 2001 / 2006 Affirmative/Negative Revoked

1995 731-TA-714 Japan Affirmative 2001 / 2006 Affirmative/Negative Revoked

1995 731-TA-715 Korea Affirmative 2001 / 2006 Affirmative/Negative Revoked

1995 731-TA-716 Mexico Affirmative 2001 / 2006 Affirmative/Negative Revoked

1995 731-TA-717 Spain Negative - - -

2002 701-TA-428 Austria Negative2 - - -

2002 731-TA-992 Austria Negative2 - - -

2002 731-TA-993 Brazil Negative2 - - -

2002 731-TA-994 China Negative2 - - -

2002 731-TA-995 Colombia (

3

) - - -

2002 731-TA-996 France Negative2 - - -

2002 731-TA-997 Germany Negative2 - - -

2002 731-TA-998 India Negative2 - - -

2002 731-TA-999 Indonesia Negative2 - - -

2002 731-TA-1000 Romania Negative2 - - -

2002 731-TA-1001 South Africa Negative2 - - -

2002 731-TA-1002 Spain Negative2 - - -

2002 731-TA-1003 Turkey Negative2 - - -

2002 731-TA-1004 Ukraine Negative2 - - -

2002 731-TA-1005 Venezuela Negative2 - - -

2009 701-TA-463 China Affirmative - - Order in place

2009 731-TA-1159 China Affirmative - - Order in place

1 “Date” or “Dates” refers to the year in which the investigation, first review, or second review was instituted by the 

Commission.

2 Preliminary determination.

3 Following the withdrawal of the petition on Colombia and Commerce’s decision not to institute an investigation on 

OCTG from that country, the Commission discontinued its investigation No. 731-TA-995 (OCTG from Colombia).

Source: Compiled from Commission determinations published in the Federal Register.

I-6
Safeguard investigations

Following receipt of a request from the Office of the United States Trade Representative 

(“USTR”) on June 22, 2001, the Commission instituted investigation No. TA-201-73, Steel, under 

section 202 of the Trade Act of 19745 to determine whether certain steel products, including 

seamless and welded OCTG,6 were being imported into the United States in such increased 

quantities as to be a substantial cause of serious injury, or the threat thereof, to the domestic 

industries producing articles like or directly competitive with the imported article.7 On July 26, 

2001, the Commission received a resolution adopted by the Committee on Finance of the U.S. 

Senate (“Senate Finance Committee” or “Committee”) requesting that the Commission 

investigate certain steel imports under section 201 of the Trade Act of 1974.8 Consistent with 

the Senate Finance Committee’s resolution, the Commission consolidated the investigation 

requested by the Committee with the Commission’s previously instituted investigation No. TA201-73.9 On December 20, 2001, the Commission issued its determinations and remedy 

recommendations. The Commission made a negative determination with respect to OCTG.10

The Commission also made a negative determination with respect to seamless tubular products 

other than OCTG.11

5 19 U.S.C. § 2252.

6 Seamless and welded casing and tubing, as well as seamless drill pipe, were found to be a single 

“like or directly competitive” product by Chairman Stephen Koplan, Vice Chairman Deanna Tanner Okun, 

and Commissioners Marcia E. Miller and Jennifer A. Hillman, while Commissioners Lynn M. Bragg and 

Dennis M. Devaney found seamless and welded OCTG to be part of broader product groupings including 

all seamless carbon and alloy steel tubular products and all welded carbon and alloy steel tubular 

products, respectively. See, e.g., Steel, Inv. No. TA- 201-73, Volume I: Determinations and Views of 

Commissioners, USITC Publication 3479, December 2001, pp. 17-18; 152-154; 274-275; and 318-319. 7 Institution and Scheduling of an Investigation under Section 202 of the Trade Act of 1974 (19 U.S.C. 

2252) (the Act), 66 FR 35267, July 3, 2001.

8 19 U.S.C. § 2251.

9 Consolidation of Senate Finance Committee Resolution Requesting a Section 201 Investigation with 

the Investigation Requested by the United States Trade Representative on June 22, 2001, 66 FR 44158, 

August 22, 2001.

10 Steel; Import Investigations, 66 FR 67304, December 28, 2001. Specifically, Chairman Koplan, Vice 

Chairman Okun, and Commissioners Miller and Hillman made a negative determination with respect to 

OCTG, while Commissioners Bragg and Devaney dissented, having made affirmative determinations with 

respect to all seamless carbon and alloy steel tubular products and all welded carbon and alloy steel 

tubular products. 11 Ibid. This product includes coupling stock. See USITC Publication 3479, Vol. I, p. 13.

I-7

 
NATURE AND EXTENT OF SUBSIDIES AND SALES AT LTFV

Subsidies

On July 18, 2014, Commerce published notices in the Federal Register of its affirmative 

final determination of countervailable subsidies for producers and exporters of OCTG from 

India12 and affirmative final determination of countervailable subsidies for producers and 

exporters of OCTG from Turkey.

13 Table I-2 presents Commerce’s findings. The following 

programs in India were determined to be countervailable:

14

I. Government of India Programs

1. Advance License Program/Advance Authorization Program

2. Duty Drawback

3. Export Promotion Capital Goods Program

4. Pre-Shipment and Post-Shipment Export Financing

5. Income Tax Exemption Program Under Section 80-IA of the Income Tax 

Act

6. Provision of Hot-Rolled Steel by the Steel Authority of India, Ltd. at Less 

Than Adequate Remuneration

II. Programs by State Government of Maharashtra (“SGOM”)

1. SGOM Sales Tax Program

2. SGOM Subsidies Under the Package Scheme of Incentives of 2007

i. Exemption from Electricity Duty for up to 15 Years

ii. Exemption from Stamp Duty

iii. Industrial Promotion Subsidy (IPS)

III. State Government of Uttar Pradesh (SGUP) – Exemption from Entry Tax for the 

Iron and Steel Industry

12 Certain Oil Country Tubular Goods From India: Final Affirmative Countervailing Duty Determination 

and Partial Final Affirmative Determination of Critical Circumstances, 79 FR 41967, July 18, 2014.

13 Certain Oil Country Tubular Goods From the Republic of Turkey: Final Affirmative Countervailing 

Duty Determination and Final Affirmative Critical Circumstances Determination, 79 FR 41964, July 18, 

2014. 14 DOC, ITA, Issues and Decision Memorandum for the Final Determination in the Countervailing Duty 

Investigation of Certain Oil Country Tubular Goods from India, July 10, 2014.

I-8

 
The following programs in Turkey were determined to be countervailable:15

I. Deductions from Taxable Income for Export Revenue

II. Export Financing

1. Rediscount Program (Short-Term Pre-Shipment Rediscount Program)

2. Pre-Export Credit Program

III. Investment Encouraging Program (“IEP”): Customs Duty and VAT Exemptions

IV. Provision of Electricity for Less Than Adequate Enumeration/ Law 5084: Energy 

Support

V. Provision of Land for LTAR

VI. Provision of HRS for LTAR

VII. Withholding of Income Tax on Wages and Salaries

VIII. Exemption from Property Tax

IX. Law 5084: Incentive for Employers’ Share in Insurance Premiums

Table I-2

OCTG: Commerce’s subsidy determinations with respect to imports from India and Turkey

Country and firm

Countervailable subsidy margin 

(percent)

India Preliminary1 Final2

 GVN Fuels Limited/

 Maharashtra Seamless Limited/Jindal Pipes Limited 3.50 5.67

 Jindal SAW Limited 0.97 (de minimis) 19.11

 All others 3.50 12.39

Turkey

 Borusan Istikbal Ticaret and Borusan Mannesmann Boru Sanayi 0.37 (de minimis) 15.89

 Tosyali Dis Ticaret A.S, Tosc ̧elik Profil ve Sac Endustrisi A.S.,

 Tosyali Elektrik Enerjisi Toptan Satis Ith. Ihr. A.S., nd Tosyali

 Holding A.S. 0.88 (de minimis) 2.53

 All others 0.63 (de minimis) 9.21

1 Certain Oil Country Tubular Goods From India: Preliminary Affirmative Countervailing Duty 

Determination and Alignment of Final Determination With Final Antidumping Determination, 78 FR 77421, 

December 23, 2013 and Certain Oil Country Tubular Goods From the Republic of Turkey: Preliminary 

Negative Countervailing Duty Determination and Alignment of Final Determination With Final Antidumping 

Determination, 78 FR 77420, December 23, 2013.

2 Certain Oil Country Tubular Goods From India: Final Affirmative Countervailing Duty Determination and 

Partial Final Affirmative Determination of Critical Circumstances, 79 FR 41967, July 18, 2014 and Certain 

Oil Country Tubular Goods From the Republic of Turkey: Final Affirmative Countervailing Duty 

Determination and Final Affirmative Critical Circumstances Determination, 79 FR 41964, July 18, 2014.

15 DOC, ITA, Issues and Decision Memorandum for the Final Determination in the Countervailing Duty 

Investigation of Certain Oil Country Tubular Goods from the Republic of Turkey, July 10, 2014.

I-9

 
Sales at LTFV

On July 10, 2014, Commerce and Interpipe finalized a suspension agreement that covers 

substantially all imports of the subject merchandise and will eliminate completely sales at LTFV 

of imported subject merchandise. 16 On July 18, 2014, Commerce published notices in the 

Federal Register of its affirmative final determinations of sales at LTFV with respect to imports 

from India, Korea, Philippines, Saudi Arabia, Taiwan (other than Chung Hung Steel Corp.), 

Thailand, Turkey (other than Borusan), Ukraine, and Vietnam. Table I-3 presents Commerce’s 

findings. 

Table I-3 

OCTG: Commerce’s weighted-average LTFV margins with respect to imports from India, Korea, 

Philippines, Saudi Arabia, Taiwan, Thailand, Turkey, Ukraine, and Vietnam

Country/producer

LTFV (dumping) margin 

(percent)

India Preliminary1 Final2

Jindal SAW Ltd. 55.29 9.91

GVN Fuels Ltd., Maharashtra Seamless Ltd., and Jindal Pipe Ltd. 0.0 2.05

All others 55.29 5.79

Korea

Hyundai HYSCO 0.00 15.75

NEXTEEL Co., Ltd. 0.00 9.89

All others (

3

) 12.82

Philippines

HLD Clark Steel Pipe Co., Inc. 8.90 9.88

All others 8.90 9.88

Saudi Arabia

Duferco SA/Jubail Energy Services Company 2.92 2.69/0.00 

All others 2.92 2.69/0.00 

Taiwan

Chung Hung Steel Corp. 0.00 0.00

Tension Steel Industries Co., Ltd. 0.00 2.52

All others (

3

) 2.52

Thailand

WSP Pipe Co., Ltd. 118.32 118.32

All others 118.32 118.32

Table continued on next page.

16 Suspension of Antidumping Investigation: Certain Oil Country Tubular Goods From Ukraine, 79 FR 

41959, July 18, 2014. 

I-10
Table I-3 

OCTG: Commerce’s weighted-average LTFV margins with respect to imports from India, Korea, 

Philippines, Saudi Arabia, Taiwan, Thailand, Turkey, Ukraine, and Vietnam

Country/producer

LTFV (dumping) margin 

(percent)

Turkey Preliminary1 Final2

Borusan Mannesmann Boru Sanayi ve Ticaret and Borusan Istikbal 

Ticaret (collectively Borusan) 0.00 0.00

Cayirova Boru Sanayi ve Ticaret A.S. and Yucel Boru IthalatIhracat ve Pazarlama A.S. (collectively Yucel) 4.87 35.86

All others 4.87 35.86

Ukraine

Interpipe Europe S.A.; Interpipe Ukraine LLC; PJSC Interpipe 

Niznedneprovsky Tube Rolling Pipe (aka Interpipe NTRP); LLC 

Interpipe Niko Tube4 5.31 6.73

All others 5.31 6.73

Vietnam

SeAH Steel VINA Corporation 9.57 24.22

Vietnam-wide entity rate 111.47 111.47

1 Certain Oil Country Tubular Goods From India: Preliminary Determination of Sales at Less Than Fair 

Value, Preliminary Affirmative Determination of Critical Circumstances, in Part, and Postponement of 

Final Determination, 79 FR 10493, February 25, 2014; Certain Oil Country Tubular Goods From the 

Republic of Korea: Negative Preliminary Determination of Sales at Less Than Fair Value, Negative 

Preliminary Determination of Critical Circumstances and Postponement of Final Determination, 79 FR 

41981, July 18, 2014; Certain Oil Country Tubular Goods From the Republic of the Philippines: 

Preliminary Affirmative Determination of Sales at Less Than Fair Value, Negative Preliminary 

Determination of Critical Circumstances, and Postponement of Final Determination, 79 FR 10491, 

February 25, 2014; Certain Oil Country Tubular Goods From Saudi Arabia: Preliminary Determination of 

Sales at Less Than Fair Value, and Postponement of Final Determination, 79 FR 10489, February 25, 

2014; Certain Oil Country Tubular Goods From Taiwan: Affirmative Preliminary Determination of Sales at 

Less Than Fair Value and Postponement of Final Determination, 79 FR 10495, February 25, 2014 and 

Certain Oil Country Tubular Goods From Taiwan: Amended Preliminary Negative Determination of Sales 

at Less Than Fair Value and Postponement of Final Determination, 79 FR 18667, April 3, 2014; Certain 

Oil Country Tubular Goods From Thailand: Preliminary Determination of Sales at Less Than Fair Value, 

and Postponement of Final Determination, 79 FR 10487, February 25, 2014; Certain Oil Country Tubular 

Goods From the Republic of Turkey: Preliminary Affirmative Determination of Sales at Less Than Fair 

Value, Negative Preliminary Determination of Critical Circumstances, and Postponement of Final 

Determination, 79 FR 10484, February 25, 2014; Certain Oil Country Tubular Goods From Ukraine: 

Preliminary Determination of Sales at Less Than Fair Value, Negative Preliminary Determination of 

Critical Circumstances, and Postponement of Final Determination, 79 FR 10482, February 25, 2014; 

Certain Oil Country Tubular Goods From the Socialist Republic of Vietnam: Preliminary Determination of 

Sales at Less Than Fair Value, Affirmative Preliminary Determination of Critical Circumstances, in Part, 

and Postponement of Final Determination, 79 FR 10478, February 25, 2014. 2 Final Determination of Sales at Less Than Fair Value and Final Negative Determination of Critical 

Circumstances: Certain Oil Country Tubular Goods From India, 79 FR 41981, July 18, 2014; Certain Oil 

Country Tubular Goods From the Republic of Korea: Final Determination of Sales at Less Than Fair 

Value and Negative Final Determination of Critical Circumstances, 79 FR 41983, July 18, 2014; Certain 

Oil Country Tubular Goods From the Republic of the Philippines: Final Determination of Sales at Less 

(Notes continued on following page)

I-11
Than Fair Value and Negative Final Determination of Critical Circumstances, 79 FR 41976, July 18, 2014; 

Certain Oil Country Tubular Goods From Saudi Arabia: Final Determination of Sales at Less Than Fair

Value, 79 FR 41986, July 18, 2014; Certain Oil Country Tubular Goods From Taiwan: Final Determination 

of Sales at Less Than Fair Value, 79 FR 41979, July 18, 2014; Certain Oil Country Tubular Goods From 

Thailand: Final Determination of Sales at Less Than Fair Value, 79 FR 41978, July 18, 2014; Certain Oil 

Country Tubular Goods From the Republic of Turkey: Final Determination of Sales at Less Than Fair 

Value and Affirmative Final Determination of Critical Circumstances, in Part, 79 FR 41971, July 18, 2014; 

Certain Oil Country Tubular Goods From Ukraine: Final Determination of Sales at Less Than Fair Value 

and Final Negative Determination of Critical Circumstances, 79 FR 41969, July 18, 2014; and Certain Oil 

Country Tubular Goods From the Socialist Republic of Vietnam: Final Determination of Sales at Less 

Than Fair Value and Final Affirmative Determination of Critical Circumstances, 79 FR 41973, July 18, 

2014.

3 Commerce did not calculate a weighted-average dumping margin for all other producers or exporters 

because it did not make an affirmative preliminary determination of sales at less than fair value. 79 FR 

10481, February 25, 2014 and 79 FR 18667, April 3, 2014. Certain Oil Country Tubular Goods From 

Ukraine: Final Determination of Sales at Less Than Fair Value and Final Negative Determination of 

Critical Circumstances, 79 FR 41969, July 18, 2014; and Certain Oil Country Tubular Goods

From the Socialist Republic of Vietnam: Final Determination of Sales at Less Than Fair Value and Final

Affirmative Determination of Critical Circumstances, 79 FR 41973, July 18, 2014. 4 The Department determined that Interpipe Europe S.A.; Interpipe Ukraine LLC; PJSC Interpipe 

Niznedneprovsky Tube Rolling Pipe (aka Interpipe NTRP); LLC Interpipe Niko Tube; North American 

Interpipe, Inc. (collectively, Interpipe) are affiliated and should be considered a single entity.

THE SUBJECT MERCHANDISE

Commerce’s scope

Commerce has defined the scope of this investigation as follows:

OCTG, which are hollow steel products of circular cross-section, including 

oil well casing and tubing, of iron (other than cast iron) or steel (both 

carbon and alloy), whether seamless or welded, regardless of end finish 

(e.g., whether or not plain end, threaded, or threaded and coupled) 

whether or not conforming to American Petroleum Institute (API) or nonAPI specifications, whether finished (including limited service OCTG 

products) or unfinished (including green tubes and limited service OCTG 

products), whether or not thread protectors are attached. The scope of 

the investigation also covers OCTG coupling stock. Excluded from the 

scope of the investigation are: casing or tubing containing 10.5 percent or 

more by weight of chromium; drill pipe; unattached couplings; and 

unattached thread protectors.17

17 Certain Oil Country Tubular Goods the Republic of Korea: Final Determination of Sales at Less Than 

Fair Value and Negative Final Determination of Critical Circumstances, 79 FR 41983, July 18, 2014.

I-12

 
Tariff treatment

The imported OCTG subject to these investigations are classified in the 2014

Harmonized Tariff Schedule of the United States (“HTSUS”) in subheadings 7304.29, 7305.20, 

and 7306.29, casing and tubing of a kind used in drilling for oil and gas.18 The HTSUS provisions 

are provided for convenience and customs purposes only; the written description of the scope 

of these investigations is dispositive. The column 1-general (most-favored-nation) rate of duty 

for the enumerated subheadings, applicable to products subject to the investigations, is free.

THE PRODUCT19

Overview

Steel pipe and tubes are made in circular, rectangular, or other cross sections, and are 

generally manufactured by either the welded or seamless process. Steel pipe and tube 

manufactured by either process can be categorized by the carbon and alloy grades used in steel 

production. In addition, steel pipe and tube can be further categorized by end-use. The 

American Iron and Steel Institute (AISI) has defined six such end-use categories: standard pipe, 

line pipe, structural pipe and tubing, mechanical tubing, pressure tubing, and oil country 

tubular goods (OCTG).20

18 The merchandise subject to the investigations is currently imported under the following statistical 

reporting numbers of the HTSUS: 7304.29.1010, 7304.29.1020, 7304.29.1030, 7304.29.1040, 

7304.29.1050, 7304.29.1060, 7304.29.1080, 7304.29.2010, 7304.29.2020, 7304.29.2030, 7304.29.2040, 

7304.29.2050, 7304.29.2060, 7304.29.2080, 7304.29.3110, 7304.29.3120, 7304.29.3130, 7304.29.3140, 

7304.29.3150, 7304.29.3160, 7304.29.3180, 7304.29.4110, 7304.29.4120, 7304.29.4130, 7304.29.4140, 

7304.29.4150, 7304.29.4160, 7304.29.4180, 7304.29.5015, 7304.29.5030, 7304.29.5045, 7304.29.5060, 

7304.29.5075, 7304.29.6115, 7304.29.6130, 7304.29.6145, 7304.29.6160, 7304.29.6175, 7305.20.2000, 

7305.20.4000, 7305.20.6000, 7305.20.8000, 7306.29.1030, 7306.29.1090, 7306.29.2000, 7306.29.3100, 

7306.29.4100, 7306.29.6010, 7306.29.6050, 7306.29.8110, and 7306.29.8150.

The merchandise subject to the investigations (including coupling stock) may also enter under the 

following HTSUS statistical reporting numbers: 7304.39.0024, 7304.39.0028, 7304.39.0032, 

7304.39.0036, 7304.39.0040, 7304.39.0044, 7304.39.0048, 7304.39.0052, 7304.39.0056, 7304.39.0062, 

7304.39.0068, 7304.39.0072, 7304.39.0076, 7304.39.0080, 7304.59.6000, 7304.59.8015, 7304.59.8020, 

7304.59.8025, 7304.59.8030, 7304.59.8035, 7304.59.8040, 7304.59.8045, 7304.59.8050, 7304.59.8055, 

7304.59.8060, 7304.59.8065, 7304.59.8070, 7304.59.8080, 7305.31.4000, 7305.31.6090, 7306.30.5055, 

7306.30.5090, 7306.50.5050, and 7306.50.5070.

19 Except as noted, information presented in the “Description and Applications” and “Manufacturing 

Processes” is drawn from Certain Oil Country Tubular Goods from China, Investigation No. 701-TA-463 

(Final), USITC Publication 4124, January 2010.

20 OCTG are steel pipe and tubes used in the drilling of oil and gas wells and in the conveying of oil 

and gas from within the well to ground level. Standard, line, and pressure pipe is generally intended to 

convey liquids and is typically tested and rated for its ability to withstand hydrostatic pressure. 

Structural pipe and tubing is used for load-bearing purposes and construction, and only small amounts 

I-13

 

(continued...)
Steel pipe and tubes are generally produced according to standards and specifications 

published by a number of organizations, including the American Society for Testing and 

Materials (ASTM), the American Society of Mechanical Engineers (ASME), and the American 

Petroleum Institute (API). Comparable organizations in the United Kingdom, Japan, and Russia, 

and other countries also have developed standard specifications for steel pipe and tubes.

Description and applications

OCTG includes casing and tubing of carbon and alloy steel used in oil and gas wells. 

Figure I-1 shows a simplified schematic arrangement of a typical well with a system of casing 

and tubing. Figure I-2 presents a more detailed representation of an oil or gas well, including 

descriptions of different types of casing by depth and function.

of seamless pipe are used in structural applications. Seamless mechanical tubing is typically a customdesigned product employed within the automotive industry and by equipment manufacturers. 

I-14

 

(...continued)
Figure I-1

Casing and tubing: Simplified diagrammatic representation of a well showing the casing strings 

and production tubing

Source: Introduction to Oil and Gas Production, Fifth Edition, American Petroleum Institute, June 1996, p. 11.

I-15
Figure I-2

Casing and tubing: Subsurface components of an oil or gas well, including descriptions of 

different types of casing by depth and function

Source: La Plata County Energy Council, Inc. (Durango, CO), “Gas Facts: Gas Well Life Cycle,” found at 

http://www.energycouncil.org/gas-well-life-cycle, retrieved July 30, 2013.

I-16
Recent advancements in oil and gas exploration technologies, including advanced 

horizontal drilling21 and hydraulic fracturing (figure I-3),22 have enabled oil and gas wells to 

reach locations that were previously deemed cost-prohibitive. In addition, the application of 

new technologies permits more wells per acre, thus increasing oil and gas production and 

recoverable reserves.

Casing is a circular pipe that serves as a structural retainer for the walls of the well. 

Casing typically has an outside diameter (OD) ranging from 4.5 inches to 20 inches and a length 

typically ranging from 34 feet to 48 feet. Casing provides a firm foundation for the drill string23

by supporting the walls of the hole to prevent caving in or wall collapse both during drilling and 

after the well is completed. After the casing is set in the well hole, concrete is usually pumped 

down through the casing to the bottom of the well and then up the annulus (the space between 

the well wall and the casing) until the annulus is filled.

21 Horizontal drilling is a variant of directional drilling in which vertical drilling within a well turns 

horizontal with the reservoir rock to expose more of the wellbore to the oil or natural gas. More oil and 

natural gas can be produced from fewer wells with less surface disturbance. American Petroleum 

Institute (API), “Advanced Drilling Techniques,” found at http://www.api.org/oil-and-natural-gasoverview/exploration-and-production/natural-gas/advanced-drilling, retrieved July 29, 2013. As of June 

6, 2014, 67 percent of active rotary rigs (1,250 rigs) in the United States employed horizontal drilling, 

while 12 percent (221 rigs) employed directional drilling; the remaining 21 percent (389 rigs) employed 

vertical drilling. Baker Hughes International Inc., “North American Rotary Rig Count,” June 6, 2014. 22 Hydraulic fracturing (commonly referred to as “fracking”) requires the high-pressure injection of a 

mixture of water, sand, and chemicals through the well and into the surrounding shale rock formations, 

creating a network of narrow fractures in the rock. The fractures allow more oil and natural gas to enter 

through perforations made in the casing and tubing.

23 The drill string consists of three different nonsubject products: drill pipe, drill collars, and the drill 

bit.

I-17

 
Figure I-3

Casing and tubing: Horizontal drilling and hydraulic fracturing

Source: American Petroleum Institute (API), “The Facts About Hydraulic Fracturing and Seismic Activity,” 2013.

Casing also serves as a surface pipe designed to prevent contamination of the 

recoverable oil and gas by surface water, gas, sand, or limestone. Casing must be sufficiently 

strong to carry its own weight, as well as to resist both external pressure and pressure within 

I-18
the well. Casing can be threaded at both ends and connected with other casing pieces with 

couplings or connectors. Because the amount of open hole that can be drilled at any one time is 

limited, larger wells require a string of concentric layers of casing rather than a single casing. 

Several sizes of casing may be set inside the well after it has been drilled, with the larger sizes 

set at the top of the well, and the smaller sizes set toward the bottom.

Tubing is a smaller-diameter pipe (between 1.050–4.5 inches OD) installed inside the 

larger-diameter casing that is used to conduct the oil or gas to the surface, either through 

natural flow or through pumping. Substances such as lubricants are also pumped into the well 

through the tubing for well treatment. Tubing must be strong enough to support its own 

weight, that of the oil or gas, and that of any pumping equipment suspended on the string. 

Tubing, like casing, usually is produced in accordance with API specification 5CT.

The API specification 5CT designates 11 separate grades of casing and tubing, identified 

by a letter and a number: H40, J55, K55, M65, N80, L80, C90, C95, T95, P110, and Q125. The API 

grade letter is an arbitrary designation, while the number refers to minimum yield strength in 

thousands of pounds per square inch, or “ksi”. 24 In addition, an API grade may be further 

delineated by chemical composition, method of production (i.e., seamless or welded), 

dimension, heat treatment, testing procedures, and other engineering specifications, 

depending on customers’ requirements.25 According to industry representatives, API grades 

H40, J55, and K55 generally refer to carbon grades that have lower minimum yield strengths 

and that do not require heat treatment. API grades N80, L80, P110, and Q125 generally refer to 

alloy grades (due to the inclusion of additional alloying elements in the steel) that have 

minimum yield strengths greater than 80,000 ksi and require heat treatment.26 Heat treatment 

enhances particular physical characteristics, including greater yield and tensile strengths.

The large majority of OCTG produced and sold in the United States is at its specified API 

grade; as presented in greater detail in Part IV, more than 95 percent of U.S. producers’ 2013 

U.S. shipments were “at grade,” as were approximately 85 percent of 2013 imports from 

nonsubject sources and 75 percent from subject sources. Much of the remainder falls into two 

categories – tubular products that require further processing to comply fully with the API 5CT 

specifications for casing and tubing, and tubular products that can be upgraded from one API 

grade to a more demanding API grade through heat treatment.

Tubular products in the first category are often referred to as “green tube” (or less 

frequently “green pipe”) and typically meet certain basic API requirements, such as those for 

diameter and wall thickness.27 The underlying steel is produced to a customer’s specification so 

24 Thus, Q125 has a higher yield strength than grade J55 or K55 (J55 and K55 differ with respect to 

minimum tensile strengths). 

25 For example, Grade L80, type 9Cr must contain 8-10 percent chromium by weight, produced by the 

seamless manufacturing process, and be tempered and quenched. 

26 Staff telephone interview with ***, July 31, 2013. 27 “Designing an OCTG finishing floor for welded pipe” in The Tube & Pipe Journal, April/May 2009.

I-19

 
that the green tube can be converted into the required casing or tubing product, but the green 

tube itself is not sold “at grade.”28 

Tubular products in the second category already meet and are certified to API 5CT 

specifications for casing and tubing, but are produced with a steel chemistry that allows them 

to be upgraded. Such upgradeable OCTG is sometimes referred to as green tube, but industry 

practice is less consistent,29 since the upgradeable product is certified to chemical and 

mechanical properties, has an API monogram, and (as discussed below) does not require heat 

treatment.30 

Upgradeable OCTG that meets the minimum specifications for lower-grade API 5CT 

casing and tubing (i.e., H40 and J55) can be certified to those grades and used in applications 

not requiring additional heat treatment.31 Alternatively, depending on its steel composition and 

wall thickness, upgradeable OCTG that meets non-heat treatable API grades of casing and 

tubing can be subsequently heat treated to increase yield and tensile strengths in order to meet 

the minimum specifications for higher-grade API 5CT casing and tubing (e.g., P110).32 33 

Overall, a comparison of the volume of tubular products heat-treated by U.S. processors to the 

overall volume of mill shipments and U.S. imports of all OCTG that was not at final grade 

suggests that a substantial volume of upgradeable OCTG is, in fact, ultimately heat treated.34

Finally, finished casing and tubing typically refers to product that has been heat treated 

(if required), tested, threaded, and coupled.

Coupling stock is a thick-walled, seamless tubular product used to manufacture coupling 

blanks. Coupling blanks, in turn, are unthreaded tube blanks used to make individual couplings. 

Couplings are thick-walled and internally threaded seamless cylinders that are used for joining 

two lengths of threaded OCTG. Couplings are produced and certified to the same API grade and 

type as the OCTG to which the couplings are joined. Coupling typically accounts for 2-3 percent 

of the weight of end-finished tubing or casing.

28 Conference transcript, pp. 154-155 (Thompson).

29 See, e.g., conference transcript, p. 88 (Mahoney); Northwest Pipe press release of February 8, 

2011, “Northwest Pipe Company's Tubular Products Group to Upgrade Mill in Houston, Texas” (stating 

“The Houston mill, which has traditionally produced only mechanical tubing products, began to produce 

green tube for OCTG in 2010. The mill upgrade will build on the OCTG green tube and other products 

already being produced on-site by adding production of 2 3/8 and 2 7/8 inch tubing with physical 

properties suitable for heat treating.”)

30 Hearing transcript, pp. 285-286 (Cameron). Prehearing brief of petitioner Maverick, pp. 3-4.

31 Green tube certified to these grades undergo further finishing operations, including threading. 

Finishing operations are described in the Manufacturing Processes section of Part I.

32 Conference transcript, pp. 222–223 (Fowler); U.S. Steel postconference brief, exh. 1, pp. 18–19.

33 API 5CT grades H40, J55, and K55 do not require heat treatment (although grades J55 and K55 can 

be heat treated at the manufacture’s option). API grades N80 (types I and II), M65, L80, C90, C95, T95, 

P110, and Q125 require some form of heat treatment. API Specification 5CT, Specification for Casing and 

Tubing, Eighth Edition, July 1, 2005, table E.4, p. 188. All grades are threaded in one form or another to 

finish the pipe.

34 Compare tables III-4, IV-9, IV-10, and IV-11.

I-20

 
Manufacturing processes

The manufacturing process for casing and tubing includes forming and finishing phases. 

The forming phase takes place entirely at the manufacturing facility or mill. Finishing, by 

contrast, may take place at the mill or at a processing or threading facility.

Forming phase

OCTG mills manufacture casing and tubing either by the seamless process or by the 

electric-resistance-welding (“ERW”) process, a lower-cost method than the seamless process, 

depending on the service requirements. By contrast, mills manufacture coupling stock for OCTG 

couplings exclusively through the seamless process.

Seamless OCTG is manufactured by either of two high-temperature methods to form a 

central cavity in a solid steel billet; namely, the rotary piercing method and the hot extrusion 

method. Round or square billets serve as the input for seamless tubing (figure I-4). If a square 

billet is used, it is first forced through a circular roll pass, which transformed the billet from 

square to round for the piercing operation. In the rotary piercing method, the heating billet is 

gripped by angled rolls, which cause the billet to rotate and advance over a piercer point, 

forming a hole through the length of the billet. In the extrusion method, the billet is hot punchpierced and then extruded axially through a die and over a mandrel, forming a hollow shell. The 

hollow shell produced by either method is then rolled with a fixed plug or with a continuous 

mandrel inside the shell to reduce the wall thickness and increase the shell’s length. Finally, the 

shell is rolled in a sizing mill or a stretch-reducing mill where it is formed to size.

Welded OCTG is manufactured from steel sheet in coil form (figure I-5). The steel sheet 

is slit to the width that corresponds to the desired diameter of tube. The slit sheet passes 

through a series of rollers while at ambient temperature and forms a tubular shape. The edges 

are then heated by electric resistance and welded together by heat and pressure, without the 

addition of filler metal. The welding pressure causes some of the metal to be squeezed from 

the welding joint, forming a bead of metal on the inside and outside of the tube. This bead, or 

welding flash, is usually trimmed from both the outside and the inside surfaces.

I-21
Figure I-4

Casing and tubing: Seamless manufacturing process

Source: JFE Steel Corporation, OCTG (Product Catalog).

I-22
Figure I-5

Casing and tubing: General schematic of the ERW manufacturing process

Source: JFE Steel Corporation, OCTG (Product Catalog).

I-23
Finishing phase

After the forming phase, the pipe body is heat-treated, and its ends upset, threaded and 

coupled, as needed. U.S. pipe mills typically are equipped with the facilities necessary to 

perform these processes. Independent processors operate facilities that are capable of fullbody heat treatment, and may upset pipe ends.35 Threaders are capable of threading and 

coupling, hydrostatic testing, and measuring the length of OCTG products. Some processors and 

threaders may also manufacture couplings that become part of finished OCTG. Processors and 

threaders mainly serve imports,

36 since OCTG are often imported with plain ends, and are heat 

treated, upset, and threaded in the United States. This approach provides the flexibility to offer 

casing and tubing in compliance with a variety of specifications, thus allowing them to serve a 

wide range of consumer needs.37

Heat treatment

In the steel manufacturing process, specific engineering characteristics and mechanical 

properties of the steel can be achieved through the application of different heat treatments. 

Heat treating may involve one or more heating cycles in either a continuous or batch furnace, 

with controlled rates of cooling. Specific heat treating requirements depend on the grade of 

steel being processed. For welded pipe, the heat treatment may cover the welded seam only, 

or the full cross-section of the pipe. API standards specify a documented procedure for every 

particular grade and type of pipe. API-specific heat treatment processes in the production of 

casing and tubing including annealing, normalizing, and quench and tempering.

Annealing is a single heat treatment process that prepares the steel for fabrication or 

service. The steel is heated to a temperature in or near a specific range, and cooled at a 

predetermined rate or cycle. Annealing relieves internal residual stresses or hardness induced 

by welding, by cold working, or by machining.

In the normalizing process, the pipe is heated above a specific temperature, held at this 

temperature for a specified time, and then air-cooled. Normalizing refines the steel grain size 

35 API defines a processor as: “firm, company, or corporation that operates facilities capable of heat 

treating pipe made by a pipe mill.” Most processors typically perform threading operations, although 

many threaders do not perform processing operations. Discussion of independent threaders is limited in 

this report, as the Commission in recent OCTG investigations has not deemed independent threaders to 

be part of the domestic industry producing casing and tubing. Oil Country Tubular Goods from 

Argentina, Italy, Japan, Korea, and Mexico, Investigation Nos. 731-TA-711 and 713-716 (Second Review), 

USITC Publication 3923, June 2007, p. 9. Certain Oil Country Tubular Goods from China, Investigation No. 

701-TA-463 (Final), USITC Publication 4124, January 2010, p. I-18.

36 Toll processors’ shipments for the account of importers accounted for *** percent of their total 

tolling revenue from 2011 to January-March 2014 (see table III-7). Processors’ purchased OCTG inputs 

were predominantly sourced from imports. ***. 37 Certain Oil Country Tubular Goods from China, Investigation No. 701-TA-463 (Final), USITC 

Publication 4124, January 2010, p. I-18.

I-24

 
and obtains a carbide size and distribution that is more suitable for future heat treatment than 

the as-rolled structure.

Quenching and tempering is a sequential process in which the pipe is heated to a 

specific temperature for a specified time period to modify the steel’s microstructure, and then 

“quenched” in a cooling medium such as water, oil, or air, depending on the thickness of the 

pipe. After quenching, the steel is very brittle and must be reheated and then cooled under 

specific conditions. This process is called “tempering.” The pipe must undergo a specified 

process of quenching and tempering in order to qualify for certain API grades.

Depending on the pipe design, API standards may specify a single heat treatment 

process or combination of processes for the pipe, such as normalizing and tempering, or 

quenching and tempering. After heat treatment, sizing rolls shape the tube to accurate 

diameter tolerances. The product is cooled and then cut to length at the end of the tube mill.

Coupling stock is made to the same grade and type specifications as casing and tubing. It 

must also be subject to the same heat treatment as pipe, except where specified by the 

purchaser.

Upsetting and threading

Casing and tubing are finished by threading and the attachment of a suitable coupling to 

one end of each length. If additional strength in the joint is required, such as for some casing or 

tubing that is subject to severe or sour service,38 the ends of the pipe are upset before threads 

are cut. In the upsetting process, the end of the pipe is heated to forging temperature, and then 

inserted endwise into an upsetting machine. The machine pushes the hot metal back, creating a 

thicker wall at the end of the pipe. The upsetting may be controlled to displace the extra 

thickness to the inside or the outside of the pipe.

Casing and tubing can be joined directly using male (outer) and female (inner) threading, 

or by using couplings with female threads on each end. Typically, the pipe is mounted on a 

lathe and threads are cut by using sharp steel cutting tools (called chasers), which are mounted 

on a threading die surrounding the pipe. As the pipe is turned on the lathe, the threading die 

moved along the pipe’s axis, producing the required spiral cut on the inner or outer surface of 

the pipe. Threading can be made to meet API standards, or made to proprietary standards that 

are designed, registered, and protected by patents or other intellectual property rights 

mechanism and that are not specified by API standards. For instance, OCTG producers may 

market proprietary “semi-premium” or “premium” threaded connections that provide higher 

torsional loads, bending resistance, or greater sealability for casing in challenging drilling

38 Sour crude oil or sour gas is defined as an oil/gas containing common impurities such as water, 

carbon dioxide, hydrogen sulfide, and oxygen, which are mixed in with the oil/gas during extraction. 

These impurities corrode or cause cracking in steel; albeit, without any observable change in appearance 

prior to failure.

I-25

 
environments.39 Premium threaded connections generally refer to OCTG connections that have 

a metal-to-metal, gas-type seal to ensure pressure integrity. Semi-premium connections 

generally refer to connections that do not have a metal-to-metal seal, yet maintain water-type 

sealability, and thus may be used in less demanding wells with no gas-type sealability 

requirements. Examples of threaded and coupled semi-premium and premium connections are 

shown in figures I-6 and I-7. After threading, a thread protector is applied to the threaded pipe 

ends during handling, transportation, or storage.40

39 For instance, U.S. Steel and EnergeX Tube produce and market various semi-premium connections. 

See, for example, U.S. Steel Tubular Products website, “Semi-Premium OCTG Connections,” found at 

http://usstubular.com/octg-products-and-services/octg-connections/semi-premium-connections 

(retrieved June 26, 2014); and EnergeX Tube website, “Semi-Premium Connections,” found at 

http://www.energextube.com/semi-premium-connections (retrieved June 26, 2014). U.S. Steel, 

Vallourec, and Tenaris produce and market various premium connections. See, for example, U.S. Steel 

Tubular Products website, “Premium OCTG Connections,” found at http://usstubular.com/octgproducts-and-services/octg-connections/premium-connections-metal-to-metal-seal (retrieved June 26, 

2014); Vallourec website, “VAM Product Lines,” found at http://www.vam-usa.com/vam-productlines.aspx (retrieved June 26, 2014); and Tenaris website, “Premium Connections,” found at 

http://www.tenaris.com/en/Products/PremiumConnections.aspx (retrieved June 26, 2014).

40 Threading can be performed after transportation to avoid damage caused by movement, water, or 

weather. Damaged threads can cause expensive ruptures of the pipe string in casing and tubing 

applications where pipes are connected to one another by threaded joints.

I-26

 
Figure I-6

Casing and tubing: Threaded and coupled semi-premium connection

Source: U.S. Steel Tubular Products, found at http://usstubular.com/octg-products-and-services/octgconnections, retrieved June 18, 2014.

I-27
Figure I-7

Casing and tubing: Threaded and coupled premium connection

Source: U.S. Steel Tubular Products, found at http://usstubular.com/octg-products-and-services/octgconnections, retrieved June 18, 2014.

DOMESTIC LIKE PRODUCT ISSUES

The scope in these investigations explicitly includes seamless and welded OCTG 

regardless of end finish, as well as unfinished OCTG, including green tubes. Petitioners contend 

that the Commission should find one domestic like product coextensive with Commerce’s 

scope.41 Petitioners argue that the Commission should continue its practice of including green 

tubes and semifinished products in the like product.42 Moreover, Petitioners contend that 

seamless and welded OCTG should not be regarded as separate like products because the 

41 Petition, p. 20. 42 Prehearing brief of Petitioner U.S. Steel, p. 6.

I-28

 
Commission has concluded that seamless and welded OCTG are part of the same like product in 

past investigations.43

Respondent ILJIN Steel Corporation (Korea) (“ILJIN”) argues that green tubes44 subject 

to heat treatment in the United States prior to sale to the merchant market constitute a 

separate like product.45 ILJIN argues that the product categories “not at API/proprietary grade” 

and “at API/proprietary grade but upgradeable” both fall within the definition of green tube.46

Without heat treatment the first product category does not have an API monogram and can not 

be used as OCTG. These tubes must be finished to be used as OCTG. Accordingly, they satisfy 

the semi-finished product analysis standards for treatment as a separate like product.47 ILJIN 

argues that there is no practical difference between “not at API/proprietary grade” and 

seamless tube that enters “at API/proprietary grade but upgradeable” since the seamless 

product is always heat treated before being sold in the U.S, merchant market.48 The 

Commission preliminarily found that “there does not appear to be a clear dividing line between 

green tubes and finished OCTG, and we do not find that they are separate like products” but 

noted that it intended to reconsider this issue in any final phase of these investigations, and 

examine the extent to which green tubes and finished OCTG are sold in separate markets.

49

Shipments of finished OCTG and unfinished OCTG (including green tubes) are provided in Part 

IV of this report.

43 Prehearing brief of Petitioner U.S. Steel, p. 6. and Exh. 1, p. 4. 44 Unlike petitioner Maverick and the other Korean respondents, ILJIN uses the term green tube to 

include not just non-API tube but also upgradeable product. Posthearing brief of Korean respondent 

ILJIN, Appendix 1, p. 42. ***. Importers’ questionnaire response of ILJIN at II-34. 45 Prehearing brief of Korean respondent ILJIN, p. 9. During the preliminary phase, ILJIN also argued 

that the Commission should reconsider the issue of whether finished seamless and welded OCTG belong 

in the same like product. Postconference brief of Korean respondent ILJIN, pp. 16 and 19. The 

Commission did not find that seamless and welded OCTG are separate like products. The Commission 

noted their identical channels of distribution, common basic physical characteristics and uses, and the 

large degree of interchangeability between the products. Certain Oil Country Tubular Goods from India, 

Korea, the Philippines, Saudi Arabia, Taiwan, Thailand, Turkey, Ukraine, and Vietnam, Inv. Nos. 701-TA499-500 and 731-TA-1215-1223 (Preliminary), USITC Publication 4422, p. 12, August 2013. 46 No party requested the collection of like product information in their comments on the 

Commission’s draft questionnaires. 47 Posthearing brief of Korean respondent ILJIN, Appendix 1, p. 42.

48 Posthearing brief of Korean respondent ILJIN, Appendix 1, p. 43.

49 Certain Oil Country Tubular Goods from India, Korea, the Philippines, Saudi Arabia, Taiwan, 

Thailand, Turkey, Ukraine, and Vietnam, Inv. Nos. 701-TA-499-500 and 731-TA-1215-1223 (Preliminary), 

USITC Publication 4422, p. 12 n. 65, August 2013.

I-29

 
INTERMEDIATE PRODUCTS

As discussed above, unfinished (or “green” if not heat-treated) OCTG is a precursor to 

finished OCTG. Therefore, in addressing whether unfinished OCTG and finished OCTG constitute 

a single domestic like product, the Commission may apply its semifinished product analysis.

Uses

“Green tube” is a term that can apply to unfinished, non-heat-treated tube bodies 

intended for casing and tubing. The same term is also applied to non-API tube bodies used in 

the production of drill pipe. The scope of these investigations, however, does not include drill 

pipe or tube bodies used to make drill pipe. According to Respondent ILJIN, green tubes refer to 

semifinished seamless and welded OCTG that is processed by heat treating, as well as by other 

processes (such as threading and coupling, upsetting, and quality testing) before being sold in 

the U.S. merchant OCTG market.50 It is the heat treatment and other processing that transform 

green tubes into commercially viable product.51

As previously noted in this section, green tube intended for an OCTG application is 

typically produced to meet the specifications for that particular application, and not for other 

applications, such as drill pipe. According to ***, green tube is produced to customer 

specifications in terms of chemistry, outside diameter, length, and tolerances.52 Because U.S. 

mills already produce and sell the vast majority of their OCTG “at grade,” only *** of 

domestically produced OCTG was sold as green tube (broadly defined) in 2013. As discussed 

above, a substantial portion of such shipments are subsequently heat treated by U.S. 

processors to final API grade.

Markets

Respondent ILJIN argues that there are different markets for green tubes requiring heat 

treatment and finished OCTG. ILJIN argues that the need for heat treatment determines the 

market in which green tubes are sold and the type of customers that purchase green tubes. 

ILJIN contends that customers for imported green tubes would be processors with available 

facilities to heat-treat and otherwise finish the imported product. Moreover, ILJIN argues that

distributors that purchase finished OCTG lack heat-treating capabilities. As such, imported 

green tube and finished OCTG are sold into different markets.

53

In 2013, two U.S. producers *** shipped *** short tons of unfinished OCTG, not at 

API/proprietary grade.

54 Both producers sold this product exclusively to distributors.55 Two U.S. 

50 Prehearing brief of ILJIN, p. 9. 51 Prehearing brief of ILJIN, p. 11.

52 Staff telephone interview with ***, July 31, 2013.

53 Prehearing brief of ILJIN, pp. 11-12. 54 ***. 

I-30

 
producers *** shipped *** short tons of unfinished OCTG that was at API/proprietary grade but 

upgradeable.56 These two producers reported only sales to distributors, but identified a 

processor (***) as a customer.

57 58 Green tube sold to processors was entirely sold to 

distributors after heat treatment. Specifically, the only independent processor known to 

purchase U.S.-produced green tube is ***.

59 This processor ***.60 

Characteristics and functions

As discussed above, green tube intended for OCTG applications is produced to the 

chemistry and dimensional specifications that permit processors to undertake finishing 

operations such as heat treatment, upsetting, threading, and coupling. Prior to heat treatment, 

however, green tube cannot be connected to other finished OCTG to form a casing or tubing 

string, and thus cannot function as a component of well casing or tubing. However, in some 

cases upgradeable OCTG that meets the minimum specifications for lower-grade API 5CT casing 

and tubing (i.e., H40 and J55) can be certified to those grades and used in applications not 

requiring additional heat treatment (following threading and coupling).61 

Value

Unfinished OCTG in its green stage is produced by both seamless and welded pipe 

mills. As shown in table IV-9, in 2013, U.S. mills’ sales of unfinished OCTG, not at API/

proprietary grade, had an average unit value of *** and U.S. mills’ sales of unfinished OCTG at 

API/proprietary grade but upgradeable had an average unit value of ***. In comparison, U.S. 

producers’ (including mills and processors) shipments of finished OCTG had an average unit 

value of $1,568 in 2013. Similarly, the average unit value of *** purchase price of green tube 

in 2013 was *** and the average unit value of its U.S. commercial shipments was ***. 

Respondent ILJIN points to the value added by tollers and stand-alone processors in heat 

treating or finishing green tubes. ILJIN argues that it is because of the substantial processing 

55 E-mail from ***, July 29, 2014 and Postconference brief of ***. 56 ***. 57 Questionnaire response of *** and questionnaire response of ***. 58 ***. During the preliminary phase of these investigations, U.S. Steel reported selling green tube to 

processors and to distributors ***. Importers also sell green tube to distributors. See questionnaire 

response of ***, which sells green tube from *** to distributors. ***’s customer is ***. Staff telephone 

interview with ***, August 8, 2013.

59 The other independent processor, ***. 60 Questionnaire response of ***. 61 In 2013, U.S. producers’ shipped *** short tons of OCTG at API/proprietary grade, but 

upgradeable, accounting for *** percent of U.S. producers’ total U.S. shipments. 

I-31

(...continued) 
costs to bring green tube to commercial levels that the cost of producing and sale value of 

finished OCTG is higher than for green tubes.62

Transformation process

Respondent ILJIN has argued that because of the necessity of heat treatment, seamless 

green tubes that have not undergone heat treatment as imported are not interchangeable with 

other finished OCTG products.63 ILJIN has argued that seamless green tubes that have not 

undergone heat treatment as imported differ in their physical and structure properties from 

finished seamless OCTG, thereby preventing them from being interchangeable for any use.64

As discussed previously, green tube intended for OCTG applications is produced by 

either the seamless or welded process. Green tubes typically undergo a heat treatment process 

to impart the necessary physical characteristics of finished OCTG. Depending on its steel 

composition and wall thickness, tube that meets certain non-heat treatable grades of the API 

specification for casing and tubing such as J55 can be subsequently heat-treated to improve its 

yield and tensile strengths in order to meet the minimum specifications for higher-grade API 

5CT casing and tubing such as P110. However, these upgradeable tubes can also be sold as J55 

tubing or casing. Petitioners note that upgradeable tube provides inventory flexibility with the 

capability to be upgraded to different grades65 and that upgradeable tube is a means for 

managing distributor inventories.66

62 Prehearing brief of ILJIN, p. 11.

63 ILJIN’s postconference brief, July 26, 2013, p. 17.

64 ILJIN’s postconference brief, July 26, 2013, p. 17.

65 Hearing transcript, p. 151 (Price), Hecht pp. (153-154).

66 Prehearing brief of Maverick, p. 6.

I-32

 
PART II: SUPPLY AND DEMAND INFORMATION

U.S. MARKET CHARACTERISTICS

Welded and seamless OCTG includes casing and tubing for use in oil and natural gas 

exploration and production. As a result, the demand for OCTG is closely associated with the 

amount of activity in these sectors. 

Both vertical drilling and horizontal drilling employ casing for structural integrity and 

tubing for liquid and gas flow (including traditional extraction and hydraulic fracturing or 

“fracking,” which requires a high-pressure injection of fracturing fluid into the well). Since 

January 2011, the use of hydraulic fracturing has increased, as has the number of rigs and total 

footage of wells drilled. The amount of OCTG used in hydraulic fracturing can be greater than 

that used in traditional vertical wells.1

Channels of distribution

Domestically produced and imported OCTG are sold mainly through distributors (table 

II-1). During January 2011-March 2014, U.S. producers shipped 100 of their OCTG to 

distributors. U.S. importers shipped more than 90 percent of OCTG imported from subject and 

nonsubject sources to distributors between January 2011 and March 2014, with limited 

exceptions: ***.

1 Preliminary conference transcript, p. 185 (Brewer).

II-1

 
Table II-1

OCTG: U.S. producers’ and U.S. importers’ U.S. shipments by sources and channels of 

distribution, 2011-13 and January-March 2014

Item

Period

2011 2012 2013

Jan.-March

2014

Share of U.S. shipments (percent)

U.S. producers’ U.S. shipments of OCTG to:

Distributors 100.0 100.0 100.0 100.0

End users 0.0 0.0 0.0 0.0

U.S. importers’ U.S. shipments of OCTG from India to:

Distributors *** *** *** ***

End users *** *** *** ***

U.S. importers’ U.S. shipments of OCTG from Korea to:

Distributors 98.4 98.6 98.1 92.0

End users 1.6 1.4 1.9 8.0

U.S. importers’ U.S. shipments of OCTG from the Philippines to:

Distributors *** *** *** ***

End users *** *** *** ***

U.S. importers’ U.S. shipments of OCTG from Saudi Arabia to:

Distributors *** *** *** ***

End users *** *** *** ***

U.S. importers’ U.S. shipments of OCTG from Taiwan (other than Chung Hung) to:

Distributors *** *** *** ***

End users *** *** *** ***

U.S. importers’ U.S. shipments of OCTG from Thailand to:

Distributors *** *** *** ***

End users *** *** *** ***

U.S. importers’ U.S. shipments of OCTG from Turkey to:

Distributors *** *** *** ***

End users *** *** *** ***

U.S. importers’ U.S. shipments of OCTG from Ukraine to:

Distributors *** *** *** ***

End users *** *** *** ***

U.S. importers’ U.S. shipments of OCTG from Vietnam to:

Distributors *** *** *** ***

End users *** *** *** ***

U.S. importers’ U.S. shipments of OCTG from nonsubject sources (including Taiwan-Chung Hung) to:

Distributors *** *** *** ***

End users *** *** *** ***

Note.--Numbers may not add to 100.0 because of rounding.

Source: Compiled from data submitted in response to Commission questionnaires.

II-2
Geographic distribution

OCTG is sold throughout the United States to distributors and, ultimately, to oil and 

natural gas exploration and production firms, as indicated earlier. Consequently, sales are 

concentrated in major oil- and gas-producing regions, especially the Central Southwest. Table II2 presents geographic market areas served by producers and importers. Eight of 13 responding 

U.S. producers supply OCTG in the contiguous United States. In addition to locations in the 

contiguous United States, two producers (***) reported making sales in Alaska. Imports from 

each subject country were shipped to the Central Southwest by at least *** importers, ***. The 

Pacific Coast, Midwest, and Mountain regions received that next-greatest coverage by subject 

imports, with imports from *** serving those regions. Importers of OCTG from India, the 

Philippines, Taiwan, and Ukraine reported serving the continental United States. 

Table II-2

OCTG: Geographic market areas in the United States served by U.S. producers and importers, by 

number of responding firms

Region

Central 

Southwest Midwest Mountains Northeast

Pacific 

Coast Southeast Other1

U.S. producers 13 10 11 10 8 9 2

India 12 2 2 1 4 2 0

Korea 17 4 3 2 2 0 0

Philippines 10 2 2 1 2 2 0

Saudi Arabia *** *** *** *** *** *** ***

Taiwan 10 2 1 1 2 2 0

Thailand 3 0 0 0 0 0 0

Turkey 5 1 1 1 1 1 1

Ukraine 3 1 1 1 1 1 1

Vietnam 12 1 2 0 2 0 0 1 All other U.S. markets, including AK, HI, PR, VI, among others.

Source: Compiled from data submitted in response to Commission questionnaires.

In general, U.S. producers shipped their OCTG longer distances than did importers of 

OCTG from subject countries. Domestic producers reported selling 10.6 percent of their OCTG 

within 100 miles of their production facility, 44.0 percent between 100 and 1,000 miles, and 

45.4 percent over 1,000 miles. U.S. importers sold the majority of their OCTG within 100 miles 

of their port of entry/warehouse, with the exception of OCTG from ***. Shipments by country 

and by distance are presented in table II-3. 

II-3
Table II-3

OCTG: Shipments by country and by distance reported by U.S. producers and importers

Item 0 to 100 miles 101-1,000 miles Over 1,000 miles

U.S. producers 10.6 44.0 45.4

India *** *** ***

Korea 77.1 17.3 5.6

Philippines *** *** ***

Saudi Arabia *** *** ***

Taiwan *** *** ***

Thailand *** *** ***

Turkey *** *** ***

Ukraine *** *** ***

Vietnam *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires.

SUPPLY AND DEMAND CONSIDERATIONS

Supply

Domestic production

The majority of the data in this section focuses on OCTG mills; there were limited sales 

of OCTG by non-toll processors. Based on available information, U.S. producers have the ability 

to respond to changes in demand with moderate changes in the quantity of shipments of U.S.-

produced OCTG to the U.S. market. The main contributing factors to this degree of 

responsiveness of supply are substantial excess capacity, some ability to use inventories, and 

the ability to switch to and from producing other products on the same equipment and 

machinery.

Industry capacity

U.S. mills’ capacity increased from 4.9 million short tons in 2011 to 5.8 million in 2013, 

and was higher in interim 2014 (1.5 million short tons) than interim 2013 (1.4 million short 

tons). Even with an increase in mill capacity of 17.9 percent during 2011-13, the capacity 

utilization rate increased from 67.6 percent in 2011 to 70.8 percent in 2013, and was 72.0

percent in January-March 2014, compared with 72.4 percent in January-March 2013. 

Continuing and additional plant openings and expansions are planned in 2014-16,

2 although as 

discussed in Part III of this report, new capacity may be partially offset by idling or closures of 

welded pipe facilities. This relatively moderate level of utilization suggests that U.S. producers

may have substantial capacity to produce OCTG in response to increases in price.

2 Part III contains specific information regarding the size and timing of these plant openings and 

expansions.

II-4

 
Producer inventory levels

Inventories are typically moderate in this industry since OCTG is usually produced-toorder for specific end users, but shipped to and inventoried by distributors to meet delivery 

schedule needs. U.S. mills’ ratio of inventories to total shipments decreased from 10.8 percent 

at the end of 2011 to 9.1 percent by the end of 2013, and was 9.1 percent of annualized 

shipments in March 2014, compared with 10.4 percent in March 2013. These levels of 

inventories suggest that U.S. producers may have some ability to use inventories to respond to 

price changes. Larger inventories are more typically held by distributors of OCTG. More 

information regarding market inventory levels is presented later in Part II.

Alternative markets

U.S. mills’ exports, as a share of total shipments, increased from 5.2 percent in 2011 to 

6.5 percent in 2013, and were 8.1 percent in January-March 2014, compared with 4.9 percent 

in January-March 2013. Based upon somewhat low but increasing export volumes, U.S. 

producers likely have some ability to shift shipments between the U.S. market and other 

markets in response to price changes.

Production alternatives

In addition to welded and seamless oil/gas well casing and tubing, U.S. producers 

manufacture mechanical tubing, and standard/line/pressure pipe on the same equipment used 

to produce OCTG. In 2011, 75.2 percent of shared welded production was used to manufacture

OCTG and 24.8 percent was used to produce other (non-OCTG) welded products. The OCTG 

share increased to 77.7 percent in 2013, and was 84.8 percent in January-March 2014, 

compared with 77.8 percent one year earlier, indicating that an increasing proportion of shared 

welded production resources is being used to manufacture OCTG. 

With respect to shared seamless pipe and tube production, shares have varied since 

2011. In that year, 75.0 percent of production on shared seamless capacity was used for OCTG. 

This increased to 78.0 percent in 2012 and to 79.8 percent in 2013. The proportion was lower 

(76.9 percent) in interim 2014, however, than in interim 2013 (80.7 percent). 

The vast majority of all heat treatment capacity in the United States is reserved for 

OCTG. This is true for both U.S. mills and independent U.S. processors.

Supply constraints

U.S. producers were asked if they refused, declined, or were unable to supply OCTG 

since January 1, 2011.

3 Four of 14 responding producers reported that they were unable to 

supply product at some time since 2011. Producer *** stated that it was cautious in bringing in 

new customers ***. ***. ***. ***.

3 This includes placing customers on allocation or “controlled order entry,” declining to accept 

customers or renew existing customers, delivering less than the quantity promised, or failing to meet 

timely shipment commitments.

II-5

 
OCTG imports from the subject countries

Subject imports of OCTG have increased since 2011. In January 2010, countervailing 

duties on OCTG imported from China entered into effect, followed by antidumping duties in 

May 2010.4 After the imposition of AD and CVD duties on Chinese product, OCTG imports from 

subject sources increased from 1.3 million short tons in 2011 to 1.8 million short tons in 2012

and 2013. Subject imports were higher in interim 2014 than in interim 2013 (463,000 short tons 

compared with 421,000 short tons).5

Imports from subject sources increased from *** percent of the quantity of apparent 

U.S. consumption in 2011 to *** percent in 2012 before falling to *** percent in 2013; they

represented *** percent of apparent U.S. consumption in the first three months of 2014, 

compared with *** percent in the first three months of 2013. 

The largest subject import sources of OCTG imports throughout this period were Korea,

India, Turkey, and Vietnam, which represented *** percent of apparent U.S. consumption in 

2013, respectively. Thailand was the smallest subject source (0.5 percent) in 2013. Country-bycountry data were available for product imported into the U.S. markets for all subject countries

(table II-4). 

4 Federal Register, 75 FR 3203, January 20, 2010 and 75 FR 28551, May 21, 2010. 5 During the first quarter of 2014, imports from Korea, which accounted for approximately threequarters of subject imports in interim 2014, were subject to a de minimis preliminary determination by 

Commerce.

II-6

 
Table II-4

OCTG: Capacity, total shipments to the U.S. market, capacity utilization, inventories, sales to its 

home market and the U.S., and overall capability to shift sales to the United States

Year

Total 

capacity

U.S. 

imports1 Cap. 

util.

Inventories 

to 

shipments

Sales to 

markets

Factors influencing supply responsiveness 

Short tons to changes in the U.S. market

Home U.S.

Percent

India:2

2011 *** *** *** *** *** ***

India was the third-largest source of subject 

imports in 2012 and the second-largest source in 

2013. Indian capacity increased over the period 

but capacity utilization decreased considerably. 

India’s home market accounts for about half of 

its sales. Indian producers’ moderate-to-large 

shipments to the United States, increasing 

capacity, low capacity utilization, and inventory 

level enhance the ability to increase shipments 

to the U.S. market.

2012 *** *** *** *** *** ***

2013 *** *** *** *** *** ***

Jan.-Mar. 

2014 *** *** *** *** *** ***

Korea:

2011 1,087,382 *** 67.5 2.7 0.7 96.3

Korea has been the largest source of imports of 

OCTG since 2011. Its low inventories and limited 

alternative markets reduce its ability to increase 

its supply to the U.S. market in the event of a 

price change. However, it has the largest 

capacity to produce welded OCTG and Korean 

producers recently added seamless capacity, 

which may increase the ability to supply the U.S. 

market.

2012 1,160,302 *** 77.8 5.1 0.9 97.3

2013 1,231,223 *** 88.7 8.6 1.1 96.9

Jan.-Mar. 

2014 329,781 *** 110.4 6.2 0.3 99.3

Philippines:

2011 *** 23,933 *** *** *** *** The producer in the Philippines had the smallest 

capacity among subject producers and the 

highest capacity utilization in 2013. The *** of 

sales are exports to the United States. No 

inventories were reported. These factors indicate 

a relatively low ability to increase shipments to 

the United States.

2012 *** 69,757 *** *** *** ***

2013 *** 73,969 *** *** *** ***

Jan.-Mar. 

2014 *** 17,794 *** *** *** ***

Saudi Arabia:

2011 *** *** *** *** *** ***

Saudi Arabia has a relatively large home market,

and its shipments to its home market increased 

in 2013 and interim 2014. Producers in Saudi 

Arabia have been adding capacity and project 

this to continue, thus increasing the ability to 

ship to the United States; however, high capacity 

utilization moderates this ability. Ending 

inventories were more than *** as much in March 

2014 than in March 2013. 

2012 *** *** *** *** *** ***

2013 *** *** *** *** *** ***

Jan.-Mar. 

2014 *** *** *** *** *** ***

Taiwan (subject):

2

2011 *** *** *** *** *** ***

Capacity increased greatly in 2012, and 

production has also grown, but capacity 

utilization has declined considerably since 2011. 

Inventories held by Taiwan producers are 

relatively low, the home market is small, and 

most production is shipped to the U.S. market. 

These factors indicate that Taiwan producers 

may have some ability to increase shipments to 

the U.S. market.

2012 *** *** *** *** *** ***

2013 *** *** *** *** *** ***

Jan.-Mar. 

2014 *** *** *** *** *** ***

Table continued on the next page.

II-7
Table II-4--Continued

OCTG: Capacity, total shipments to the U.S. market, capacity utilization, inventories, sales to 

various markets and overall capability to shift sales to the United States

Year

Total 

capacity

U.S. 

imports1 Capacity 

utilization

Inventories 

to 

shipments

Sales to 

markets

Factors influencing supply responsiveness 

Short tons to changes in the U.S. market

Home U.S.

Percent

Thailand:

2011 *** 6,135 *** *** *** ***

Thai producers3 had the fewest sales of 

subject OCTG to the United States over 2011-

13. All of the Thai producer’s shipments were 

of seamless OCTG. A high proportion already 

sold to the U.S. market may decrease the 

ability to further increase supply to the U.S. 

market; low capacity utilization and relatively 

large ending inventories increase the Thai 

producer’s ability to shift shipments to the U.S. 

market, however. 

2012 *** 31,833 *** *** *** ***

2013 *** 33,741 *** *** *** ***

Jan.-Mar. 

2014 *** 11,911 *** *** *** ***

Turkey:

2011 *** 140,806 *** *** *** ***

Producers in Turkey shipped over *** percent 

of their OCTG to the U.S. market. Despite 

higher capacity, production was lower in 2013 

than 2011 and in interim 2014 compared with 

interim 2013. Ending inventories were 

maintained at a low level. Lower capacity 

utilization enhances Turkish producers’ ability 

to ship to the United States, while low 

inventories and limited alternative markets 

diminish it. 

2012 *** 151,576 *** *** *** ***

2013 *** 133,773 *** *** *** ***

Jan.-Mar. 

2014 *** 34,158 *** *** *** ***

Ukraine:

2011 *** *** *** *** *** *** Ukraine only produces seamless OCTG. Its 

capacity did not change, but its capacity 

utilization was lower in 2013 and interim 2014 

than in 2011 or 2012. This, combined with the 

existence of large third-country markets and 

high inventories, indicates that producers in 

Ukraine have some ability to increase 

shipments to the U.S. market.

2012 *** *** *** *** *** ***

2013 *** *** *** *** *** ***

Jan.-Mar. 

2014 *** *** *** *** *** ***

Vietnam:

2011 *** 56,697 *** *** *** ***

Producers in Vietnam had the largest

percentage increase in shipments to the 

United States between 2011 and 2013. 

Vietnam does not have any developed hydrocarbon mining, so all production is exported, 

with *** percent shipped to the United States 

since 2011. Ending inventories were ***

percent of annualized total shipments in 

March 2014.

2012 *** 219,997 *** *** *** ***

20134 *** 144,871 *** *** *** ***

Jan.-Mar. 

2014 *** 2,757 *** *** *** *** 1 U.S. imports are from official Commerce statistics, as adjusted. All other data are from the foreign producers’ questionnaires and 

reflect the coverage provided in the foreign producer questionnaires.

2 These data exclude data for Indian processors and for nonsubject Taiwan producer Chung Hung. 4 These data cover one Thai producer. A second Thai producer responded in the preliminary phase, but not in the final phase of these 

investigations. This producer, WSP, began production in 2011, reported *** short tons of capacity, *** short tons of production, and 

exported *** short tons to the United States in 2012. WSP did not project any increases in capacity for 2013. 5 This capacity figure does not include data for three producers in Vietnam which did not respond to the Commission’s questionnaire 

but were in operation and exporting during 2012. One of the producers, ***. Respondent SeAH Vina’s postconference brief, pp. 8-9.

Note.–Foreign producer data for most subject countries cover the majority of imports into the United States in 2013: ***. For further 

information, see Part VII.

Source: Compiled from data submitted in response to Commission questionnaires.

II-8
Supply constraints

Thirty-three of 43 responding importers stated that they had not had any constraints on 

their supply. The other 10 importers attributed supply constraints to issues including: a fire in 

the production plant; delayed shipments and declining prices; an inability to source “P110 

regular and HC pipe;” lack of heat treating and finishing facilities in the United States

(specifically, Houston, Texas); the limited availability/inability to access of premium and semipremium threads; the inability to be a primary provider on program sales due to long lead 

times; a country of origin ruling by Commerce; logistical issues; an exclusive contract; being on 

allocation from the mill; and the need for the mill to order blooms specifically for OCTG orders.

Nonsubject imports

Imports from nonsubject sources accounted for between *** percent of apparent U.S. 

consumption since 2011. The leading nonsubject sources for U.S. imports of OCTG between 

January 1, 2011 and March 31, 2014 were Canada, Japan, Mexico, Argentina, and Germany. The 

industries in each of these countries include one or more producers that are related to at least

one domestic producer or distributor of OCTG. Overall, Canada and Argentina were the secondand third-largest sources of imports of OCTG into the United States in 2013, behind Korea. 

Canada and Japan were the second- and third-largest sources of imports of OCTG into the 

United States in January 2011-March 2014 behind Korea.

Inventories

Inventories are held domestically by producers, distributors, importers, and end users in 

the United States. Distributors will typically stock OCTG from producers and importers, and try 

to maintain inventory levels that are neither too small (risking missed delivery time frames or 

lost sales) or too large (risking price fluctuations that affect the valuation of any held stock). 

When inventories are perceived to be too large, less OCTG will be required from producers and 

importers.

The staff report in the Commission’s previous investigation of OCTG, published in 2010, 

noted that market participants prefer to see inventories at or below six months of anticipated 

use.

6 At the Commission’s hearing in the present investigations on July 15, 2014, petitioners 

testified that five months of inventory is presently too much, and three months of inventory is 

preferred, based on increased supply chain efficiencies and a decrease in the variety of OCTG 

used in extracting shale oil and gas.7 Respondents testified at the preliminary staff conference 

that the preferred level of inventories on hand is around five months, as the number of storage 

facilities have increased, especially outside of Texas.8

6 Oil Country Tubular Goods from China, Inv. No. 701-TA-463 (Final), USITC Publication 4124, January 

2010, p. II-4. 7 Hearing transcript, p. 112 (Tait) and 109 (DuBois).

8 Preliminary staff conference transcript, pp. 169 and 272 (Fowler).

II-9

 
Producers, importers, and purchasers were asked how many months of inventory they 

prefer to hold.9 Six of eight producers reported that they prefer to keep 3 months of inventory 

on hand. The other three producers prefer to hold less – between 1 and 2 months’ supply.

Fourteen of 19 responding importers indicated that they prefer to hold about the same –

between 2 and 3 months. The other four importers prefer to hold somewhat more – between 4 

and 8 months. Purchasers reportedly prefer to hold between 1 and 6 months of inventory, with 

an average of 3.3 months. Specifically, two purchasers prefer to hold one month of inventory, 9

prefer two months of inventory, 15 prefer three months, 9 prefer four months, and 6 prefer to 

hold six months of inventory. Fourteen purchasers have changed these prefered levels since 

2011, equally split between those holding more and those holding less. Reasons for holding 

more inventory included securing program sales, increased demand or drilling activity, 

increased supply causing longer holding periods, and the mitigation of seamless supply risk due 

to these investigations. Reasons for holding less inventory included the loss of a program sale, 

cost cutting (with one purchaser noting that it must cut costs due to “lack of trade protection 

destroying markets”), better forecasting, and more efficient mill rolling cycles.

Producers, importers, and purchasers were also asked whether the price of OCTG was 

affected by the levels of inventory on hand held by suppliers, distributors, and end users. All 12 

responding producers, 34 of 40 responding importers, and 46 of 51 purchasers replied 

affirmatively. Most firms described a general oversupply/undersupply relationship between 

inventory and prices. Producers *** stated that four months, and maybe even three months,

indicate a well-balanced market, down from five to six months a few years ago. Importer ***

and purchasers *** noted that inventory above 4 or 5 months, respectively, will cause prices to 

drop. Importer/purchaser *** and importers *** stated that inventories have been at normal 

levels since 2011 given the current market. Three other purchasers stated that price levels and 

inventories are related on a per-item basis, not on a general inventory level.

Figure II-1 presents the inventory, in millions of tons and the number of months of 

inventory on hand (based on operator consumption). The number of months of inventory on 

hand had reached a peak prior to 2011, reaching over 3.8 million tons (16 months) in early

2009,10 but then decreased through the end of 2011. Despite purchasers’ desire to hold an 

average of 3.3 months of inventory, inventories have not reached that level since 2011.

Inventory levels reached a trough of 4.2 months in January 2012, but then increased until 

October 2012. After dipping slightly at the end of 2012, inventories increased until the fourth 

quarter of 2013 (October for months of inventory, November for tonnage) and then dropped 

once again in the first quarter of 2014. As of March 2014, inventory levels were 2.6 million 

short tons, equivalent to 4.6 months’ supply on hand.11

9 It should be noted that these data refer to firms’ preference, not their standard business practice.

10 Certain Oil Country Tubular Goods from China, Investigation No. 701-TA-463 (Final), USITC

Publication 4124, January 2010, Figure II-1 and Table II-2. 11 There was also 4.6 months’ of inventory on hand in June 2014. Preston Pipe & Tube Report, 

Preston Publishing, July 2014.

II-10

 
Figure II-1

OCTG: U.S. inventory levels and months’ supply on hand, January 2011-March 2014

Source: Preston Publishing Co.

Demand

U.S. demand

Based on available information, it is likely that changes in the price level of OCTG will 

result in a small change in the quantity of OCTG demanded. The main contributing factors to

the small degree of responsiveness are the lack of substitute products for OCTG and that OCTG 

represents a small to moderate cost share for most of its end-use products.

Demand determinants

Demand for OCTG is driven by the level of activity in the U.S. economy, and is derived 

from the demand for hydrocarbon (oil and natural gas) exploration and drilling. The amount of 

drilling is influenced, at least partially, by the price of oil and natural gas. 

The level of economic activity, as measured by U.S. real GDP, shrank in the first quarter 

of 2011 (figure II-2). Between the second quarter of 2011 and the fourth quarter of 2013, real 

GDP increased by 0.1 to 4.9 percent, but shrank by 1.0 percent in the first quarter of 2014. The

level of economic activity drives the demand for hydrocarbons, which are produced by oil and 

gas rigs. In late 2011, the number of rigs reached similar levels to those reached during the 

2008 peak (just before the 2008-09) recession, but decreased through 2012 and has

leveled off at a similar count to that seen in the years before the pre-recession peak (figure II3). 

II-11
Figure II-2

Percent changes in real gross domestic product (GDP) growth, by quarters, January 2011-March 

2014

Source: Bureau of Economic Analysis, U.S. Department of Commerce.

Figure II-3

Baker-Hughes rig count, weekly, January 5, 2007-March 27, 2014

Source: Baker-Hughes North America Rotary Rig Count.

-2

-1

0

1

2

3

4

5

6

2011 2012 2013 2014

Percentage change

Real GDP

II-12
According to data from Preston Publishing, OCTG operator consumption, a measure of 

tonnage of OCTG used, increased between January 2010 and November 2011, continuing an 

increasing trend that began in late 2009 as the economy began to recover from the recession.

Operator consumption then declined through the first quarter of 2013, but has been generally 

increasing since that time (figure II-4).

12 OCTG consumption was 17.2 percent higher in the first 

quarter of 2014 compared with the first quarter of 2013, and was higher than at any point since 

before the recession.

13 Operator consumption reached period-highs in 2014, even as the 

number of rigs leveled off below their 2008 and 2011 peaks.

Figure II-4

OCTG: Operator consumption, monthly, January 2009-March 2014

Source: Preston Publishing Co., various issues, 2011-2013.

As operator consumption has increased, the total production of natural gas and oil has 

increased as well (figure II-5). Oil production has increased at a faster rate than natural gas 

production since 2011.

The number of rigs typically responds to the price of natural gas and oil. As the price of 

oil increased beginning in 2009 (figure II-6), the number and proportion of rigs devoted to oil 

production increased. Between 2002 and 2009, more than 80 percent of rigs in the United 

States were gas rigs. This change is seen starting in 2009, and the proportion is now more than

80 percent oil rigs and 20 percent natural gas rigs (figure II-7). 

The quantity of OCTG used in oil and natural gas exploration and extraction is 

determined by the number of rigs that are operating as well as the length and depth of the 

wells being drilled. Market participants at the preliminary staff conference noted that the 

increased use of horizontal drilling on shale plays has led to an increased need for OCTG, as 

some lengths of horizontal wells can reach 2 miles.14

12 Shading in the figures identifies periods outside the January 2011-March 2014 time frame.

13 Preston Pipe & Tube Report, April 2014. 14 Preliminary conference transcript, p. 263 (Fowler).

II-13

 
Figure II-5

Crude oil and dry natural gas production, monthly, January 2009-May 2014, estimated June 2014-

December 2015

Source: Energy Information Administration.

Figure II-6

OCTG: Crude oil (WTI) and natural gas (Henry Hub spot) prices, monthly, January 2009-May 2014, 

estimated June 2014-December 2015

Source: Energy Information Administration.

0

10

20

30

40

50

60

70

80

90

0

1

2

3

4

5

6

7

8

9

10

2009 2010 2011 2012 2013 2014 2015

e

Billion cubic feet per day

Million barrels per day

 Crude oil production Dry natural gas production

0

1

2

3

4

5

6

7

0

20

40

60

80

100

120

140

2009 2010 2011 2012 2013 2014 2015e

Dollars per MMBtu

Dollars per barrel

 Crude oil prices Natural gas Henry Hub spot price

Estimate

Estimate

II-14
Figure II-7

OCTG: Proportion of U.S. rigs devoted to natural gas and oil mining, weekly, January 2009-March 

2014

Source: Baker-Hughes North America Rotary Rig Count.

Figure II-8 displays the proportion of rigs by drilling type (i.e., horizontal, vertical, or 

directional). As shown in this figure, the proportion of rigs that employ horizontal drilling has 

increased substantially, from 20 percent of total rigs at the beginning of 2007, to more than 56

percent at the beginning of 2010. The proportion continued to climb, reaching 67 percent in 

March 2014 before declining slightly. Vertical drilling has continued its decline, dropping below 

22 percent of rigs in March 2014.

Figure II-8

OCTG: Proportion of U.S. rigs, by drilling type, weekly, January 2007-March 2014

Source: Baker-Hughes North America Rotary Rig Count.

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

1/2/2009 1/2/2010 1/2/2011 1/2/2012 1/2/2013 1/2/2014

Oil Gas

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

1/5/2007 1/5/2008 1/5/2009 1/5/2010 1/5/2011 1/5/2012 1/5/2013 1/5/2014

Directional Horizontal Vertical

II-15
Demand perceptions

When asked how demand for OCTG has changed within the United States since January 

2011, the majority of responding producers (10 of 14), importers (29 of 43), and purchasers (32 

of 49) reported that demand for OCTG has increased (table II-5). The next most-frequently 

given response by all three groups was that demand had fluctuated since 2011. Producer ***

described 2010 to 2013 as “probably the best four-year period for OCTG demand in this country 

since the 1980s.”15 Reasons provided by market participants mostly focused on the 

development of shale plays, increased drilling, and increased OCTG requirements per rig due to 

horizontal drilling. *** reported that it estimates that demand in the United States will increase 

slightly between 2013 and 2014.

Table II-5

OCTG: U.S. producer and importer responses regarding the demand for OCTG in and outside the 

United States since 2011 

Item

Number of firms reporting

Increase No Change Decrease Fluctuate

Demand in the United States:

 U.S. producers 10 0 1 3

 Importers 29 4 2 8

 Purchasers 32 5 5 7

Demand outside the United 

States:

 U.S. producers 8 1 0 3

 Importers 14 5 0 9

 Purchasers 9 5 4 9

Source: Compiled from data submitted in response to Commission questionnaires.

Product mix

Producers and importers were asked whether there had been any changes in the 

product mix of OCTG since 2011. Eleven of fourteen responding producers and 15 of 43

responding importers noted changes since 2011. The majority of responding firms indicated 

that the increase in demand for OCTG used in horizontal drilling has caused an increase in 

demand for higher-grade OCTG such as more heat-treated or alloy-grade OCTG. Importer ***

stated that it has noticed a change to more seamless OCTG, whereas importer *** and ***

reported an increasing acceptance of welded products for the same application as seamless 

products. Producer *** and importer *** reported that the increase in oil drilling instead of gas 

drilling contributed to an increased demand for standard API pipe with standard API 

connections, and these account for 80 percent of U.S. consumption. Producer *** noted that 

there has been increased demand for smaller-diameter OCTG. Hearing witnesses, producer ***

and importer *** both noted increased standardization in casing string designs. This has

15 *** producer questionnaire response.

II-16

 
decreased the varieties that are demanded, and can lead to distributors stocking fewer items

and decreased necessary lead time for distributors.

16

Seasonality and business cycles

Most U.S. producers (11 of 12), but less than half of importers (15 of 37) and purchasers 

(18 of 38), reported that there are business cycles or seasonality in OCTG demand. In general, 

demand was noted to be affected by the weather (different areas may have different seasonal 

demand changes based on temperature and precipitation), as well as budgetary concerns (at 

the end of the year, exploration budgets may be exhausted and firms may want to seek to 

reduce tax exposure on inventories located in Houston), and financial matters (oil and gas 

prices). In contrast, there may be some seasonality with respect to increased drilling in the 

winter in Canada when ice allows transit to more remote locations.17

A majority of responding producers (9 of 10) and purchasers (26 of 46), along with 13 of 

35 responding importers indicated that there are conditions of competition distinct to the 

OCTG market as well. The conditions included: the effect of oil and gas prices, the advent of 

horizontal fracturing, the switch to more drilling for oil instead of gas, fluctuations in U.S.

import volumes and the related price effects of such fluctuations, and the amount and types of 

OCTG used per rig.

Substitute products

Eleven of 12 responding U.S. producers, 37 of 39 responding importers, and 43 of 50 

responding purchasers reported that there are no substitutes for OCTG. Importer and producer

*** stated that A500 could be used as a limited service casing. Another possible substitute for 

OCTG is coiled tubing, which could be used in well interventions, completions, and workovers of 

both new and old wells, as noted by ***.

18 Importer *** stated that line pipe could also be 

used as a surface casing. Six purchasers noted that in certain situations, line pipe could be used 

in the place of OCTG, especially for use as a casing.

Cost share

OCTG accounts for a small share of the cost of the end-use products in which it is used. 

Industry firms gave highly varying answers, however, depending on what firms considered as 

the end-use product. Producers that noted oil and gas wells/extraction as the end use reported 

that OCTG accounts for 5 to 15 percent of the cost of oil and gas drilling/extraction. Importers 

*** also reported OCTG’s share in this range.

19 Producer *** stated that Pipe Logix, Inc. 

estimates that OCTG accounts for approximately 11 percent of total well costs.

16 Hearing transcript, pp. 84 (Lowe) and 123 (Herald and Thompson). 17 Preliminary conference transcript, p. 247 (Brewer) and *** producer questionnaire responses.

18 *** stated, however, that this was very limited and would not likely have any effect on the OCTG 

market.

19 Nineteen importers, three producers, and two purchasers stated that OCTG accounts for 100

percent of the cost of end-use application, but noted end use applications such as “tubing,” “drilling,” 

II-17

 
Demand outside the United States

Most U.S. producers (8 of 12) and importers (14 of 27) reported that demand outside 

the U.S. market has increased since January 2011. Purchasers were more divided. Nine of 27 

responding purchasers reported increased demand, 9 reported fluctuating demand, 5 reported 

no change, and 4 reported decreased demand outside the United States. While some firms 

reported the same reasons for increased demand overseas as they reported for the U.S.

market, *** noted that there is a flat rig count in Canada. *** stated that it expects increases in 

some markets but decreases in others, with a slight decline in OCTG demand in 2013 to 2014, 

although *** expects a slight increase in global demand over 2012 to 2014. Importer ***

reported that the international rig count increased 4 percent from January 2011 to March 2014, 

while *** stated the need for more OCTG per rig. Purchaser *** stated that, “Overall drilling 

outside the U.S. has not seen as great a focus as the U.S.A. has.”

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported OCTG depends upon such 

factors as relative prices, quality (e.g., physical characteristics, consistency, tubing and casing 

type and grade, etc.), and conditions of sale (e.g., price discounts/rebates, availability, payment 

terms, product services, reliability of supply, etc.). Based on available data, staff believes that 

there is a moderate to high degree of substitutability between U.S.-produced OCTG and that 

imported from subject countries.

Purchaser characteristics

The Commission sent questionnaires to 123 purchasers. Responses were received from 

58 of these firms, 52 of which provided useable data.20 Responding purchasers accounted for

6.7 million short tons of OCTG purchased in the United States in 2013.21 The majority of this 

(58.2 percent) was purchased from domestic producers, 26.4 percent from subject sources, and 

15.4 percent was purchased from nonsubject countries. 

The supply chain in the OCTG market can vary in length. The majority of purchasers 

responding the Commission questionnaire are distributors, and a majority (26 of 44) reported 

that they compete with their own suppliers. Purchasers’ customers are mostly oil and gas 

exploration firms. Although the large majority of producers’ and importers’ sales are made to 

distributors, the supply chain could go directly from producers or importers to end users, or 

through one or more distributors. Additionally, nearly half (19 of 43) of responding importers 

“oil and gas rigs,” “couplings,” or “casing and tubing.” Producer *** stated that OCTG accounts for 85 

percent of the cost of oil and gas drilling.

20 Thirty-eight of the responding purchasers identified themselves as distributors, 6 as end users, and 

10 as “other” purchasers. Among the “other” group, purchasers identified themselves as coupling 

manufacturers, mills, a processor/finishers, mill representatives, trader/resellers, and an oil and gas 

producer. Questionnaire respondents that identified themselves as distributors made up 83.7 percent of 

the volume of purchases, end users made up 10.7 percent, and “others” made up 5.6 percent. 21 Since purchasers questionnaires were sent to both distributors (including master distributors) and 

end users, some of this product could be double-counted. There is no apparent reason to believe that 

this would cause any shift in percentages attributable to different sources, however.

II-18

 
supply other distributors at least occasionally with OCTG, demonstrating the varied nature of 

the supply chain.

Thirteen purchasers buy OCTG on a daily basis, 17 on a weekly basis, 16 on a monthly 

basis, 1 quarterly, 1 annually, and 8 on some other basis (typically “as-needed”). Twenty-two of 

52 responding purchasers noted that their purchasing pattern had changed since 2011, and 

their patterns were varied. Some purchasers noted increased purchases and some noted 

decreased purchases, while others noted increased frequency to maintain low inventories or 

decreased frequency due to the optimization of supply chains and material performance. 

Purchasers reported contacting between 1 and 24 suppliers before purchasing OCTG, but 

typically between 2 and 6 suppliers are contacted. Since 2011, 28 of 52 responding purchasers 

became aware of new suppliers in the OCTG market, and 27 of 52 had changed suppliers in that

time. These included both foreign and domestic sources. Some purchasers reported that their 

main suppliers did not change, but additional sources for smaller spot purchases were added.

Knowledge of country sources

Purchasers were asked to indicate the countries of origin for which they have actual 

OCTG marketing/pricing knowledge. Table II-6 presents how familiar purchasers were with 

OCTG produced in the United States, subject countries, and nonsubject countries. Overall, 

purchasers were most familiar with product from the United States and, among countries 

subject to these investigations, Korea. In contrast, fewer than half of the responding purchasers 

had any familiarity with OCTG produced in Thailand or the Philippines.

Table II-6

OCTG: U.S. purchaser familiarity with product from the United States, subject countries, and 

nonsubject countries

Country

Familiarity

Significant Somewhat None

United States 34 13 4

India 7 31 13

Korea 28 16 7

Philippines 6 19 26

Saudi Arabia 7 22 21

Taiwan 6 21 24

Thailand 4 14 31

Turkey 9 24 19

Ukraine 7 24 20

Vietnam 4 23 22

Nonsubject countries1 35 22 --

1 Purchasers reported “significant” familiarity with nonsubject OCTG from Austria, Belarus, Canada, Germany, 

Greece, Japan, Russia, and Spain. Purchasers reported they were “somewhat” familiar with nonsubject OCTG 

from Argentina, Brazil, Canada, China, Czech Republic, Germany, Italy, Japan, Romania, Russia, South Africa, 

and Spain. 

Source: Compiled from data submitted in response to Commission questionnaires.

II-19
Purchasers were also asked how frequently they and their customers made purchasing 

decisions based on the country of origin or the manufacturer of OCTG (table II-7). The

manufacturer of the OCTG is reportedly more important to the purchaser than country of

origin, with a majority of purchasers indicating that their decisions are “always” or “usually” 

based on the manufacturer. Quality, price, consistency, availability, mill relationships, 

reputation, and location (e.g., being located in North America), delivery performance, 

contracts, and program sales were noted as reasons for making decisions based on the 

producer, though quality-related factors were most often noted by those purchasers. A 

majority of purchasers reported that their customers “usually” or “sometimes” make a 

purchasing decision based on the manufacturer or country of origin of the OCTG that they buy.

The same factors were noted to be important to the purchasers’ customers. Two purchasers 

stated that price is the deciding factor as long as the quality is acceptable, whereas one stated 

that if prices are equivalent, then mill reputation could be a deciding factor.

Table II-7

OCTG: Purchaser responses to questions regarding the origin of their purchases

Purchaser/customer decision Always Usually Sometimes Never

Purchaser makes purchase decision based 

on country of origin 13 16 15 8

Purchaser makes purchase decision based 

on the manufacturer 22 16 11 2

Purchaser’s customer makes purchase 

decision based on country of origin 6 15 22 4

Purchaser’s customer makes purchase 

decision based on the manufacturer 7 20 18 2

Source: Compiled from data submitted in response to Commission questionnaires.

Purchasers and their customers make the decision somewhat less frequently on country 

of origin than they did on the manufacturer of the pipe. Purchasers were fairly evenly split 

among whether they “always,” “frequently,” or “sometimes” purchase based on the country of 

origin, but their customers are most often only “sometimes” basing their purchase decision on 

the country of origin. Purchasers reported a preference for domestic OCTG based on criteria

such as shorter lead times, more consistent supply, ease of logistics, customer’s acceptance, 

and support for the domestic industry. Six purchasers’ explanations reflected the importance of 

the mill over the country of origin. Thirty-three purchasers provided reasons why their 

customers make decisions based on the country of origin. Of these, three purchasers noted that 

their customers prefer domestically produced OCTG, and six reported that some customers 

have preferences against certain countries, with two of these mentioning China and India 

specifically.

II-20
Factors affecting purchasing decisions

Major factors in purchasing

A number of factors influence purchasers’ decisions regarding the source of the OCTG 

they buy. OCTG must meet the required API specification for the project, and must be of an 

acceptable quality to the purchaser. Some projects require the OCTG be produced by a certain 

process (i.e., seamless). Lead times and availability were also noted as important factors 

determining purchasers’ sourcing decisions. 

Purchasers were asked to identify the three most important factors considered by their 

firm in deciding from which firm to buy OCTG (table II-8). Quality was the most frequently cited 

most important factor (cited by 31 purchasers) followed by price (19 purchasers); price was the 

most frequently reported second- and third-most important factor (16 and 18 purchasers, 

respectively). Price was reported to be one of the top three factors reported by all 53 of the 

responding purchasers, and quality was reported to be one of the top three factors reported by 

46 firms.22

Table II-8 

OCTG: Ranking of factors used in purchasing decisions as reported by U.S. purchasers, by 

number of reporting firms

Factor First Second Third Total

Quality 31 8 7 46

Price 19 16 18 53

Availability/production schedule 3 10 9 22

Delivery/dependability/reliability/lead time 1 7 7 15

Product line/range 0 0 4 4

Other1 4 7 5 16 1 Other factors include: approval/acceptance, customer preference, domestic manufacturer, and traditional supplier 

for the first factors; ability to handle problems, financial strength, performance, physical location of the mill (North 

America or abroad), service, and “specific item” for the second factor; and country of origin, history of the company, 

and “market competitive” as the third factors.

Source: Compiled from data submitted in response to Commission questionnaires.

Purchasers were asked how often they purchase the OCTG that is offered at the lowest 

price; of the 52 purchasers which responded, 23 firms indicated “usually,” 22 firms indicated 

“sometimes,” 5 firms indicated “rarely,” and 1 firm each indicated “always” and “never.” Fortysix purchasers listed reasons why they purchased higher-priced OCTG even though lower-priced 

OCTG was available. A broad range of reasons were indicated by purchasers, but were generally 

the same as those qualities listed in the purchasers’ three most important factors when making 

their decisions (e.g., quality, availability, reliability, delivery, credit terms, U.S. mills). Some 

purchasers indicated that proprietary or premium connections were another reason and one 

stated that domestic OCTG has a lower liability risk. 

22 Some firms answered more than one factor for one or more of the ranks. All responses were 

included in these summary statistics.

II-21

 
Purchasing patterns

Purchasers were asked a number of questions about whether their purchasing patterns 

for OCTG from domestic, subject, and nonsubject sources had changed since 2011 (table II-9). 

Most purchasers reported that they had not purchased product from the majority of the 

subject countries. A plurality of purchasers that bought from sources in subject countries 

reported that their purchases had fluctuated for all of these sources except for those from

three Korean sources, Thailand, and smaller Turkish suppliers (i.e., other than Borusan and 

Yucel). A plurality had increased their purchases from domestic and Korean sources, decreased 

their purchases from Thailand, and was evenly split between increasing and decreasing 

purchases from smaller Turkish suppliers.

Table II-9

OCTG: Changes in purchase patterns from U.S., subject, and nonsubject countries since 2011

Source of purchases Decreased Increased Constant Fluctuated

United States 7 19 11 6

India – GVN Fuels Limited 3 1 2 4

India – Jindal Saw 7 3 1 11

India – Other 5 3 1 13

Korea – Hyundai HYSCO 7 11 4 8

Korea – NEXTEEL 11 13 1 11

Korea – Other 4 20 2 9

Philippines 5 4 6 8

Saudi Arabia 7 3 4 10

Taiwan – Chung Hung 5 2 2 7

Taiwan – Tension 4 4 3 8

Taiwan – Other 3 2 3 8

Thailand 4 1 1 3

Turkey – Borusan 6 7 5 13

Turkey – Yucel 3 1 1 4

Turkey – Other 3 3 0 3

Ukraine 9 2 3 11

Vietnam 8 4 3 11

All other countries 11 6 9 16

Note.—Based on preliminary Commerce findings, purchasers were asked separately for data from certain companies 

in India, Korea, Taiwan, and Turkey. Data with respect to each firm is presented separately herein to prevent the 

possible triple-counting of responses.

Source: Compiled from data submitted in response to Commission questionnaires.

Purchasers reported buying OCTG at different stages of processing. The majority 

purchased finished OCTG, but there was a sizeable number that purchased OCTG that was 

either unfinished and not at API grade, unfinished at API grade but upgradeable, and unfinished 

at API grade but required end finishing. Whereas purchasers reported buying most OCTG that is 

finished, unfinished and not at API grade, and unfinished at API grade but requiring end 

finishing from the United States, the majority purchasing OCTG that is unfinished at API grade

but upgradeable did so from countries subject to these investigations. For further detail, see 

table II-10.

II-22
Table II-10

OCTG: Purchasers’ sources of supply, by stage of processing and source

Stage of processing

Source

United 

States

Subject 

countries

Nonsubject 

countries All sources

Finished OCTG 39 34 30 45

Unfinished not at API 8 4 4 10

Unfinished at API but upgradeable 4 16 10 19

Unfinished at API but requiring end 

finishing 23 19 19 35

All others 5 5 2 6

Source: Compiled from data submitted in response to Commission questionnaires.

Importance of specified purchase factors

Purchasers were asked to rate the importance of 18 factors when making their 

purchasing decisions (table II-11). The factors listed as “very important” by at least half of the 

responding firms were availability (51 purchasers); product consistency (49 purchasers); price 

and reliability of supply (47 purchasers each); quality meets industry standards (46 purchasers);

delivery time (40 purchasers); quality exceeds industry standards (28 purchasers); technical 

support (27 purchasers); and delivery terms (26 purchasers). 

Table II-11

OCTG: Importance of purchase factors, as reported by U.S. purchasers, by number of responding 

firms

Factor Very important Somewhat important Not important

Availability 51 1 0

Delivery terms 26 24 1

Delivery time 40 10 1

Discounts offered 22 20 9

Extension of credit 19 23 10

Minimum quantity requirements 11 24 16

Packaging 6 20 25

Price 47 4 0

Product consistency 49 2 0

Product range 24 21 7

Program sales 18 16 17

Proprietary connections 14 21 16

Quality exceeds industry standards 28 20 3

Quality meets industry standards 46 5 0

Reliability of supply 47 4 0

Suppliers' U.S. inventory 18 22 11

Technical support/service 27 17 6

U.S. transportation costs 21 22 8

Source: Compiled from data submitted in response to Commission questionnaires.

Factors determining quality

A variety of factors are important to purchasers in determining the quality of the OCTG 

they purchase. These factors have not only to do with the pipe itself (conformance to API 

II-23
specifications, mechanical properties, dimensional tolerances, finishing, threading, testing 

results, number of failures, no transportation damage), but the raw materials used (its 

metallurgy and the source of the hot-rolled steel used), the mill (its age, type of equipment 

used to make the OCTG, mill reputation, processes within the mill, historical testing data), and

post-sale factors (documentation, end user acceptance, failure rate in the well, manufacturer 

liability, and claims resolution).

Nineteen of the 52 responding purchasers reported that certain grades/types/sizes/ 

connections of OCTG were available from only one source (either domestic or foreign). 

Purchasers listed a variety of sizes (e.g., small diameter ERW OCTG from Korea, or large end 

sizes up to 24” from U.S. Steel), specifications, base metals, (e.g., chrome from Japan and

corrosion-resistant alloys), and proprietary connections and threads (e.g., those from Tenaris, 

TMK IPSCO, U.S. Steel, and Vallourec, OCTG producers that reportedly will not put their 

proprietary threads on any other mill’s products).23

Supplier certification

Domestic producers noted that suppliers do not need to get certified by individual 

purchasers.24 Rather, the casing and tubing under consideration must meet the grade 

standards. As long as a mill’s or processor’s facility meets the API’s specifications, it can be 

certified to use the API stamp on its products. Receiving API certification typically requires four 

to nine months, depending on the process for which certification is sought (e.g., threading, heat 

treatment, or manufacturing).25

Thirty-three of 52 responding purchasers reported they require their suppliers to 

become certified or pre-qualified in order to sell OCTG to their firm. Factors considered in 

certification or prequalification include: certifications (ISO and API and/or API 5CT certification); 

certificate of liability/insurance coverage; customer supplier specification; factors related to the 

mill (its location, processes, quality, reputation, warranties); meeting financial and 

governmental requirements; passing independent audits; raw material sourcing; reliability of 

supply; supplier history; and trials of material from new suppliers. The time to qualify a new 

supplier ranged from one day to seven months; 11 purchasers reported that it took less than 

one month, whereas 14 reported that it took three to seven months to qualify a new supplier.

Forty-one of the 50 responding purchasers indicated that no domestic or foreign producer had 

failed in its attempts to certify or qualify OCTG nor had any producers lost their approved status

since 2011. Two reported that ISMT of India’s quality kept it from qualifying; one reported that 

Chinese mills’ consistency was an issue; one reported that domestic firms Northwest Pipe and 

Lakeside Steel (EnergeX) did not qualify due to availability/delivery/ dependability and AJU 

Besteel of Korea did not qualify due to quality concerns. One purchaser did not qualify Jindal 

Saw of India due to its ***, ***, and quality. Evraz USA failed at one purchaser due to 

“inconsistencies in ovality and straightness caused issues with threading their materials.” 

23 Purchaser *** listed these firms as not using proprietary threading on other firms’ OCTG. 

Petitioners disagree with this assertion, noting that ***. Posthearing brief of Petitioner Group 

Boomerang et al., p. 7. 24 Conference transcript, p. 120 (Miller and Schagrin).

25 Conference transcript, p. 248 (Brewer).

II-24

 
Another purchaser reported that WSP failed to qualify due to quality concerns. Finally, two 

purchasers reported broadly that certain countries did not qualify, including the United States, 

India, Thailand, Turkey, and Vietnam.

Lead times

The majority of domestic production of OCTG (88.3 percent) is made on a produced-toorder basis, including all OCTG sold by ***. Domestic lead times for produced-to-order OCTG 

ranged between 1 and 4 months, with an average of almost 2 months. For sales from inventory, 

lead times ranged between 1 and 15 days, averaging 8 days.

A majority of importers’ shipments of OCTG (53.5 percent across all named countries) 

were also made on a produced-to-order basis. However, OCTG from *** were sold from 

importers’ U.S. inventories a majority of the time in 2013 (*** percent of shipments, 

respectively). Very few imports were sold from foreign inventories, however, with these 

imports accounting for the greatest share among the nine countries from ***, but still 

accounting for *** percent or less of its imports. Across all

subject countries, lead times for produced-to-order OCTG ranged from 3 to 6 months and 

averaged about 4 months. For those shipped from importers’ inventories, lead time ranged 

between 2 days and 2 months,

26 and averaged 26 days across 16 responding importers. Imports 

shipped from overseas inventories were rare, and data regarding lead times was reported by 

two importers, who noted lead times of *** days. 

Price leadership

Purchasers identified a number of suppliers or countries that exhibited price leadership.

U.S. Steel was the firm that was labeled most frequently as a price leader. In all, 22 purchasers 

indicated that U.S. Steel has been a price leader. Other domestic firms reported by purchasers 

included TMK-IPSCO (13 purchasers), Tenaris (11),27 Vallourec (10), Northwest Pipe (2), EnergeX 

(1), and Evraz (1). Among foreign sources, purchasers indicated that sources that either 

produced in Korea or imported from Korea were price leaders. Although some did not identify

specific firms, 18 purchasers identified: Atlas Tubular, Hyundai HYSCO, ILJIN, NEXTEEL, and 

SeAH. Among Korean mills, NEXTEEL was mentioned most frequently (7 purchasers), with 

multiple Korean mills or Korean mills in general mentioned slightly less often (6 purchasers). In 

addition, Trident was named as a price leader by 6 purchasers, and GVN from India and Jesco 

from Taiwan were named by 1 purchaser each. 

26 In addition, one importer, ***, reported lead times of 5 months from its U.S. inventories, but did 

not report lead times for sales from overseas inventories or for produced-to-order OCTG, whereas 

another, ***, reported just-in-time lead times, but did not quantify its response. 27 ***.

II-25

 
Comparisons of domestic products, subject imports, and nonsubject imports

Interchangeability

To determine whether U.S.-produced OCTG can generally be used in the same 

applications as imports from the nine subject countries as well as other countries, U.S. 

producers and importers were asked whether the products can “always,” “frequently,” 

“sometimes,” or “never” be used interchangeably. As shown in table II-12, most producers

reported that product from all country pairs was “always” or “frequently” interchangeable. A 

plurality of importers, frequently a majority, also reported that OCTG from all country pairs 

were “always” interchangeable, with the exception of Korea vs. nonsubject countries, wherein 

seven importers replied “always” and eight replied “sometimes.” Purchasers’ perceptions were 

a bit more evenly spread out among “always,” “frequently,” and “sometimes.”

Factors cited by importers as limiting interchangeability included: issues with respect to 

welded vs. seamless OCTG (noted by 9 importers and 7 purchasers); quality issues (7 importers 

and 11 purchasers); grades, sizes and connections (7 importers and 6 purchasers); and 

customer experience and acceptance, as well as producer credibility/reliability (3 importers and 

7 purchasers). 

II-26
Table II-12

OCTG: Interchangeability between OCTG produced in the United States and in other countries, by 

country pair

Country pair

Number of U.S. 

producers reporting

Number of U.S. 

importers reporting

Number of U.S. 

purchasers reporting

A F S N A F S N A F S N

U.S. vs. subject countries:

U.S. vs. India 12 0 0 0 13 4 8 0 14 13 14 0

U.S. vs. Korea 12 0 0 0 15 4 9 0 18 17 9 1

U.S. vs. Philippines 12 0 0 0 12 5 8 0 12 10 10 1

U.S. vs. Saudi Arabia 12 0 0 0 12 4 7 0 14 9 11 0

U.S. vs. Taiwan 12 0 0 0 11 6 8 0 12 9 13 0

U.S. vs. Thailand 12 0 0 0 13 3 6 0 13 6 9 0

U.S. vs. Turkey 12 0 0 0 11 4 8 0 12 12 13 0

U.S. vs. Ukraine 12 0 0 0 11 5 7 0 13 10 11 1

U.S. vs. Vietnam 12 0 0 0 11 6 6 0 12 9 10 0

Subject vs. subject 

countries:

India vs. Korea 11 0 0 0 9 3 7 0 11 16 10 1

India vs. Philippines 11 0 0 0 10 3 5 0 13 10 8 1

India vs. Saudi Arabia 11 0 0 0 9 2 5 0 12 9 11 0

India vs. Taiwan 11 0 0 0 8 3 5 0 12 10 10 0

India vs. Thailand 11 0 0 0 9 2 5 0 13 5 9 0

India vs. Turkey 11 0 0 0 10 4 5 0 12 12 10 0

India vs. Ukraine 11 0 0 0 8 5 4 0 12 11 10 1

India vs. Vietnam 11 0 0 0 9 3 4 0 12 9 7 0

Korea vs. Philippines 11 0 0 0 10 4 7 0 13 11 11 0

Korea vs. Saudi Arabia 11 0 0 0 8 2 7 0 13 10 9 1

Korea vs. Taiwan 11 0 0 0 8 4 7 0 12 11 11 0

Korea vs. Thailand 11 0 0 0 9 2 8 0 12 7 8 0

Korea vs. Turkey 11 0 0 0 9 4 7 0 12 16 8 0

Korea vs. Ukraine 11 0 0 0 8 4 8 0 12 10 10 2

Korea vs. Vietnam 11 0 0 0 9 4 6 0 11 9 10 0

Philippines vs. Saudi Arabia 11 0 0 0 8 3 4 0 11 5 12 1

Philippines vs. Taiwan 11 0 0 0 8 5 4 0 12 10 10 1

Philippines vs. Thailand 11 0 0 0 9 3 4 0 13 6 8 0

Philippines vs. Turkey 11 0 0 0 9 3 6 0 11 9 12 1

Philippines vs. Ukraine 11 0 0 0 8 3 6 0 12 6 11 1

Philippines vs. Vietnam 11 0 0 0 9 4 4 0 12 6 10 0

Table continued on next page.

II-27
Table II-12--Continued

OCTG: Interchangeability between OCTG produced in the United States and in other countries, by 

country pair

Country pair

Number of U.S. 

producers reporting

Number of U.S. 

importers reporting

Number of U.S. 

purchasers reporting

A F S N A F S N A F S N

Subject vs. subject 

countries:

Saudi Arabia vs. Taiwan 11 0 0 0 8 3 4 0 11 6 13 0

Saudi Arabia vs. Thailand 11 0 0 0 9 3 4 0 12 3 10 0

Saudi Arabia vs. Turkey 11 0 0 0 9 2 6 0 10 6 14 0

Saudi Arabia vs. Ukraine 11 0 0 0 8 5 5 0 11 4 12 1

Saudi Arabia vs. Vietnam 11 0 0 0 8 3 3 0 11 3 10 0

Taiwan vs. Thailand 11 0 0 0 9 2 5 0 14 8 6 0

Taiwan vs. Turkey 11 0 0 0 8 3 6 0 11 11 9 0

Taiwan vs. Ukraine 11 0 0 0 8 2 6 0 12 8 9 1

Taiwan vs. Vietnam 11 0 0 0 8 4 4 0 13 8 8 0

Thailand vs. Turkey 11 0 0 0 9 2 6 0 11 7 9 0

Thailand vs. Ukraine 11 0 0 0 8 2 6 0 12 5 9 1

Thailand vs. Vietnam 11 0 0 0 9 2 4 0 12 7 6 0

Turkey vs. Ukraine 11 0 0 0 8 4 6 0 13 8 10 1

Turkey vs. Vietnam 11 0 0 0 9 3 5 1 12 7 10 0

Ukraine vs. Vietnam 11 0 0 0 8 4 4 0 12 6 10 1

Comparisons with 

nonsubject countries:

U.S. vs. nonsubject 11 1 0 0 11 6 6 0 12 16 8 0

India vs. nonsubject 10 1 0 0 7 6 4 0 11 10 9 0

Korea vs. nonsubject 10 1 0 0 7 5 8 0 11 12 9 0

Philippines vs. nonsubject 10 1 0 0 7 5 5 0 10 7 9 2

Saudi Arabia vs. nonsubject 10 1 0 0 7 7 4 0 11 5 10 0

Taiwan vs. nonsubject 10 1 0 0 7 5 5 0 10 6 9 0

Thailand vs. nonsubject 10 1 0 0 7 4 5 0 10 6 7 0

Turkey vs. nonsubject 10 1 0 0 7 6 4 0 12 9 9 0

Ukraine vs. nonsubject 10 1 0 0 7 5 5 0 11 6 9 1

Vietnam vs. nonsubject 10 1 0 0 7 6 5 0 10 5 11 0

Note.—A=Always, F=Frequently, S=Sometimes, N=Never.

Source: Compiled from data submitted in response to Commission questionnaires.

II-28
Welded vs. seamless OCTG

There are certain applications in which welded and seamless OCTG cannot be used 

interchangeably. Seamless OCTG could be used in any application which required welded 

OCTG.28 The same is not true in reverse for all applications. At a minimum, high stress 

applications such as sour service in Alaska or drilling in the Gulf, which could account for an 

estimated 8-10 percent of the market, require seamless OCTG.29 A witness for petitioners 

estimated that welded OCTG could be used for 70 percent of seamless applications and a 

witness for respondents noted that they are interchangeable in many cases from an 

engineering perspective.30 Petitioners further stated that beyond that, the project engineers’ 

preference can be a deciding factor. Witnesses for respondents noted that engineers’ 

preference for a higher-priced seamless product may be due to a preference to reduce risk, in 

light of incidents such as the BP Macondo oil spill in 2010. 31 32 At the hearing, respondents 

noted that seamless OCTG is the standard outside of North America and welded product is not 

considered, even for U.S. offshore rigs, even though welded OCTG producers argue that it is 

equal to seamless OCTG.33

The domestic industry sells both welded and seamless OCTG. However, as noted earlier, 

most subject countries have typically supplied either seamless or welded OCTG, which may limit 

substitutability among subject countries.34 Subject countries Saudi Arabia, Thailand, and

Ukraine only supplied seamless OCTG, and approximately 80 percent of imports of OCTG from 

India were seamless. In contrast, the other subject sources shipped 90-100 percent welded 

OCTG.

Quality

OCTG is typically produced to meet, if not exceed, API specifications. Petitioners 

contend that if a pipe meets the API specification then it is interchangeable, except for those at 

the top end of the product range.35 API certification confirms that the pipe meets 

specifications, but does not imply a level of quality beyond those specifications.

36

A large majority of purchasers (46 of 51) indicated that one factor that is “very 

important” is that the product quality meets industry standards, but a majority (28 of 51) 

indicated that quality exceeding industry standards is also “very important.” Furthermore, 

28 Conference transcript, p. 109 (Matthews).

29 Hearing transcript, p. 144 (Schagrin).

30 Conference transcript, pp. 109 (Matthews) and 261 (Brewer).

31 Conference transcript, pp. 263-4 (Blomberg and Fowler).

32 Conference transcript, p. 263 (Fowler).

33 Hearing transcript, pp. 329-330 (Blomberg) and 331 (Scianna).

34 For more information regarding welded vs. seamless OCTG production, see Part III. For more 

information regarding welded and seamless OCTG production in other countries, see Part VII.

35 Hearing transcript, p. 144 (Schagrin). Whereas counsel for some petitioners describe 90 percent of 

the OCTG as a “commodity,” counsel for others describes it not as a “commodity,” but “commoditylike,” pp. 145 (Schagrin) and 191 (Price).

36 Conference transcript, p. 249 (Brewer and Cameron).

II-29

 
although pipe may meet API specifications, purchasers noted that their customers have sources 

that they either prefer or want to avoid, based on quality issues.

Premium connections and alloy grades

A proportion of demand in the United States reportedly requires premium or semipremium connections or threads.37 Semi-premium and premium threads are used in high-stress 

applications that need to withstand high torque, high compression, and bending, such as

offshore and horizontal drilling. Petitioners stated that demand for these connections is 

decreasing, however, as more rigs are converted from drilling for gas to drilling for oil.38

Counsel for petitioners estimated that 90 percent of threads are “commodity type,” and that 

semi-premium or premium threads can be added to welded or seamless pipe from any source, 

including that from subject countries.39 Another witness testified that his firm had lost a sale of 

OCTG with semi-premium threading to OCTG imported from Korea.40 Purchaser *** stated, 

however, that domestic producers Tenaris, TMK IPSCO, U.S. Steel, and Vallourec will not add a

proprietary thread to any OCTG from any other mill.41 Petitioners disagree with this assertion, 

noting that ***.

42

Witnesses for respondents at the hearing testified that premium and semi-premium 

threads and alloy grades are being emphasized by domestic producers, and that “subject 

imports have essentially no presence in this segment of the market.”43 In its questionnaire 

response, importer *** indicated that premium connections are not available from Korea.

Purchasers were asked what proportion of OCTG that they purchase has proprietary 

connections that are required by them or their customers, preferred by them or their 

customers, or in which they were unrestricted in the connection type for their purchases of 

OCTG. For seamless OCTG, 37.4 percent of purchases required proprietary connections, 8.3 

percent preferred proprietary connections, and 54.2 percent were unrestricted, based on a 

simple average. A smaller proportion was required for welded OCTG: 14.4 percent of purchases 

required proprietary connections, 4.2 percent preferred, and 81.4 percent unrestricted.44

37 As noted in Part I, proprietary “semi-premium” or “premium” threaded connections provide higher 

torsional loads, bending resistance, or greater sealability for casing in challenging drilling environments.

Premium threaded connections generally refer to OCTG connections that have a metal-to-metal, gastype seal to ensure pressure integrity. Semi-premium connections generally refer to connections that do 

not have a metal-to-metal seal, yet maintain water-type sealability, and thus may be used in less 

demanding wells with no gas-type sealability requirements.

38 Hearing transcript, pp. 194 (Curá) and 195 (Longhi).

39 Hearing transcript, p. 144 (Schagrin).

40 Conference transcript, p. 137 (Snyder). 41 E-mail from ***, June 18, 2014. 42 Posthearing brief of Petitioner Group Boomerang et al., p. 7.

43 Hearing transcript, pp. 223-224 (Dougan). 44 Based upon a simple average of purchaser responses; a breakdown of purchasers’ seamless vs. 

welded purchases was not reported.

II-30

 
An increasing focus of domestic OCTG demand has been higher alloy grades of OCTG 

such as P110.45 Respondents at the hearing noted that many of the imports of OCTG from 

subject countries are not imported at alloy grades. Instead, more basic upgradeable J55 pipe or 

green tubes are imported and then heat treated to increase the grade to an alloy grade.46 For 

further information regarding pipe processing, grades, and connections, see Part IV.

Program sales

Program sales are non-contractual obligations between mills, distributors, and end users 

which encompass what type of OCTG is to be supplied, when it will be supplied, and at what 

price it will be supplied. Program sales can help minimize supply chain disruption. U.S. 

producers reported that more than half of their 2013 sales were made under program sales. 

Respondents indicated that there is limited participation in the program sale market.

47 Further 

information regarding program sales can be found in Part V.

Purchase factors comparisons

Purchasers were asked a number of questions comparing OCTG produced in the United 

States, subject countries, and nonsubject countries. First, purchasers were asked to provide a

country-by-country comparison for the 18 factors for which they were asked to rate the 

importance, presented above in table II-11.

When comparing U.S. product to product from subject countries, most responding 

purchasers reported that the U.S. product was superior to product imported from most subject 

sources for 11 of the 18 factors, comparable on 5 factors, and inferior on 1 factor (price). Table 

II-13 presents the data for each of these comparisons with subject sources and all nonsubject 

sources combined. Table II-14 presents similar data comparing each of the subject sources with 

each of the other subject and combined nonsubject sources. Whereas purchasers’ responses 

rated most of these sources as comparable for most factors, table II-15 presents a summary of 

the factors in which a plurality or majority of purchasers rated one of the sources as superior or 

inferior. All subject countries were rated “superior” on price compared to nonsubject countries.

45 Conference transcript, pp. 165 (Fowler) and 188 (Sumer), and “The Five Year Outlook for the Global 

OCTG Industry,” Metal Bulletin Research, 2013.

46 Hearing transcript, pp. 230-231 (Scianna) and 325 (Cameron). 47 Hearing transcript, pp. 226 (Pi) and 304-305 (Scianna).

II-31

 
Table II-13

OCTG: Purchasers' comparisons of domestic OCTG with subject and nonsubject countries 

regarding 18 purchase factors 1

Factor

U.S. vs. India U.S vs. Korea U.S vs. Philippines

U.S. vs. Saudi 

Arabia

S C I S C I S C I S C I

Availability 22 17 2 15 26 3 19 14 2 18 10 2

Delivery terms 23 17 1 16 25 2 18 15 3 16 13 2

Delivery time 24 13 4 21 19 4 21 11 4 22 7 2

Discounts offered 10 24 7 7 29 7 11 18 7 10 18 3

Extension of credit 12 25 4 8 29 6 12 21 3 9 21 1

Minimum quantity requirements 10 25 6 6 33 4 10 20 6 9 19 3

Packaging 10 30 1 7 36 1 10 24 3 7 23 1

Price 3 1 37 3 8 33 4 2 30 4 3 24

Product consistency 26 12 3 10 32 2 22 13 1 13 18 0

Product range 23 16 2 20 22 2 23 11 2 22 8 1

Program sales 22 13 4 19 21 2 20 10 4 18 10 2

Proprietary connections 32 6 1 32 10 1 29 4 1 24 5 1

Quality exceeds industry 

standards 27 12 2 14 29 0 23 12 1 16 15 0

Quality meets industry 

standards 18 20 1 9 34 0 16 17 1 11 18 0

Reliability of supply 23 15 3 12 31 1 19 15 2 20 10 1

Suppliers’ U.S. inventories 21 12 7 18 20 5 19 12 4 19 10 2

Technical support/service 28 9 3 27 12 3 25 9 1 24 6 1

U.S. transportation costs 10 28 2 10 32 1 10 24 1 10 21 0

Factor

U.S. vs. Taiwan U.S vs. Thailand U.S vs. Turkey U.S. vs. Ukraine

S C I S C I S C I S C I

Availability 20 12 3 19 8 2 19 15 3 23 11 4

Delivery terms 17 16 2 17 10 2 19 17 2 18 18 2

Delivery time 21 10 4 18 7 3 24 11 3 24 10 4

Discounts offered 12 20 3 11 14 4 9 25 4 11 23 4

Extension of credit 12 21 2 10 17 2 10 27 1 11 24 3

Minimum quantity requirements 11 18 6 10 14 5 9 26 3 11 22 5

Packaging 10 24 1 9 19 1 8 28 2 10 26 2

Price 5 2 28 4 2 23 4 4 30 8 1 29

Product consistency 22 13 0 20 8 1 19 19 0 25 12 1

Product range 26 8 1 22 6 1 26 11 1 27 10 1

Program sales 22 10 2 19 7 2 21 13 2 24 10 2

Proprietary connections 27 6 0 23 3 1 29 6 1 28 7 1

Quality exceeds industry 

standards 22 13 0 20 9 0 21 17 0 25 12 1

Quality meets industry 

standards 11 22 0 12 14 1 12 24 0 16 19 1

Reliability of supply 19 15 1 18 10 1 21 16 1 24 13 1

Suppliers’ U.S. inventories 19 11 4 17 8 3 20 13 4 20 12 5

Technical support/service 24 8 2 21 6 1 22 14 1 25 10 2

U.S. transportation costs 11 23 0 11 17 0 12 25 0 12 24 1

Table continued on next page.

II-32
Table II-13--Continued

OCTG: Purchasers' comparisons of domestic OCTG with subject and nonsubject countries 

regarding 18 purchase factors 1

Factor

U.S. vs. Vietnam

U.S. vs. 

nonsubject 

countries2

S C I S C I

Availability 21 10 2 36 42 1

Delivery terms 18 13 2 27 48 4

Delivery time 23 7 3 51 26 2

Discounts offered 10 19 4 7 63 9

Extension of credit 10 21 2 8 68 3

Minimum quantity requirements 13 14 6 6 65 7

Packaging 10 20 2 6 71 2

Price 5 2 26 4 48 27

Product consistency 22 10 1 12 61 5

Product range 25 7 1 31 44 3

Program sales 22 7 2 30 46 3

Proprietary connections 25 5 1 39 37 0

Quality exceeds industry 

standards 24 8 1 18 59 2

Quality meets industry 

standards 12 18 1 7 65 1

Reliability of supply 21 10 1 30 47 2

Suppliers’ U.S. inventories 19 9 4 36 35 5

Technical support/service 23 8 1 20 53 6

U.S. transportation costs 12 20 0 14 62 3 1 A rating of superior means that price/U.S. transportation costs is generally lower. For example, if a firm reported “U.S. superior,” it 

meant that the U.S. product was generally priced lower than the imported product. 2 The imports from nonsubject countries that the U.S. product was compared to were: Argentina, Austria, Belarus, Brazil, Canada, 

China, Czech Republic, Germany, Greece, Italy, Japan, Mexico, Romania, Russia, South Africa, and Spain. 

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.

II-33
Table II-14 

OCTG: Purchasers' comparisons of subject and nonsubject countries regarding 18 purchase 

factors

Factor

India vs. Korea India vs. Philippines

India vs. Saudi 

Arabia

S C I S C I S C I

Availability 1 19 16 4 25 2 1 27 2

Delivery terms 1 28 7 3 26 2 1 27 2

Delivery time 2 23 12 4 26 2 3 24 3

Discounts offered 2 31 3 1 28 2 0 29 1

Extension of credit 1 32 3 2 28 1 0 28 2

Minimum quantity requirements 1 27 8 2 27 2 0 27 3

Packaging 1 32 3 2 28 1 0 29 1

Price 6 19 11 3 19 9 3 23 4

Product consistency 2 16 18 5 22 4 1 19 10

Product range 4 22 10 6 23 2 3 22 4

Program sales 1 21 13 2 25 3 0 25 5

Proprietary connections 3 25 5 4 23 1 2 24 2

Quality exceeds industry standards 2 20 13 4 22 4 1 21 7

Quality meets industry standards 1 26 9 3 25 3 0 22 8

Reliability of supply 1 20 15 5 23 3 1 24 5

Suppliers’ U.S. inventories 1 19 15 4 23 3 1 25 4

Technical support/service 1 21 13 2 25 3 0 26 4

U.S. transportation costs 1 29 5 1 27 2 0 27 3

Factor

India vs. Taiwan India vs. Thailand India vs. Turkey

S C I S C I S C I

Availability 3 26 3 3 22 1 2 25 6

Delivery terms 3 27 2 3 22 1 2 28 3

Delivery time 3 27 2 3 22 1 3 24 6

Discounts offered 2 28 2 2 22 2 2 27 4

Extension of credit 1 30 1 1 24 1 1 28 4

Minimum quantity requirements 1 30 1 1 24 1 1 28 4

Packaging 1 30 1 1 24 1 1 30 2

Price 3 22 7 2 18 6 3 22 8

Product consistency 6 22 4 6 18 2 3 23 7

Product range 6 25 1 4 21 1 5 25 3

Program sales 3 27 1 3 21 1 1 26 4

Proprietary connections 4 24 1 5 17 1 4 23 3

Quality exceeds industry standards 5 22 4 6 16 3 3 25 4

Quality meets industry standards 4 27 1 5 19 1 2 27 4

Reliability of supply 5 23 4 5 19 2 2 26 5

Suppliers’ U.S. inventories 3 25 3 3 20 2 2 26 4

Technical support/service 2 27 2 2 22 1 1 26 5

U.S. transportation costs 1 28 2 1 23 1 1 28 3

Table continued on next page.

II-34
Table II-14--Continued

OCTG: Purchasers' comparisons of subject and nonsubject countries regarding 18 purchase 

factors

Factor

India vs. Ukraine India vs. Vietnam India vs. nonsubject3

S C I S C I S C I

Availability 7 23 4 5 25 1 4 38 27

Delivery terms 3 28 3 4 26 1 0 53 16

Delivery time 3 28 3 3 27 1 2 39 28

Discounts offered 2 28 4 1 27 3 1 52 16

Extension of credit 3 28 3 2 28 1 0 53 16

Minimum quantity requirements 3 29 2 1 29 1 1 54 14

Packaging 2 31 1 1 28 1 0 57 11

Price 3 25 6 2 21 8 27 27 15

Product consistency 6 24 4 6 21 4 2 22 44

Product range 7 25 2 9 21 1 8 32 29

Program sales 5 26 2 4 23 2 0 44 25

Proprietary connections 4 26 1 3 24 1 0 33 30

Quality exceeds industry standards 5 25 3 4 23 3 0 25 41

Quality meets industry standards 5 28 1 4 25 2 1 36 32

Reliability of supply 8 24 2 7 22 2 3 33 34

Suppliers’ U.S. inventories 6 24 3 5 24 1 6 40 21

Technical support/service 4 27 2 5 24 1 1 27 41

U.S. transportation costs 2 29 2 1 28 1 2 54 13

Factor

Korea vs. 

Philippines

Korea vs. Saudi 

Arabia Korea vs. Taiwan

S C I S C I S C I

Availability 18 14 0 17 13 0 15 17 0

Delivery terms 9 23 0 9 21 0 10 22 0

Delivery time 10 22 0 9 21 0 10 22 0

Discounts offered 5 26 1 6 24 0 4 27 1

Extension of credit 6 26 0 5 25 0 6 26 0

Minimum quantity requirements 7 25 0 4 26 0 5 27 0

Packaging 5 27 0 5 25 0 4 27 0

Price 3 21 8 13 15 2 2 22 8

Product consistency 15 17 0 8 21 1 15 17 0

Product range 16 16 0 13 15 2 16 16 0

Program sales 14 17 0 13 17 0 14 17 0

Proprietary connections 5 24 0 3 24 1 4 25 0

Quality exceeds industry standards 14 17 0 8 21 0 13 18 0

Quality meets industry standards 12 20 0 7 23 0 12 20 0

Reliability of supply 16 16 0 12 18 0 13 19 0

Suppliers’ U.S. inventories 16 14 1 14 15 1 13 17 1

Technical support/service 12 19 0 8 22 0 10 21 0

U.S. transportation costs 5 26 0 5 25 0 4 27 0

3 The imports from nonsubject countries that the India product was compared to were: Argentina, Austria, Belarus, Brazil, Canada, 

China, Czech Republic, Germany, Greece, Italy, Japan, Mexico, Romania, Russia, South Africa, and Spain.

Table continued on next page.

II-35
Table II-14--Continued

OCTG: Purchasers' comparisons of subject and nonsubject countries regarding 18 purchase 

factors

Factor

Korea vs. Thailand Korea vs. Turkey Korea vs. Ukraine

S C I S C I S C I

Availability 12 13 0 14 19 2 17 16 1

Delivery terms 8 17 0 8 26 1 12 22 0

Delivery time 8 17 0 8 26 1 13 21 0

Discounts offered 6 18 1 5 29 1 8 26 0

Extension of credit 6 19 0 5 30 0 9 25 0

Minimum quantity requirements 6 19 0 6 29 0 9 25 0

Packaging 5 20 0 4 31 0 7 27 0

Price 3 15 7 8 23 4 9 18 7

Product consistency 14 11 0 11 22 2 18 15 1

Product range 12 13 0 13 21 1 14 18 2

Program sales 11 13 0 12 22 0 14 19 0

Proprietary connections 5 17 0 5 27 0 7 22 2

Quality exceeds industry standards 11 13 0 10 23 1 14 18 1

Quality meets industry standards 11 14 0 9 25 1 15 19 0

Reliability of supply 12 13 0 13 21 1 19 15 0

Suppliers’ U.S. inventories 12 11 1 14 18 2 15 16 2

Technical support/service 8 16 0 7 24 3 10 23 0

U.S. transportation costs 4 19 0 4 29 1 7 26 0

Factor

Korea vs. Vietnam

Korea vs. 

nonsubject4 Philippines vs. Saudi Arabia

S C I S C I S C I

Availability 16 14 0 32 33 0 2 20 5

Delivery terms 11 19 0 11 54 0 0 25 2

Delivery time 13 17 0 21 43 1 1 22 4

Discounts offered 7 22 1 11 53 0 1 24 2

Extension of credit 7 23 0 8 56 0 0 22 5

Minimum quantity requirements 10 20 0 12 52 0 0 24 3

Packaging 6 24 0 7 57 0 0 25 2

Price 3 18 9 44 20 0 12 13 2

Product consistency 17 13 0 13 36 15 1 18 8

Product range 17 13 0 21 26 17 1 20 6

Program sales 16 13 0 13 44 7 0 23 4

Proprietary connections 8 19 0 9 30 22 0 21 4

Quality exceeds industry standards 15 14 0 9 39 14 0 17 9

Quality meets industry standards 13 17 0 8 46 11 0 21 6

Reliability of supply 17 13 0 17 41 7 0 22 5

Suppliers’ U.S. inventories 15 13 1 30 34 1 0 20 7

Technical support/service 11 18 0 8 40 17 0 22 5

U.S. transportation costs 7 22 0 10 51 3 0 24 3 4 The imports from nonsubject countries that the Korea product was compared to were: Argentina, Austria, Belarus, Brazil, Canada, 

China, Czech Republic, Germany, Greece, Italy, Japan, Mexico, Romania, Russia, South Africa, and Spain.

Table continued on next page.

II-36
Table II-14--Continued

OCTG: Purchasers' comparisons of subject and nonsubject countries regarding 18 purchase 

factors

Factor

Philippines vs. 

Taiwan

Philippines vs. 

Thailand

Philippines vs. 

Turkey

S C I S C I S C I

Availability 1 26 3 0 24 1 0 24 6

Delivery terms 0 30 0 0 25 0 0 24 5

Delivery time 1 28 1 1 24 0 0 22 8

Discounts offered 0 30 0 0 25 0 0 27 3

Extension of credit 0 27 3 0 24 1 0 25 4

Minimum quantity requirements 0 30 0 0 25 0 0 27 3

Packaging 0 30 0 0 25 0 0 29 1

Price 2 28 0 1 23 0 9 21 0

Product consistency 0 27 3 1 23 1 0 24 6

Product range 0 28 2 1 23 1 1 25 4

Program sales 0 25 3 0 22 1 0 23 5

Proprietary connections 0 26 1 0 21 1 0 24 3

Quality exceeds industry standards 0 26 3 0 23 1 0 23 6

Quality meets industry standards 0 29 1 0 25 0 0 26 4

Reliability of supply 0 27 3 0 25 0 0 24 6

Suppliers’ U.S. inventories 0 26 3 0 23 1 0 25 4

Technical support/service 0 27 2 0 23 1 0 23 6

U.S. transportation costs 0 28 1 0 23 1 0 28 1

Factor

Philippines vs. 

Ukraine

Philippines vs. 

Vietnam

Philippines vs. 

nonsubject5

S C I S C I S C I

Availability 1 25 2 1 27 0 3 27 22

Delivery terms 1 25 2 1 27 0 0 33 18

Delivery time 2 23 3 0 26 2 0 29 22

Discounts offered 1 26 1 0 28 0 0 35 15

Extension of credit 1 25 2 0 28 0 0 35 16

Minimum quantity requirements 1 26 1 0 28 0 3 37 11

Packaging 1 26 1 0 28 0 3 40 8

Price 5 21 2 1 27 0 32 14 5

Product consistency 2 23 3 0 26 2 0 16 35

Product range 1 25 2 0 27 1 2 19 30

Program sales 1 23 2 0 25 1 0 25 25

Proprietary connections 1 22 2 0 24 1 0 20 27

Quality exceeds industry standards 1 24 2 0 26 1 0 14 34

Quality meets industry standards 1 26 1 0 27 1 0 29 22

Reliability of supply 2 24 2 1 26 1 1 21 30

Suppliers’ U.S. inventories 1 23 3 0 27 0 3 23 25

Technical support/service 1 24 2 0 26 1 0 17 34

U.S. transportation costs 1 25 1 0 27 0 1 37 13 5 The imports from nonsubject countries that the Philippines product was compared to were: Argentina, Austria, Belarus, Brazil, 

Canada, China, Czech Republic, Germany, Greece, Italy, Japan, Mexico, Romania, Russia, South Africa, and Spain.

Table continued on next page.

II-37
Table II-14--Continued

OCTG: Purchasers' comparisons of subject and nonsubject countries regarding 18 purchase 

factors

Factor

Saudi Arabia vs. 

Taiwan

Saudi Arabia vs. 

Thailand

Saudi Arabia vs. 

Turkey

S C I S C I S C I

Availability 6 20 2 6 19 0 1 25 4

Delivery terms 3 25 0 3 22 0 1 28 1

Delivery time 4 24 0 3 22 0 2 25 3

Discounts offered 3 25 0 3 22 0 1 28 1

Extension of credit 5 23 0 5 20 0 2 26 2

Minimum quantity requirements 4 24 0 5 20 0 2 26 2

Packaging 3 25 0 3 22 0 1 28 1

Price 1 15 12 0 14 10 1 20 9

Product consistency 10 18 0 9 16 0 5 24 1

Product range 6 20 2 6 18 1 4 22 4

Program sales 3 23 0 3 21 0 1 25 3

Proprietary connections 4 21 0 3 20 0 1 26 1

Quality exceeds industry standards 9 17 0 9 14 0 4 23 1

Quality meets industry standards 7 21 0 8 17 0 4 25 1

Reliability of supply 6 22 0 8 18 0 3 26 1

Suppliers’ U.S. inventories 6 22 1 5 20 0 2 23 5

Technical support/service 3 25 0 2 23 0 1 25 4

U.S. transportation costs 3 25 0 3 22 0 1 28 1

Factor

Saudi Arabia vs. 

Ukraine

Saudi Arabia vs. 

Vietnam

Saudi Arabia vs. 

nonsubject6

S C I S C I S C I

Availability 6 21 3 8 19 1 4 38 23

Delivery terms 4 26 0 4 24 0 1 47 16

Delivery time 5 23 2 6 22 0 3 38 23

Discounts offered 4 25 1 4 24 0 1 48 15

Extension of credit 5 24 1 7 21 0 1 48 15

Minimum quantity requirements 5 24 1 6 22 0 4 45 15

Packaging 4 26 0 4 24 0 2 53 10

Price 2 16 12 1 15 12 30 26 8

Product consistency 11 19 0 12 16 0 3 37 23

Product range 6 21 3 8 18 2 5 34 25

Program sales 5 23 2 4 23 0 2 33 27

Proprietary connections 3 24 1 4 22 0 3 28 27

Quality exceeds industry standards 9 19 1 9 17 1 2 41 18

Quality meets industry standards 9 20 1 10 17 1 4 46 14

Reliability of supply 9 18 3 8 19 1 2 40 22

Suppliers’ U.S. inventories 6 22 2 6 21 1 3 35 24

Technical support/service 6 23 1 5 22 1 1 34 29

U.S. transportation costs 4 26 0 4 23 0 3 51 10 6 The imports from nonsubject countries that the Saudi Arabia product was compared to were: Argentina, Austria, Belarus, Brazil, 

Canada, China, Czech Republic, Germany, Greece, Italy, Japan, Mexico, Romania, Russia, and Spain.

Table continued on next page.

II-38
Table II-14--Continued

OCTG: Purchasers' comparisons of subject and nonsubject countries regarding 18 purchase 

factors

Factor

Taiwan vs. Thailand Taiwan vs. Turkey Taiwan vs. Ukraine

S C I S C I S C I

Availability 2 19 1 0 25 4 5 22 2

Delivery terms 0 21 1 0 26 3 1 27 2

Delivery time 1 20 1 0 25 4 2 24 3

Discounts offered 0 21 1 0 27 2 2 25 2

Extension of credit 1 20 1 0 27 2 2 25 2

Minimum quantity requirements 1 20 1 0 28 1 2 26 1

Packaging 0 22 0 0 28 1 1 27 1

Price 2 18 2 6 21 2 4 23 2

Product consistency 1 20 1 1 25 3 3 24 2

Product range 2 19 1 0 27 2 1 26 2

Program sales 1 19 1 1 23 3 2 23 2

Proprietary connections 0 19 1 0 24 2 1 23 2

Quality exceeds industry standards 2 18 1 1 24 3 4 22 2

Quality meets industry standards 2 19 1 1 27 1 4 24 1

Reliability of supply 2 19 1 0 25 4 3 23 2

Suppliers’ U.S. inventories 2 19 1 0 24 4 4 23 1

Technical support/service 1 20 1 0 25 3 3 23 2

U.S. transportation costs 0 22 0 0 28 0 1 26 1

Factor

Taiwan vs. Vietnam

Taiwan vs. 

nonsubject7 Thailand vs. Turkey

S C I S C I S C I

Availability 5 24 0 4 33 17 1 18 6

Delivery terms 0 29 0 0 38 15 1 20 4

Delivery time 2 27 0 0 29 24 1 19 5

Discounts offered 0 29 0 0 39 14 1 22 2

Extension of credit 1 28 0 0 36 17 1 22 2

Minimum quantity requirements 1 28 0 1 39 13 1 22 2

Packaging 0 29 0 0 44 9 1 23 1

Price 0 28 1 35 14 3 6 17 2

Product consistency 2 27 0 0 20 33 1 18 6

Product range 1 28 0 0 22 31 1 17 7

Program sales 1 26 0 0 29 21 1 19 3

Proprietary connections 0 26 0 0 28 22 0 20 2

Quality exceeds industry standards 2 25 1 0 20 30 1 18 5

Quality meets industry standards 2 27 0 1 35 17 1 21 3

Reliability of supply 2 25 0 0 27 26 1 17 7

Suppliers’ U.S. inventories 3 25 0 3 26 24 0 16 8

Technical support/service 2 26 0 0 19 34 1 17 6

U.S. transportation costs 0 28 0 2 41 10 0 22 2 7 The imports from nonsubject countries that the Taiwan product was compared to were: Argentina, Austria, Belarus, Brazil, 

Canada, China, Czech Republic, Germany, Greece, Italy, Japan, Mexico, Romania, Russia, South Africa, and Spain.

Table continued on next page.

II-39
Table II-14--Continued

OCTG: Purchasers' comparisons of subject and nonsubject countries regarding 18 purchase 

factors

Factor

Thailand vs. 

Ukraine Thailand vs. Vietnam

Thailand vs. 

nonsubject8

S C I S C I S C I

Availability 1 21 3 1 23 1 3 21 18

Delivery terms 1 21 3 1 23 1 0 22 20

Delivery time 1 20 4 2 22 1 0 20 22

Discounts offered 1 22 2 1 23 1 0 25 17

Extension of credit 1 23 1 1 23 1 0 22 20

Minimum quantity requirements 1 23 0 1 23 1 1 24 17

Packaging 1 23 1 1 24 0 0 30 12

Price 5 19 1 2 23 0 28 11 3

Product consistency 1 20 4 1 23 1 0 9 33

Product range 1 20 4 1 23 1 0 15 27

Program sales 1 20 2 1 22 0 0 20 19

Proprietary connections 0 20 2 1 21 0 0 17 22

Quality exceeds industry standards 1 21 2 1 22 1 0 11 28

Quality meets industry standards 2 21 2 1 24 0 0 20 22

Reliability of supply 1 22 2 1 23 1 0 18 24

Suppliers’ U.S. inventories 0 21 3 1 22 1 3 15 24

Technical support/service 1 21 2 1 22 1 0 12 30

U.S. transportation costs 0 23 1 1 21 1 2 28 12

Factor

Turkey vs. Ukraine Turkey vs. Vietnam

Turkey vs. 

nonsubject9

S C I S C I S C I

Availability 8 22 1 8 21 0 10 38 18

Delivery terms 3 28 0 3 26 0 3 50 13

Delivery time 5 25 1 9 20 0 4 42 20

Discounts offered 4 27 0 3 26 0 3 49 14

Extension of credit 3 27 1 4 25 0 3 48 15

Minimum quantity requirements 3 26 2 4 25 0 4 49 13

Packaging 3 27 1 3 26 0 3 53 10

Price 3 23 5 1 23 5 36 25 5

Product consistency 5 26 0 6 23 0 3 30 33

Product range 6 23 2 6 23 0 4 30 32

Program sales 3 26 0 5 22 0 3 37 23

Proprietary connections 2 24 2 3 23 0 3 29 31

Quality exceeds industry standards 4 25 1 6 22 0 3 31 27

Quality meets industry standards 5 26 0 5 24 0 4 38 22

Reliability of supply 6 24 1 6 23 0 7 33 24

Suppliers’ U.S. inventories 6 22 2 6 22 0 9 34 21

Technical support/service 7 23 0 5 23 0 5 29 30

U.S. transportation costs 3 26 1 2 25 0 5 47 12 8 The imports from nonsubject countries that the Thailand product was compared to were: Argentina, Austria, Belarus, Brazil, 

Canada, China, Czech Republic, Germany, Greece, Italy, Japan, Mexico, Romania, Russia, and Spain.

9 The imports from nonsubject countries that the Turkey product was compared to were: Argentina, Austria, Belarus, Brazil, Canada, 

China, Czech Republic, Germany, Greece, Italy, Japan, Mexico, Romania, Russia, South Africa, and Spain.

Table continued on next page.

II-40
Table II-14--Continued

OCTG: Purchasers' comparisons of subject and nonsubject countries regarding 18 purchase 

factors

Factor

Ukraine vs. 

Vietnam

Ukraine vs. 

nonsubject10 Vietnam vs.nonsubject11

S C I S C I S C I

Availability 2 26 1 12 31 22 4 26 23

Delivery terms 2 26 1 2 43 20 0 33 20

Delivery time 4 24 1 6 35 24 0 28 24

Discounts offered 1 27 1 2 41 21 0 32 21

Extension of credit 1 27 1 3 41 21 0 32 21

Minimum quantity requirements 2 26 1 4 40 21 1 34 18

Packaging 1 28 0 2 48 15 0 40 12

Price 3 22 4 38 17 10 36 13 3

Product consistency 2 25 2 3 17 45 0 15 38

Product range 4 24 1 4 22 38 0 20 33

Program sales 2 25 0 2 31 29 0 23 27

Proprietary connections 3 23 0 1 26 32 0 20 30

Quality exceeds industry standards 2 25 1 1 20 41 0 15 35

Quality meets industry standards 1 27 1 1 27 37 0 28 25

Reliability of supply 3 25 1 3 30 32 0 24 29

Suppliers’ U.S. inventories 3 24 1 8 28 29 4 20 29

Technical support/service 3 24 1 0 23 41 0 18 35

U.S. transportation costs 0 27 1 2 48 15 4 40 9 10 The imports from nonsubject countries that the Ukraine product was compared to were: Argentina, Austria, Belarus, Brazil, 

Canada, China, Czech Republic, Germany, Greece, Italy, Japan, Mexico, Russia, South Africa, and Spain.

11 The imports from nonsubject countries that the Vietnam product was compared to were: Argentina, Austria, Belarus, Brazil, 

Canada, China, Czech Republic, Germany, Greece, Italy, Japan, Mexico, Romania, Russia, South Africa, and Spain.

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.

Purchasers were asked if they were willing to pay more for OCTG produced domestically 

than OCTG imported from the subject and other countries. A close majority of purchasers was 

willing to pay more for domestically produced OCTG than for OCTG from six of the subject 

countries, but not from Korea, Saudi Arabia, or Turkey. Table II-16 presents their responses per 

country, along with a range of how much more they would be willing to pay for domestically 

produced OCTG. The biggest differential was between U.S.-produced OCTG and OCTG imported 

from Ukraine.48 However, a witness for petitioners disagreed with this characterization, stating 

that, “for like products, for like quality from mills that make commensurate products, there is 

not a serious or a real measureable increase or premium for domestic product.” 49

48 Purchasers were asked to report the minimum and the maximum amount that they would be 

willing to pay for domestic OCTG. Some firms reported did not list a minimum amount or reported a 

minimum of as little as 1 percent, but listed a maximum amount. A very low or missing minimum value 

may reflect that the firm would prefer to pay as little as possible premium to purchase domestic OCTG. 

The largest maximum amount that a firm would be willing to pay was 100 percent ***. 

49 Hearing transcript, p. 194 (Miller).

II-41

 
Table II-15

OCTG: Summary of purchaser subject country comparisons in which a plurality or majority of 

purchasers report one country as superior

Factor Comparison Superior Country

Number of purchasers stating

Superior Comparable Inferior

Availability Korea vs. Philippines Korea 18 14 0

Korea vs. Saudi Arabia Korea 17 13 0

Korea vs. Ukraine Korea 17 16 1

Korea vs. Vietnam Korea 16 14 0

Delivery time Thailand vs. nonsubject Nonsubject 0 20 22

Price India vs. nonsubject India 27 27 15

Korea vs. nonsubject Korea 44 20 0

Philippines vs. nonsubject Philippines 32 14 5

Saudi Arabia vs. nonsubject Saudi Arabia 30 26 8

Taiwan vs. nonsubject Taiwan 35 14 3

Thailand vs. nonsubject Thailand 28 11 3

Turkey vs. nonsubject Turkey 36 25 5

Ukraine vs. nonsubject Ukraine 38 17 10

Vietnam vs. nonsubject Vietnam 36 13 3

Product 

consistency India vs. nonsubject Nonsubject 2 22 44

Korea vs. Thailand Korea 14 11 0

Korea vs. Ukraine Korea 18 15 1

Korea vs. Vietnam Korea 17 13 0

Philippines vs. nonsubject Nonsubject 0 16 35

Taiwan vs. nonsubject Nonsubject 0 20 33

Thailand vs. nonsubject Nonsubject 0 9 33

Turkey vs. nonsubject Nonsubject 3 30 33

Ukraine vs. nonsubject Nonsubject 3 17 45

Vietnam vs. nonsubject Nonsubject 0 15 38

Product range Korea vs. Philippines Korea 16 16 0

Korea vs. Taiwan Korea 16 16 0

Korea vs. Vietnam Korea 17 13 0

Philippines vs. nonsubject Nonsubject 2 19 30

Taiwan vs. nonsubject Nonsubject 0 22 31

Thailand vs. nonsubject Nonsubject 0 15 27

Turkey vs. nonsubject Nonsubject 4 30 32

Ukraine vs. nonsubject Nonsubject 4 22 38

Vietnam vs. nonsubject Nonsubject 0 20 33

Program sales Korea vs. Vietnam Korea 16 13 0

Philippines vs. nonsubject Nonsubject 0 25 25

Vietnam vs. nonsubject Nonsubject 0 23 27

Proprietary 

connections

Philippines vs. nonsubject Nonsubject 0 20 27

Turkey vs. nonsubject Nonsubject 3 29 31

Ukraine vs. nonsubject Nonsubject 1 26 32

Vietnam vs. nonsubject Nonsubject 0 20 30

Table continued on next page.

II-42
Table II-15--Continued

OCTG: Summary of purchaser subject country comparisons in which a plurality or majority of 

purchasers report one country as superior

Factor Comparison

Superior 

Country

Number of purchasers stating

Superior Comparable Inferior

Quality exceeds 

industry standards

India vs. nonsubject Nonsubject 0 25 41

Philippines vs. nonsubject Nonsubject 0 14 34

Taiwan vs. nonsubject Nonsubject 0 20 30

Korea vs. Vietnam Korea 15 14 0

Thailand vs. nonsubject Nonsubject 0 11 28

Ukraine vs. nonsubject Nonsubject 1 20 41

Vietnam vs. nonsubject Nonsubject 0 15 35

Quality meets industry 

standards 

Thailand vs. nonsubject Nonsubject 0 20 22

Ukraine vs. nonsubject Nonsubject 1 27 37

Reliability of supply India vs. nonsubject Nonsubject 3 33 34

Korea vs. Philippines Korea 16 16 0

Korea vs. Ukraine Korea 19 15 0

Korea vs. Vietnam Korea 17 13 0

Philippines vs. nonsubject Nonsubject 1 21 30

Thailand vs. nonsubject Nonsubject 0 18 24

Ukraine vs. nonsubject Nonsubject 3 30 32

Vietnam vs. nonsubject Nonsubject 0 24 29

Suppliers’ U.S. 

inventories

Korea vs. Philippines Korea 16 14 1

Korea vs. Thailand Korea 12 11 1

Korea vs. Vietnam Korea 15 13 1

Philippines vs. nonsubject Nonsubject 3 23 25

Thailand vs. nonsubject Nonsubject 3 15 24

Ukraine vs. nonsubject Nonsubject 8 28 29

Vietnam vs. nonsubject Nonsubject 4 20 29

Technical 

support/service India vs. nonsubject Nonsubject 1 27 41

Philippines vs. nonsubject Nonsubject 0 17 34

Taiwan vs. nonsubject Nonsubject 0 19 34

Thailand vs. nonsubject Nonsubject 0 12 30

Turkey vs. nonsubject Nonsubject 5 29 30

Ukraine vs. nonsubject Nonsubject 0 23 41

Vietnam vs. nonsubject Nonsubject 0 18 35

Source: Compiled from data submitted in response to Commission questionnaires.

II-43
Table II-16

OCTG: Purchasers’ willingness to pay for domestically produced OCTG compared with subject

and nonsubject countries

Country

Purchasers not 

willing to pay more

Purchasers willing to 

pay more

How much more purchasers 

willing to pay (percent)

1

India 22 26 6 to 15

Korea 30 19 6 to 16

Philippines 22 25 7 to 15

Saudi Arabia 25 23 5 to 14

Taiwan 22 24 7 to 15

Thailand 20 25 7 to 15

Turkey 25 23 5 to 14

Ukraine 21 27 11 to 19

Vietnam 21 26 7 to 15

Other countries 21 12 3 to 6

 1 This column reflects a simple average of purchasers’ responses to the minimum and the maximum amount 

that purchasers would be willing to pay for domestic OCTG compared with OCTG from the listed country, 

based on responses from purchasers reporting that they would be willing to pay more.

Note.--The category with the majority of purchasers is listed in bold.

Source: Compiled from data submitted in response to Commission questionnaires.

The majority of responding purchasers or their customers (34 of 52) specifically orders 

OCTG from one country, or one firm or mill, in particular, over other possible sources of supply. 

Nineteen purchasers reported a preference for domestic OCTG. Among foreign sources, 11 

reported ordering OCTG specifically from Korea, 6 from Japan, 4 from Mexico, 3 each from 

Argentina, Canada, and Germany, 2 each from Austria, Taiwan, and Turkey, and 1 each from 

Brazil, India, Saudi Arabia, Spain, Vietnam, and “Western Europe.”

Differences other than price

Producers, importers, and purchasers were asked to assess how often differences other 

than price were significant in sales of OCTG from the United States, subject, and nonsubject 

countries. As seen in table II-17, all producers reported that there were either “sometimes” or 

“never” differences other than price for product from each of the country pairs. Importers’ 

responses were considerably more varied. Few importers reported that there were “always” 

differences other than price between two countries; rather, responses were split among 

“frequently,” “sometimes,” and “never” depending on the comparison, with purchasers most 

commonly reporting “sometimes.” Purchasers more frequently noted that there were “always” 

differences than “never” differences for each of the subject sources compared with the United 

States.

II-44
Table II-17

OCTG: Significance of differences other than price between OCTG produced in the United States, 

subject and nonsubject countries, by country pair

Country pair

Number of U.S. 

producers reporting

Number of U.S.

importers reporting

Number of U.S. 

purchasers reporting

A F S N A F S N A F S N

U.S. vs. subject countries:

U.S. vs. India 0 0 3 9 3 7 8 5 12 13 12 4

U.S. vs. Korea 0 0 3 9 4 7 11 6 10 9 20 6

U.S. vs. Philippines 0 0 3 9 2 6 8 6 9 9 10 3

U.S. vs. Saudi Arabia 0 0 3 9 1 8 7 5 9 8 12 5

U.S. vs. Taiwan 0 0 3 9 2 7 8 6 9 9 11 3

U.S. vs. Thailand 0 0 3 9 1 5 8 6 8 8 7 2

U.S. vs. Turkey 0 0 3 9 1 8 8 5 11 9 14 4

U.S. vs. Ukraine 0 0 3 9 1 8 7 5 12 10 10 3

U.S. vs. Vietnam 0 0 3 9 2 6 8 6 8 9 10 2

Subject vs. subject countries:

India vs. Korea 0 0 2 8 1 5 5 6 6 11 13 6

India vs. Philippines 0 0 2 8 0 5 5 6 6 3 12 7

 India vs. Saudi Arabia 0 0 2 8 1 5 3 5 4 6 11 9

India vs. Taiwan 0 0 2 8 0 5 4 6 5 2 14 7

India vs. Thailand 0 0 2 8 0 5 4 5 5 2 9 6

India vs. Turkey 0 0 2 8 1 4 5 7 5 4 12 8

India vs. Ukraine 0 0 2 8 0 5 3 7 5 4 14 8

India vs. Vietnam 0 0 2 8 1 3 4 6 5 1 13 6

Korea vs. Philippines 0 0 2 8 3 4 6 7 6 8 12 4

Korea vs. Saudi Arabia 0 0 2 8 3 4 5 5 4 8 13 6

Korea vs. Taiwan 0 0 2 8 3 4 6 7 5 6 14 5

Korea vs. Thailand 0 0 2 8 3 4 6 5 5 6 8 3

Korea vs. Turkey 0 0 2 8 2 4 7 6 6 7 14 7

Korea vs. Ukraine 0 0 2 8 3 5 6 5 6 8 12 5

Korea vs. Vietnam 0 0 2 8 3 3 6 7 5 5 14 3

Philippines vs. Saudi Arabia 0 0 2 8 0 4 3 6 4 4 6 7

Philippines vs. Taiwan 0 0 2 8 0 4 3 9 4 4 8 7

Philippines vs. Thailand 0 0 2 8 1 3 3 7 4 3 7 6

Philippines vs. Turkey 0 0 2 8 1 5 4 7 5 4 9 7

Philippines vs. Ukraine 0 0 2 8 0 6 4 5 5 4 7 7

Philippines vs. Vietnam 0 0 2 8 1 3 3 8 5 1 9 6

Table continued on next page.

II-45
Table II-17--Continued

OCTG: Significance of differences other than price between OCTG produced in the United States, 

subject and nonsubject countries, by country pair

Country pair

Number of U.S. 

producers reporting

Number of U.S. 

importers reporting

Number of U.S. 

purchasers reporting

A F S N A F S N A F S N

Subject vs. subject countries:

Saudi Arabia vs. Taiwan 0 0 2 8 0 4 4 5 4 5 10 6

Saudi Arabia vs. Thailand 0 0 2 8 0 4 5 5 4 5 7 5

Saudi Arabia vs. Turkey 0 0 2 8 1 4 5 5 4 4 13 7

Saudi Arabia vs. Ukraine 0 0 2 8 0 7 2 6 5 6 9 7

Saudi Arabia vs. Vietnam 0 0 2 8 1 4 3 5 5 2 10 5

Taiwan vs. Thailand 0 0 2 8 0 5 3 6 4 4 6 8

Taiwan vs. Turkey 0 0 2 8 1 5 4 8 4 4 12 7

Taiwan vs. Ukraine 0 0 2 8 0 6 4 5 5 4 10 8

Taiwan vs. Vietnam 0 0 2 8 1 3 4 8 5 1 12 7

Thailand vs. Turkey 0 0 2 8 1 5 3 6 4 4 7 6

Thailand vs. Ukraine 0 0 2 8 0 6 3 5 5 4 5 7

Thailand vs. Vietnam 0 0 2 8 1 3 2 6 5 1 7 6

Turkey vs. Ukraine 0 0 2 8 1 6 4 6 5 3 14 7

Turkey vs. Vietnam 0 0 2 8 2 4 3 7 5 2 12 6

Ukraine vs. Vietnam 0 0 2 8 1 4 4 5 5 2 12 7

Comparisons with nonsubject 

countries:

U.S. vs. nonsubject 0 0 3 8 1 7 9 5 8 7 13 6

India vs. nonsubject 0 0 3 7 0 6 5 4 7 5 8 6

Korea vs. nonsubject 0 0 3 7 3 4 7 5 5 3 15 5

Philippines vs. nonsubject 0 0 3 7 0 4 6 5 6 2 5 6

Saudi Arabia vs. nonsubject 0 0 3 7 0 7 5 4 5 2 11 6

Taiwan vs. nonsubject 0 0 3 7 0 5 5 5 5 4 7 6

Thailand vs. nonsubject 0 0 3 7 0 5 5 4 5 3 3 5

Turkey vs. nonsubject 0 0 3 7 1 4 7 3 6 2 11 7

Ukraine vs. nonsubject 0 0 3 7 0 6 5 4 6 3 7 7

Vietnam vs. nonsubject 0 0 3 7 0 5 6 5 5 3 7 6

Note.—A=Always, F=Frequently, S=Sometimes, N=Never.

Source: Compiled from data submitted in response to Commission questionnaires.

II-46
ELASTICITY ESTIMATES

This section discusses elasticity estimates for the OCTG market in the United States.

U.S. supply elasticity

The domestic supply elasticity for OCTG measures the sensitivity of the quantity 

supplied by U.S. producers to changes in the U.S. market price of OCTG. The elasticity of 

domestic supply depends on several factors including the level of excess capacity, the ease with 

which producers can alter capacity, producers’ ability to shift to production of other products, 

the low level of inventories, and a lack of many alternate markets for U.S.-produced OCTG. 

Earlier analysis of these factors indicates that the U.S. industry has a moderate ability to 

increase or decrease shipments to the U.S. market; an estimate in the range of 2 to 4 is 

suggested.

U.S. demand elasticity

The U.S. demand elasticity for OCTG measures the sensitivity of the overall quantity 

demanded to a change in the U.S. market price of OCTG. This estimate depends on factors 

discussed earlier such as the existence, availability, and commercial viability of substitute 

products, the level of inventories held, and the component share of OCTG in the production oil 

and gas exploration and production. Based on the available information, the aggregate demand 

for OCTG is likely to be moderately inelastic and in a range of -0.75 to -1.0. Purchasers would 

not likely be very sensitive to changes in the price of OCTG and would continue to demand 

fairly constant quantities over a considerable range of prices.

Substitution elasticity

The elasticity of substitution depends upon the extent of product differentiation 

between the domestic and imported products. Product differentiation, in turn, depends upon 

such factors as quality and conditions of sale. Based on available information, the elasticity of 

substitution between domestic and subject imports is likely to be moderate to high and in the 

range of 3 to 5.

II-47

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 subsidies and dumping margins was 

presented in Part I of this report and information on the volume and pricing of imports of the 

subject merchandise is presented in Part IV and Part V. 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 17 firms (including eleven established mills, one firm that was 

historically a processor but has begun mill operations, and five independent/stand-alone 

processors) that accounted for the vast majority of U.S. production of OCTG during 2013.

U.S. PRODUCERS

The Commission issued a U.S. producer questionnaire to 13 firms based on information 

contained in the petition, and to 22 U.S. firms that maintain certification to manufacture or 

process products in accordance with API specification 5CT. Seventeen firms provided useable 

data on their productive operations.1 Staff believes that these responses represent the vast 

majority of U.S. production of OCTG.

Table III-1 lists U.S. producers of OCTG, their production locations, type of operations at 

production locations, positions on the petition, total production, and shares of mill production

and shares of independent processing (toll and non-toll). 

1 Six firms responded that they did not produce OCTG. *** did not provide usable data. ***.

III-1

 
Table III-1

OCTG: U.S. producers, their positions on the petition, production locations, types of operations,

and shares of reported production and processing, January 2011 through March 2014

Firm Position on petition

Production location(s) and type of 

operation(s)1

Share of mill 

production 

(percent)

Share of 

processing

(percent)

Boomerang 

Tube2 Petitioner Liberty, TX (pipe forming, heat treatment, and T&C)

*** N/A

Drill Pipe 

International3 *** New Hope, MN (heat treatment and T&C) N/A ***

EnergeX Tube5 Petitioner Thomasville, AL (heat treatment and T&C)

Warren, OH (T&C)

Blytheville, AR (pipe forming)

Sharon, PA (pipe forming)

*** ***

Evraz Rocky 

Mountain6 *** Pueblo, CO (pipe forming and heat treatment) *** N/A

Laguna Tubular 

Products7 *** Houston, TX (heat treatment) N/A ***

Maverick8 Petitioner

(No Position on 

Saudi Arabia)

Hickman, AR (pipe forming, heat treatment, 

and T&C)

Conroe, TX (pipe forming, heat treatment, and 

T&C)

Texas Arai, TX (T&C)

Houston, TX (T&C)

Westwego, LA (T&C)

Bakersfield, CA (T&C)

*** N/A

Northwest Pipe Petitioner Bossier City, LA (pipe forming)

Houston, TX (pipe forming)

*** N/A

Paragon 

Industries

*** Sapulpa, OK (pipe forming and T&C)

Muskogee, OK (upstream steel slitting)

*** N/A

RDT9 *** Beasley, TX (heat treatment) N/A ***

Tejas Tubular Petitioner Houston, TX (2 establishments: 2 heat 

treatment, 2 T&C)

Stephenville, TX (pipe forming, heat treatment, 

and T&C)

New Carlisle, IN (heat treatment and T&C)

*** ***

Texas Steel 

Conversion10 *** Houston, TX (3 establishments: 3 heat treatment, 1 T&C)

Bryan, TX (heat treatment and T&C)

N/A ***

Texas Tubular11 Support Lone Star, TX (pipe forming) *** N/A

TMK IPSCO12 Petitioner Blytheville, AR (pipe forming, heat treatment, 

and T&C)

Camanche, IA (pipe forming and T&C)

Wilder, KY (pipe forming and T&C)

Ambridge, PA (pipe forming and heat 

treatment)

Koppel, PA (heat treatment)

Baytown, TX (heat treatment and T&C)

Catoosa, OK (heat treatment and T&C)

*** N/A

Tubular 

Services13 *** Houston, TX (heat treatment and T&C)Channelview, TX (heat treatment and T&C)

N/A ***

Table continued on next page.

III-2
Table III-1--Continued

OCTG: U.S. producers, their positions on the petition, production locations, types of operations, 

and shares of reported production and processing, January 2011 through March 2014

Firm Position on petition

Production location(s) and type of 

operation(s)1

Share of mill 

production 

(percent)

Share of 

processing

(percent)

U.S. Steel14 Petitioner Fairfield, AL (pipe forming, heat treatment, and 

T&C)

Lorain, OH (pipe forming, heat treatment, and 

T&C)

Lone Star, TX (pipe forming, heat treatment, 

and T&C)

Bellville, TX (pipe forming and T&C)

Houston, TX (heat treatment and T&C)

*** N/A

Vallourec15 Petitioner

(No Position on 

Saudi Arabia)

Youngstown, OH (pipe forming, heat 

treatment, and T&C)

Houston, TX (heat treatment and T&C)

Muskogee, OK (heat treatment and T&C)

*** N/A

Welded Tube 

USA16 Petitioner Lackawanna, NY (pipe forming) *** N/A

Total 100.0 100.0

1 T&C is threading and coupling.

Footnotes 2 through 16 have been redacted.

Source: Compiled from data submitted in response to Commission questionnaires.

As indicated in table III-1, one U.S. producer, Vallourec, is related to a foreign producer 

of the subject merchandise. One U.S. producer imports OCTG, and five U.S. producers are 

related to importers of OCTG – none of which, however, import from subject sources. U.S. 

producers’ imports and U.S. producers’ related importers’ import data are presented later in 

this chapter in table III-9.

U.S. PRODUCTION, CAPACITY, AND CAPACITY UTILIZATION

Overall pipe forming and heat treatment production, capacity, and capacity utilization

U.S. mills and independent/stand-alone processors made a number of investments in 

their operations which have increased capacity. Several firms invested in new pipe forming 

mills, heat treatment operations, and other finishing operations. Several firms also made 

investments to improve existing operations. Table III-2a lists industry events, including 

investments in equipment, machinery, and capacity reported in the trade press along with 

information provided in questionnaire responses. Table III-2b lists additional industry events, 

including information regarding announced investments that have not yet resulted in actual 

OCTG operations as of March 31, 2014.

III-3
Table III-2a

OCTG: Industry events, January 2011 – March 2014

Year Company Description of event

2011 Boomerang Capacity increase: Boomerang Tube begins commercial production of 

OCTG at its new 400,000 tpy welded tubular products mill in Liberty, TX ($***

investment. The mill also produces limited quantities of welded line pipe.

EnergeX Capacity increase, pipe forming: ***.

Laguna New finishing facility, capacity increase in heat treatment: ***.

Maverick Capacity increase, pipe forming and heat treatment: ***. ***. ***.

Northwest Pipe 

Co.

Capacity increase: Northwest Pipe ramps up production of OCTG and line 

pipe at its 150,000 tpy rolling mill located in Bossier City, LA.

***.

OMK Acquisition: OMK acquires Tubular Solutions, a processing and finishing 

facility.

Tejas Tubular Capacity increase, pipe forming: Tejas Tubular commissions a new 

welded OCTG rolling mill in Stephenville, TX.

Texas Steel 

Conversion

New finishing facility, capacity increase in heat treatment and 

threading: ***.

TMK IPSCO 

(Houston, TX)

Capacity increase, pipe forming, heat treatment, threading and 

coupling: ***.

Capacity increase: ***.

Capacity increase, threading: TMK IPSCO announces plans to build an 

OCTG threading facility at its 570,000 tpy welded rolling mill in Wilder, KY. 

The facility produces OCTG, line pipe, and standard pipe.

TMK IPSCO Idling: ***.

Tubular Services New finishing facility, capacity increase in heat treatment: ***.

U.S. Steel Capacity increase, heat treatment: U.S. Steel completes the construction 

of an additional quench and temper line, as well as threading and coupling 

stations, at its Lorain, OH, rolling mill. The $*** investment added *** short 

tons of new heat treating capacity to the facility.

Capacity increase, heat treatment and threading: ***.

***.

2012 Boomerang Capacity increase, heat treatment: ***

New finishing facility: ***.

Other investment: ***.

Evraz Other: ***.

JMC Steel Group 

(parent company 

of EnergeX)

Acquisition/merger: JMC Steel Group acquires and merges Canadian 

OCTG producer Lakeside Steel (Welland, Ontario, Canada) with its own 

tubular assets to form a new division called EnergeX Tube. Lakeside’s U.S.-

based facilities are located in Thomasville, AL, and Corpus Christi, TX. 

EnergeX casing and tubing is produced in Thomasville, AL; Warren, OH; and 

Welland, Ontario, Canada.

Shutdown: JMC Steel Group ***.

Paragon Capacity increase, pipe forming: ***.

Maverick ***

Northwest Idling/shut down: ***.

RDT Capacity increase, heat treatment: Built heat treatment operation in 2012-

13 for ***.

Tejas Tubular Capacity increase: Tejas Tubular ***. 

TMK IPSCO Capacity increase: ***.

Capacity increase pipe forming and heat treatment: ***.

TMK IPSCO Consolidation: TMK IPSCO ***.

Idling: ***. *** ***.

U.S. Steel Joint venture: U.S. Steel and Buth Gilliam Enterprises form a new joint 

venture, Patriot Premium Threading Services (Midland, TX) to provide OCTG 

threading and repair services.

Vallourec New mill, new finishing facility, increase in pipe forming, heat treatment, 

threading/coupling: ***.

Table continued on next page.

III-4
Table III-2a--Continued

OCTG: Industry events, January 2011 – March 2014

Year Company Description of event

2013 Boomerang Capacity increase, threading/coupling: ***.

EnergeX Replace/upgrade: ***

Shutdown: Thomasville, AL South (casing production facility) shutdown in 

January 2013.

Northwest Upgrade: ***.

Idling/shut down: ***. ***.

OMK Capacity increase: United Metallurgical Company (OMK) commissions a 

200,000 tpy welded OCTG mill in Houston, TX ($100 million investment). The 

rolling mill will produce OCTG in outside diameters ranging from 2.75–7 

inches, and will source hot-rolled coil feedstock primarily from local 

producers.

Texas Steel 

Conversion

Capacity increase: Texas Steel Conversion ***.

Other: ***.

TMK IPSCO Other: ***.

Pipe formation: ***.

Tubular Services Capacity increase, heat treatment and threading and coupling: ***.

U.S. Steel Acquisition: ***.

Vallourec End finishing: ***.

Capacity increase: Vallourec starts commercial production of seamless 

OCTG at its new 500,000 tpy seamless rolling mill in Youngstown, OH. Heat 

treatment and finishing operations begin in 2013.

Welded Tube 

USA 

Capacity increase: Welded Tube USA, a subsidiary of Canada-based pipe 

and tube producer Welded Tube of Canada, begins construction of a *** tpy 

welded OCTG rolling mill in Lackawanna, NY ($50 million investment). 

Production of OCTG begins in September 2013.

2014 Centric Pipe

(affiliate of 

importer SB 

International)

Acquisition: In March, Centric Pipe, LLC, an affiliate of steel trading 

company, distributor, and importer SB International, acquires substantially all 

of Northwest Pipe’s OCTG assets for $42.7 million, including Northwest 

Pipe’s casing mill in Bossier City, LA and its tubing mill in Houston, TX. The 

two mills have a reportedly combined capacity of 200,000 tpy.

DPI Finishing, threading and coupling: $45,000 for equipment and machinery.

EnergeX Tube Heat treatment, capacity increase: ***.

Northwest Other: ***. ***.

Sale: As noted above, in March, Northwest sells its OCTG assets to Centric 

pipe.

Texas Steel 

Conversion

***

Texas Tubular New finishing facility, threading: ***.

U.S. Steel Capacity increase, pipe forming: ***. 

Source: Metal Bulletin, various issues; responses to the Commission questionnaire.

III-5
Table III-2b

OCTG: Ongoing industry events

Year Company Description of event

2011 Tianjin Pipe Corp. 

(China)

Announcement: Tianjin Pipe Group Corp (TPCO) breaks ground on a 500,000 tpy 

seamless OCTG mill in Gregory, TX ($1 billion investment). Finishing and threading 

operations were expected to be completed by 2013, followed by the construction of 

a rolling mill and electric arc furnace (EAF) steel-making facility. This project is 

ongoing

2012 Benteler 

Steel/Tube 

(Germany)

Announcement: Benteler Steel/Tube announces plans to build a 320,000 tpy 

seamless OCTG facility, including a hot-rolling mill and finishing lines, in Caddo, LA 

($975 million investment). A second phase of the mill will include the completion of 

an EAF mill. Groundbreaking at the facility commences in 2013, with completion of 

the seamless OCTG facility slated for 2015.

2013 Benteler 

Steel/Tube 

(Germany)

Capacity increase: Benteler Steel breaks ground on its 320,000 tpy seamless 

OCTG facility in Caddo, LA. The seamless hot-rolling mill is expected to become 

operational by 2015; a planned EAF to produce steel is due to be opened in 2020.

Big River Steel Announcement: Big River Steel announces a proposed $1.1 billion project to 

produce OCTG, coiled products, and electrical steels in Osceola, AK. The proposed 

mill would have an annual capacity of 1.7 million short tons for all products.

Borusan and 

Mannesmann 

(Turkey)

Capacity increase: Borusan and Mannesmann breaks ground on a 300,000 tpy 

welded OCTG mill in Baytown, TX ($150 million investment). The mill, which will 

employ 250 workers, is expected to begin production of OCTG in 2015.

Prolamsa/Axis Pipe 

and Tube

Capacity increase: Announces plan to build $120 million pipe and tubular facility in 

Bryan, TX with a capacity of 300,000+ short tons of ERW energy tubular products.

PTC Seamless 

Tube Corp.

Capacity increase: Announces plan to invest $102 million to retrofit a former 

production facility in Hopkinsville, KY to produce seamless tubes for the energy 

industry, including OCTG.

Tejas Tubular Capacity increase, heat treatment: Tejas Tubular announces plans to build a 

72,000 tpy OCTG heat treatment facility in New Carlisle, IN. The facility will provide 

heat treatment for well casing in 4.5–9.625 inch OD. Investment is for ***. ***

Tenaris Capacity increase: Tenaris announces its intention to build a new seamless 

OCTG mill in Bay City, TX, expected to be completed by mid-2016. The plant will 

have an OCTG capacity of 600,000 tpy with heat treatment and premium threading 

facilities, but no melting capacity. Groundbreaking began in September, with 

completion scheduled for mid-2016. 

Tianjin Pipe Corp. 

(China)

Announcement: TPCO begins partial commissioning of heat treatment operations 

at its 500,000 tpy seamless OCTG mill in Gregory, TX.

2014 Alamo Tube Announcement: Alamo Tube is planning to invest $62.5 million to build a 250,000 

tpy ERW mill near San Antonio, TX. The plant is expected to employ more than 200 

workers and will produce tubing currently being used in 80 percent of the new well 

completions.

Borusan and 

Mannesmann 

(Turkey)

Capacity increase: Borusan and Mannesmann begins commissioning of its coldrolling mill and threading operations at its 300,000 tpy welded OCTG mill in 

Baytown, TX. The mill will produce OCTG in 4.5–10.75 inches OD and process 

plain-end casing imported from its plant in Turkey.

Centric Pipe

(affiliate of importer 

SB International)

Shutdown: Houston, TX welded tubing mill shut down in March ***.

Tejas Tubular Announcement: Tejas is planning to build a *** 150,000 tpy seamless casing, drill 

pipe, and line pipe facility in Norfolk, NE. The facility is expected to create 200 jobs. 

***. ***. ***.

TMK IPSCO Production idling: In April, TMK IPSCO idles its 8-inch welded OCTG mill in 

Wilder, KY and reduces OCTG production at its Blytheville, AK and Camanche, IA 

facilities.

U.S. Steel Idling: U.S. Steel announces in June that in early August it will idle tubular 

manufacturing facilities in McKeesport, PA and Bellville, TX (identified in table III-1 

as an ERW facility producing OCTG), impacting approximately 260 employees.

Source: American Metal Markets, thefabricator.com, Metal Bulletin, various issues; company websites, and responses 

to the Commission questionnaire.

III-6
Table III-3 presents U.S. mills’ production, capacity, and capacity utilization of welded 

and seamless tubular products, as well as overall heat treatment capacity,2 production, and 

capacity utilization. 

U.S. producers added 948,733 short tons of shared capacity between 2011 and 2013, 

with additional shared capacity in the first quarter of 2014. As discussed in table III-2a, much of 

the new shared capacity was for the production of welded OCTG. However, as discussed in 

table III-2b, the largest portion of anticipated new shared capacity is for seamless OCTG 

production, while anticipated new shared capacity for welded OCTG production is smaller and 

balanced against recent reductions in the form of closures or idling of facilities.

Table III-3

OCTG: U.S. producers’ production, capacity, and capacity utilization of welded and seamless 

tubular products and heat treatment, 2011-13, January to March 2013, and January to March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

Capacity to produce,--

 Welded tubular products 3,935,834 4,499,145 4,652,567 1,159,220 1,213,870

Seamless tubular products 2,631,085 2,631,085 2,863,085 687,771 696,625

Overall tubular product production 

capacity 6,566,919 7,130,230 7,515,652 1,846,991 1,910,495

Production.--

 Welded tubular products.--

 OCTG oil/gas well casing and tubing 1,847,690 2,001,581 2,395,225 568,421 642,093

Other welded tubular products 609,210 727,531 689,309 161,936 114,650

All welded products 2,456,900 2,729,112 3,084,534 730,357 756,743

Seamless tubular products.--

 OCTG oil/gas well casing and tubing 1,427,326 1,545,268 1,664,280 421,243 407,397

OCTG coupling stock 53,987 40,763 47,928 5,804 15,188

subtotal, seamless OCTG 1,481,313 1,586,031 1,712,208 427,047 422,585

Other seamless tubular products 422,425 395,760 372,433 94,860 107,488

All seamless products 1,903,738 1,981,791 2,084,641 521,907 530,073

Total welded and seamless 

production 4,360,638 4,710,903 5,169,175 1,252,264 1,286,816

of which OCTG 3,329,003 3,587,612 4,107,433 995,468 1,064,678

of which other products 1,031,635 1,123,291 1,061,742 256,796 222,138

Ratio (percent)

Overall capacity utilization.--

 on welded OCTG forming machinery 62.4 60.7 66.3 63.0 62.3

on seamless OCTG forming machinery 72.4 75.3 72.8 75.9 76.1

on all OCTG forming machinery 66.4 66.1 68.8 67.8 67.4

Table continued on next page.

2 Heat treatment data presented in III-3 include not only independent processors’ data but also data 

for mills with heat treatment operations.

III-7

 
Table III-3--Continued

OCTG: U.S. producers’ production, capacity, and capacity utilization of welded and seamless 

tubular products and heat treatment, 2011-13, January to March 2013, and January to March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

Overall heat treatment capacity 3,794,093 4,248,207 4,807,429 1,166,833 1,293,116

Heat treatment of.--

 OCTG 2,424,089 2,903,052 3,495,949 806,575 881,447

Other tubular products 66,010 71,306 66,366 18,898 24,136

Overall heat treatment 2,490,099 2,974,358 3,562,315 825,473 905,583

Ratio (percent)

Overall capacity utilization (heat treatment) 65.6 70.0 74.1 70.7 70.0

 

Source: Compiled from data submitted in response to Commission questionnaires.

Heat treatment capacity is almost entirely used to heat treat OCTG. Other products 

produced on the same equipment and machinery used to produce OCTG, such as line pipe, do 

not undergo heat treatment. Heat treatment of OCTG increased from 2011 to 2013 by 44.2 

percent and was 9.3 percent higher in January-March 2014 than in January-March 2013. Of the 

3.5 million short tons of heat treated OCTG in 2013, 78 percent was heat treated by mills with 

their own heat treatment operations and the remaining 22 percent (783,266 short tons) was

processed by independent processors, including toll processors.

3

OCTG production, capacity, and capacity utilization

Table III-4 presents U.S. producers’ OCTG production, capacity, and capacity utilization. 

Data are presented separately for U.S. mills4 and U.S. processors.

5 U.S. mills’ capacity increased 

by 17.9 percent from 2011 to 2013; the majority of the increase occurred from 2012 to 2013.6

Nonetheless, apparent U.S. consumption exceeded mill capacity by approximately one-fifth. 

3 Processors include DPI, RDT, Tejas, Texas Steel Conversion, Tubular Services, and Laguna Tubular. 

***. ***. 4 Based on API’s definition, the Commission defined pipe forming by mills as the manufacture of 

casing, tubing, or coupling stock either by the seamless process or by the electric-resistance-welding 

process (“ERW”). Instruction Booklet, p. 9. 5 Based on API’s definition, the Commission defined processors as firms that operate facilities 

capable of heat-treating pipe made by a pipe mill but do not perform the pipe forming manufacturing 

process. Instruction Booklet, p. 9.

6 Reported constraints on mill production include: ***. ***. ***. ***. ***. ***. ***. ***. ***. ***. 

***. ***.

Reported constraints on heat treatment include: ***. ***. ***. ***. ***. ***. ***. ***. ***. ***.

III-8

 
No mill reported decreased capacity from 2011 to 2013. ***. EnergeX reported the ***

Vallourec ***, Maverick ***, and U.S. Steel ***. Of the *** firms that reported higher capacity 

in January-March 2014 compared to January-March 2013, ***. ***. 

Table III-4 

OCTG: U.S. producers' capacity, production, and capacity utilization, 2011-13, January to March 

2013, and January to March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

U.S. mills':1

 Capacity 4,925,253 5,181,573 5,804,450 1,374,216 1,478,139

Production 3,329,004 3,587,613 4,107,433 995,468 1,064,678

Ratio (percent)

Capacity utilization 67.6 69.2 70.8 72.4 72.0

Quantity (short tons)

U.S. stand-alone processors':

 Capacity 674,376 996,876 1,093,280 257,642 320,084

Production 512,674 693,525 783,266 175,046 235,359

Ratio (percent)

Capacity utilization 76.0 69.6 71.6 67.9 73.5

Quantity (short tons)

U.S. non-toll processors':1

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

Production (non-toll) *** *** *** *** ***

Ratio (percent)

Capacity utilization *** *** *** *** ***

Quantity (short tons)

U.S. toll processors':1

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

Production (toll) *** *** *** *** ***

Ratio (percent)

Capacity utilization *** *** *** *** *** 1 U.S. mills' data relate to the production (pipe forming) of OCTG inclusive of any in house heat treatment, while U.S. 

stand-alone processors' data relate to their heat treating operations not involved in tolling operations and U.S. toll 

processors' data relate (primarily but not exclusively) to heat treatment operations under toll contract. 

Source: Compiled from data submitted in response to Commission questionnaires.

U.S. mills’ production of OCTG increased from 2011 to 2013 by 23.4 percent and was 7.0

percent higher in January-March 2014 than in January-March 2013. Of the 12 responding mills, 

10 experienced increased production from 2011 to 2013.7Boomerang, Maverick, TMK IPSCO, 

and Vallourec *** during this period, ***. Seven mills reported higher production in JanuaryMarch 2014 compared to January-March 2013, three mills reported lower production (one 

mill, ***). 

7 Combined production by *** was *** short tons lower in 2013 than in 2011.

III-9 
U.S. mills’ production slightly outpaced their capacity expansions, resulting in higher

capacity utilization, rising from 67.6 percent in 2011 to 70.8 percent in 2013. Capacity 

utilization rates were 72.0 percent in January-March 2014 compared to 72.4 percent in JanuaryMarch 2013. 

U.S. processors’ heat treatment capacity passed 1 million short tons 2013, and was 24.2 

percent higher in January-March 2014 than in January-March 2013.8 These increases reflect 

increased capacity reported by ***9 in 2012, while the increase in capacity from 2012 to 2013 

reflects ***. 

U.S. processors heat treated 783,266 short tons of OCTG in 2013, and 34.5 percent more

in January-March 2014 than in January-March 2013. Toll processors’ share of independently 

heat treated OCTG increased reached *** percent in 2013, and was *** percent in JanuaryMarch 2014 compared to *** percent in January-March 2013. Toll processors predominantly 

processed OCTG for the accounts of importers, which accounted for *** percent of their 

shipments during January 2011-March 2014. 

Processors’ inclusion in the industry

In the Commission’s questionnaire, firms with operations that include heat treatment 

but not pipe forming were asked to describe the source and extent of their capital and 

investment, the quantity and type of parts sourced in the United States, the value-added 

operations performed in the United States, and technical expertise involved in U.S. production 

activity. Four firms provided responses.

Four firms (***) reported private capital and credit lines as the source of their capital to 

help finance working capital, expansion projects, and investment in land and equipment. Five

firms10 combined for $*** in investments in processing equipment and machinery. ***11 ***,

12

***, 13 ***.

14 ***.15 16

8 Any changes in processors’ data using 2011 as a base period are slightly overstated due to ***. The 

inclusion of ***. ***. 9 ***. 10 ***. 11 *** U.S. producers’ questionnaire response, II-3. 12 *** U.S. producers’ questionnaire response, II-3.

13 *** U.S. producers’ questionnaire response, II-3. 14 *** U.S. producers’ questionnaire response, II-3. 15 *** U.S. producers’ questionnaire response, II-3.

16 As discussed previously in tables III-2a and III-2b, several mills have invested in heat treatment 

capabilities. For example, ***. Two mills that came online since 2011 include pipe forming and heat 

treatment operations, namely, Vallourec’s $1 billion seamless OCTG plant and Borusan’s $150 million 

welded OCTG plant. Not all mills’ operations include heat treatment, however. For example, neither ***

nor Alamo’s planned $62.5 million welded pipe mill include heat treatment operations.

III-10
In regard to quantity and type of parts sourced in the United States, one firm (***) 

reported that it sourced heat treatment and temper furnaces, and a straightener in the United 

States, while another firm (***) reported sourcing green tube from ***. 

Four firms described their value-added operations performed in the United States. All 

four firms (***) reported performing heat treatment on casing or tubing, or both. *** reporting 

performing inspecting and testing of casing or tubing, or both. *** reported performing 

threading operations. *** reported performing upsetting operations. *** reported producing 

couplings. As discussed in greater detail in Part VI, the value added by processors ranges from 

*** percent to *** percent.

Three firms described the expertise involved in U.S. production activity. *** reported 

metallurgical personnel and a heat treat equipment operator. *** reported technical expertise 

in heat treating, inspection, and threading. *** reported having a heat treatment production 

director and API 5CT quality director. 

Finally, as shown in table III-10, in 2013, the six reporting toll and non-toll processors’

combined production-related workers was 2,019 compared to the 12 mills with 6,891 

production-related workers.

U.S. PRODUCERS’ U.S. SHIPMENTS AND EXPORTS 

Table III-5 presents U.S. mills’ U.S. shipments, export shipments, and total shipments. 

The quantity of these U.S. producers’ U.S. shipments of OCTG increased by 19.1 percent from 

2011 to 2013 and was 9.2 percent higher in January-March 2014 compared to January-March 

2013. Average unit values of U.S. shipments increased from 2011 to 2012 by 2.7 percent, but 

decreased by 9.9 percent from 2012 to 2013, resulting in an overall decrease of 7.4 percent 

from 2011 to 2013. The average unit values of U.S. mills’ U.S. shipments were 1.2 percent lower 

in January-March 2014 compared to January-March 2013.

III-11
Table III-5 

OCTG: U.S. mills' U.S. shipments, export shipments, and total shipments, 2011-13, January to 

March 2013, and January to March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

U.S. shipments 3,135,876 3,387,771 3,736,381 870,703 950,579

Export shipments 173,398 209,086 258,589 44,839 83,823

Total shipments 3,309,274 3,596,857 3,994,970 915,542 1,034,402

Value (1,000 dollars)

U.S. shipments 5,286,771 5,867,506 5,833,652 1,359,773 1,466,007

Export shipments 306,292 360,066 359,637 74,504 107,397

Total shipments 5,593,063 6,227,572 6,193,289 1,434,277 1,573,404

Unit value (dollars per short ton)

U.S. shipments 1,686 1,732 1,561 1,562 1,542

Export shipments 1,766 1,722 1,391 1,662 1,281

Total shipments 1,690 1,731 1,550 1,567 1,521

Share of quantity (percent)

U.S. shipments 94.8 94.2 93.5 95.1 91.9

Export shipments 5.2 5.8 6.5 4.9 8.1

Total shipments 100.0 100.0 100.0 100.0 100.0

Share of value (percent)

U.S. shipments 94.5 94.2 94.2 94.8 93.2

Export shipments 5.5 5.8 5.8 5.2 6.8

Total shipments 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires.

Table III-6 presents U.S. non-toll processors’ shipments. The quantity of U.S. non-toll 

processors’ U.S. shipments of OCTG *** percent from 2011 to 2012 but decreased by less than 

*** from 2012 to 2013, resulting in an overall increase from 2011 to 2013 of *** percent. U.S. 

shipments were *** in January-March 2014 compared to January-March 2013. The value of

U.S. non-toll processors’ U.S. shipments of OCTG *** percent from 2011 to 2013, and was ***

in January-March 2014 compared to January-March 2013. Average unit values of U.S. 

shipments *** from 2011 to 2012 by *** percent, *** from 2012 to 2013 by *** percent, 

resulting in an *** of *** percent from 2011 to 2013. The average unit values of U.S. non-toll 

processors’ U.S. shipments were *** percent *** in January-March 2014 compared to JanuaryMarch 2013. 

Table III-6 

OCTG: U.S. non-toll processors' U.S. shipments, export shipments, and total shipments, 2011-13, 

January to March 2013, and January to March 2014

* * * * * * *

III-12
Table III-7 presents U.S. toll processors’ tolling volume and tolling revenue. Tolled 

volume grew steadily, increasing from 2011 to 2012 by *** percent and from 2012 to 2013 by 

*** percent, resulting in an overall increase from 2011 to 2013 of *** percent. Tolling on behalf 

of importers accounted for *** percent of the increase from 2011 to 2013. Tolling volume was 

*** percent higher in January-March 2014 compared to January-March 2013. Tolling revenue

also grew steadily, increasing from 2011 to 2013 by *** percent; tolling revenue was ***

percent higher in January-March 2014 compared to January-March 2013. Tolling processing 

fees increased from $*** per short ton in 2011 to $*** per short ton in 2012 and remained 

stable in 2013. 

Table III-7 

OCTG: U.S. toll processors' U.S. shipments for account of U.S. mills, U.S. importers, and other 

customers, 2011-13, January to March 2013, and January to March 2014

* * * * * * *

U.S. PRODUCERS’ INVENTORIES

Table III-8 presents U.S. mills’ and processors’ end-of-period inventories and the ratio of 

these inventories to U.S. mills’ and processors’ production, U.S. shipments, and total shipments.

Table III-8 

OCTG: U.S. producers' inventories, 2011-13, January to March 2013, and January to March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

U.S. mills' end-of-period inventories 357,030 319,151 365,485 382,283 375,999

Ratio (percent)

Ratio of inventories to.--

 U.S. production 10.7 8.9 8.9 9.6 8.8

U.S. shipments 11.4 9.4 9.8 11.0 9.9

Total shipments 10.8 8.9 9.1 10.4 9.1

Quantity (short tons)

U.S. processors' end-of-period 

inventories *** *** *** *** ***

Ratio (percent)

Ratio of inventories to.--

 U.S. production *** *** *** *** ***

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

Total shipments *** *** *** *** ***

Note.—U.S. processors’ inventories include finished and unfinished OCTG. Therefore inventories 

reported by processors may include both inputs and finished goods.

Source: Compiled from data submitted in response to Commission questionnaires.

III-13
U.S. PRODUCERS’ IMPORTS

One U.S. producer, EnergeX, imported OCTG. Other U.S. producers are not importers, 

but are related to firms that import OCTG.17 Table III-9 shows the U.S. production, imports, and 

ratio of imports to production of these U.S. firms. In addition, three companies reported 

purchases of imported OCTG countries. *** reported purchases of OCTG imported from India. 

*** reported purchases of OCTG imported from ***. *** reported purchases of imported OCTG 

from ***.

18

Table III-9 

OCTG: U.S. producers' imports, 2011-13, January to March 2013, and January to March 2014

* * * * * * *

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

Table III-10 presents U.S. producers’ employment-related data.

19 U.S. mills reported an 

increase in production and related workers from 2011 to 2012 and a decrease from 2012 to 

2013. Overall, U.S. mills’ production and related workers increased by 915 (15.3 percent) from 

2011 to 2013. U.S. mills employed 332 more production and related workers in January-March 

2014 compared to January-March 2013. U.S. mills’ increases in employment from 2011 to 2012 

track mills’ increases in production. However, in 2013, U.S. mills reported 244 fewer employees 

than in 2012. *** reported higher production in 2013 compared to 2012, but fewer production 

and related workers. 

The two largest toll processors, Texas Steel Conversion and Tubular Services, each had 

more than *** production and related workers in 2013 and combined had *** workers. Tubular 

Services accounts for *** percent of the increase in production and related workers from 2011 

to 2013, coinciding with its increasing investments in new capacity and increasing production.20

17 U.S. producer Evraz Rocky Mountain Steel is owned by Evraz Inc., NA, the importer of record. ***. 

Maverick is related to Tenaris Global Services (“TGS”), the official importer of record. Maverick is 

separately organized under the Tenaris umbrella from TGS. ***. U.S. producer TMK IPSCO is related 

through common ownership to TMK NA and TMK IPSCO International, the official importer of record. 

U.S. producer Vallourec U.S.A. is related through common ownership to importer Vallourec Star. U.S. 

producer Welded Tube is related to Welded Tube of Canada Corp., the importer of record, and Welded 

Tube’s parent company. ***. 18 Questionnaire response of ***, II-20. ***. 19 ***. 20 *** E-mail from ***, May 27, 2014.

III-14
Table III-10

OCTG: U.S. producers' employment related data, 2011-13, January to March 2013, and January to 

March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

U.S. mills

Production-related workers (PRWs) 

(number) 5,976 7,135 6,891 6,760 7,092

Total hours worked (1,000 hours) 13,017 15,059 16,015 3,913 3,973

Hours worked per PRW (hours) 2,178 2,111 2,324 579 560

Wages paid ($1,000) 369,492 451,581 507,746 110,092 129,040

Hourly wages (dollars per hour) $28.39 $29.99 $31.70 $28.13 $32.48

Productivity (short tons per 1,000 hours) 255.7 238.2 256.5 254.4 268.0

Unit labor costs (dollars per short ton) $111 $126 $124 $111 $121

U.S. non-toll processors

Production-related workers (PRWs) 

(number) *** *** *** *** ***

Total hours worked (1,000 hours) *** *** *** *** ***

Hours worked per PRW (hours) *** *** *** *** ***

Wages paid ($1,000) *** *** *** *** ***

Hourly wages (dollars per hour) *** *** *** *** ***

Productivity (short tons per 1,000 hours) *** *** *** *** ***

Unit labor costs (dollars per short ton) *** *** *** *** ***

U.S. toll processors

Production-related workers (PRWs) 

(number) *** *** *** *** ***

Total hours worked (1,000 hours) *** *** *** *** ***

Hours worked per PRW (hours) *** *** *** *** ***

Wages paid ($1,000) *** *** *** *** ***

Hourly wages (dollars per hour) *** *** *** *** ***

Productivity (short tons per 1,000 hours) *** *** *** *** ***

Unit labor costs (dollars per short ton) *** *** *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires.

III-15

PART IV: U.S. IMPORTS, APPARENT U.S. CONSUMPTION, AND MARKET 

SHARES

U.S. IMPORTERS

The Commission issued importer questionnaires to 65 firms believed to be importers of 

subject OCTG, as well as to all U.S. producers of OCTG.

1 Usable questionnaire responses were 

received from 47 companies, representing 89.4 percent of total imports from all sources in 

2013, 67.8 percent of total imports from India, 97.0 percent of total imports from Korea, 90.7

percent of total imports from the Philippines, all imports from Saudi Arabia, 75.8 percent of 

total subject imports from Taiwan, 27.5 percent of total imports from Thailand, 82.7 percent of 

total imports from Turkey, all imports from Ukraine, 87.0 percent of total imports from 

Vietnam, and 88.4 percent of total imports from all other sources under relevant HTS statistical 

reporting numbers, as adjusted.2 Table IV-1 lists all responding U.S. importers of OCTG from the 

nine subject sources and other sources, their locations, their sources of imports, and their 

shares of U.S. imports from subject sources, nonsubject sources, and total imports during 

January 2011 through March 2013.

1 The Commission issued questionnaires to those firms identified in the petition, along with firms 

that, based on a review of proprietary data from by U.S. Customs and Border Protection (“Customs”), 

were believed to import OCTG. 2 The relevant statistical reporting numbers appear in Part I of this report. Official Commerce 

statistics were adjusted using questionnaire response data to include imports of OCTG under HTS 

statistical reporting numbers other than those specified for casing and tubing.

IV-1

 
Table IV-1

OCTG: U.S. importers, sources of imports, U.S. headquarters, and shares of imports, January 

2011 through March 2014

Firm Headquarters

Share of imports by source (percent)

Sources

of imports

Subject

sources

Nonsubject 

sources

Total

imports

AJU Besteel USA Inc.1 Houston, TX *** *** *** ***

ArcelorMittal International America, 

LLC2 Chicago, IL *** *** *** ***

Bell Supply3 Gainesville, TX *** *** *** ***

Benteler Steel & Tube Corporation4 Houston, TX *** *** *** ***

Borusan Mannesmann Pipe U.S., 

Inc.5 Houston, TX *** *** *** ***

C&F International Incorporated6 Houston, TX *** *** *** ***

Commercial Metals Company Irving, TX *** *** *** ***

Daewoo International (America) 

Corp.7 Teaneck, NJ *** *** *** ***

Dongbu USA, Inc.

8 Torrance, CA *** *** *** ***

DSL Corporation Houston, TX *** *** *** ***

Duferco Steel Inc.

9 Matawan, NJ *** *** *** ***

EnergeX Tube10 Chicago, IL *** *** *** ***

EVRAZ Inc. NA11 Chicago, IL *** *** *** ***

Fremak Industries New York, NY *** *** *** ***

Hanwa American Corporation12 Houston, TX *** *** *** ***

HUSTEEL USA, INC.13 Houston, TX *** *** *** ***

Hyundai HYSCO USA, INC.14 Houston, TX *** *** *** ***

Iljin Steel Corporation15 Korea, *** *** *** ***

IMCO International Inc. Burlington, ON *** *** *** ***

Jindal SAW Limited (Seamless Tube 

Division)16 Nashik, MH *** *** *** ***

Kumkang Kind USA, Inc. Brea, CA *** *** *** ***

Kurt Orban Partners LLC

Burlingame, 

CA *** *** *** ***

Marubeni-Itochu Tubulars America 

Inc.17 Houston, TX *** *** *** ***

NEXTEEL America, LLC18 Houston, TX *** *** *** ***

North American Interpipe, Inc.19 Houston, TX *** *** *** ***

Okaya U.S.A., Inc.20 Houston, TX *** *** *** ***

OMK North America, Inc.

21 Houston, TX *** *** *** ***

Optima Steel International, LLC Concord, CA *** *** *** ***

Table continued on next page.

IV-2
Table IV-1--Continued

OCTG: U.S. importers, sources of imports, U.S. headquarters, and shares of imports, January 

2011 through March 2014

Firm Headquarters

Share of imports by source 

(percent)

Sources

of imports

Subject

sources

Nonsubject 

sources

Total

imports

Salzgitter Mannesmann 

International (USA), Inc.22 Houston, TX *** *** *** ***

Samsung C&T America, Inc.23 Ridgefield Park, NJ *** *** *** ***

SB International, Inc.24 Dallas, TX *** *** *** ***

SDB Trade International, LP25 Pasadena, TX *** *** *** ***

SeAH Steel America, Inc.

26 Santa Fe 

Spring, CA *** *** *** ***

Standard Tube Company Houston, TX *** *** *** ***

Stemcor USA Inc.

27 New York, NY *** *** *** ***

Sumitomo Corporation of 

America28 Houston, TX *** *** *** ***

Tata Steel International (Americas) 

Inc. (TSIA)29 Schaumburg, IL *** *** *** ***

Tata Steel International (North 

America) Ltd.

30 Schaumburg, IL *** *** *** ***

Tenaris Global Services USA31 Houston, TX *** *** *** ***

ThyssenKrupp Materials NA, Inc.32 Southfield, MI *** *** *** ***

TMK NA and TMK IPSCO 

International33 Houston, TX

***

*** *** ***

Toyota Tsusho America, Inc.34 Georgetown, KY *** *** *** ***

Vallourec USA Corporation35 Houston, TX *** *** *** ***

Varsun eTechnologies Group, Inc. Orange, CA *** *** *** ***

Voest-Alpine Tubular Corporation36 Houston, TX *** *** *** ***

Welded Tube of Canada Corp37 Concord, ON *** *** *** ***

WSP Houston OCTG38 Houston, TX *** *** *** ***

Total *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires.

Footnotes 1 through 38 have been redacted.

IV-3
U.S. IMPORTS

Table IV-2 presents data for U.S. imports of OCTG from subject sources.

Table IV-2

OCTG: U.S. imports, by source, 2011-13, January to March 2013, and January to March 2014

Source

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

India *** *** *** *** ***

Korea *** *** *** *** ***

Philippines 23,933 69,757 73,969 12,030 17,794

Saudi Arabia *** *** *** *** ***

Taiwan1 *** *** *** *** ***

Thailand 6,135 31,833 33,741 3,424 11,911

Turkey 140,806 151,576 133,773 24,217 34,158

Ukraine *** *** *** *** ***

Vietnam 56,697 219,997 144,871 31,876 2,757

Subtotal *** *** *** *** ***

All other sources2 *** *** *** *** ***

Total imports 2,839,740 3,570,796 3,242,306 734,735 890,275

Value (1,000 dollars)

India *** *** *** *** ***

Korea *** *** *** *** ***

Philippines 21,542 64,567 60,391 9,784 13,739

Saudi Arabia *** *** *** *** ***

Taiwan1 *** *** *** *** ***

Thailand 8,053 43,815 39,752 4,593 16,280

Turkey 133,698 144,280 114,981 22,481 29,012

Ukraine *** *** *** *** ***

Vietnam 53,923 201,905 119,291 26,414 3,144

Subtotal *** *** *** *** ***

All other sources2 *** *** *** *** ***

Total imports 3,981,070 5,053,876 3,997,131 952,338 1,067,990

Table continued on next page.

IV-4
Table IV-2--Continued

OCTG: U.S. imports, by source, 2011-13, January to March 2013, and January to March 2014

Source

Calendar year January to March

2011 2012 2013 2013 2014

Unit value (dollars per short ton)

India *** *** *** *** ***

Korea *** *** *** *** ***

Philippines 900 926 816 813 772

Saudi Arabia *** *** *** *** ***

Taiwan1 *** *** *** *** ***

Thailand 1,313 1,376 1,178 1,341 1,367

Turkey 950 952 860 928 849

Ukraine *** *** *** *** ***

Vietnam *** *** *** *** ***

Subtotal *** *** *** *** ***

All other sources2 *** *** *** *** ***

Total imports 1,402 1,415 1,233 1,296 1,200

Share of quantity (percent)

India *** *** *** *** ***

Korea *** *** *** *** ***

Philippines 0.8 2.0 2.3 1.6 2.0

Saudi Arabia *** *** *** *** ***

Taiwan1 *** *** *** *** ***

Thailand 0.2 0.9 1.0 0.5 1.3

Turkey 5.0 4.2 4.1 3.3 3.8

Ukraine *** *** *** *** ***

Vietnam *** *** *** *** ***

Subtotal 44.7 49.6 54.8 57.3 52.0

All other sources2 *** *** *** *** ***

Total imports 100.0 100.0 100.0 100.0 100.0

1 Data for Taiwan exclude imports from nonsubject supplier Chung Hung. 2 Data for all other sources include imports from nonsubject Taiwan supplier Chung Hung. 

 

Source: Official imports statistics of the U.S. Department of Commerce using HTS statistical reporting 

numbers 7304.29.1010, 7304.29.1020, 7304.29.1030, 7304.29.1040, 7304.29.1050, 7304.29.1060, 

7304.29.1080, 7304.29.2010, 7304.29.2020, 7304.29.2030, 7304.29.2040, 7304.29.2050, 7304.29.2060, 

7304.29.2080, 7304.29.3110, 7304.29.3120, 7304.29.3130, 7304.29.3140, 7304.29.3150, 7304.29.3160, 

7304.29.3180, 7304.29.4110, 7304.29.4120, 7304.29.4130, 7304.29.4140, 7304.29.4150, 7304.29.4160, 

7304.29.4180, 7304.29.5015, 7304.29.5030, 7304.29.5045, 7304.29.5060, 7304.29.5075, 7304.29.6115, 

7304.29.6130, 7304.29.6145, 7304.29.6160, 7304.29.6175, 7305.20.2000, 7305.20.4000, 7305.20.6000, 

7305.20.8000, 7306.29.1030, 7306.29.1090, 7306.29.2000, 7306.29.3100, 7306.29.4100, 7306.29.6010, 

7306.29.6050, 7306.29.8110, and 7306.29.8150 with adjustments based on data submitted in response 

to Commission questionnaires. Official import statistics reported through to December 2013 reflect 

revisions available as of July 2014.

IV-5
Table IV-3 presents data for U.S. imports of OCTG from nonsubject sources.

Table IV-3 

OCTG: U.S. imports from nonsubject sources, 2011-13, January to March 2013, and January to 

March 2014

Source

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

U.S. imports from.--

 Taiwan (Chung Hung) *** *** *** *** ***

Argentina 119,362 138,985 206,359 45,692 37,442 

Austria 118,572 108,933 107,904 25,088 28,618 

Canada 409,964 409,681 311,532 84,713 86,178 

Germany 107,632 163,797 127,865 32,597 26,353 

Japan 148,812 228,201 164,916 39,824 42,337 

Mexico 197,508 153,524 151,420 24,801 62,120 

All other sources 367,955 458,111 279,276 48,303 108,616 

Nonsubject adjustment based on

questionnaire data, specific source unknown 57,929 104,055 89,796 8,028 32,103

Total nonsubject imports *** *** *** *** ***

Share of total imports (percent)

U.S. imports from.--

 Taiwan (Chung Hung) *** *** *** *** ***

Argentina 4.2 3.9 6.4 6.2 4.2

Austria 4.2 3.1 3.3 3.4 3.2

Canada 14.4 11.5 9.6 11.5 9.7

Germany 3.8 4.6 3.9 4.4 3.0

Japan 5.2 6.4 5.1 5.4 4.8

Mexico 7.0 4.3 4.7 3.4 7.0

All other sources 13.0 12.8 8.6 6.6 12.2

Nonsubject adjustment based on

questionnaire data, specific source unknown 2.0 2.9 2.8 1.1 3.6

Total nonsubject imports *** *** *** *** ***

Source: Official imports statistics of the U.S. Department of Commerce using HTS statistical reporting 

numbers 7304.29.1010, 7304.29.1020, 7304.29.1030, 7304.29.1040, 7304.29.1050, 7304.29.1060, 

7304.29.1080, 7304.29.2010, 7304.29.2020, 7304.29.2030, 7304.29.2040, 7304.29.2050, 7304.29.2060, 

7304.29.2080, 7304.29.3110, 7304.29.3120, 7304.29.3130, 7304.29.3140, 7304.29.3150, 7304.29.3160, 

7304.29.3180, 7304.29.4110, 7304.29.4120, 7304.29.4130, 7304.29.4140, 7304.29.4150, 7304.29.4160, 

7304.29.4180, 7304.29.5015, 7304.29.5030, 7304.29.5045, 7304.29.5060, 7304.29.5075, 7304.29.6115, 

7304.29.6130, 7304.29.6145, 7304.29.6160, 7304.29.6175, 7305.20.2000, 7305.20.4000, 7305.20.6000, 

7305.20.8000, 7306.29.1030, 7306.29.1090, 7306.29.2000, 7306.29.3100, 7306.29.4100, 7306.29.6010, 

7306.29.6050, 7306.29.8110, and 7306.29.8150 with adjustments based on data submitted in response 

to Commission questionnaires. Official import statistics reported through to December 2013 reflect 

revisions available as of July 2014.

IV-6
CRITICAL CIRCUMSTANCES

On July 18, 2014, Commerce issued its final determinations for these investigations, 

which included affirmative determinations of critical circumstances for several sources.

3 In its 

final countervailing duty determination for India, Commerce determined that critical 

circumstances exist with regard to imports from India of OCTG from Jindal SAW and from all 

other producers other than GVN Fuels Limited and its cross-owned producers Maharashtra 

Seamless Limited and Jindal Pipes Limited (GVN/MSL/JPL).4 Table IV-4 presents monthly data of 

imports of OCTG by U.S. importer Jindal SAW and all other producers other than GVN/MSL/JPL, 

for the six-month periods before and after the filing of the petition on July 2, 2013 (January 

2013 through June 2013 and July 2013 through December 2013), as well as end-of-period 

inventories.

In its final countervailing duty determination for Turkey, Commerce determined that 

critical circumstances exist with regard to imports of all OCTG from Turkey.

5 Table IV-5 presents 

monthly data of imports of OCTG by U.S. importers from Turkey, for the six-month periods 

before and after the filing of the petition on July 2, 2013, as well as end-of-period inventories. 

In its final determination of sales at less than fair value for Turkey, Commerce determined that 

critical circumstances exist with regard to imports from Turkey from all producers and 

exporters other than Borusan and Yucel.6 Table IV-6 presents monthly data of imports of OCTG 

by U.S. importers from Turkey from producers and exporters other than Borusan and Yucel, for 

the six-month periods before and after the filing of the petition on July 2, 2013, as well as endof-period inventories.

In its final determination of sales at less than fair value for Vietnam, Commerce

determined that critical circumstances exist for from the Vietnam-wide entity, excluding SeAH 

3 When petitioners file timely allegations of critical circumstances, Commerce examines whether 

there is a reasonable basis to believe or suspect that (1) either there is a history of dumping and 

material injury by reason of dumped imports in the United States or elsewhere of the subject 

merchandise, or the person by whom, or for whose account, the merchandise was imported knew or 

should have known that the exporter was selling the subject merchandise at LTFV and that there was 

likely to be material injury by reason of such sales; and (2) there have been massive imports of the 

subject merchandise over a relatively short period. 4 Certain Oil Country Tubular Goods From India: Final Affirmative Countervailing Duty Determination 

and Partial Final Affirmative Determination of Critical Circumstances, 79 FR 41967, July 18, 2014. 5 Certain Oil Country Tubular Goods From the Republic of Turkey: Final Affirmative Countervailing 

Duty Determination and Final Affirmative Critical Circumstances Determination, 79 FR 41964, July 18, 

2014.

6 Certain Oil Country Tubular Goods From the Republic of Turkey: Final Determination of Sales at Less 

Than Fair Value and Affirmative Final Determination of Critical Circumstances, in Part, 79 FR 41971, July 

18, 2014.

IV-7

 
Steel VINA Corp. 7 Table IV-7 presents monthly data of imports of OCTG by U.S. importers from 

Vietnam, excluding SeAH Steel VINA Corp., for the six-month periods before and after the filing 

of the petition on July 2, 2013, as well as end-of-period inventories.

Where Commerce has made affirmative final critical circumstances determinations, and 

if the Commission makes affirmative critical circumstances findings, certain subject imports 

from India may be subject to countervailing duties retroactive by 90 days from December 23, 

2013, the effective date of Commerce’s preliminary CVD determination. Subject imports from 

Turkey may be subject to countervailing duties retroactive by 90 days from July 18, 2014, the 

effective date of Commerce’s final CVD determination.8 Further, certain subject imports may be 

subject to LTFV duties retroactive by 90 days from February 25, 2014, the effective date of 

Commerce’s preliminary affirmative LTFV determinations.

Table IV-4

OCTG: U.S. imports and end-of-period (EOP) inventories from India excluding GVN, Maharashtra, 

and Jindal, by month, January 2013 through June 2013 and July 2013 through December 2013

* * * * * * *

7 Certain Oil Country Tubular Goods From the Socialist Republic of Vietnam: Final Determination of 

Sales at Less Than Fair Value and Final Affirmative Determination of Critical Circumstances, 79 FR 41973, 

July 18, 2014.

8 Commerce preliminarily made a negative countervailing determination for Turkey. Certain Oil 

Country Tubular Goods From the Republic of Turkey: Preliminary Negative Countervailing Duty 

Determination and Alignment of Final Determination With Final Antidumping Determination, 78 FR 

77420, December 23, 2013.

IV-8

 
Table IV-5

OCTG: U.S. imports and end-of-period (EOP) inventories from Turkey, by month, January 2013 

through June 2013 and July 2013 through December 2013

Month

U.S. imports from Turkey

Quantity

(short tons)

Share of total 

(percent)

2013:

 January 17,615 13.2

February 6,602 4.9

March 0 0.0

April 20,090 15.0

May 13,054 9.8

June 1,812 1.4

Subtotal, six months preceding the petition 59,173 44.2

July 12,240 9.1

August 10,897 8.1

September 15,887 11.9

October 13,039 9.7

November 4,825 3.6

December 17,711 13.2

Subtotal, six months following the petition 74,599 55.8

Total imports 2013 133,773 100.0

Item

Calendar year

2012 2013

U.S. importers' EOP inventories *** ***

Note.-- Data do not include imports of OCTG under HTS statistical reporting numbers other than those 

specified for casing and tubing.

Source: Compiled from official Commerce statistics (import data) and data submitted in response to 

Commission questionnaires (inventory data).

Table IV-6

OCTG: U.S. imports and end-of-period (EOP) inventories from Turkey excluding Borusan and 

Yucel, by month, January 2013 through June 2013 and July 2013 through December 2013

* * * * * * *

Table IV-7

OCTG: U.S. imports and end-of-period (EOP) inventories from Vietnam excluding SeAH, by month, 

January 2013 through June 2013 and July 2013 through December 2013

* * * * * * *

IV-9
NEGLIGIBILITY

The statute requires that an investigation be terminated without an injury

determination if imports of the subject merchandise are found to be negligible.9 Negligible

imports are defined in the Tariff Act of 1930, as amended, as imports from a country of

merchandise corresponding to a domestic like product where such imports account for less

than 3 percent of the volume of all such merchandise imported into the United States in the

most recent 12-month period for which data are available that precedes the filing of the

petition or the initiation of the investigation. However, if there are imports of such merchandise

from a number of countries subject to investigations initiated on the same day that individually

account for less than 3 percent of the total volume of the subject merchandise, and if the

imports from those countries collectively account for more than 7 percent of the volume of all

such merchandise imported into the United States during the applicable 12-month period, then

imports from such countries are deemed not to be negligible.

10 The statute further provides

that, in the case of countervailing duty investigations involving developing countries, the

negligibility limits are 4 percent and 9 percent, rather than 3 percent and 7 percent.11 Table IV-8 

presents data for imports during July 2012-June 2013 for each subject source for which 

Commerce has made an affirmative determination. Four sources individually accounted for less

than 3 percent of the volume of U.S. imports of OCTG in 2013. Imports from the Philippines 

accounted for 2.2 percent, imports from Saudi Arabia accounted for *** percent, subject 

imports from Taiwan accounted for *** percent, and imports from Thailand accounted for 0.8

percent. Collectively, these four sources accounted for *** percent of subject imports. 

9 Sections 703(a)(1), 705(b)(1), 733(a)(1), and 735(b)(1) of the Act (19 U.S.C. §§ 1671b(a)(1), 

1671d(b)(1), 1673b(a)(1), and 1673d(b)(1)).

10 Section 771 (24) of the Act (19 U.S.C § 1677(24)). 11 Section 771 (24)(B) of the Act (19 U.S.C § 1677(24)(B)).

IV-10
Table IV-8 

OCTG: U.S. imports by source and share of imports, July 2012-June 2013

Source

U.S. imports

Quantity 

(short tons)

Share of total 

(percent)

India *** ***

Korea *** ***

Philippines 68,988 2.2

Saudi Arabia *** ***

Taiwan1

*** ***

Thailand 26,454 0.8

Turkey 130,422 4.1

Ukraine *** ***

Vietnam 173,312 5.5

Subtotal *** ***

Of which individually negligible sources *** ***

All other sources2

*** ***

Total imports 3,177,252 100.0

1 Data for Taiwan exclude imports from nonsubject supplier Chung Hung. 2 Data for all other sources include imports from nonsubject Taiwan supplier Chung Hung. 

Source: Compiled from official Commerce statistics, with adjustments using questionnaire data, and 

reclassifying Chung Hung based on questionnaire data. Official import statistics reflect revisions available 

as of July 2014.

CUMULATION CONSIDERATIONS

In assessing whether imports should be cumulated, the Commission determines 

whether U.S. imports from the subject countries compete with each other and with the 

domestic like product and has generally considered four factors: (1) fungibility, (2) presence of 

sales or offers to sell in the same geographical markets, (3) common or similar channels of 

distribution, and (4) simultaneous presence in the market. Additional information concerning 

fungibility, geographical markets, and simultaneous presence in the market is presented below.

IV-11
Fungibility

Tables IV-9 through IV-1112 present OCTG data by stage of finish for U.S. producers’ U.S. 

shipments (table IV-9), U.S. importers’ U.S. imports from subject sources (table IV-10), and from 

all other sources (table IV-11). The tabulation below presents data for U.S. producers’ ratios of 

production of welded OCTG and seamless OCTG, and subject imports’ ratios of imports for 

welded OCTG and seamless OCTG, by source.

Welded Seamless

Item Share (percent)

U.S. producers' production 42.0 58.0

U.S. imports from--

India 20.2 79.8

Korea 97.6 2.4

Philippines 99.4 0.6

Saudi Arabia 0.0 100.0

Taiwan 97.2 2.8

Thailand 0.0 100.0

Turkey 100.0 0.0

Ukraine 0.0 100.0

Vietnam 92.8 7.2

Note: Shares of seamless for India and Korea do not 

include entries under HTS numbers other than those for 

casing and tubing not included and thus are slightly 

understated.

Source: Official Commerce Statistics.

12 Appendix D presents disaggregated data by country.

IV-12

 
Table IV-9

OCTG: U.S. producers’ U.S. shipments, by stage of finish, 2011-13, January to March 2013, and 

January to March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

Finished OCTG 2,817,381 3,087,843 3,506,476 815,767 897,473

Unfinished OCTG.--

 Not at API *** *** *** *** ***

At API but upgradeable *** *** *** *** ***

At final API but needs end finishing *** *** *** *** ***

All others *** *** *** *** ***

Subtotal, unfinished OCTG 435,444 468,643 397,504 94,158 93,829

Total U.S. shipments 3,252,825 3,556,486 3,903,980 909,925 991,302

Value (1,000 dollars)

Finished OCTG 4,800,693 5,265,083 5,498,430 1,272,846 1,396,249

Unfinished OCTG.--

 Not at API *** *** *** *** ***

At API but upgradeable *** *** *** *** ***

At final API but needs end finishing *** *** *** *** ***

All others *** *** *** *** ***

Subtotal, unfinished OCTG 699,591 885,931 619,898 151,454 135,183

Total U.S. shipments 5,500,284 6,151,014 6,118,328 1,424,300 1,531,432

Unit value (dollars per short ton)

Finished OCTG 1,704 1,705 1,568 1,560 1,556

Unfinished OCTG.--

 Not at API *** *** *** *** ***

At API but upgradeable *** *** *** *** ***

At final API but needs end finishing *** *** *** *** ***

All others *** *** *** *** ***

Subtotal, unfinished OCTG 1,607 1,890 1,559 1,609 1,441

Total U.S. shipments 1,691 1,730 1,567 1,565 1,545

Share of quantity (percent)

Finished OCTG 86.6 86.8 89.8 89.7 90.5

Unfinished OCTG.--

 Not at API *** *** *** *** ***

At API but upgradeable *** *** *** *** ***

At final API but needs end finishing *** *** *** *** ***

All others *** *** *** *** ***

Subtotal, unfinished OCTG 13.4 13.2 10.2 10.3 9.5

Total U.S. shipments 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires.

IV-13
Table IV-10

OCTG: U.S. importers’ imports from subject sources, by stage of finish, 2011-13, January to March 

2013, and January to March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

Finished OCTG 167,796 250,011 214,867 58,508 12,610

Unfinished OCTG.--

 Not at API 68,850 94,883 72,399 14,073 18,638

At API but upgradeable 244,658 270,263 293,200 70,018 70,957

At final API but needs end finishing 725,631 990,153 994,129 259,808 167,354

All others 36,818 42,841 27,846 8,564 512

Subtotal, unfinished OCTG 1,075,957 1,398,140 1,387,574 352,463 257,461

Total U.S. imports 1,243,753 1,648,151 1,602,441 410,971 270,071

Value (1,000 dollars)

Finished OCTG 238,196 338,485 261,597 76,387 14,556

Unfinished OCTG.--

 Not at API 72,215 104,691 66,027 12,483 16,762

At API but upgradeable 277,173 290,026 274,993 71,778 65,065

At final API but needs end finishing 771,075 995,027 893,113 236,829 145,376

All others 48,657 57,836 36,911 11,520 494

Subtotal, unfinished OCTG 1,169,120 1,447,580 1,271,044 332,610 227,697

Total U.S. imports 1,407,316 1,786,065 1,532,641 408,997 242,253

Unit value (dollars per short ton)

Finished OCTG 1,420 1,354 1,217 1,306 1,154

Unfinished OCTG.--

 Not at API 1,049 1,103 912 887 899

At API but upgradeable 1,133 1,073 938 1,025 917

At final API but needs end finishing 1,063 1,005 898 912 869

All others 1,322 1,350 1,326 1,345 965

Subtotal, unfinished OCTG 1,087 1,035 916 944 884

Total U.S. imports 1,132 1,084 956 995 897

Share of quantity (percent)

Finished OCTG 13.5 15.2 13.4 14.2 4.7

Unfinished OCTG.--

 Not at API 5.5 5.8 4.5 3.4 6.9

At API but upgradeable 19.7 16.4 18.3 17.0 26.3

At final API but needs end finishing 58.3 60.1 62.0 63.2 62.0

All others 3.0 2.6 1.7 2.1 0.2

Subtotal, unfinished OCTG 86.5 84.8 86.6 85.8 95.3

Total U.S. imports 100.0 100.0 100.0 100.0 100.0

Note.— Data for January-March 2014 does not include imports from ***.

Source: Compiled from data submitted in response to Commission questionnaires.

IV-14
Table IV-11

OCTG: U.S. importers' U.S. imports from nonsubject sources, by type, 2011-13, January to March 

2013, and January to March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

Finished OCTG 793,843 824,816 717,079 141,636 185,774

Unfinished OCTG.--

 Not at API 30,361 79,890 62,505 14,709 12,789

At API but upgradeable 41,421 87,105 96,086 28,054 25,481

At final API but needs end finishing 403,801 526,302 384,997 73,701 94,058

All others 24,863 35,158 36,269 2,867 18,827

Subtotal, unfinished OCTG 500,446 728,455 579,857 119,331 151,155

Total U.S. imports 1,294,289 1,553,271 1,296,936 260,967 336,929

Value (1,000 dollars)

Finished OCTG 1,429,563 1,560,770 1,228,131 262,735 330,461

Unfinished OCTG.--

 Not at API 40,179 88,441 75,182 15,327 12,304

At API but upgradeable 42,144 110,761 103,854 31,257 29,913

At final API but needs end finishing 776,117 1,127,330 726,857 167,269 188,420

All others 33,629 51,143 51,221 4,243 26,615

Subtotal, unfinished OCTG 892,069 1,377,675 957,114 218,096 257,252

Total U.S. imports 2,321,632 2,938,445 2,185,245 480,831 587,713

Unit value (dollars per short ton)

Finished OCTG 1,801 1,892 1,713 1,855 1,779

Unfinished OCTG.--

 Not at API 1,323 1,107 1,203 1,042 962

At API but upgradeable 1,017 1,272 1,081 1,114 1,174

At final API but needs end finishing 1,922 2,142 1,888 2,270 2,003

All others 1,353 1,455 1,412 1,480 1,414

Subtotal, unfinished OCTG 1,783 1,891 1,651 1,828 1,702

Total U.S. imports 1,794 1,892 1,685 1,842 1,744

Share of quantity (percent)

Finished OCTG 61.3 53.1 55.3 54.3 55.1

Unfinished OCTG.--

 Not at API 2.3 5.1 4.8 5.6 3.8

At API but upgradeable 3.2 5.6 7.4 10.8 7.6

At final API but needs end finishing 31.2 33.9 29.7 28.2 27.9

All others 1.9 2.3 2.8 1.1 5.6

Subtotal, unfinished OCTG 38.7 46.9 44.7 45.7 44.9

Total U.S. imports 100.0 100.0 100.0 100.0 100.0

 Source: Compiled from data submitted in response to Commission questionnaires.

IV-15
Table IV-1213 presents data for U.S. producers’ and U.S. importers’ shipments of OCTG, 

aggregated by grade. Table IV-1314 presents data for U.S. producers’ and U.S. importers’ 

shipments of OCTG, aggregated by end finish.

Table IV-12

OCTG: U.S. producers’ and U.S. importers’ U.S. shipments, aggregated by grade, 2013

Type

Source

US Subject sources Nonsubject sources

Quantity (short tons)

Below API/limited service *** *** ***

H-40 *** *** ***

J-55 806,818 1,037,784 140,368

K-55 *** *** ***

M-65 *** *** ***

L-80 553,466 209,235 207,754

C-95 *** *** ***

N-80, Type I *** *** ***

N-80, Type II *** *** ***

C-90 *** *** ***

T-95 *** *** ***

P-110 1,727,521 175,315 685,331

Q-125 *** *** ***

Premium/proprietary *** *** ***

Total reported U.S. shipments 3,903,975 1,551,952 1,224,036

Table continued on next page.

13 Appendix D presents data showing U.S. producers’ shipments of OCTG by grade and type of end 

finish. 14 Appendix D presents data showing U.S. importers’ shipments of OCTG by grade and type of end 

finish for each subject source and aggregated data for nonsubject sources.

IV-16

 
Table IV-12--Continued

OCTG: U.S. producers’ and U.S. importers’ U.S. shipments, aggregated by grade, 2013

Type

Source

US Subject sources Nonsubject sources

Value (1,000 dollars)

Below API/limited service *** *** ***

H-40 *** *** ***

J-55 944,565 1,001,943 159,762

K-55 *** *** ***

M-65 *** *** ***

L-80 903,604 283,198 356,850

C-95 *** *** ***

N-80, Type I *** *** ***

N-80, Type II *** *** ***

C-90 *** *** ***

T-95 *** *** ***

P-110 2,977,589 245,965 1,299,377

Q-125 *** *** ***

Premium/proprietary *** *** ***

Total reported U.S. shipments 6,109,989 1,682,550 2,242,185

Unit value (dollars per short ton)

Below API/limited service *** *** ***

H-40 *** *** ***

J-55 1,171 965 1,138

K-55 *** *** ***

M-65 *** *** ***

L-80 1,633 1,353 1,718

C-95 *** *** ***

N-80, Type I *** *** ***

N-80, Type II *** *** ***

C-90 *** *** ***

T-95 *** *** ***

P-110 1,724 1,403 1,896

Q-125 *** *** ***

Premium/proprietary *** *** ***

Total reported U.S. shipments 1,565 1,084 1,832

Table continued on next page.

IV-17
Table IV-12--Continued

OCTG: U.S. producers’ and U.S. importers’ U.S. shipments, aggregated by grade, 2013

Type

Source

US Subject sources Nonsubject sources

Share of quantity (percent)

Below API/limited service *** *** ***

H-40 *** *** ***

J-55 20.7 66.9 11.5

K-55 *** *** ***

M-65 *** *** ***

L-80 14.2 13.5 17.0

C-95 *** *** ***

N-80, Type I *** *** ***

N-80, Type II *** *** ***

C-90 *** *** ***

T-95 *** *** ***

P-110 44.3 11.3 56.0

Q-125 *** *** ***

Premium/proprietary *** *** ***

Total reported U.S. shipments 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires.

Table IV-13

OCTG: U.S. producers’ and U.S. importers’ U.S. shipments, aggregated by end finish, 2013

Finish

Source

US Subject sources

Nonsubject 

sources

Quantity (short tons)

Threaded and coupled, proprietary 903,197 20,441 ***

Threaded and coupled, not proprietary 2,538,982 541,916 ***

Threaded but not coupled, proprietary *** *** ***

Threaded but not coupled, not 

proprietary *** *** ***

Subtotal, proprietary threaded *** *** ***

Subtotal, not proprietary threaded *** *** ***

Subtotal, coupled 3,442,179 562,357 ***

Subtotal, not coupled *** *** ***

Subtotal, threaded *** *** ***

Plain end 358,140 967,049 ***

Coupling stock *** *** ***

All finishing types 9,903,975 1,551,952 ***

Table continued on next page.

IV-18
Table IV-13

OCTG: U.S. producers’ and U.S. importers’ U.S. shipments, aggregated by end finish, 2013

Finish

Source

US Subject sources

Nonsubject 

sources

Value (1,000 dollars)

Threaded and coupled, proprietary 1,731,583 27,609 ***

Threaded and coupled, not proprietary 3,606,864 703,957 ***

Threaded but not coupled, proprietary *** *** ***

Threaded but not coupled, not 

proprietary *** *** ***

Subtotal, proprietary threaded *** *** ***

Subtotal, not proprietary threaded *** *** ***

Subtotal, coupled 5,338,447 731,566 ***

Subtotal, not coupled *** *** ***

Subtotal, threaded *** *** ***

Plain end 541,940 914,658 ***

Coupling stock *** *** ***

All finishing types 6,109,989 1,682,550 ***

Unit value (dollars per short ton)

Threaded and coupled, proprietary 1,917 1,351 ***

Threaded and coupled, not proprietary 1,421 1,299 ***

Threaded but not coupled, proprietary *** *** ***

Threaded but not coupled, not 

proprietary *** *** ***

Subtotal, proprietary threaded *** *** ***

Subtotal, not proprietary threaded *** *** ***

Subtotal, coupled 1,551 1,301 ***

Subtotal, not coupled *** *** ***

Subtotal, threaded *** *** ***

Plain end 1,513 946 ***

Coupling stock *** *** ***

All finishing types 1,565 1,084 ***

Table continued on next page.

IV-19
Table IV-13--Continued

OCTG: U.S. producers’ and U.S. importers’ U.S. shipments, aggregated by end finish, 2013

Finish

Source

US Subject sources

Nonsubject 

sources

Share of quantity (percent)

Threaded and coupled, proprietary 23.1 1.3 ***

Threaded and coupled, not proprietary 65.0 34.9 ***

Threaded but not coupled, proprietary *** *** ***

Threaded but not coupled, not 

proprietary *** *** ***

Subtotal, proprietary threaded *** *** ***

Subtotal, not proprietary threaded *** *** ***

Subtotal, coupled 88.2 36.2 ***

Subtotal, not coupled *** *** ***

Subtotal, threaded *** *** ***

Plain end 9.2 62.3 ***

Coupling stock *** *** ***

All finishing types 100.0 100.0 ***

Source: Compiled from data submitted in response to Commission questionnaires.

Presence in the market

Table IV-14 summarizes the number of months in which imports were present in the 

U.S. market from each subject source.

Table IV-14

OCTG: Number of months with entries of imports from subject sources, 2011-13 and JanuaryMarch 2014

Source

Calendar year

January to 

March

2011 2012 2013 2014 Total

Number of months of import entries

India 12 12 12 3 39

Korea 12 12 12 3 39

Philippines 5 10 10 2 27

Saudi Arabia 8 8 10 0 26

Taiwan (subject) *** *** *** *** 36

Thailand 5 11 12 1 29

Turkey 11 12 11 3 37

Ukraine 10 11 10 3 34

Vietnam 7 12 12 2 33

Subtotal 12 12 12 3 39

Source: Compiled from official Commerce statistics, except Taiwan based on proprietary Customs data.

IV-20
Geographical markets

Official Commerce statistics show that in 2013, approximately 96 percent of U.S. 

imports of casing and tubing from subject countries entered the United States through the 

Houston-Galveston, TX customs district. For seven of the nine subject sources, the vast majority 

of such imports entered through the customs district for Houston-Galveston, TX. Imports of 

casing and tubing from India entered through the customs district for Houston-Galveston, TX

(78.2 percent), New Orleans, LA (13.6 percent), Los Angeles, CA (7.6 percent), and other 

customs districts in very small quantities. Imports of casing and tubing from Thailand entered 

through the customs district for Houston, Galveston, TX (73.4 percent), Los Angeles, CA (26.3 

percent), and Dallas, TX (0.3 percent).

APPARENT U.S. CONSUMPTION 

Table IV-15 presents data on apparent U.S. consumption for OCTG. Because the 

Commission has previously found processors to be part of the domestic industry, table IV-15

includes toll processors’ revenue and non-toll processors’ incremental values. Specifically, this 

additional value line consists of (1) toll processors’ revenue for shipments for the accounts of 

importers, (2) toll processors’ revenue for shipments for the accounts of “other” (non-mill/nonimporter) customers, and (3) non-toll processors’ incremental value (sales net of raw material 

costs, calculated by multiplying the difference between their unit value of sales and their unit 

value of purchases by the quantity sold). The additional processor values plus U.S. mill 

shipment values represent “total U.S. producer contributions.”

U.S. MARKET SHARES 

U.S. market share data are presented in table IV-16. As discussed above, the market 

shares shown for “total U.S. producer contributions” are based on combined U.S. mill shipment 

values and U.S. processors’ toll revenue and incremental value.

IV-21
Table IV-15

OCTG: U.S. shipments of domestic product, U.S. imports, and apparent U.S. consumption, 2011-

13, January to March 2013, and January to March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

U.S. producers' U.S. shipments 3,135,876 3,387,771 3,736,381 870,703 950,579 

U.S. imports from.--

 India *** *** *** *** ***

Korea *** *** *** *** ***

Philippines 23,933 69,757 73,969 12,030 17,794

Saudi Arabia *** *** *** *** ***

Taiwan (subject) *** *** *** *** ***

Thailand 6,135 31,833 33,741 3,424 11,911

Turkey 140,806 151,576 133,773 24,217 34,158

Ukraine *** *** *** *** ***

Vietnam 56,697 219,997 144,871 31,876 2,757

Subtotal *** *** *** *** ***

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

Total imports 2,839,740 3,570,796 3,242,306 734,735 890,275

Apparent U.S. consumption 5,975,616 6,958,567 6,978,687 1,605,438 1,840,854

Value (1,000 dollars)

U.S. producers' U.S. shipments.--

 Mills' U.S. shipments 5,286,771 5,867,506 5,833,652 1,359,773 1,466,007 

Processors’ toll

revenue/incremental value 160,655 218,147 264,793 61,864 69,767

Total U.S. producer contributions 5,447,426 6,085,653 6,098,445 1,421,637 1,535,774

U.S. imports from.--

 India *** *** *** *** ***

Korea *** *** *** *** ***

Philippines 21,542 64,567 60,391 9,784 13,739

Saudi Arabia *** *** *** *** ***

Taiwan (subject) *** *** *** *** ***

Thailand 8,053 43,815 39,752 4,593 16,280

Turkey 133,698 144,280 114,981 22,481 29,012

Ukraine *** *** *** *** ***

Vietnam 53,923 201,905 119,291 26,414 3,144

Subtotal *** *** *** *** ***

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

Total imports 3,981,070 5,053,876 3,997,131 952,338 1,067,990

Apparent U.S. consumption 9,428,496 11,139,529 10,095,576 2,373,975 2,603,764

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce 

statistics. Official import statistics reported through to December 2013 reflect revisions available as of July 

2014.

IV-22
Table IV-16

OCTG: U.S. consumption and market shares, 2011-13, January to March 2013, and January to 

March 2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

Apparent U.S. consumption 5,975,616 6,958,567 6,978,687 1,605,438 1,840,854

Market share based on quantity (percent)

U.S. producers' U.S. shipments 52.5 48.7 53.5 54.2 51.6

U.S. imports from.--

 India *** *** *** *** ***

Korea *** *** *** *** ***

Philippines 0.4 1.0 1.1 0.7 1.0

Saudi Arabia *** *** *** *** ***

Taiwan (subject) *** *** *** *** ***

Thailand 0.1 0.5 0.5 0.2 0.6

Turkey 2.4 2.2 1.9 1.5 1.9

Ukraine *** *** *** *** ***

Vietnam 0.9 3.2 2.1 2.0 0.1

Subtotal *** *** *** *** ***

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

Total imports 47.5 51.3 46.5 45.8 48.4

Value (1,000 dollar)

Apparent U.S. consumption 9,428,496 11,139,529 10,095,576 2,373,975 2,603,764

Market share based on value (percent)

U.S. producers' U.S. shipments.--

 Mills' U.S. shipments 56.1 52.7 57.8 57.3 56.3

Processors’ toll

revenue/incremental value 1.7 2.0 2.6 2.6 2.7

Total U.S. producer contributions 57.8 54.6 60.4 59.9 59.0

U.S. imports from.--

 India *** *** *** *** ***

Korea *** *** *** *** ***

Philippines 0.2 0.6 0.6 0.4 0.5

Saudi Arabia *** *** *** *** ***

Taiwan (subject) *** *** *** *** ***

Thailand 0.1 0.4 0.4 0.2 0.6

Turkey 1.4 1.3 1.1 0.9 1.1

Ukraine *** *** *** *** ***

Vietnam 0.6 1.8 1.2 1.1 0.1

Subtotal *** *** *** *** ***

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

Total imports 26.3 27.7 22.6 22.1 24.9

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce statistics.

Official import statistics reported through to December 2013 reflect revisions available as of July 2014.

IV-23
RATIO OF IMPORTS TO PRODUCTION

Table IV-17 presents data on the ratio of U.S. imports to U.S. production.

Table IV-17

OCTG: Ratio of U.S. imports to U.S. production, 2011-13, January-March 2013, and January-March 

2014

Item

Calendar year January to March

2011 2012 2013 2013 2014

Quantity (short tons)

U.S. production (mills only) 3,329,004 3,587,613 4,107,433 995,468 1,064,678

Ratio to U.S. production (percent)

U.S. imports from.—

 India *** *** *** *** ***

 Korea *** *** *** *** ***

 Philippines 0.7 1.9 1.8 1.2 1.7

 Saudi Arabia *** *** *** *** ***

 Taiwan (subject) *** *** *** *** ***

 Thailand 0.2 0.9 0.8 0.3 1.1

 Turkey 4.2 4.2 3.3 2.4 3.2

 Ukraine *** *** *** *** ***

 Vietnam 1.7 6.1 3.5 3.2 0.3

 Subtotal *** *** *** *** ***

 Nonsubject sources *** *** *** *** ***

 Total imports 85.3 99.5 78.9 73.8 83.6

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce 

statistics with adjustments using questionnaire data.

IV-24
PART V: PRICING DATA

FACTORS AFFECTING PRICES

Raw material costs

Raw materials, primarily hot-rolled steel or billets (and associated inputs such as coke, 

scrap, pig iron, and hot-briqueted iron), account for the majority of the cost of OCTG. Raw 

materials as a share of cost of goods sold for domestic producers of OCTG decreased from 59.3

percent in 2011 to 58.3 percent in 2012 and increased to 59.0 percent in 2013, and were 58.1

percent in January-March 2014, compared with 59.3 percent in January-March 2013. U.S. 

producers and importers generally reported fluctuating raw material costs since 2011, with

increasing input prices toward the end of the period.

 Average costs of hot-rolled steel sheet used to make welded OCTG and scrap used to 

make hot-rolled billets used in the manufacture of seamless OCTG during January 2011 through 

March 2014 are presented in figure V-1. Figure V-2 presents longer-term trends, specifically 

January 2006-March 2014. Since a peak in 2011, there has been a general decline in prices for 

steel sheet and scrap, although prices increased slightly in late 2013 before declining in the first 

three months of 2014.

Figure V-1 

OCTG: Average consumer ferrous scrap prices (No. 1 heavy melt, Chicago) and hot-rolled steel 

sheet prices (Midwest), monthly, January 2011-March 2014

Source: American Metal Market.

V-1
Figure V-2

OCTG: Average consumer ferrous scrap prices (No. 1 heavy melt, Chicago) and hot-rolled steel 

sheet prices (Midwest), monthly, January 2006-March 2014

Source: American Metal Market.

In addition to steel, energy (mainly natural gas and electricity) accounts for a portion of 

OCTG production costs. Although the price of natural gas helps drive demand for OCTG, it is 

also a cost factor in pipe formation and mills’ and processors’ heat treatment. It also plays a 

large part in the cost of heat treating OCTG to a higher grade. The price of natural gas declined 

between 2011 and 2012, but increased in 2013 and the first quarter of 2014. The prices of 

electricity and iron ore remained relatively steady, changing by less than 1 percent between 

2011 and 2013 (table V-1).

Table V-1

OCTG: Prices of inputs, yearly, 2011-13 and January - March 2014

Item 2011 2012 2013 Jan.-Mar. 2014

Natural gas price (end-use,

industrial sector, per mmBTU) $5.13 $3.88 4.66 6.17

Electricity (industrial, cents per kwh) 6.82 6.67 6.82 7.02

Iron ore (per metric ton) $99.45 $98.16 98.75e n/a

Note.--An “e” after a number indicates that data for the period is unavailable, so the presented data is an estimate. 

Sources: Energy Information 

Administration, http://www.eia.doe.gov, http://www.eia.gov/forecasts/steo/tables/?tableNumber=8#, and

http://minerals.usgs.gov/minerals/pubs/commodity/iron_ore/mcs-2014-feore.pdf.

V-2
Seamless OCTG producers generally produce their own billets. Billets are not typically 

sold in the United States. Figure V-3 presents one measure of the cost of billets, though it 

should be noted this may be a proxy for the use of a firm’s billets, not a direct cost of buying 

them.

Figure V-3

OCTG: Hot-rolled billet prices (Black Sea export, FOB), weekly, January 2011-March 2014

Source: Metal Bulletin.

U.S. inland transportation costs

Seven U.S. producers provided usable U.S. transportation costs, averaging 6 percent and 

ranging from 4 to 10 percent of the total delivered cost of their U.S. shipments.1

 Although U.S.-

produced OCTG is shipped a variety of distances, U.S. producers generally shipped OCTG 

between 101 and 1,000 miles (44.0 percent) or more than 1,000 miles (45.4 percent) in 2013.

2

Six producers reported arranging transportation for purchasers, whereas seven reported that 

purchasers arrange it themselves.

Nineteen importers reported usable U.S. transportation costs, with eight reporting 

transportation costs of 2 percent or less and ranged from 0.2 to 10 percent of total delivered

1 Two producers additionally reported transportation costs as either zero or above 50 percent. These 

data were not used. 2 See Part II for further detail regarding shipment distances.

V-3

 
costs.3 On average, importers’ inland transportation costs averaged 4 percent. Low 

transportation costs were expected, as more than 75 percent of imports from these nine 

countries were shipped distances of less than 100 miles from their point of importation, 

whereas less than 6 percent was shipped distances of greater than 1,000 miles.4 Thirty-three of 

40 responding importers reported that purchasers arrange transportation.

PRICING PRACTICES

Pricing methods

Pricing basis

Most firms reported selling OCTG on a spot basis. Eleven U.S. producers reported that 

they set prices for OCTG on a transaction-by-transaction basis, 4 reported selling via contracts, 

and 1 reported using price lists (table V-2). A majority of importers also reported setting prices 

on a transaction-by-transaction basis. One producer (***) and one importer (***) reported 

using current competitive offers for all of its sales whether on the spot market or subject to 

short- or long-term contracts. One other producer (***) noted that most of its sales are 

program sales (discussed in greater detail below).

Table V-2

OCTG: U.S. producers’ and importers’ reported price setting methods, by number of responding 

firms1

Method U.S. producers Importers

Transaction-by-transaction 11 43

Contract 4 11

Set price list 1 1

Other 2 1 1 The sum of responses down will not add up to the total number of responding firms as each firm was instructed to 

check all applicable price setting methods employed.

Source: Compiled from data submitted in response to Commission questionnaires.

The largest proportion – 56 percent – of domestic sales are program sales. The 

remainder of domestic sales is divided between short-term and long-term contracts or spot 

sales (table V-3). 

3 Transportation costs reported by importers *** were reported to be 10 percent. 4 As discussed in Part IV, a substantial portion of U.S. imports enter through the port of HoustonGalveston, Texas. 

V-4

 
Table V-3

OCTG: U.S. producers’ and importers’ reported shares of contracts, program sales, and spot 

sales, by type of sale, 2013

* * * * * * *

Two producers (***) reported using long-term contracts unrelated to program sales, 

whereas four (***) reported selling via short-term contracts unrelated to program sales. These 

sales accounted for *** and *** percent of the volume of domestic sales in 2013, respectively. 

One producer (***) sells via long-term program sales, but these only accounted for *** percent 

of its sales in 2013. 

U.S. importers most frequently reported spot sales of OCTG, with exceptions for imports 

from Korea (*** percent) and Saudi Arabia (*** percent). Overall, 47 percent of subject 

imports were sold on the spot market in 2013. The next most-frequently used method is via 

short-term contracts, which accounted for another 38 percent.

5

 Short-term program sales 

accounted for less than 10 percent of importers’ sales, but were made for imports from all 

countries except Saudi Arabia (***), Thailand, and Ukraine (***). 

Program sales

A program sale was defined in the Commission’s instructions as “an agreement or 

obligation among end users, distributor, and/or mills which specifies the type of OCTG, 

approximate quantities to be supplied, delivery time frames, and/or prices. Prices and/or 

quantities may be subject to adjustment.” Due to the variable nature of these agreements, 

further information was requested of producers, purchasers, and importers who had program 

sales from the nine named countries to help to define characteristics of program sales. The 

characteristic noted by most participants as being included in program sale agreements was the 

grade of OCTG. Slightly fewer firms cited the delivery schedule and estimated consumption. 

More producers and importers reported a general pricing framework than firm prices, but a 

slight majority of purchasers reported the opposite. In all, 9 of 14 responding producers, 4 of 44 

responding importers, and 31 of 52 purchasers reported buying or selling via program sales 

since January 1, 2011. Their responses are summarized in table V-4. 

5 These data are heavily influenced by data reported for ***. Nonetheless, importers of OCTG from 

all nine countries reported sales in 2013 pursuant to short-term contracts.

V-5

 
Table V-4

OCTG: Characteristics of program sales

Agreement characteristic U.S. producers Importers Purchasers

Firm prices 5 2 22

General pricing framework 9 3 20

Renegotiable prices 6 0 18

Grade of OCTG 9 4 29

Connection type 7 1 21

Delivery schedule 8 3 28

Estimated consumption 8 2 26

Other1

1 0 8 1 Other characteristics noted include: distributor inventory on hand, end finish, material specification, payment 

terms and conditions, range length, relationships, shipping locations, size, standard vs. non-standard thread 

type, time frame, and weight.

Source: Compiled from data submitted in response to Commission questionnaires.

Market participants were also asked which portions of the agreements or obligations 

were legally binding. Available responses are presented in table V-5. Although most responses 

described program sales as not legally binding, characterizations ranged substantially.

Table V-5

OCTG: Legally binding portions of program sale agreements

* * * * * * *

Producers, importers, and purchasers were asked about their involvement with program 

sales. Nine of 14 responding producers reported having sold OCTG via program sales since 

January 1, 2011, accounting for at least 2.25 million short tons of OCTG in 2013.

6 Only 4 of 44

importers – *** – reported program sales of OCTG imported from the subject countries, 

accounting for *** short tons of OCTG in 2013. Twenty-one of 52 responding purchasers 

reported no purchases of any OCTG pursuant to program sales, 25 purchased from domestic 

sources pursuant to program sales, 22 from the subject countries, and 18 from nonsubject 

countries. Purchasers reported purchasing 2.5 million short tons of OCTG via program sales 

from domestic sources and 664,000 short tons from nonsubject sources in 2013. They also 

reported purchasing 435,000 short tons from the subject countries pursuant to program sales, 

with each country named by at least one purchaser.7

 

6 *** gave a lower-bound estimate and did not include tonnage for coupling stock or tubing. 7 Of this total, *** short tons were imported from Korea, and *** short tons were imported from 

Turkey (Borusan). The remainder is accounted for by purchasers which bought OCTG imported from at 

least two named countries via program sales. After Korea, Turkey and Saudi Arabia were most 

frequently mentioned as the source. Purchasers that included Taiwan did not specify the firm that 

manufactured or exported the OCTG, so the total may be slightly overstated if any was purchased from 

Chung Hung in Taiwan due to this. The total may be understated, however, because some firms which 

V-6

 
Six of 37 responding importers noted that they had tried to sell OCTG from these 

countries via program sale agreements but had been unable to do so.8

 Importer *** stated 

that occasionally overseas shipments are late, which create supply disruptions. Importer ***

stated that program sales are dominated by domestic producers, which makes it difficult for 

distributors of imported product to compete. Various reasons were stated by approximately 

half of the 32 importers that did not attempt to sell imported OCTG from the nine countries.

Most of these reported either not importing from these countries, or that they sell product in 

other ways. Among importers that did provide reasons, *** stated that it supplies distributors 

that participate in program sales, *** stated that it does not qualify for program sales mainly on 

the basis of not maintaining U.S. inventories, *** noted that its material is unfinished so it 

cannot supply end users, *** only sells to distributors, *** prefers spot sales and spot 

purchases, and *** stated that deliveries would be too inconsistent and take too long to sell via 

programs.

Fourteen of 47 responding purchasers stated that they had attempted to purchase 

OCTG via program sales but could not. Among the purchasers that gave reasons why they were 

unsuccessful in making program purchases, *** noted an inventory requirement, *** stated 

that its customer’s orders sometimes do not allow enough time for mill scheduling to produce 

the OCTG within their time requirement, *** noted that there are volume restrictions based on 

mill bookings, *** reported that sometimes suppliers are unwilling to offer program pricing, 

and *** stated that the “Koreans are going direct to end users to take out distributors.” Among 

the 33 other purchasers, 8 reported that they have been successful in buying via program sales,

9 indicated no desire to purchase via programs, 10 provided no explanation, and 6 provided 

other reasons. When asked about the importance of foreign inventories in relation to program 

sales, purchasers’ responses were disparate with no general consensus, ranging from “not 

important” to “extraordinarily important!”

Firms were also asked if volumes not sold pursuant to program sales could substitute for 

volumes that were sold as part of program sales. Ten of 12 responding producers and 35 of 44 

responding purchasers indicated that there could be substitution, while 20 of 35 responding

importers indicated the opposite. When asked whether non-program sales of OCTG affect the 

prices of program sales, 8 of 10 producers and 27 of 43 responding purchasers stated that there 

is an effect, while 20 of 36 responding importers indicated the opposite. 

Contract terms

The length of contracts in the market varied. Nine U.S. producers’ short-term contracts 

were reported to be between 11⁄2 and 12 months long (averaging five months). Terms also 

reported purchasing via program sales did not report quantities—four which purchased from subject 

countries, and two each which purchased from domestic firms and nonsubject sources. Among those 

that did not report a quantity was ***. 

8 Producers were asked this same question regarding their domestically-produced OCTG. Although 

four replied that they had attempted to sell but had been unable to do so, these four also reported that 

they had some sales of OCTG via program sale agreements since January 1, 2011. Two of these stated 

that some of their attempted program sales were unsuccessful, based on competition from foreign 

sources. In addition to these four, ***.

V-7

 
varied: two responding producers’ short-term contracts fixed only price, whereas three fixed 

price and quantity; four typically had renegotiable prices whereas four did not; and six typically 

did not contain meet-or-release clauses, compared with two which did not.

9 Fourteen

responding importers which use short-term contracts reported durations ranging between one 

and six months (averaging three months), typically fixed both price and quantity, did not allow 

price renegotiation, or contain meet-or-release provisions. Only one importer (***) reported 

data concerning its long-term contract provisions; it is typically 4 years in length, and does not 

contain any meet-or-release provisions.

Producers and importers were asked whether raw material prices were referenced in 

OCTG price negotiations. Eight of 11 responding producers reported that they were, but 23 of 

38 responding importers indicated that they were not referenced. The input most frequently 

noted by domestic producers and importers was hot-rolled steel coils. Six of 12 responding 

producers indicated that OCTG prices were linked or indexed to raw material prices available in 

publications such as CRU, Pipe Logix, or an index for scrap steel. Two of these producers noted

that it is either only for certain purchase agreements, while another producer stated that it has 

in the past, but does not have any current agreements that are linked. Only four of 42 

responding purchasers indicated that their sales are tied to price indices.

Sales terms and discounts

Twelve of 16 responding producers and 26 of 34 responding importers reported that the 

majority of their sales were on an f.o.b. basis; 4 producers and 8 importers reported that most 

of their sales were on a delivered basis, and 2 producers reported selling on both bases. The 

majority of producers shipping on an f.o.b. basis do so from their mill, while a majority of 

importers shipping on an f.o.b. basis (14) do so from Houston, Texas; six others noted selling 

from the port of entry or dock, which may also include Houston as a port of entry or dock. 

Slightly more than half (8 of 14) of responding producers do not offer discounts to 

purchasers of OCTG except for early payment discounts, whereas four offer quantity or annual 

volume discounts (***). The industry standard payment terms producers offered are 2% 10/net 

30 days, although *** offers terms of 2% 25/net 60.10 Thirty-six importers offer no discounts, 

whereas four (***) offer quantity or total volume discounts. Five importers offer a discount 

other than quantity discounts: four offer a 2 percent early payment discount and four offer 

discounts on a transaction-by-transaction basis. Sales are typically made on a net 30 payment 

basis, although seven responding importers reported net 60 payment terms. One importer, 

***, stated that its standard payment terms are net 180 days. 

9 Not all producers which indicated that they used short-term contracts responded to all portions of 

this question.

10 Eight of 14 responding producers offer these terms, while another three offer net 30 terms and 

three offer something different.

V-8

 
PRICE DATA

The Commission asked U.S. producers (including processors) and U.S. importers of OCTG

to provide quarterly data for the total quantity and value of OCTG that was shipped to 

unrelated customers in the U.S. market. Quarterly data were requested for the period January 

2011–March 2014. The products for which pricing data were requested are as follows:

Product 1.-- Tubing, Grade L-80, 2 7/8" O.D., 6.5 lbs./ft., threaded and coupled, range 2, 

seamless

Product 2.-- Tubing, Grade J-55, 2 3/8" O.D., 4.7 lbs./ft., threaded and coupled, range 2, welded

Product 3.-- Casing, Grade J-55, 5 1⁄2" O.D., 17.0 lbs./ft., threaded and coupled, range 3, welded

Product 4.-- Casing, Grade P-110, 5 1⁄2" O.D., 17.0 lbs./ft., threaded and coupled, range 3, 

seamless

Product 5.-- Casing, Grade J-55, 8 5/8" O.D., 32.0 lbs./ft., threaded and coupled, range 3, 

welded

Product 6.-- Casing, Grade J-55, 9 5/8" O.D., 36.0 lbs./ft., threaded and coupled, range 3, 

welded.

Ten U.S. producers (mills and processors) and 23 importers provided usable price data 

for sales of the six products, although not all firms reported prices for all products and all 

quarters.

11 After the Commission’s hearing, firms that had supplied pricing data for seamless 

products 1 and 4 were asked to divide their sales for those products among OCTG that had APIstandard threading and OCTG that had non-API standard threading.12 Both subsets of data are 

presented below.13

 Reported pricing products represented 11.6 percent of U.S. shipments of U.S.-

produced products in the period for which data were collected. Among subject imports, they 

represent *** percent of shipments of imported product from India, *** from Korea, ***

11 U.S. price data consist primarily of data reported by U.S. mills but also include data reported by 

U.S. non-toll processors ***. No importer reported any price data for imported items 1-6 that 

underwent heat treatment in the United States prior to being sold (see Importer’s Questionnaire, p. 

115). 12 Premium threading is more common in high-stress applications where seamless OCTG is used, and 

can add a price premium onto the cost of the OCTG. Hearing transcript, p. 231 (Scianna). To avoid 

commingling the pricing data, data for the two seamless pricing products were resubmitted separately. 

Data revisions breaking out product 1 *** and revisions for product 4 ***. 

13 Some data that was reported by importers or producers was misclassified with respect to the 

described pricing products. These data were adjusted in order to increase the accuracy of the 

comparisons.

V-9

 
percent from the Philippines, *** percent from Saudi Arabia, *** percent from Taiwan, ***

percent from Thailand, *** percent from Turkey, *** percent from Ukraine, and *** percent 

from Vietnam.14 For Chung Hung in Taiwan, which was determined by Commerce to be 

nonsubject, pricing data accounted for *** percent of its shipments from Taiwan. Pricing data 

regarding imports from Chung Hung in Taiwan, along with pricing data for five nonsubject 

countries (Argentina, Canada, Germany, Japan, and Mexico) are presented in appendix E. 

Domestic price data, along with price data for subject countries are presented in tables V-6 to 

V-11 and figures V-4 to V-9. All data are reported in short tons and dollars per short ton.

Products 6 and 5 had the largest volumes among the pricing products, respectively.

14 The selected products are representative of those used in the market. Because there are a large 

variety of grades and sizes of casing and tubing in the OCTG market, these percentages are expectedly 

small. In particular, plain end OCTG does not represent a large proportion of domestic sales, but does 

represent a large proportion of OCTG imports.

V-10

 
Table V-6

OCTG: Weighted-average f.o.b. prices and quantities of domestic and imported product 1,

1

including API and non-API threading, non-API threading price premium, and margins of 

underselling/(overselling), by quarter, January 2011-March 2014

Period

United States – API2 United States – Non-API2 India

Price (dollars 

per ton) Quantity (tons)

Price 

(dollars 

per ton)

Quantity 

(tons) Premium

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. 1,804 5,531 *** *** *** *** *** ***

 Apr.-Jun. 1,773 6,448 -- 0 -- -- 0 --

 Jul.-Sept. 1,960 7,390 -- 0 -- -- 0 --

 Oct.-Dec. 2,040 5,508 -- 0 -- -- 0 --

2012:

 Jan.-Mar. 2,034 5,663 *** *** *** *** *** ***

 Apr.-Jun. 2,074 6,741 -- 0 -- *** *** ***

 Jul.-Sept. 2,006 12,623 -- 0 -- *** *** ***

 Oct.-Dec. 1,911 10,148 *** *** *** *** *** ***

2013:

 Jan.-Mar. 1,766 6,980 -- 0 -- *** *** ***

 Apr.-Jun. 1,839 9,865 *** *** *** *** *** ***

 Jul.-Sept. 1,858 11,253 -- 0 -- *** *** ***

 Oct.-Dec. 1,833 8,116 *** *** *** *** *** ***

2014:

 Jan.-Mar. 1,783 9,014 *** *** *** -- 0 --

Period

Thailand Ukraine Vietnam

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. -- 0 -- *** *** *** -- 0 --

 Apr.-Jun. -- 0 -- *** *** *** -- 0 --

 Jul.-Sept. -- 0 -- *** *** *** -- 0 --

 Oct.-Dec. -- 0 -- *** *** *** -- 0 --

2012:

 Jan.-Mar. -- 0 -- *** *** *** -- 0 --

 Apr.-Jun. -- 0 -- *** *** *** -- 0 --

 Jul.-Sept. *** *** *** *** *** *** -- 0 --

 Oct.-Dec. *** *** *** *** *** *** -- 0 --

2013:

 Jan.-Mar. -- 0 -- *** *** *** *** *** ***

 Apr.-Jun. *** *** *** *** *** *** *** *** ***

 Jul.-Sept. *** *** *** *** *** *** -- 0 --

 Oct.-Dec. *** *** *** *** *** *** *** *** ***

2014:

 Jan.-Mar. -- 0 -- -- 0 -- -- 0 --

Note..—One quarter of pricing data were received for imports from Turkey. Turkey does not produce seamless OCTG, 

so it has been excluded from the data set.

1 Product 1.-- Tubing, Grade L-80, 2 7/8" O.D., 6.5 lbs./ft., threaded and coupled, range 2, seamless. 2 Domestic product 1 is divided into 2 subsets – the first subset contains data for API-threaded OCTG, and the second 

set contains data for non-API standard threading such as premium or semi-premium threading. No importers of subject 

OCTG reported non-API threading, so margin comparisons are with respect to API-standard threaded OCTG. The 

“premium” column represents the difference between the U.S. sales price for non-API standard threaded product with 

API-standard threaded product.

Source: Compiled from data submitted in response to Commission questionnaires.

V-11
Table V-7

OCTG: Weighted-average f.o.b. prices and quantities of domestic and imported product 2,1 and 

margins of underselling/(overselling), by quarter, January 2011-March 2014

Period

United States India Korea

Price 

(dollars 

per ton)

Quantity 

(tons)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. *** *** *** *** *** *** *** ***

 Apr.-Jun. *** *** -- 0 -- *** *** ***

 Jul.-Sept. 1,565 10,256 -- 0 -- *** *** ***

 Oct.-Dec. 1,566 12,470 -- 0 -- *** *** ***

2012:

 Jan.-Mar. 1,538 8,482 -- 0 -- *** *** ***

 Apr.-Jun. 1,478 10,872 -- 0 -- *** *** ***

 Jul.-Sept. 1,448 5,078 -- 0 -- *** *** ***

 Oct.-Dec. 1,364 6,923 *** *** *** *** *** ***

2013:

 Jan.-Mar. 1,399 7,327 *** *** *** *** *** ***

 Apr.-Jun. 1,329 7,774 -- 0 -- *** *** ***

 Jul.-Sept. 1,276 8,762 *** *** *** *** *** ***

 Oct.-Dec. *** *** *** *** *** *** *** ***

2014:

 Jan.-Mar. *** *** -- 0 -- *** *** ***

Period

Philippines Turkey

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. -- 0 -- *** *** ***

 Apr.-Jun. *** *** *** *** *** ***

 Jul.-Sept. *** *** *** *** *** ***

 Oct.-Dec. *** *** *** *** *** ***

2012:

 Jan.-Mar. *** *** *** *** *** ***

 Apr.-Jun. *** *** *** *** *** ***

 Jul.-Sept. *** *** *** *** *** ***

 Oct.-Dec. *** *** *** *** *** ***

2013:

 Jan.-Mar. *** *** *** 1,354 705 3.2

 Apr.-Jun. *** *** *** *** *** ***

 Jul.-Sept. *** *** *** *** *** ***

 Oct.-Dec. *** *** *** 1,154 1,722 ***

2014:

 Jan.-Mar. 1,171 514 *** *** *** *** 1 Product 2.-- Tubing, Grade J-55, 2 3/8" O.D., 4.7 lbs./ft., threaded and coupled, range 2, welded.

Source: Compiled from data submitted in response to Commission questionnaires.

V-12
Table V-8

OCTG: Weighted-average f.o.b. prices and quantities of domestic and imported product 3,1 and 

margins of underselling/(overselling), by quarter, January 2011-March 2014

Period

United States India Korea

Price 

(dollars per 

ton)

Quantity 

(tons)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. 1,153 12,402 -- 0 -- *** *** ***

 Apr.-Jun. 1,202 9,836 -- 0 -- *** *** ***

 Jul.-Sept. 1,302 11,821 -- 0 -- *** *** ***

 Oct.-Dec. 1,293 13,536 -- 0 -- *** *** ***

2012:

 Jan.-Mar. 1,277 11,373 -- 0 -- -- 0 --

 Apr.-Jun. 1,272 13,787 -- 0 -- *** *** ***

 Jul.-Sept. 1,258 15,566 -- 0 -- *** *** ***

 Oct.-Dec. 1,187 11,180 *** *** *** *** *** ***

2013:

 Jan.-Mar. 1,117 8,458 -- 0 -- -- 0 --

 Apr.-Jun. 1,149 11,634 *** *** *** *** *** ***

 Jul.-Sept. 1,081 13,159 *** *** *** *** *** ***

 Oct.-Dec. 1,120 9,572 -- 0 -- *** *** ***

2014:

 Jan.-Mar. 1,127 10,562 -- 0 -- *** *** ***

Period

Philippines Taiwan (subject) Turkey

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. -- 0 -- *** *** *** -- 0 --

 Apr.-Jun. -- 0 -- *** *** *** *** *** ***

 Jul.-Sept. -- 0 -- *** *** *** *** *** ***

 Oct.-Dec. -- 0 -- -- 0 -- *** *** ***

2012:

 Jan.-Mar. -- 0 -- -- 0 -- *** *** ***

 Apr.-Jun. *** *** *** *** *** *** *** *** ***

 Jul.-Sept. -- 0 -- *** *** *** *** *** ***

 Oct.-Dec. *** *** *** *** *** *** *** *** ***

2013:

 Jan.-Mar. *** *** *** *** *** *** -- 0 --

 Apr.-Jun. *** *** *** *** *** *** *** *** ***

 Jul.-Sept. -- 0 -- *** *** *** *** *** ***

 Oct.-Dec. *** *** *** *** *** *** *** *** ***

2014:

 Jan.-Mar. *** *** *** *** *** *** *** *** ***

Table continued on next page.

V-13
Table V-8--Continued

OCTG: Weighted-average f.o.b. prices and quantities of domestic and imported product 3,1 and 

margins of underselling/(overselling), by quarter, January 2011-March 2014

Period

United States Vietnam

Price (dollars 

per ton) Quantity (tons)

Price (dollars 

per ton) Quantity (tons) Margin (percent)

2011:

 Jan.-Mar. 1,153 12,402 -- 0 --

 Apr.-Jun. 1,202 9,836 -- 0 --

 Jul.-Sept. 1,302 11,821 *** *** ***

 Oct.-Dec. 1,293 13,536 *** *** ***

2012:

 Jan.-Mar. 1,277 11,373 *** *** ***

 Apr.-Jun. 1,272 13,787 *** *** ***

 Jul.-Sept. 1,258 15,566 *** *** ***

 Oct.-Dec. 1,187 11,180 *** *** ***

2013:

 Jan.-Mar. 1,117 8,458 *** *** ***

 Apr.-Jun. 1,149 11,634 *** *** ***

 Jul.-Sept. 1,081 13,159 *** *** ***

 Oct.-Dec. 1,120 9,572 *** *** ***

2014:

 Jan.-Mar. 1,127 10,562 *** *** *** 1 Product 3.-- Casing, Grade J-55, 5 1⁄2" O.D., 17.0 lbs./ft., threaded and coupled, range 3, welded.

Source: Compiled from data submitted in response to Commission questionnaires.

V-14
Table V-9

OCTG: Weighted-average f.o.b. prices and quantities of domestic and imported product 4,1

including API and non-API threading, non-API threading price premium, and margins of 

underselling/(overselling), by quarter, January 2011-March 2014

Period

United States – API2 United States – non-API2 India

Price 

(dollars per 

ton)

Quantity 

(tons)

Price 

(dollars 

per ton)

Quantity 

(tons) Premium

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. 1,915 1,698 -- 0 -- *** *** ***

 Apr.-Jun. 1,806 203 -- 0 -- *** *** ***

 Jul.-Sept. *** *** -- 0 -- 1,659 1,251 ***

 Oct.-Dec. *** *** -- 0 -- *** *** ***

2012:

 Jan.-Mar. 1,895 6,085 -- 0 -- 1,736 867 8.4

 Apr.-Jun. 1,905 5,146 -- 0 -- *** *** ***

 Jul.-Sept. 1,762 4,385 -- 0 -- *** *** ***

 Oct.-Dec. *** *** -- 0 -- *** *** ***

2013:

 Jan.-Mar. 1,600 9,006 -- 0 -- *** *** ***

 Apr.-Jun. *** *** *** *** *** *** *** ***

 Jul.-Sept. 1,520 2,701 *** *** *** 1,473 1,067 3.1

 Oct.-Dec. 1,544 1,362 *** *** *** 3 *** *** ***

2014:

 Jan.-Mar. *** *** *** *** *** *** *** ***

Period

Saudi Arabia Thailand Ukraine

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. *** *** *** -- 0 -- *** *** ***

 Apr.-Jun. *** *** *** -- 0 -- *** *** ***

 Jul.-Sept. *** *** *** -- 0 -- -- 0 --

 Oct.-Dec. *** *** *** -- 0 -- *** *** ***

2012:

 Jan.-Mar. *** *** *** *** *** *** *** *** ***

 Apr.-Jun. *** *** *** -- 0 -- *** *** ***

 Jul.-Sept. *** *** *** -- 0 -- *** *** ***

 Oct.-Dec. *** *** *** *** *** *** *** *** ***

2013:

 Jan.-Mar. *** *** *** -- 0 -- -- 0 --

 Apr.-Jun. *** *** *** -- 0 -- -- 0 --

 Jul.-Sept. *** *** *** -- 0 -- *** *** ***

 Oct.-Dec. *** *** *** *** *** *** -- 0 --

2014:

 Jan.-Mar. *** *** *** -- 0 -- -- 0 --

Table continued on next page.

V-15
Table V-9--Continued

OCTG: Weighted-average f.o.b. prices and quantities of domestic and imported product 4,1

including API and non-API threading, non-API threading price premium, and margins of 

underselling/(overselling), by quarter, January 2011-March 2014

Period

United States – API2 Vietnam

Price (dollars per 

ton) Quantity (tons)

Price (dollars per 

ton) Quantity (tons)

Margin 

(percent)

2011:

 Jan.-Mar. 1,915 1,698 -- 0 --

 Apr.-Jun. 1,806 203 -- 0 --

 Jul.-Sept. *** *** -- 0 --

 Oct.-Dec. *** *** -- 0 --

2012:

 Jan.-Mar. 1,895 6,085 -- 0 --

 Apr.-Jun. 1,905 5,146 *** *** ***

 Jul.-Sept. 1,762 4,385 -- 0 --

 Oct.-Dec. *** *** -- 0 --

2013:

 Jan.-Mar. 1,600 9,006 -- 0 --

 Apr.-Jun. *** *** -- 0 --

 Jul.-Sept. 1,520 2,701 *** *** ***

 Oct.-Dec. 1,544 1,362 -- 0 --

2014:

 Jan.-Mar. *** *** -- 0 -- 1 Product 4.-- Casing, Grade P-110, 5 1⁄2" O.D., 17.0 lbs./ft., threaded and coupled, range 3, seamless. 2 Domestic product 4 is divided into 2 subsets – the first subset contains data for API-threaded OCTG, and the 

second set contains data for non-API standard threading such as premium or semi-premium threading. No 

importers of subject OCTG reported non-API threading, so margin comparisons are with respect to API-standard 

threaded OCTG. The “premium” column represents the difference between the U.S. sales price for non-API 

standard threaded product with API-standard threaded product. 3 Price data for this quarter were affected by ***.

Source: Compiled from data submitted in response to Commission questionnaires.

V-16
Table V-10

OCTG: Weighted-average f.o.b. prices and quantities of domestic and imported product 5,

1 and 

margins of underselling/(overselling), by quarter, January 2011-March 2014

Period

United States India Korea

Price 

(dollars per 

ton)

Quantity 

(tons)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. 1,130 17,726 *** *** *** *** *** ***

 Apr.-Jun. 1,208 13,018 -- 0 -- *** *** ***

 Jul.-Sept. 1,258 9,338 *** *** *** *** *** ***

 Oct.-Dec. 1,296 18,333 *** *** *** *** *** ***

2012:

 Jan.-Mar. 1,280 22,639 -- 0 -- *** *** ***

 Apr.-Jun. 1,272 23,542 -- 0 -- -- 0 --

 Jul.-Sept. 1,242 25,329 -- 0 -- *** *** ***

 Oct.-Dec. 1,193 25,024 *** *** *** *** *** ***

2013:

 Jan.-Mar. 1,110 23,751 *** *** *** *** *** ***

 Apr.-Jun. 1,104 25,261 *** *** *** -- 0 --

 Jul.-Sept. 1,130 25,321 *** *** *** -- 0 --

 Oct.-Dec. 1,118 24,952 -- 0 -- -- 0 --

2014:

 Jan.-Mar. 1,131 28,322 *** *** *** *** *** ***

Period

Philippines Taiwan (subject) Turkey

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. -- 0 -- *** *** *** *** *** ***

 Apr.-Jun. -- 0 -- *** *** *** *** *** ***

 Jul.-Sept. -- 0 -- *** *** *** -- 0 --

 Oct.-Dec. -- 0 -- *** *** *** *** *** ***

2012:

 Jan.-Mar. -- 0 -- *** *** *** *** *** ***

 Apr.-Jun. -- 0 -- *** *** *** *** *** ***

 Jul.-Sept. *** *** *** *** *** *** *** *** ***

 Oct.-Dec. -- 0 -- *** *** *** *** *** ***

2013:

 Jan.-Mar. *** *** *** *** *** *** *** *** ***

 Apr.-Jun. *** *** *** *** *** *** -- 0 --

 Jul.-Sept. *** *** *** *** *** *** *** *** ***

 Oct.-Dec. -- 0 -- *** *** *** *** *** ***

2014:

 Jan.-Mar. *** *** *** *** *** *** *** *** ***

Table continued on next page.

V-17
Table V-10--Continued

OCTG: Weighted-average f.o.b. prices and quantities of domestic and imported product 5,

1 and 

margins of underselling/(overselling), by quarter, January 2011-March 2014

Period

United States Vietnam

Price (dollars 

per ton) Quantity (tons)

Price (dollars 

per ton) Quantity (tons) Margin (percent)

2011:

 Jan.-Mar. 1,130 17,726 *** *** ***

 Apr.-Jun. 1,208 13,018 *** *** ***

 Jul.-Sept. 1,258 9,338 *** *** ***

 Oct.-Dec. 1,296 18,333 *** *** ***

2012:

 Jan.-Mar. 1,280 22,639 *** *** ***

 Apr.-Jun. 1,272 23,542 *** *** ***

 Jul.-Sept. 1,242 25,329 *** *** ***

 Oct.-Dec. 1,193 25,024 *** *** ***

2013:

 Jan.-Mar. 1,110 23,751 *** *** ***

 Apr.-Jun. 1,104 25,261 *** *** ***

 Jul.-Sept. 1,130 25,321 *** *** ***

 Oct.-Dec. 1,118 24,952 *** *** ***

2014:

 Jan.-Mar. 1,131 28,322 *** *** *** 1 Product 5.-- Casing, Grade J-55, 8 5/8" O.D., 32.0 lbs./ft., threaded and coupled, range 3, welded.

Source: Compiled from data submitted in response to Commission questionnaires.

V-18
Table V-11

OCTG: Weighted-average f.o.b. prices and quantities of domestic and imported product 6,1 and 

margins of underselling/(overselling), by quarter, January 2011-March 2014

Period

United States India Korea

Price 

(dollars per 

ton)

Quantity 

(tons)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. 1,155 28,362 -- 0 -- *** *** ***

 Apr.-Jun. 1,237 34,555 -- 0 -- *** *** ***

 Jul.-Sept. 1,291 30,419 -- 0 -- *** *** ***

 Oct.-Dec. 1,294 43,763 -- 0 -- *** *** ***

2012:

 Jan.-Mar. 1,293 47,873 -- 0 -- *** *** ***

 Apr.-Jun. 1,270 35,100 *** *** *** *** *** ***

 Jul.-Sept. 1,221 43,430 *** *** *** *** *** ***

 Oct.-Dec. 1,163 43,753 *** *** *** *** *** ***

2013:

 Jan.-Mar. 1,112 44,384 *** *** *** *** *** ***

 Apr.-Jun. 1,101 54,817 *** *** *** *** *** ***

 Jul.-Sept. 1,082 50,126 *** *** *** *** *** ***

 Oct.-Dec. 1,102 56,113 *** *** *** *** *** ***

2014:

 Jan.-Mar. 1,103 42,111 *** *** *** *** *** ***

Period

Philippines Taiwan (subject) Turkey

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

Price 

(dollars 

per ton)

Quantity 

(tons)

Margin 

(percent)

2011:

 Jan.-Mar. -- 0 -- -- 0 -- *** *** ***

 Apr.-Jun. -- 0 -- *** *** *** *** *** ***

 Jul.-Sept. -- 0 -- *** *** *** *** *** ***

 Oct.-Dec. -- 0 -- *** *** *** *** *** ***

2012:

 Jan.-Mar. -- 0 -- *** *** *** *** *** ***

 Apr.-Jun. -- 0 -- *** *** *** *** *** ***

 Jul.-Sept. *** *** *** *** *** *** *** *** ***

 Oct.-Dec. *** *** *** *** *** *** *** *** ***

2013:

 Jan.-Mar. *** *** *** *** *** *** *** *** ***

 Apr.-Jun. *** *** *** *** *** *** *** *** ***

 Jul.-Sept. *** *** *** *** *** *** *** *** ***

 Oct.-Dec. *** *** *** *** *** *** *** *** ***

2014:

 Jan.-Mar. *** *** *** *** *** *** *** *** *** 1 Product 6.-- Casing, Grade J-55, 9 5/8" O.D., 36.0 lbs./ft., threaded and coupled, range 3, welded.

Source: Compiled from data submitted in response to Commission questionnaires.

Figure V-4

OCTG: Weighted-average f.o.b. prices and quantities of domestic and imported product 1, by 

quarter, January 2011-March 2014

* * * * * * *

V-19
Figure V-5

OCTG: Weighted-average f.o.b. prices and quantities of domestic product 2, by quarter, January 

2011-March 2014

* * * * * * *

Figure V-6

OCTG: Weighted-average f.o.b. prices and quantities of domestic product 3, by quarter, January 

2011-March 2014

* * * * * * *

Figure V-7

OCTG: Weighted-average f.o.b. prices and quantities of domestic product 4, by quarter, January 

2011-March 2014

* * * * * * *

Figure V-8

OCTG: Weighted-average f.o.b. prices and quantities of domestic product 5, by quarter, January 

2011-March 2014

* * * * * * *

Figure V-9

OCTG: Weighted-average f.o.b. prices and quantities of domestic product 6, by quarter, January 

2011-March 2014

* * * * * * *

Price trends

In general, prices increased during 2011, decreased during 2012 and in the first quarter 

of 2013, and then leveled off or slightly increased in the second half of 2013 and the first 

quarter of 2014. Table V-12 summarizes the price trends, by country and by product. Domestic 

prices were lower (1.2 to 19.3 percent) for five of the six products in the first quarter of 2014 

compared with the first quarter of 2011.

15 Domestic prices were highest in either the third or 

fourth quarter of 2011 for five of the six pricing products, and lowest in the first through third 

quarters of 2013 for five of the six pricing products. Domestic prices for product 2, however, 

generally declined from its peak in late 2011 through the rest of the period. 

15 The price of product 5 increased by 0.1 percent.

V-20

 
Table V-12

OCTG: Summary of weighted-average prices for products 1 through 6 from the United States and 

subject countries

* * * * * * *

Prices for the domestically produced welded OCTG products (products 2, 3, 5, and 6) 

moved in a somewhat similar fashion between the first quarter of 2011 and the first quarter of 

2014, as did the seamless products (products 1 and 4). The largest quarterly price decreases 

occurred with respect to the seamless products. In the last two quarters of 2012, prices for 

product 4 decreased by more than *** percent each quarter, whereas prices for product 1 

decreased by approximately *** percent in those two quarters combined, but a further *** 

percent in the first quarter of 2013. General price trends for domestic prices are also presented 

in figure V-10. 

Figure V-10

OCTG: Quarterly changes in domestic prices for products 1 through 6

* * * * * * *

Pricing data for importers was more varied, both in terms of price changes between the 

first and last year of the period, and with respect to when the highest or lowest values were 

observed. Importer price changes ranged between a decrease of 42.9 percent and an increase 

of 24.3 percent. Prices for imported OCTG were lower in the last quarter of available data 

compared with the first quarter of available data in 16 of 19 comparisons where data were 

available in at least one of the first four quarters and one of the last four quarters of the period.

In general, the prices for the imported product tended to move in the same general 

direction as domestic prices over time, although with much more varied patterns. Part of this 

may be due to some large swings in quantities of imports from various countries. For example, 

for product 1 from India, there were *** short tons shipped in the third quarter of 2012 

compared with *** short tons in the preceding quarter and *** tons in the quarter afterward. 

Some variation also may reflect differences in the particular importers reporting in a given 

quarter. 

Price comparisons

As shown in table V-13, prices for OCTG imported from the subject countries were 

below those for U.S.-produced product in 239 of 276 possible instances; margins of underselling 

ranged from 0.3 to 37.8 percent, averaging 8.0 percent. In the remaining 37 instances, prices 

for OCTG from the nine subject countries were between 0.0 and 29.7 percent above prices for 

the domestic product, averaging 7.2 percent.

V-21
Table V-13

OCTG: Instances of underselling/overselling and the range and average margins, all subject 

countries combined, January 2011-March 2014

Product 

Number of 

quarters of 

underselling

Number of 

quarters of 

(overselling)

Margins of underselling Margins of (overselling)

Average 

(percent) 

Range (percent)

Average 

(percent)

Range (percent)

Min Max Min Max

1 29 0 *** *** *** -- -- --

2 37 6 *** *** *** *** *** ***

3 48 5 *** *** *** *** *** ***

4 29 10 *** *** *** *** *** ***

5 48 11 *** *** *** *** *** ***

6 48 5 *** *** *** *** *** ***

Total 239 37 8.0 0.3 37.8 (7.2) (0.0) (29.7)

Source: Compiled from data submitted in response to Commission questionnaires.

Data by country are provided in table V-14. The countries with the greatest number of 

possible comparisons were Turkey, India, and Korea. All countries undersold U.S. OCTG in at 

least two-thirds of quarters for which comparisons were possible.

Products 1 and 4 are seamless products. Among these products, there were 55 quarters 

of underselling, compared with 10 quarters of overselling. For welded products (products 2, 3, 

5, and 6) in general, there were 181 quarters of underselling and 27 quarters of overselling. 

When comparing margins among all subject countries, the average margins of 

underselling ranged between *** percent (Saudi Arabia) and *** percent (Ukraine). The 

country with the largest average margins of underselling was Ukraine (*** percent) although 

India, Thailand, and Vietnam each had average margins of underselling ***. Average overselling 

margins ranged between *** percent (Taiwan (subject)) and 12.5 percent (India). 

V-22
Table V-14

OCTG: Instances of underselling/overselling and the range and average margin by country, 

January 2011-March 2014

Product 

and 

Country

Number of 

quarters of 

underselling

Number of 

quarters of 

(overselling)

Margins of underselling Margins of (overselling)

Average 

(percent) 

Range (percent)

Average 

(percent)

Range (percent)

Min Max Min Max

India

1 9 0 *** *** *** -- -- --

2 2 3 *** *** *** *** *** ***

3 2 1 *** *** *** *** *** ***

4 9 4 *** *** *** *** *** ***

5 7 1 *** *** *** *** *** ***

6 8 0 *** *** *** -- -- --

Total 37 9 9.8 0.4 30.9 (12.5) (0.7) (29.7)

Korea

2 12 1 *** *** *** *** *** ***

3 10 1 *** *** *** *** *** ***

5 7 2 *** *** *** *** *** ***

6 13 0 *** *** *** -- -- --

Total 42 4 7.3 0.6 37.8 (6.3) (2.2) (10.6)

Philippines

2 11 1 *** *** *** *** *** ***

3 6 0 *** *** *** -- -- --

5 5 0 *** *** *** -- -- --

6 6 1 *** *** *** *** *** ***

Total 28 2 6.8 1.2 12.6 *** *** ***

Saudi Arabia

4 *** *** *** *** *** *** *** ***

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

Table continued on next page.

V-23
Table V-14--Continued

OCTG: Instances of underselling/overselling and the range and average margin by country, 

January 2011-March 2014

Product 

and 

Country

Number of 

quarters of 

underselling

Number of 

quarters of 

(overselling)

Margins of underselling Margins of (overselling)

Average 

(percent) 

Range (percent)

Average 

(percent)

Range (percent)

Min Max Min Max

Taiwan (subject)

3 9 2 *** *** *** *** *** ***

5 10 3 *** *** *** *** *** ***

6 11 1 *** *** *** *** *** ***

Total 30 6 6.0 0.8 16.3 *** *** ***

Thailand

1 5 0 *** *** *** -- -- --

4 2 1 *** *** *** *** *** ***

Total 4 1 *** *** *** *** *** ***

Turkey

2 12 1 *** *** *** *** *** ***

3 10 1 *** *** *** *** *** ***

5 8 3 *** *** *** *** *** ***

6 10 3 *** *** *** *** *** ***

Total 40 8 6.6 0.3 11.7 (5.3) (0.1) (24.0)

Ukraine

1 12 0 *** *** *** -- -- --

4 7 1 *** *** *** *** *** ***

Total 19 1 *** *** *** *** *** ***

Vietnam

1 3 0 *** *** *** -- -- --

3 11 0 *** *** *** -- -- --

4 2 0 *** *** *** -- -- --

5 11 2 *** *** *** *** *** ***

Total 27 2 9.2 2.9 22.1 *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires.

V-24
LOST SALES AND LOST REVENUES

The Commission requested that U.S. producers of OCTG to report any instances of lost 

sales or revenue they experienced due to competition from imports of OCTG from India, Korea, 

the Philippines, Saudi Arabia, Taiwan, Thailand, Turkey, Ukraine, and Vietnam since January 

2010. All but two allegations involved imports from Korea. The majority were included in the 

petition, although *** added allegations in their preliminary or final questionnaire responses.16

The 84 lost sales allegations totaled $285 million and involved 167,079 short tons and the 15 

lost revenue allegations totaled $11.2 million and involved 19,197 short tons. Staff contacted 

28 purchasers; a summary of the information obtained is presented in tables V-15 and V-16

along with the 18 responding purchasers’ replies. In total, purchasers agreed with allegations 

totaling 42,501 short tons of lost sales, accounting for $68.2 million, as well as 9,905 short tons 

of lost revenue accounting for $935,287. *** of the confirmed instances involved OCTG from 

***. Of the 10 responding U.S. producers, nine reported that they had to either reduce prices 

or roll back announced price increases.

Table V-15

OCTG: U.S. producers’ lost sales allegations

* * * * * * *

Table V-16 

OCTG: U.S. producers’ lost revenue allegations

* * * * * * *

The majority of purchasers provided comments regarding the allegations. *** stated 

that they could not recall the specific allegations and were therefore unable to provide 

verification. *** stated that it had insufficient information to make any conclusions regarding 

OCTG pricing by U.S. producers. *** further noted that it purchases a mix of products from 

domestic and foreign producers, but that no orders were “pulled” from U.S. producers since

2010. It added that U.S. producers have occasionally reduced their price on specific quotes to 

compete with foreign producers of OCTG.

*** agreed with the alleged price differences, but did not purchase the imported foreign 

OCTG out of support for domestic mills. However, it stated that domestic producers of OCTG 

have had to lower their prices to compete with the imported product. According to its 

response, “our selling price has decreased ***% selling domestic product.” 

*** agreed with both allegations, and stated that it was a long term domestic customer 

lost to a Korean product based on price. 

*** disagreed with the allegation and further stated that they did not know which 

transaction the allegation was referring to. They also stated that there are many factors which 

16 Not all allegations contained sufficient contact information for the Commission to confirm the 

allegations. Those allegations without sufficient information are not included in this presentation. All 

other allegations were investigated.

V-25

 
determine whether a sale is won or lost. These factors may include, but are not limited to, 

quality, mill delivery, requirement dates, relationships, customer preference, construction, 

reputation, etc.

For ***, price did influence the choice to shift purchases away from domestic 

producers, but “availability of domestic tons for specific requirements also plays a big part in 

the selection of tubulars.” 

*** commented that it only began focusing on domestic mill sources in ***, but noted 

that domestic producers have reduced their prices since late 2012 as a result of oversupply and 

more competitive market conditions. 

*** stated that its rejection of the original quote from U.S. producers was not 

necessarily in response to competing imports from the specified subject country, but that,

in general, domestic mills are forced to lower prices to compete with imported OCTG product 

prices. 

*** noted that “these {foreign} mills were always below domestic pricing,” and that “to 

sell domestic pipe, it requires an end user that prefers it, and is willing to spend more to have it. 

Otherwise, the prices are too high.” Even in cases where domestic producers reduced their 

prices, it stated that the cost of domestically produced OCTG was “still higher than the mills 

mentioned in this trade case.” 

*** added that prices of OCTG from the specified subject country are roughly 

$***/short ton less expensive than domestic goods. It further noted that it prefers domestic 

product, and thus often ***. 

In addition to the data regarding the specific allegations, purchasers named in the 

allegations during the preliminary phase of these investigations were asked two questions 

regarding the OCTG market. The first is whether the purchaser switched suppliers from a U.S. 

producer to imports of subject product since January 2010, and if price was the reason for the 

switch. They were also asked if U.S. producers had to decrease their prices in order to compete 

with the price of OCTG from subject sources. Responses are presented in table V-17. Six of 15 

responding purchasers noted switching to subject imports, with each reporting that they did so 

for price reasons. Eleven of 14 responding purchasers indicated that U.S. producers had to 

reduce their prices to compete with OCTG from subject countries.

Table V-17

OCTG: Purchasers’ responses regarding shifting supply and price reductions

* * * * * * *

V-26
PART VI: FINANCIAL EXPERIENCE OF U.S. PRODUCERS

BACKGROUND

Seventeen U.S. firms provided useable financial data on their operations on OCTG.

1

These data are believed to account for the vast majority of U.S. production of OCTG in 2013. No 

firm reported internal consumption and *** reported transfers in the financial section of the 

Commission’s questionnaire. Three non-toll independent processors provided data on their 

operations on OCTG, which were equivalent to *** percent by value of mill sales in 2013. Five

firms provided data on their tolling operations on OCTG, which were equivalent to *** percent 

of mill sales by value in 2013. All but three of the firms reported a fiscal year end of December 

31.

In 2013, nine mills2 reported producing welded OCTG casing and tubing and four mills

reported producing seamless OCTG casing and tubing (there is some overlap as U.S. Steel and 

TMK IPSCO produce both seamless and welded OCTG casing and tubing); the same four mills

that produce seamless casing and tubing reported producing seamless coupling stock. As noted 

earlier in this report, the production of welded OCTG casing and tubing increased between 

2011 and 2013 by 497,535 short tons, or 26.9 percent (nine of ten firms reported increased 

production, including ***). The production of seamless OCTG casing and tubing also increased 

between the two full years (by 236,954 short tons or 16.6 percent, accounted for mostly by 

***). As noted, four firms produced seamless OCTG coupling stock in 2013, the production of 

which declined by 6,059 short tons (11.2 percent) between 2011 and 2013. Overall, production 

is concentrated among a few firms: The top four firms, ***, accounted for *** percent of total 

net sales by quantity and *** percent by value in 2013.

As noted in the preliminary-phase staff report, several U.S. producers started producing 

or expanded their production of OCTG since 2010, including ***.

3 These firms together 

accounted for approximately *** percent of the mills’ and processors’ combined operating 

income in 2013, largely accounted for by ***.

1 These firms include 11 OCTG-producing mills, three non-toll processors, and five firms reporting 

tolling data (***). The OCTG-producing mills are: ***. The three non-toll processors are: ***. Five firms 

provided tolling data (section V of the Commission’s questionnaire): ***. The majority of U.S. producers 

reported their financial results on the basis of GAAP. Maverick and TMK IPSCO reported theirs on the 

basis of International Financial Reporting Standards (IFRS).

Differences between the trade and financial sections of the Commission’s questionnaire are 

accounted for by timing differences, differences in rounding, and because ***. 2 This does not include ***. 3 Certain Oil Country Tubular Goods from India, Korea, The Philippines, Saudi Arabia, Taiwan, 

Thailand, Turkey, Ukraine, and Vietnam, Investigation Nos. 701-TA-499-500 and 731-TA-1215-1223 

(Preliminary), USITC Publication 4422, August 2013, p. VI-1. 

VI-1

 
OPERATIONS ON OCTG

Income-and-loss data for U.S. producers’ mill operations on OCTG are presented in table 

VI-1; table VI-2 presents similar information for U.S. processors; and table VI-3 presents 

selected company-specific financial data for U.S. mills and U.S. non-toll processors together.

The results of operations on OCTG are briefly described here: For the reporting mills, total net 

sales rose by quantity and value between 2011 and 2013 and both were greater in JanuaryMarch 2014 compared with the same period in 2013. The average unit sales values declined

irregularly between 2011 and 2013 and were lower in January-March 2014 compared with 

January-March 2013. Total cost of goods sold (“COGS”) and total selling, general, and 

administrative (“SG&A”) expenses increased between the yearly periods in dollar terms, and 

both were greater in January-March 2014 compared with January-March 2013. The ratio of 

COGS to sales increased between the yearly periods and was greater in January-March 2014 

compared with January-March 2013; per-unit total COGS declined irregularly from 2011 to 2013 

but was greater in January-March 2014 compared with January-March 2013. The change in 

total COGS was led by the cost categories of raw material costs and other factory costs. Total 

operating income was positive in each period but fell from 2011 to 2013 in dollar terms, as a 

ratio to sales, and on a per-unit basis, and was lower by each measure in January-March 2014 

than in the one-year prior period. Net income before taxes and cash flows was positive in 2011 

and 2012, but decidedly negative in 2013, ***. Net income was positive in interim 2013 but 

negative in interim 2014; cash flow was positive in both interim periods.

VI-2
Table VI-1

OCTG: Results of operations of U.S. mills, fiscal years 2011-13, January-March 2013, and JanuaryMarch 2014

Item

Fiscal year January-March

2011 2012 2013 2013 2014

Quantity (short tons)

Total net sales 3,306,386 3,602,983 4,010,042 929,328 1,032,178 

Value (1,000 dollars)

Total net sales 5,590,347 6,235,687 6,229,566 1,450,989 1,591,597 

Cost of goods sold (COGS):

 Raw materials 2,677,605 2,966,086 3,161,396 735,729 818,588 

 Direct labor 426,046 494,572 517,931 119,640 134,428 

 Other factory costs 1,432,759 1,697,472 1,731,902 392,907 467,581 

 Total COGS 4,536,410 5,158,130 5,411,229 1,248,276 1,420,597 

Gross profit 1,053,937 1,077,557 818,337 202,713 171,000 

SG&A expense 412,811 463,714 506,639 115,314 124,365 

Operating income 641,126 613,843 311,698 87,399 46,635 

Other expense or (income), net1

170,099 *** *** *** ***

Net income or (loss) 471,027 *** *** *** ***

Depreciation/amortization 220,066 *** *** *** ***

Cash flow 691,093 *** *** *** ***

Ratio to net sales (percent)

COGS:

 Raw materials 47.9 47.6 50.7 50.7 51.4 

 Direct labor 7.6 7.9 8.3 8.2 8.4 

 Other factory costs 25.6 27.2 27.8 27.1 29.4 

 Average COGS 81.1 82.7 86.9 86.0 89.3 

Gross profit 18.9 17.3 13.1 14.0 10.7 

SG&A expense 7.4 7.4 8.1 7.9 7.8 

Operating income 11.5 9.8 5.0 6.0 2.9 

Net income or (loss) 8.4 *** *** *** ***

Table continued on next page.

VI-3
Table VI-1--Continued

OCTG: Results of operations of U.S. mills, fiscal years 2011-13, January-March 2013, and JanuaryMarch 2014

Item

Fiscal year January-March

2011 2012 2013 2013 2014

Unit value (dollars per short ton)

Total net sales 1,691 1,731 1,553 1,561 1,542 

COGS:

 Raw materials 810 823 788 792 793 

 Direct labor 129 137 129 129 130 

 Other factory costs 433 471 432 423 453 

 Average COGS 1,372 1,432 1,349 1,343 1,376 

Gross profit 319 299 204 218 166 

SG&A expense 125 129 126 124 120 

Operating income 194 170 78 94 45 

Net income or (loss) 142 *** *** *** ***

Number of firms reporting

Operating losses2

*** *** 4 *** 3 

Data 10 9 11 9 10 

1 Composed of interest expense, other expenses, and other income. The category of “other expenses” led 

to the industry as a whole recording a net loss in 2013. This was from ***. 2 Firms reporting an operating loss were: ***.

Source: Compiled from data submitted in response to Commission questionnaires.

In addition to results of operations reported by U.S. mills in table VI-1, three firms, ***, 

reported data on their non-toll processing operations. These data are shown in table VI-2 and in 

the firm-by-firm data in table VI-3.

Table VI-2

OCTG: Results of operations of non-toll processors, fiscal years 2011-13, January-March 2013, 

and January-March 2014

* * * * * * *

Table VI-3

OCTG: Results of operations of U.S. mills and non-toll processors, by firm, fiscal years 2011-13, 

January-March 2013, and January-March 2014

* * * * * * *

Total net sales quantity and value

As the data in table VI-1 indicate, total net sales increased by 703,656 short tons (21.3

percent) between 2011 and 2013 and were greater by 102,850 short tons (11.1 percent) in 

January-March 2014 than in January-March 2013; by value, the increase was $639.2 million 

VI-4
(11.4 percent) between 2011 and 2013 and total net sales were greater by $140.6 million (9.7

percent) in January-March 2014 than in January-March 2013. The quantity of total net sales 

increased from 2011 to 2012 and from 2012 to 2013 although it increased more between 2012 

and 2013 than between 2011 and 2012. The increase of the value of total net sales took place

between 2011 and 2012 as total sales value fell by $6.1 million between 2012 and 2013. 

Between these two yearly periods, five of nine mills for which data are comparable reported

lower sales, and much of the decline was accounted for by the data of ***. Four mills reported 

higher sales, by value, in 2013 compared with 2012: ***.

As the data in table VI-3 indicate, directional changes in period-to-period sales were 

generally the same for a majority of the reporting firms. It also appears that changes in average 

sales values were due to changes in underlying prices as opposed to changes in product mix.4

The average unit value of total net sales of the reporting firms did not keep pace with the 

increase in quantity, and thus the average unit sales value declined between the two full yearly 

periods for nearly all U.S. mills (exceptions are those mills and non-toll processors that did not 

report data in 2011, for which no comparison may be made, and by ***.

Four firms, ***, responded to the Commission’s question on start-up and/or expansion 

of production capacity.

5 The sales quantity and operating costs related to incremental 

expansion was ***. The incremental costs were equivalent to *** percent of total COGS in 

2011, *** percent in 2012, and *** percent in 2013.6

4 The steel industry sometimes uses a measure termed the “metal spread,” which denotes the 

difference between the average unit values of sales and raw material costs. If the difference widens, this 

usually means that sales are increasing more than raw material costs, whereas if the spread decreases, it 

may mean that sales are decreasing more than raw material costs. Whether for mills only (table VI-1) or 

for mills and non-toll processors combined, the metal spread widened slightly from 2011 to 2012 (sales 

AUVs increasing more than raw material costs’ AUVs) and narrowed between 2012 and 2013, and was 

smaller in interim 2014 than in interim 2013 (sales AUVs decreasing more than raw material costs’ 

AUVs). These are shown in the following tabulation:

Metal spread 2011 2012 2013

January-March

2013 2014

Average unit value (dollars per short ton)

U.S. mills 881 907 765 770 749 

U.S. mills and non-toll 

processors *** *** *** *** ***

With respect to the relationship between prices and raw material costs, see Posthearing brief of 

Maverick, exh. 1, pp. 18-19; see also hearing transcript, pp. 106-107 (Shoaff—pricing in the U.S. market 

is very transparent). 5 Section III-10 of the U.S. producers’ questionnaire. ***. E-mail from ***. 6 Calculated by dividing the reported incremental start-up/investment costs by total COGS in 

table VI-1.

VI-5

 
Operating costs and expenses

Total COGS of mills and non-toll processors together (table VI-3) increased between 

2011 and 2013 in dollar terms by $*** (*** percent), which represented a slightly smaller

percentage-rate increase than that of sales volume but twice the rate of sale value; total COGS 

was greater in January-March 2014 than in January-March 2013 by $*** (*** percent). The 

ratio of total COGS to total net sales increased by *** percentage points from 2011 to 2013 and 

was higher in January-March 2014 than in January-March 2013 by *** percentage points; 

directional changes were similar for the majority of firms, with one exception being that of ***.

Most of the increase in the absolute value of total COGS occurred between 2011 and 2012.

Between 2011 and 2013, directional changes in the value of total COGS were generally the 

same for each firm. Between 2012 and 2013, changes differed by firm: Total COGS of four firms 

fell and that of seven firms increased out of 11 firms for which comparison can be made; and 

total COGS of seven firms out of 11 firms for which a comparison may be made was greater in 

January-March 2014 than in January-March 2013.

Total raw material costs, the single largest cost component of OCTG, increased in dollar 

terms and as a ratio to sales with increasing sales volume between 2011 and 2013 and was 

greater in January-March 2014 than in January-March 2013. On a per-unit value basis, it was 

little changed comparing 2013 with 2011 or January-March 2013 and January-March 2014. The 

pattern was somewhat consistent during the period—overall, raw material costs increased 

between 2011 and 2013, with most of the increase occurring between 2011 and 2012. As a 

ratio to total net sales, the cost categories of raw material costs and other factory costs

increased the most for mills (table VI-1); for processors, the cost category of raw materials 

increased while those of direct labor and other factory costs declined between 2011 and 2013

(table VI-2). Other factory costs of mills and processors also increased in dollar terms; for mills, 

other factory costs increased on a per-unit basis during the yearly periods; most of this is 

accounted for by the greater volume of sales and some, to a much smaller extent, is accounted 

for by start-up problems of certain U.S. producers.7 For mills, other factory costs were greater 

in January-March 2014 than in January-March 2013 in dollar terms, as a ratio to total sales, and 

on a per-unit basis. As a share of total COGS, however, each of the three cost categories was

relatively stable between the reporting periods.

Total SG&A expenses of mills and processors rose in dollar terms between the yearly 

periods and were greater in January-March 2014 than in January-March 2013. SG&A expenses 

increased slightly between 2011 and 2013 and were flat between the interim periods; on a perunit basis SG&A expenses were flat throughout the period. Generally, the direction of change 

by firm tracked the industry total and ratio to net sales, except for ***.

7 For example, ***. Questionnaire response of ***, section III-9. Also, ***. These firms’ other factory 

costs and total COGS represent a small percentage of the industry’s total costs in these two categories. 

VI-6

 
Profitability

As depicted in tables VI-1, VI-2, and VI-3, gross profit and operating income of mills and 

non-toll processors fell from 2011 to 2013 and both indicators were lower in January-March 

2014 than in January-March 2013. Similarly, gross profit and operating income as a ratio to total 

net sales and the per-unit value of those two indicators fell between the yearly periods and 

were lower in January-March 2014 than in January-March 2013. The number of mills and nontoll processors recording operating losses are shown in tables VI-1 and VI-2, respectively. The 

total number of mills and non-toll processors reporting losses combined was *** firms in both 

2011 and 2012, but increased to six firms in 2013; and four firms reported operating losses in 

each of the two quarterly periods. Among reporting mills, *** reported operating losses in each 

period, while non-toll processors *** reported operating losses. Overall, operating income fell 

from 2011 to 2013, with the majority of the decline occurring between 2012 and 2013. The 

lower reported operating income of *** accounted for a large share of the total reduction of 

industry operating income between 2012 and 2013. Industry operating income also was lower 

in January-March 2014 than in January-March 2013 and while operating income of eight firms 

out of 11 firms for which a comparison may be made was lower, the reduction of operating 

income of *** accounted for a majority of the reduction of industry operating income between 

those two interim periods.

Net income before taxes and cash flow followed the change in operating income and 

incorporated an increase in other expenses. Both net income and cash flow fell substantially 

between 2012 and 2013 (and were negative in the latter year); also, both were much lower in 

January-March 2014 than in January-March 2013. The change between 2012 and 2013 was 

primarily due to a dramatic increase in the category of “all other expenses,” which rose from 

approximately *** percent of sales revenue to *** percent. The increase was largely accounted 

for ***.

8 Interest charges were relatively stable at approximately 2 percent of sales revenue in 

each reporting period.

Tolling

In a tolling arrangement, one firm (the tollee) provides the input material (retaining title 

to the input) to another, often independent, firm (the toller) which upgrades the input to the 

desired form and quality. In the case of OCTG, the toll processing that is performed is typically 

that of heat-treating of tubular products to their final API grade. Five firms reported data on 

their tolling operations; of these, two firms, Texas Steel Conversion and Tubular Services, 

accounted for the majority of reported data and *** (other firms reporting tolling data were 

8 Questionnaire responses of ***. Other firms that reported data in the category of other expenses in 

2013 included ***.

VI-7

 
RDT, EnergeX Tube,9 and Laguna Tubular Products although these firms did not report data in 

all periods). 

With respect to tolling, the Commission has examined value-added by tollers. A valueadded calculation shows two ratios: (1) a ratio of the sum of direct factory labor and factory 

overhead costs (conversion costs) to cost of goods sold (COGS); and (2) a ratio of conversion 

costs plus selling, general, and administrative expenses (SG&A) to the sum of COGS and SG&A

expenses. Ratio 1 varies from *** percent (in 2011) to *** percent (in 2013) and from ***

percent (interim 2014) to *** percent (interim 2013). Ratio 2 varies from *** percent (2012) to 

*** percent (2013) and from *** percent (interim 2014) to *** percent (interim 2013).10

Similarly, the ratio 1 value-added by non-toll processors varied from *** percent (2012) to ***

percent (2011) and from *** percent (interim 2014) to *** percent (interim 2013). Ratio 2 

value-added for non-toll processors varied from 32.0 percent (2012) to *** percent (2011) and 

was *** percent in 2013; ratio 2 in interim 2013 was *** percent while in interim 2014 it was 

*** percent. Tolling data are presented in table VI-4.

Table VI-4

OCTG: Results of operations of U.S. toll producers, 2011-13, January-March 2013, and JanuaryMarch 2014

* * * * * * *

9 EnergeX Tube reported tolling in 2012 only on behalf of ***. The firm stated that ***. E-mail from 

***.

10 This depicts the incremental amount of value added to the unfinished tubular products by 

processing. Processing includes heat treatment as well as threading, coupling, and testing operations. 

For the purposes of computing these ratios, Commission staff estimated “raw material costs” by using 

the average unit value of raw materials as reported by non-toll processors (shown in table VI-2, earlier) 

and applying that value to the reported tolled quantity in table VI-4. The product is an estimated value 

of raw materials (tubular inputs) provided to the toller by the tollee and provides the basis of the valueadded calculation. These ratios may change depending on whether the tollee purchased or produced 

the tubular inputs. The raw material input in tolling transaction would be at cost in the case of a 

producer (i.e., sales profit excluded) but at a purchase cost (i.e., including sales profit) in the case of a 

distributor or importer that contracted for the tolling service. Hence, the two ratios may be somewhat 

lower in the case of purchased tubular inputs because the estimated value of raw materials includes 

producer’s sales profit, which is estimated here; the ratios would be higher in the case of a producer 

contracting for tolling because the input would be at cost. 

VI-8

 
Variance analysis

The variance analysis showing the effects of prices and volume on U.S. mills’ net sales of 

OCTG, and of costs and volume on their total expenses, is presented in table VI-5 while table VI6 presents a variance analysis for mills and non-toll processors combined.

11 The information for 

this variance analysis is derived from data for mills in table VI-1, and for mills and non-toll 

processors together in tables VI-2 and VI-3. The variance analysis provides an assessment of 

changes in profitability as related to changes in pricing, cost, and volume. As shown in table VI5, the variance analysis for the reporting mills indicates that the decline in operating income 

between 2011 and 2013 and between 2012 and 2013 was entirely due to the effect of an

unfavorable price variance on sales (unit sales values fell) that was much greater than the 

favorable net cost/expense variances (unit costs decreased) and volume increase. The 

composition of variances changed, and operating income fell from 2011 to 2012 when a 

favorable price variance (unit prices increased) was overwhelmed by an unfavorable net 

cost/expense variance. Operating income was lower in January-March 2014 than in JanuaryMarch 2013 due to the combined effects of unfavorable price and net cost/expense variances. 

The variance analysis for reporting mills and non-toll processors together, which is shown in 

table VI-6, is similar for each period to that depicted in table VI-5. The composition of net 

operating variance is summarized at the bottom of tables VI-5 and VI-6.

11 The Commission’s variance analysis is calculated in three parts: Sales variance, cost of sales 

variance (COGS variance), and SG&A expense variance. Each part consists of a price variance (in the 

case of the sales variance) or a cost or expense variance (in the case of the COGS and SG&A expense 

variance), and a volume variance. The sales or cost/expense variance is calculated as the change in unit 

price or per-unit cost/expense times the new volume, while the volume variance is calculated as the 

change in volume times the old unit price or per-unit cost/expense. Summarized at the bottom of the 

table, the price variance is from sales; the cost/expense variance is the sum of those items from COGS 

and SG&A variances, respectively, and the volume variance is the sum of the volume components of the 

net sales, COGS, and SG&A expense variances. The overall volume component of the variance analysis is 

generally small.

VI-9

 
Table VI-5

OCTG: Variance analysis on the operations of U.S. mills, fiscal years 2011-13, January-March 

2013, and January-March 2014

Value ($1,000)

Between fiscal years Jan.-March

Item 2011-13 2011-12 2012-13 2013-14

Total net sales: 

 Price variance (574,868) 113,377 (700,215) (21,900)

 Volume variance 1,287,452 609,615 689,807 163,825 

 Total net sales variance 712,584 722,992 (10,408) 141,925 

Cost of sales:

 Cost variance 94,162 (212,624) 329,235 (32,363)

 Volume variance (1,046,939) (495,731) (573,657) (141,282)

 Total cost variance (952,777) (708,355) (244,422) (173,645)

Gross profit variance (240,193) 14,637 (254,830) (31,720)

SG&A expenses:

 Expense variance (1,894) (9,791) 8,931 2,871 

 Volume variance (95,471) (45,206) (51,299) (12,966)

 Total SG&A variance (97,365) (54,997) (42,368) (10,095)

Operating income variance (337,558) (40,360) (297,198) (41,815)

Summarized as:

 Price variance (574,868) 113,377 (700,215) (21,900)

 Net cost/expense variance 92,268 (222,415) 338,166 (29,492)

 Net volume variance 145,042 68,678 64,851 9,576 

Note.—Unfavorable variances are shown in parentheses; all others are favorable. The data are 

comparable to changes in operating income as presented in table VI-1 (U.S. mills). Toll processors are

not included.

Source: Compiled from data submitted in response to Commission questionnaires.

VI-10
Table VI-6

OCTG: Variance analysis on the operations of U.S. mills and non-toll processors together, fiscal 

years 2011-13, January-March 2013, and January-March 2014

* * * * * * *

CAPITAL EXPENDITURES AND RESEARCH AND DEVELOPMENT EXPENSES

Table VI-7 presents capital expenditures and research and development (“R&D”) 

expenses by firm. Total capital expenditures fell between 2011 and 2013 and were lower during 

January-March 2014 than in the same period one year earlier. Some of this apparent decrease

may be attributed to investment programs being largely completed with new plants coming on 

line (***). Total R&D expenses declined irregularly from 2011 to 2013 and were lower in 

January-March 2014 than in January-March 2013.

Table VI-7

OCTG: Capital expenditures and research and development expenses of U.S. mills and non-toll 

processors, by firm, fiscal years 2011-13, January-March 2013, and January-March 2014

* * * * * * *

Four of the firms providing tolling services reported data on capital expenditures, which 

are shown in table VI-8. None of the toll processors reported data for R&D expenses.

Table VI-8

OCTG: Capital expenditures of U.S. toll processors, by firm, fiscal years 2011-13, January-March 

2013, and January-March 2014

* * * * * * *

Firms commented on their expansion efforts, including opening of plants, expansion of 

production capacity, and other changes in their OCTG operations in their questionnaire 

responses.12 Their comments provide information regarding the capital expenditures programs 

of individual firms and are summarized below.

• Boomerang Tube ***.

13

• Drill Pipe International ***.

14

• EnergeX ***.

15

12 See also table III-2, presented earlier in this report.

13 ***. 14 ***. 15 ***.

VI-11

 
• Evraz Rocky Mountain ***.

16

• Laguna Tubular Products ***.

17

• Maverick ***.

18

• Northwest Pipe reported ***.

• Paragon Industries ***.

19

• Tejas Tubular ***.

20 Constraints noted were those of ***.

• Texas Tubular ***.

21

• TMK IPSCO ***.

22 The firm noted that its ***.

• Tubular Services, ***.

23

• U.S. Steel ***.

24 Reportedly, these investments ***.25 U.S. Steel noted that constraints 

on capital expenditures were those ***.

• Vallourec Star ***.

• Welded Tube ***.

26

Firms indicated that constraints on capital expenditures included the company’s 

financial resources, as well as market conditions, the economy, and the impact of subject 

imports.

ASSETS AND RETURN ON INVESTMENT

Table VI-9 presents data on the U.S. mills’ and non-toll processors’ total assets and their 

return on investment (“ROI”). Operating income was divided by total net assets resulting in ROI. 

Total net assets increased by 9.1 percent from 2011 to 2013 because of capital expenditures 

from existing and new mills and processors.

27 Because assets increased while operating income 

declined, the ratio declined to a greater extent than did the operating margin alone.

16 ***. 17 ***. 18 ***. 19 ***. 20 ***. 21 ***. 22 ***. 23 ***. 24 ***. Additionally, ***. 25 Ibid.

26 ***. 27 Capital expenditures increase the value of net fixed assets (property, plant, and equipment) while 

depreciation charges reduce the net value of assets. Allocation of values of assets to and from OCTG due 

to changes in a plant’s mix of production between the years also affected the value of assets.

VI-12

 
Table VI-9

OCTG: U.S. mills’ and non-toll processors’ total assets and return on investment, fiscal years 

2011-13

* * * * * * *

CAPITAL AND INVESTMENT

The Commission requested that U.S. producers of OCTG describe any actual or potential 

negative effects of imports of OCTG from India, Korea, Philippines, Saudi Arabia, Taiwan, 

Thailand, Turkey, Ukraine, and Vietnam 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 F.

VI-13

PART VII: THREAT CONSIDERATIONS AND INFORMATION ON 

NONSUBJECT COUNTRIES

Section 771(7)(F)(i) of the Act (19 U.S.C. § 1677(7)(F)(i)) provides that—

In determining whether an industry in the United States is threatened 

with material injury by reason of imports (or sales for importation) of the 

subject merchandise, the Commission shall consider, among other 

relevant economic factors1--

(I) if a countervailable subsidy is involved, such information as may be 

presented to it by the administering authority as to the nature of 

the subsidy (particularly as to whether the countervailable subsidy 

is a subsidy described in Article 3 or 6.1 of the Subsidies 

Agreement), and whether imports of the subject merchandise are 

likely to increase,

(II) any existing unused production capacity or imminent, substantial 

increase in production capacity in the exporting country indicating 

the likelihood of substantially increased imports of the subject 

merchandise into the United States, taking into account the 

availability of other export markets to absorb any additional 

exports,

(III) a significant rate of increase of the volume or market penetration of 

imports of the subject merchandise indicating the likelihood of 

substantially increased imports,

(IV)whether imports of the subject merchandise are entering at prices 

that are likely to have a significant depressing or suppressing 

effect on domestic prices, and are likely to increase demand for 

further imports,

(V) inventories of the subject merchandise,

1 Section 771(7)(F)(ii) of the Act (19 U.S.C. § 1677(7)(F)(ii)) provides that “The Commission shall 

consider {these factors} . . . as a whole in making a determination of whether further dumped or 

subsidized imports are imminent and whether material injury by reason of imports would occur unless 

an order is issued or a suspension agreement is accepted under this title. The presence or absence of 

any factor which the Commission is required to consider . . . shall not necessarily give decisive guidance 

with respect to the determination. Such a determination may not be made on the basis of mere 

conjecture or supposition.”

VII-1

 
(VI)the potential for product-shifting if production facilities in the foreign 

country, which can be used to produce the subject merchandise, 

are currently being used to produce other products,

(VII) in any investigation under this title which involves imports of both 

a raw agricultural product (within the meaning of paragraph

(4)(E)(iv)) and any product processed from such raw agricultural 

product, the likelihood that there will be increased imports, by 

reason of product shifting, if there is an affirmative determination 

by the Commission under section 705(b)(1) or 735(b)(1) with 

respect to either the raw agricultural product or the processed 

agricultural product (but not both),

(VIII) the 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

(IX)any other demonstrable adverse trends that indicate the probability 

that there is likely to be material injury by reason of imports (or 

sale for importation) of the subject merchandise (whether or not it 

is actually being imported at the time).2

Information on the nature of the subsidies was presented earlier in this report;

information on the volume and pricing of imports of the subject merchandise is presented in 

Parts IV and V; 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 thirdcountry markets, follows. Also presented in this section of the report is information obtained 

for consideration by the Commission on nonsubject countries.

2 Section 771(7)(F)(iii) of the Act (19 U.S.C. § 1677(7)(F)(iii)) further provides that, in antidumping 

investigations, “. . . the Commission shall consider whether dumping in the markets of foreign countries 

(as evidenced by dumping findings or antidumping remedies in other WTO member markets against the 

same class or kind of merchandise manufactured or exported by the same party as under investigation) 

suggests a threat of material injury to the domestic industry.”

VII-2

 
THE INDUSTRY IN INDIA

The petition in these investigations identified 49 producers and/or exporters of OCTG in 

India.3

 The Commission issued foreign producers questionnaires to these firms and received a 

completed response from seven producers and one exporter: GVN Fuels Limited (“GVN Fuels”) 

solely an exporter, Jindal (India), Jindal Pipes, Jindal Saw Ltd. (“Jindal Saw”), M/S United 

Seamless Tubulaar (“United Seamless”), Maharashtra Seamless Limited (“Maharashtra”), Oil 

Country Tubular Ltd. (“Oil Country Tubular”), and Surya Global Steel Tube Limited (“Surya”).4 

GVN Fuels reported that *** percent of its total sales in the most recent fiscal year were sales 

of OCTG. Jindal (India) reported that *** percent of its total sales in the most recent fiscal year 

were sales of OCTG. Jindal Pipes reported that *** percent of its total sales in the most recent 

fiscal year were sales of OCTG. Jindal Saw reported that *** percent of its total sales in the 

most recent fiscal year were sales of OCTG. United Seamless reported that *** percent of its 

total sales in the most recent fiscal year were sales of OCTG. Maharashtra reported that ***

percent of its total sales in the most recent fiscal year were sales of OCTG. Oil Country Tubular 

reported that *** percent of its total sales in the most recent fiscal year were sales of OCTG. 

Surya reported that *** percent of its total sales in the most recent fiscal year were sales of 

OCTG. 

Responding firms combined estimate that their OCTG exports to the United States 

accounted for approximately *** percent of all such exports of OCTG from India in 2013.

5

 A 

comparison of the responding firms’ export data to adjusted official Commerce import statistics 

shows that in 2013 they accounted for *** percent of U.S. imports of OCTG from India.6

Six of the seven responding Indian producers have pipe forming operations ***. Of the 

six with pipe forming operations, ***.

7 Welded OCTG producers include ***. Seamless OCTG

producers include ***.

Two firms reported investments in equipment and machinery that added capacity to 

their operations. ***.

8 Oil Country Tubular invested ***.9 Two firms reported investing in 

equipment to improve the quality of their OCTG. ***.

10 Jindal (India) reported improvements to 

***, but indicated that this development does not affect capacity. 11

3 Petition, exh. I-5A. 4 During the preliminary phase of these investigations, two additional producers, Welspun and ISMT, 

provided completed questionnaire responses and accounted for *** percent of Indian production of 

OCTG in 2012. 5 Questionnaire responses of Indian producers, II-16.

6 Four Indian producers, ***, provided estimates of their shares of India’s total production of OCTG, 

cumulatively accounting for approximately *** percent of production in 2013. 7 Questionnaire responses of Indian producers, I-2.

8 Questionnaire response of ***, II-2 and preliminary phase questionnaire response at II-2a.

9 Questionnaire response of ***, II-4.

10 Questionnaire response of ***, II-2. 11 Questionnaire response of ***, II-2.

VII-3

 
Operations on OCTG

Table VII-1a presents information on the OCTG operations of the six responding mills

and one exporter in India. Table VII-1b presents information on processor Oil Country Tubular’s 

operations. Reported mill capacity in India increased by *** percent from 2011 to 2013, and 

remained the same in January-March 2014 relative to January-March 2013. The changes in 

capacity reflect *** new production equipment coming online. Reported capacity is projected 

to remain at 2013 levels through 2015. Production decreased by *** percent from 2011 to 2013

and was *** percent lower in January-March 2014 than in January-March 2013. Four firms 

experienced declining production with *** accounting for approximately *** percent of the

decline.

12 Production is projected to be *** percent higher in 2014 than in 2013 and ***

percent higher in 2015 than 2013, led by increases from ***, respectively. Capacity utilization

was stable during 2011 and 2012 but decreased in 2013 to *** percent. Capacity utilization 

was *** percent in January-March 2014 compared to *** percent in January-March 2013.

13

Table VII-1a

OCTG: Data for producers and exporters in India (mills), 2011-13, January to March 2013, January 

to March 2014, and projected 2014 and 2015

* * * * * * *

In 2013, *** percent of mills’ total shipments of OCTG from India were exported to the 

United States, and *** percent were exported to other markets. Exports of OCTG from India to 

the United States decreased during 2011-13, experiencing an overall decrease of *** percent. 

Exports to the United States were *** percent lower in January-March 2014 than in JanuaryMarch 2013. 

Table VII-1b presents information on processor Oil Country Tubular’s operations. Oil 

Country Tubular’s operations include ***.

14 In March 2013, Oil Country Tubular ***.15 Oil 

Country Tubular ***. Oil Country does ***.

16

Table VII-1b

OCTG: Data for Indian processor Oil Country Tubular, 2011-13, January to March 2013, January to 

March 2014, and projected 2014 and 2015

* * * * * * *

12 ***. 13 With respect to production constraints, Jindal (India) reported ***, Jindal Pipes reported ***, 

Jindal Saw reported ***, Maharashtra reported ***, Oil Country Tubular reported ***, Surya reported 

***, United Seamless reported ***. Questionnaire responses of Indian producers, II-8. 14 Questionnaire response of Oil Country Tubular, I-2. 15 Questionnaire response of Oil Country Tubular, II-4.

16 Questionnaire response of Oil Country Tubular, II-10.

VII-4

 
Alternative products

Table VII-2 presents information on the total welded and total seamless tubular capacity 

and production of the nine responding producers in India.17

Table VII-2

OCTG: Indian capacity, production, and capacity utilization of welded, seamless, and heat treated 

tubular products, 2011-13, January to March 2013, and January to March 2014

* * * * * * *

 THE INDUSTRY IN KOREA

The petition in these investigations identified 10 producers and/or exporters of OCTG in 

Korea.18 The Commission issued foreign producers questionnaires to these firms and received 

a completed response from seven firms: AJU Besteel Co., Ltd. (“AJU Besteel”), Daewoo 

International Corp. (“Daewoo”) (***), Husteel, Hyundai HYSCO, ILJIN Steel Corp. (“ILJIN”), 

NEXTEEL Co., Ltd. (NEXTEEL), and SeAH Steel Corp. (“SeAH”). AJU Besteel reported that ***

percent of its total sales in the most recent fiscal year were sales of OCTG. Daewoo reported 

that *** percent of its total sales in the most recent fiscal year were sales of OCTG. Husteel 

reported that *** percent of its total sales in the most recent fiscal year were sales of OCTG. 

Hyundai HYSCO reported that *** percent of its total sales in the most recent fiscal year were 

sales of OCTG. ILJIN reported that *** percent of its total sales in the most recent fiscal year 

were sales of OCTG. NEXTEEL reported that *** percent of its total sales in the most recent 

fiscal year were sales of OCTG. SeAH reported that *** percent of its total sales in the most 

recent fiscal year were sales of OCTG.

The seven responding firms’ exports to the United States accounted for all U.S. imports 

of OCTG from Korea in 2013, based on a comparison to official import statistics, as adjusted. 

According to estimates provided by the responding Korean producers, the production of OCTG 

in Korea reported by the responding producers accounts for virtually all production of OCTG in 

Korea.

All Korean firms reported having pipe forming operations. ***. One Korean firm, ILJIN, 

reported establishing a seamless pipe production facility in *** and started to produce trial 

products in ***.

19 Three firms reported investing in heat treatment equipment. ***. ***.20 ***.

17 With respect to constraints on product shifting, Jindal (India) reported ***, Jindal Pipes reported 

***, Jindal Saw reported ***, Maharashtra reported ***, Oil Country Tubular reported ***, United 

Seamless reported ***. Questionnaire responses of Indian producers, II-9.

18 Petition, exh. I-5D.

19 Questionnaire response of ***, II-2. ***. Questionnaire response of ***, II-2b.

20 Questionnaire response of ***, II-2 and II-4.

VII-5

 
VII‐6

Operations on OCTG

Table VII‐3 presents information on the OCTG operations of the seven responding

producers and exporters in Korea. Capacity in Korea increased by 13.2 percent from 2011 to

2013 and was 7.1 percent higher in January‐March 2014 than in January‐March 2013. 21  

Capacity is projected to remain at the 2013 level in 2014 and 2015. Production in Korea

increased by 48.7 percent from 2011 to 2013 and was 64.8 percent higher in January‐March

2014 than in January‐March 2013. Production is projected to decline by 16.9 percent from 2013

to 2014, and to not change from 2014 to 2015. The capacity utilization rate increased from

2011 to 2013, and rose to 110 percent in January‐March 2014.22  

In 2013, 96.9 percent of total shipments of OCTG from Korea were exported to the

United States, and 1.5 percent were exported to other markets.  Exports of OCTG from Korea to

the United States increased by 43.3 percent from 2011 to 2013, and were 69.4 percent higher

in January‐March 2014 than in January‐March 2013.

Alternative products

Table VII‐4 presents information on the total welded and total seamless tubular capacity

and production of the responding producers and exporters in Korea.23 ILJIN is the sole Korean

producer with a seamless pipe mill, accounting for all seamless capacity and production

reported below. *** explains the increase in welded pipe capacity. Husteel reported that this

incremental production capacity cannot be used to produce OCTG, accordingly it did not report

increased OCTG production capacity.24 Increases in heat treatment capacity are due to ***

investments in new heat treatment facilities.25

                                                            

21 With respect to production constraints, AJU Besteel ***, Hyundai HYSCO reported ***, Husteel

and SeAH reported ***, ILJIN reported ***, and Nexteel reported ***.  Questionnaire responses of

Korean producers, II‐8. 22 ***. E‐mail, ***, June 3, 2014. In January‐March 2013, *** short tons of OCTG, in January‐March

2014, *** short tons of OCTG. Questionnaire response of ***, II‐10.   23 With respect to constraints on product shifting, AJU reported ***, Husteel reported ***, Hyundai

HYSCO reported ***, ILJIN reported ***, Nexteel ***, and SeAH reported ***.  Questionnaire responses

of Korean producers, II‐9.

24 E‐mail from ***, June 3, 2014.

25 Questionnaire responses of Korean foreign producers, II‐4.
VII‐7

Table VII-3 

OCTG: Data for producers and exporters in Korea, 2011-13, January to March 2013, January to 

March 2014, and projected 2014 and 2015 

Item 

Actual experience Projections

Calendar year January to March Calendar year

2011 2012 2013 2013 2014 2014 2015

 Quantity (short tons)

Capacity 1,087,382 1,160,302 1,231,223 307,906 329,781 1,231,223 1,231,223

Production 733,854 902,636 1,091,539 221,000 364,165 907,088 907,088

End-of-period inventories 20,021 44,842 89,975 44,053 89,960 82,703 83,439

Shipments: 

 Internal consumption/ transfers 2,484 1,515 4,436 553 1,522 1,934 1,934

Home market shipments 5,292 8,011 11,875 3,611 942 12,384 12,384

Export shipments to: 

 United States 709,005 853,703 1,016,147 213,404 361,564 884,540 884,540

All other markets 19,787 14,586 16,195 4,221 152 17,044 17,044

Total exports 728,792 868,289 1,032,342 217,625 361,716 901,584 901,584

Total shipments 736,568 877,815 1,048,653 221,789 364,180 915,902 915,902

 Ratios and shares (percent) 

Capacity utilization 67.5 77.8 88.7 71.8 110.4 73.7 73.7

Inventories/production 2.7 5.0 8.2 5.0 6.2 9.1 9.2

Inventories/total shipments 2.7 5.1 8.6 5.0 6.2 9.0 9.1

Share of total shipments: 

 Internal consumption/ transfers 0.3 0.2 0.4 0.2 0.4 0.2 0.2

Home market shipments 0.7 0.9 1.1 1.6 0.3 1.4 1.4

Export shipments to: 

 United States 96.3 97.3 96.9 96.2 99.3 96.6 96.6

All other markets 2.7 1.7 1.5 1.9 0.0 1.9 1.9

Total exports 98.9 98.9 98.4 98.1 99.3 98.4 98.4

Total shipments 100.0 100.0 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires. 

Table VII-4 

OCTG: Korean capacity, production, and capacity utilization of welded, seamless, and heat 

treated tubular products, 2011-13, January to March 2013, and January to March 2014 

* * * * * * * 
THE INDUSTRY IN THE PHILIPPINES

The petition in these investigations identified one producer and/or exporter of OCTG, 

HLD Clark Steel Pipe Co., Inc. (“HLD Clark”).26 The Commission issued a foreign producer 

questionnaire to HLD Clark and received a completed response. HLD Clark reported that ***

percent of its total sales in the most recent fiscal year were sales of OCTG.27

HLD Clark estimated that its OCTG exports to the United States accounted for 

approximately *** percent of U.S imports of OCTG from the Philippines in 2013.

28 A 

comparison of HLD Clark’s export data to official Commerce import statistics shows that in 2013

it accounted for *** U.S. imports from the Philippines. HLD Clark estimates that it accounts for 

all production of OCTG in the Philippines.29 

HLD Clark was established in 2009.30 This firm is a welded pipe manufacturing 

subsidiary of Huludao City Steel Pipe Industrial, a Chinese firm.31 HLD Clark added *** and 

began to produce OCTG in 2011.32 HLD Clark’s OCTG operations include ***.

33

Operations on OCTG

Table VII-5 presents information on the OCTG operations of the sole producer and 

exporter in the Philippines. Capacity in the Philippines remained stable during 2011-13, shifting 

slightly from one period to the next, as result of capacity allocated based on the relative shared

of production of products produced on the same equipment and machinery used to produce 

OCTG.34 Capacity was *** percent lower in January-March 2014 relative to January-March 

2013. Capacity is projected to decrease by *** percent from 2013 to 2014 and to *** from 

2014 to 2015. The change in capacity is based on ***.

35 Production in the Philippines increased 

by *** percent from 2011 to 2013, but was *** percent lower in January-March 2014 than in 

January-March 2013. Production is projected to *** from 2013 to 2014 but not change from 

2014 to 2015. Capacity utilization increased from *** percent in 2011 to *** percent in 2012, 

26 Petition, exh. I-5B. 27 Questionnaire response of HLD Clark, II-4.

28 Questionnaire response of HLD Clark, II-8.

29 Questionnaire response of HLD Clark, II-15.

30 HLD Clark Steel Pipe Co., Inc., “About Us,” http://www.hldphpipe.com/Item/list.asp?id=1, accessed 

on July 18, 2013.

31 Petition, exh I-8

32 Preliminary-phase questionnaire response of HLD Clark Steel Pipe Co., Inc., II-2. HLD Clark ***. 33 Questionnaire response of HLD Clark, I-3 and II-4.

34 Questionnaire response of HLD Clark, II-13.

35 Questionnaire response of HLD Clark, II-10.

VII-8

 
and remained above *** percent through 2013 and into January-March 2014.

36 Capacity 

utilization rates are projected to *** in 2014 and 2015.

Table VII-5

OCTG: Data for producers and exporters in the Philippines, 2011-13, January to March 2013, 

January to March 2014, and projected 2014 and 2015

* * * * * * *

In 2013, *** percent of total shipments of OCTG from the Philippines were exported to 

the United States, and *** percent were exported to other markets, with *** being identified 

as its principal export market.

37 Exports of OCTG from the Philippines to the United States 

increased by *** percent from 2011 to 2012, were *** in 2013 compared to 2012, but were 

*** percent lower in January-March 2014 than in January-March 2013. 

Alternative products

Table VII-6 presents information on the total welded tubing capacity and production of 

HLD Clark the sole producer and exporter in the Philippines. HLD Clark reported that it 

produces *** on the same equipment used to produce OCTG.38 39

Table VII-6

OCTG: Philippine capacity, production, and capacity utilization of welded, seamless, and heat 

treated tubular products, 2011-13, January to March 2013, and January to March 2014

* * * * * * *

THE INDUSTRY IN SAUDI ARABIA

The petition in these investigations identified 13 producers and/or exporters of OCTG in 

Saudi Arabia.40 The Commission issued foreign producers questionnaires to these firms and 

received a completed response from four firms, ArcelorMittal Tubular Products Jubail 

(“ArcelorMittal Jubail”), Jubail Energy Services Company (“JESCO”), Saudi Seamless Pipes 

Factory Co., Ltd., (“Saudi Seamless”),41 and Saudi Steel Pipe Company (“SSP”). Three firms 

36 With respect to production constraints, HLD Clark identified ***. Questionnaire response of HLD 

Clark, II-8.

37 Questionnaire response of HLD Clark, II-10.

38 Questionnaire response of HLD Clark, II-5.

39 With respect to constraints on product shifting, HLD Clark reported ***. Questionnaire response of 

HLD Clark, II-9a.

40 Petition, exh. I-5C. 41 Saudi Seamless is related to U.S. producer Vallourec. 

VII-9

 
currently produce OCTG. JESCO reported that *** percent of its total sales in the most recent

fiscal year were sales of OCTG.42 Saudi Seamless reported that *** percent of its total sales in 

the most recent fiscal year were sales of OCTG. 43 SSP reported that *** percent of its total 

sales in the most recent fiscal year were sales of OCTG.44 As of July 24, 2014 ArcelorMittal 

Jubail ***.

45

JESCO estimated that its OCTG exports to the United States accounted for *** percent 

of all such exports of OCTG from Saudi Arabia (*** and ***).46 A comparison of *** export data 

with adjusted official Commerce statistics shows that in 2013 *** percent of U.S. imports from 

Saudi Arabia. According to estimates requested of the responding Saudi Arabian producers, the 

production of OCTG in Saudi Arabia reported by the responding producers accounts for 

approximately *** percent of overall production of OCTG in Saudi Arabia.

SSP, a producer of welded OCTG, which ***,

47 reported that it invested ***.48 SSP 

reported that its investment to produce ERW *** OCTG was in order to supply ***.

49 SSP 

started producing OCTG in ***, and projects that its OCTG capacity will increase from *** short 

tons in 2012 to *** short tons in 2014 and 2015.50 JESCO, a producer of seamless OCTG, which 

has ***51 reported that its mill ***.

52 JESCO noted that its capacity increases are not the result 

of new investments, but reflect the start-up process of the mill as it slowly increased capacity 

and production.53 54 Saudi Seamless ***55 reported that it invested ***.

56 Saudi Seamless 

started its operations in ***.

57

Finally, according to its annual report for 2013, ArcelorMittal’s seamless tube joint 

venture in Jubail, Saudi Arabia, “successfully produced its first saleable pipe on November 30, 

2013.” ArcelorMittal reported a total project cost of $910-950 million for the seamless pipe 

facility, which at full production will have an installed rolling capacity of more than 600,000 

42 Questionnaire response of JESCO, II-14.

43 Questionnaire response of Saudi Seamless, II-14. 44 Questionnaire response of SSP, II-14. 45 E-mail from ***, July 24, 2014.

46 Questionnaire responses of JESCO, II-16, Saudi Seamless II-10, and SSP, II-10. 47 Questionnaire response of SSP, I-3.

48 Questionnaire response of SSP, II-4. SSP also reported that it ***. Preliminary phase questionnaire 

response of SSP, I-3.

49 Preliminary phase questionnaire of SSP, II-2a and II-2b.

50 Questionnaire response of SSP, II-5a. 51 Questionnaire response of JESCO, I-3.

52 Questionnaire response of JESCO, II-2. In its preliminary phase questionnaire response, JESCO 

anticipated that it ***. Preliminary phase questionnaire response of JESCO, II-2a.

53 Questionnaire response of JESCO, II-4, II-7, and II-12. JESCO also reported that it took *** months 

to fully commission and accept the installed equipment. Questionnaire response of JESCO, II-2. 54 JESCO also reported that it is ***. Questionnaire response of JESCO, II-8. 55 Questionnaire response of Saudi Seamless, II-4.

56 Questionnaire response of Saudi Seamless, II-4. 57 Questionnaire response of Saudi Seamless, II-2.

VII-10
metric tons (661,380 short tons). ArcelorMittal Jubail’s product range will include seamless 

OCTG casing, seamless OCTG tubing, and seamless line pipe. OCTG offerings will range from 

2.375 inches to 13.375 inches in diameter, and include API grades H40 through Q125 with a 

variety of end finishes, including premium connections. As of the first quarter of 2014, 

ArcelorMittal reported that the joint venture “produced some limited ranges of ASTM1 pipes 

and is in the process of obtaining American Petroleum Institute (API) certification ... after which 

commercial production of API products can start, as well as certification from key regional 

customers (i.e. Aramco).” API issued certifications 5CT-1675 (Casing and Tubing) and 5L-1026 

(Line Pipe) to ArcelorMittal Jubail on March 14, 2014.58 As of July 24, 2014 ArcelorMittal Jubail

***.

59 ArcelorMittal Jubail reported ***.60

Operations on OCTG

Table VII-7a presents information on the OCTG operations of the responding producers 

in Saudi Arabia. Table VII-2b presents information on processor Saudi Seamless. ***. Increases 

in mill capacity reflect ***. Reported capacity for Saudi Arabian mills increased by *** percent 

from 2011 to 2012 and by *** percent from 2012 to 2013, for an overall increase of ***

percent from 2011 to 2013. Capacity was *** percent higher in January-March 2014 than in 

January-March 2013. Capacity is projected to be *** percent higher in 2014 compared to 2013, 

and *** percent higher in 2015 compared to 2013. Reported production in Saudi Arabia 

fluctuated during 2011-13, decreasing by *** percent from 2011 to 2012, then increasing by 

*** percent from 2012 to 2013, resulting in an overall increase of *** percent from 2011 to 

2013. Production was *** percent higher in January-March 2014 than in January-March 2013. 

Production is projected to be *** percent higher in 2014 compared to 2013 and *** percent 

higher in 2015 compared to 2013. Capacity utilization increased, reflecting responding firms’ 

ramping up of production as their capacity increased. 61

Table VII-7a

OCTG: Data for producers and exporters in Saudi Arabia (mills), 2011-13, January to March 2013, 

January to March 2014, and projected 2014 and 2015

* * * * * * *

58 ArcelorMittal, Annual Review 2013, pp. 1, 18, and 19; ArcelorMittal, Tubular Products Division, 

“Product Range Jubail,” p. 38/41 of PDF (2012); API Composite List, “Product Listing for ArcelorMittal 

Tubular Products Jubail” and listing of certifications issued in the previous six months, retrieved on July 

24, 2014.

59 E-mail from ***, July 24, 2014.

60 Questionnaire response of ArcelorMittal Jubail, II-10.

61 With respect to production constraints, JESCO reported *** and that its current ***. SSP reported 

the ***. Questionnaire responses of Saudi Arabian producers, II-8a.

VII-11

 
In 2013, *** percent of total shipments of OCTG from Saudi Arabia were exported to 

the United States, and *** percent were exported to other markets, predominantly in ***. 

Exports of OCTG from Saudi Arabia to the United States decreased by *** percent from 2011 to 

2013, and were *** in January-March 2014. Exports to all other markets, increased by ***

percent from 2011 to 2013, but were *** in January-March 2014 compared to *** short tons in 

January-March 2013. During 2011 through January-March 2013, exports to markets other than 

the United States were *** than exports to the United States. Projected exports for 2014 to the 

United States and all other markets are almost the same and for 2015 projected exports to 

markets other than the United States are expected to be larger than exports to the United 

States. ***.

62 ***.63

Table VII-2b presents information on processor Saudi Seamless. Saudi Seamless’s 

operations include ***.

64 Saudi Seamless’s plant was built in January 2012, ***.65 Saudi

Seamless projects higher capacity in 2014 and 2015 relative to 2013, along with increased 

production. All of Saudi Seamless’s ***.

66

Table VII-7b

OCTG: Data for Saudi Arabian processor Saudi Seamless, 2011-13, January to March 2013, 

January to March 2014, and projected 2014 and 2015

* * * * * * *

Alternative products

Table VII-8 presents information on the total welded and seamless tubular capacity and 

production of the two responding mills in Saudi Arabia and heat treatment production and 

capacity for Saudi Seamless. SSP reported *** on the same equipment and machinery used to 

produce welded OCTG.67 JESCO reported *** on the pipe forming equipment and machinery 

used to produce OCTG and that it also heat treats products other than OCTG.

68 69

62 Questionnaire response of JESCO, II-10. ***. Questionnaire response of SSP, II-10.

63 Questionnaire response of ArcelorMittal Jubail, II-10.

64 Questionnaire response of Saudi Seamless, I-3.

65 Questionnaire response of Saudi Seamless, II-2.

66 Questionnaire response of Saudi Seamless, II-10.

67 Questionnaire response of SSP, II-5. ***. 68 Questionnaire response of JESCO, I-5.

69 With respect to product shifting, JESCO reported ***. Questionnaire response of JESCO, II-9a. 

JESCO also reported that ***. Questionnaire response of JESCO, II-9a and II-9b. Saudi Seamless reported 

that ***. Questionnaire response of Saudi Seamless, II-9. SSP reported ***. Questionnaire response of 

SSP, II-9a.

VII-12

 
Table VII-8 

OCTG: Saudi Arabian capacity, production, and capacity utilization of welded, seamless, and heat 

treated tubular products, 2011-13, January to March 2013, and January to March 2014

* * * * * * *

THE INDUSTRY IN TAIWAN

The petition in these investigations identified five producers and/or exporters of OCTG

in Taiwan. 70 The Commission issued foreign producer questionnaires to these firms and

received a completed response from all five: Chung Hung Steel Corp. (“Chung Hung”) a 

nonsubject producer,

71 Far East Machinery Co. Ltd. (“Far East Machinery”), Kao Hsing Chang 

Iron & Steel Corp. (“Kao Hsing”), Shin Yang Steel Co., Ltd., (“Shin Yang”), and Tension Steel

Industries Co., Ltd. (“Tension Steel”). Far East Machinery reported that *** percent of its total

sales in the most recent fiscal year were sales of OCTG.72 Kao Hsing reported that *** percent

of its total sales in the most recent fiscal year were sales of OCTG.73 Shin Yang reported that

*** percent of its total sales in the most recent fiscal year were sales of OCTG.74 Tension Steel 

reported that *** percent of its total sales in the most recent fiscal year were sales of OCTG.75

A comparison of these firms’ export data with official Commerce import statistics shows 

that in 2013 they accounted for all of U.S. imports of subject OCTG from Taiwan. According to 

estimates requested of the responding Taiwan producers, the production of OCTG in Taiwan 

reported by the responding producers accounts for *** production of subject OCTG in 

Taiwan.76

*** is the one subject Taiwan producer that reported investing in a new OCTG mill. ***. 

Shin Yang’s *** investment in ***.

77 The new equipment explains the increases in Taiwan 

capacity in 2012 shown in table VII-9 and *** capacity in table VII-10. ***.

78

70 Petition, exh. I-5E. 71 Commerce calculated a final weighted-average margin of 0.00 percent for Chung Hung. 

Accordingly, Chung Hung is not a subject producer. Chung Hung’s operations are not included in this 

chapter. 72 Questionnaire response of Far East Machinery, II-14.

73 Questionnaire response of Kao Hsing, II-14. 74 Questionnaire response of Shin Yang, II-14. 75 Questionnaire response of Tension Steel, II-14.

76 Questionnaire responses of Taiwan producers, II-15. 77 Questionnaire response of Shin Yang, II-2 and II-4. Shin Yang ***. Questionnaire response of Shin 

Yang, I-2.

78 Questionnaire response of Shin Yang, II-10.

VII-13
Operations on OCTG

Table VII-9 presents information on the OCTG operations of the four responding subject 

producers and exporters in Taiwan. All Taiwan subject producers reported having only pipe 

forming operations.79 Capacity in Taiwan increased from 2011 to 2012, entirely due to ***.

Production in Taiwan was steady during 2011-2013, but was *** percent less in January-March 

2014 than in January-March 2013. Production is expected to be *** percent higher in 2014 than

in 2013 and *** percent higher in 2015 than in 2013. Capacity utilization decreased from ***

percent in 2011 to less than *** percent in 2012 and 2013, largely as a result of Shin Yang’s new 

plant coming online but having little production. Capacity utilization was *** percent in 

January-March 2014 compared to *** percent in January-March 2013.

80

Table VII-9

OCTG: Data for producers and exporters in Taiwan, 2011-13, January to March 2013, January to 

March 2014, and projected 2014 and 2015

* * * * * * *

In 2013, *** percent of total shipments of OCTG from Taiwan were to the United States 

and *** percent were exported to other markets, predominantly Australia and Canada. Exports 

of OCTG from Taiwan to the United States were steady from 2011 to 2012, but increased by 

*** percent from 2012 to 2013. Exports in January-March 2014 were *** percent less than 

those in January-March 2013.

Alternative products

Table VII-10 presents information on the total welded tubular capacity and production 

of the four responding producers in Taiwan.81

Table VII-10

OCTG: Taiwan capacity, production, and capacity utilization of welded, seamless, and heat 

treated tubular products, 2011-13, January to March 2013, and January to March 2014

* * * * * * *

79 Questionnaire responses of Taiwan producers, I-2.

80 With respect to production constraints, Far East Machinery identified ***, Kao Hsing identified 

***, Shin Yang reported ***, and Tension Steel identified ***. Questionnaire responses of Taiwan 

producers, II-8a. 

81 With respect to product shifting, Far East Machinery identified ***, Kao Hsing identified ***, Shin 

Yang reported ***, and Tension Steel reported ***. Questionnaire responses of Taiwan producers, II9a.

VII-14

 
THE INDUSTRY IN THAILAND

The petition in these investigations identified three producers and/or exporters of OCTG

from Thailand.

82 The Commission issued foreign producer questionnaires to these firms and 

received a completed response from one firm, Boly Pipe, a producer of seamless OCTG. Boly 

Pipe reported that *** percent of its total sales in the most recent fiscal year were sales of 

OCTG.83 Boly Pipe estimated that its exports to the United States accounted for approximately 

*** percent of U.S imports of OCTG from Thailand in 2013.

84 A comparison of Boly Pipe’s

export data to official Commerce import statistics, as adjusted, shows that in 2013 Boly Pipe

accounted for *** of all U.S. imports from Thailand. According to estimates requested of the 

responding Thai producer, the production of OCTG in Thailand reported in this part of the 

report accounts for approximately *** percent of overall production of OCTG in Thailand.85 

There is one other known producer of OCTG in Thailand, WSP Pipe Co., Ltd., (“WSP”).86

WSP was established in 2010 and is the branch enterprise of WSP Holdings Limited, a Chinese 

firm.

87 88 WSP opened its first plant in 2011, beginning with a single production line in April and 

expanding to two production lines in August.89 WSP Pipe reported investing ***.

90 WSP

produces seamless OCTG.91 Boly Pipe believes that ***.

92

Operations on OCTG

Table VII-11 presents information on the OCTG operations of the responding producer 

and exporter in Thailand. Boly Pipe opened its OCTG plant in *** at a cost of $***.

93 94 Its 

operations include ***.

95 Boly Pipe ***. The projections below ***. Boly Pipe notes that ***.96

82 Petition, exh. I-5F.

83 Questionnaire response of Boly Pipe, II-14.

84 Questionnaire response of Boly Pipe, II-16.

85 Questionnaire response of Boly Pipe, II-7.

86 In the preliminary phase of these investigations, WSP provided the sole Thai foreign producers’ 

questionnaire response WSP started producing OCTG in 2011. In 2012, WSP reported *** short tons of 

capacity, *** short tons of production, and exported *** short tons to the United States. WSP did not 

project any increases in capacity for 2013 or 2014, but did project ***. 87 WSP Pipe Co., Ltd., “Company Introduction,” http://wspp.co.th/index.php/about-us, accessed on 

July 19, 2013.

88 WSP Holdings Limited, “Contact Us,” http://www.wsphl.com/elxwm.asp, accessed on July 19, 

2013.

89 Preliminary-phase questionnaire response of WSP, II-2.

90 Preliminary-phase questionnaire response of WSP, II-2.

91 Preliminary-phase questionnaire response of WSP, II-4.

92 Posthearing brief of Thai Respondent Boly Pipe, pp. 3-4.

93 Questionnaire response of Boly Pipe, II-2 and II-4.

VII-15

 
VII‐16

Table VII-11 

OCTG: Data for producers and exporters in Thailand, 2011-13, January to March 2013, January to 

March 2014, and projected 2014 and 2015 

* * * * * * * 

Alternative products

Table VII‐12 presents information on the reported seamless tubular capacity and

production of the Boly Pipe.  Boly Pipe reported *** on the same equipment and machinery

used to produce seamless OCTG.97 98

Table VII-12 

OCTG: Thai capacity, production, and capacity utilization of welded, seamless, and heat treated 

tubular products, 2011-13, January to March 2013, and January to March 2014 

* * * * * * * 

THE INDUSTRY IN TURKEY

The petition in these investigations identified five producers and/or exporters of OCTG

in Turkey. 99  The Commission issued foreign producers questionnaires to these firms and

received a completed response from three firms, Borusan Mannesmann Boru Sanayi Ve Ticaret

Tas (“Borusan”), Çayirova Boru Sanayi Ve Ticaret A.Ş (“Çayirova”), and Toscelik Profil Ve Sac

Endustrisi A.S (“Toscelik”). Borusan reported that *** percent of its total sales in the most

recent fiscal year were sales of OCTG.100 Çayirova reported that *** percent of its total sales in

the most recent fiscal year were sales of OCTG.101 Toscelik reported that *** percent of its total

sales in the most recent fiscal year were sales of OCTG.102

                                                            

(...continued)

94 With respect to production constraints, Boly Pipe identified ***. Questionnaire response of Boly

Pipe, II‐8.

95 Questionnaire response of Boly Pipe, I‐2.

96 Questionnaire response of Boly Pipe, II‐10.   97 Questionnaire response of Boly Pipe, II‐5. WSP also reported that it produces line pipe on the same

equipment and machinery used to produce OCTG. Preliminary phase questionnaire response of WSP, II‐

4.  

98 With respect to product shifting, Boly Pipe reported ***. Questionnaire response of Boly Pipe, II‐

9a.

99 Petition, exh. I‐5G.

100 Questionnaire response of Borusan, II‐14.

101 Questionnaire response of Çayirova, II‐14.

102 Questionnaire response of Toscelik, II‐14.
Borusan estimated that its OCTG exports to the United States accounted for 

approximately *** percent of all such exports of OCTG from Turkey in 2013, while Çayirova 

estimated that its exports to the United States accounted for approximately *** percent, and 

Toscelik estimated that its exports to the United States accounted for approximately ***

percent. A comparison of these firms’ exports data to official Commerce import statistics 

shows that in 2013 they accounted for *** percent of all U.S. imports from Turkey. According to 

estimates requested of the responding Turkish producers, the production of OCTG in Turkey 

reported by the responding producers account for approximately all production of OCTG in 

Turkey and all exports to the United States.103

The three responding Turkish producers reported changes in operations through 

investments in new equipment and plant capabilities. Borusan reported that it ***.

104 Çayirova 

reported that it ***.

105 Toscelik reported that it ***106 and that individual lines ***.107 ***.

Toscelik also notes that the ***.

108

Operations on OCTG

Table VII-13 presents information on the OCTG operations of the responding producers 

and exporters in Turkey. Borusan’s OCTG operations include ***,

109 Cayirova’s includes ***,110

and Toscelik’s includes ***.

111 Capacity increased by *** percent from 2011 to 2013 and was 

*** percent higher in January-March 2014 compared to January-March 2013. Capacity is 

projected to be ***percent lower in 2014 than in 2013, and to not change from 2014 to 2015.

The projected reduced capacity is entirely attributable to ***.

112 Production in Turkey 

increased by *** percent from 2011 to 2012 but was *** percent lower in 2013 compared to 

2012, resulting in an overall decrease in production of *** percent from 2011 to 2013. 

Production in January-March 2014 was *** percent lower than in January-March 2013. 

Production is projected to *** by *** percent from 2013 to 2014 and to be *** percent in 

lower in 2015 compared to 2013.

113 Most of the reduction in projected production is 

attributable to ***. *** projected *** production in 2014 and 2015 compared to 2013, 

whereas *** reported increased production of *** short tons in 2014 and 2015 compared to 

2013. ***.

103 Questionnaire responses of Turkish producers, II-15.

104 Questionnaire response of Borusan, II-4.

105 Questionnaire response of Cayirova, II-4.

106 Questionnaire response of Toscelik, II-4.

107 Questionnaire response of Toscelik, II-2.

108 Questionnaire response of Toscelik, II-4.

109 Questionnaire response of Borusan, I-2 and I-3. ***. 110 Questionnaire response of Cayirova, I-2. 111 Questionnaire response of Toscelik, I-2. 112 Questionnaire response of Borusan, II-10.

113 With respect to production constraints, Borusan identified ***, Çayirova identified ***, and 

Toscelik identified ***. Questionnaire responses of Turkish foreign producers, II-8.

VII-17

 
In March 2014, Borusan commenced operations at its $150 million ERW pipe mill, heat 

treatment, and threading facility in Baytown, Texas. This facility with have pipe-forming 

capacity of 300,000 short tons per year. Pipe production at the new facility is limited to 4.5-inch 

diameter to 10.75-inch diameter pipes. Accordingly, Borusan plans to import from Turkey sizes 

outside of these diameters. Borusan expects that once its U.S. plant is fully operational, its 

exports from Turkey to the United States will be greatly reduced. 114 Projections included in 

table VII-13 for exports to the United States reflect this anticipated decline.

Table VII-13

OCTG: Data for producers and exporters in Turkey, 2011-13, January to March 2013, January to 

March 2014, and projected 2014 and 2015

* * * * * * *

In 2013, *** percent of total shipments of OCTG from Turkey were exported to the 

United States, and *** percent were exported to other markets. Exports of OCTG from Turkey 

to the United States decreased by *** percent from 2011 to 2013, but were *** percent higher 

in January-March 2014 than in January-March 2013.

Alternative products

Table VII-14 presents information on the overall welded tubular capacity and production 

of the responding producers in Turkey.115

Table VII-14

OCTG: Turkish capacity, production, and capacity utilization of welded, seamless, and heat 

treated tubular products, 2011-13, January to March 2013, and January to March 2014

* * * * * * *

THE INDUSTRY IN UKRAINE

The petition in these investigations identified two producers and/or exporters of 

OCTG.116 The Commission issued foreign producer questionnaires to these firms and received a 

completed response from both firms, Interpipe Nizhnedneprovsky (“Interpipe NTRP”) and 

Interpipe Niko Tube Limited Liability Company (“Interpipe Niko”). Interpipe NTRP reported that 

*** percent of its total sales in the most recent fiscal year were sales of OCTG.117 Interpipe 

114 Hearing Transcript, pp. 235-238 (Brewer). 115 With respect to constraints on product shifting, Borusan identified ***, Çayirova identified ***, 

Toscelik stated ***. Questionnaire responses of Turkish foreign producers, II-4e.

116 Petition, exh. I-5H. 117 Questionnaire response of Interpipe Nizhnedneprovsky (Interpipe NTRP), II-14.

VII-18

 
Niko reported that *** percent of its total sales in the most recent fiscal year were sales of 

OCTG.118

Interpipe NTRP estimated that its OCTG exports to the United States accounted for 

approximately *** percent of all such exports of OCTG from Ukraine in 2013, while Interpipe 

Niko’s estimated that its OCTG exports to the United States accounted for approximately ***

percent.119 A comparison of these firms’ export data to official Commerce import statistics, as 

adjusted, shows that in 2013 they accounted for *** U.S. imports from Ukraine. According to 

estimates requested of the responding Ukrainian producers, the production of OCTG in Ukraine 

reported by the responding producers accounts for essentially *** production of OCTG in 

Ukraine.120 

Interpipe NTRP and Interpipe Niko are mills belonging to Interpipe Group.121 122 

According to their website, Interpipe Group is one of the biggest employers in Ukraine.123 

Neither Interpipe NTRP nor Interpipe Niko reported making any investments increasing their 

OCTG production capacity between 2010 and 2012.124 Both Interpipe NTRP and Interpipe Niko 

produce seamless OCTG.125 Niko Tube’s OCTG production operations include ***.

126 Interpipe 

NTRP’s OCTG production operations include ***.

127

Operations on OCTG

Table VII-15 presents information on Ukrainian OCTG operations. Capacity in Ukraine 

remained constant from 2011 to 2013, and was unchanged in January-March 2014 relative to 

January-March 2013. Capacity is projected ***. Production in Ukraine increased by ***

percent from 2011 to 2012, but was *** percent lower 2013 than in 2012. Production was ***

less in January-March 2014 than in January-March 2013. Production is projected to increase by 

118 Questionnaire response of Interpipe Niko Tube Limited Liability Company, II-14.

119 Questionnaire responses of Interpipe Nizhnedneprovsky (Interpipe NTRP) and Interpipe Niko Tube 

Limited Liability Company, II-14.

120 Ibid., II-15. Dniprovskiy Pipe Works is also capable of producing casing and tubing. In March 2012, 

the company announced monthly capacity of up to 3,000 metric tons for GOST and API casing and up to 

1,500 metric tons for GOST and API tubing. Dnipovskiy Pipe Works, “Oil & Gas Country Tubular Goods 

Manufacturer” and Wire Tube News, March 30, 2012, “New Brand OCTG in Ukraine.” 121 Interpipe Group, “Interpipe NTRP – Dnepropetrovsk, Ukraine,” 

http://interpipe.biz/en/company/productions/ntz/, accessed on July 25, 2013. 122 Interpipe Group, “Interpipe NIKO TUBE – Nikopol, Ukraine,” 

http://interpipe.biz/en/company/productions/nikotube/, accessed on July 25, 2013.

123 Interpipe Group, “Social Policy,” http://interpipe.biz/en/company/respons/social/, accessed on 

July 25, 2013. 124 Questionnaire responses of Interpipe NTRP and Interpipe Niko, II-2.

125 Ibid., II-4.

126 Questionnaire response of Interpipe Niko, I-3. Niko Tube also identified Pavlograd Plant of 

Technological Equipment, LLC and Kalibar LLC as manufacturers and suppliers of couplings. 127 Questionnaire response of Interpipe NTRP, I-3. 

VII-19

 
*** percent from 2013 to 2014 and to remain at the same level in 2015. Capacity utilization 

increased from *** percent in 2011 to *** percent in 2012 and was *** percent in 2013. 

Capacity utilization was *** percent in January-March 2014 compared to *** percent in 

January-March 2012.128

Table VII-15

OCTG: Data for producers and exporters in Ukraine, 2011-13, January to March 2013, January to 

March 2014, and projected 2014 and 2015

* * * * * * *

In 2013, *** percent of total shipments of OCTG from Ukraine were exported to the 

United States, and *** percent were exported to other markets, predominantly ***.

129 Exports 

of OCTG from Ukraine to the United States increased by *** percent from 2011 to 2012, but 

decreased by *** percent from 2012 to 2013. Exports to the United States were *** percent 

lower in January-March 2014 than in January-March 2013. 

Alternative products

Table VII-16 presents information on the total seamless tubular capacity and production 

of the responding producers and exporters in Ukraine.130 Interpipe NTRP reported that it ***

on the same equipment used to produce OCTG.131 Interpipe Niko reported that it *** on the 

same equipment used to produce OCTG.132

Table VII-16

OCTG: Ukrainian capacity, production, and capacity utilization of welded, seamless, and heat 

treated tubular products, 2011-13, January to March 2013, and January to March 2014

* * * * * * *

THE INDUSTRY IN VIETNAM

The petition in these investigations identified eight producers and/or exporters of OCTG 

in Vietnam.133 The Commission issued foreign producer questionnaires to these firms and 

128 With respect to production constraints, Interpipe NTRP stated ***, and Interpipe Niko identified 

***. Questionnaire response of Ukrainian producers, II-8.

129 Ibid., II-10.

130 With respect to constraints on product shifting, Interpipe NTRP stated ***, Interpipe Niko 

identified ***, Questionnaire responses of Ukrainian producers, II-9.

131 Questionnaire response of Interpipe NTRP, II-5.

132 Questionnaire response of Interpipe Niko, II-5.

133 Petition, exh. I-5I.

VII-20

 
received a completed response from one firm, SeAH Steel Vina Corp. (“SeAH Steel Vina”)134 

SeAH Steel Vina reported that *** percent of its total sales in the most recent fiscal year were 

sales of OCTG.135 Hot Rolling Pipe did not provide a response, but reported that *** percent of 

its total sales in the most recent fiscal year were sales of OCTG in the preliminary phase of 

these investigations.

136

SeAH Steel Vina estimated that its OCTG exports to the United States accounted for 

approximately *** percent of all such exports of OCTG from Vietnam in 2013.

137 A comparison 

of its export data with official Commerce import statistics shows that in 2013 it accounted for 

*** percent of all U.S. imports of OCTG from Vietnam. According to estimates requested of the

responding Vietnamese producer, the production of OCTG in Vietnam reported by SeAH Steel 

Vina accounts for approximately *** percent of overall production of OCTG in Vietnam.138

SeAH Steel Vina’s first production lines came online in May of 1999.139 SeAH Steel Vina 

is a subsidiary of the SeAH Group, which is based in Korea. SeAH Steel Vina’s OCTG operation 

includes ***.

140 In the beginning of 2013, SeAH Steel Vina invested *** towards the 

construction of a new production line capable of producing ***.

141 SeAH Steel Vina cited ***.142

SeAH Steel Vina produces welded OCTG.143

Hot Rolling Pipe was established in August 2011, and opened its plant in December 

2011.144 145 A total of *** was invested in ***. 146 According to their website, Hot Rolling Pipe 

is the only producer of seamless OCTG in Vietnam.147

134 During the preliminary phase of these investigations, the Commission received two completed 

questionnaire responses from producers in Vietnam, SeAH Steel Vina and Hot Rolling Pipe. Counsel for 

Hot Rolling Pipe informed Staff that Hot Rolling Pipe *** E-mail from Kristin Mowry, Counsel to Hot 

Rolling Pipe, Mowry & Grimson PLLC, May 15, 2014. Hot Rolling Pipe did not respond to an additional 

request from Staff for Hot Rolling Pipe to complete a response, explaining that doing so entails largely 

updating data already provided in the preliminary phase of the investigations. Staff e-mail to ***, May 

16, 2014.

135 Questionnaire response of SeAH Steel Vina Corporation, II-6.

136 Preliminary phase questionnaire response of Hot Rolling Pipe Co., Ltd Vietnam, II-6.

137 Questionnaire response of SeAH Steel Vina, II-16.

138 Ibid., II-15.

139 SeAH Steel Vina Corporation, “Company’s History,” http://SeAHvina.com.vn/gioi-thieu/companyshistory.html, accessed on July 26, 2013.

140 Questionnaire response of SeAH Steel Vina, I-2. 141 Questionnaire response of SeAH Steel Vina, II-2 and II-4. 142 Preliminary phase questionnaire response of SeAH Steel Vina, II-2.

143 Questionnaire response of SeAH Steel Vina, II-5. 144 Hot Rolling Pipe Co., Ltd Vietnam, “About Us,” http://www.hrpvietnam.com/about_us.php, 

accessed on July 26, 2013. 145 Preliminary-phase questionnaire response of Hot Rolling Pipe Co., II-2.

146 Ibid. 147 Hot Rolling Pipe Co., Ltd Vietnam, “About Us,” http://www.hrpvietnam.com/about_us.php, 

accessed on July 26, 2013.

VII-21

 
Operations on OCTG

Table VII-17 presents information on the OCTG operations of the one responding 

producer and exporter in Vietnam. Reported capacity in Vietnam remained the same 

throughout 2011-13.148 These data do not reflect Hot Rolling Pipe’s mill which started up in 

2012 with *** tons of capacity to produce OCTG.149 Reported capacity is projected to increase 

by *** percent from 2013 to 2014, and remain at that level in 2015. Reported production in 

Vietnam increased by *** percent from 2011 to 2012, but was *** percent lower 2013 than in 

2012. Production was *** percent lower in January-March 2014 than in January-March 2013. 

Production for full year 2014 is projected to be *** percent lower than production in 2013, but 

production is projected to increase by *** percent from 2014 to 2015. Capacity utilization 

fluctuated during 2011-13, and is projected to be at its lowest levels in 2014 and 2015.

Table VII-17

OCTG: Data for producers and exporters in Vietnam, 2011-13, January to March 2013, January to 

March 2014, and projected 2014 and 2015

* * * * * * *

Since 2011, *** shipments of OCTG from Vietnam were exports to the United States.

Exports, like production, fluctuated during 2011-13. Exports of OCTG from Vietnam to the 

United States increased by *** percent from 2011 to 2012, but were *** percent lower in 2013 

than in 2012. *** projected production in 2014 and 2015 is expected to be exported to the 

United States.

Alternative products

Table VII-18 presents information on the total welded and seamless tubular capacity 

and production of the responding producer in Vietnam. SeAH Steel Vina reported that it ***.

150

Table VII-18

OCTG: Vietnamese capacity, production, and capacity utilization of welded, seamless, and heat 

treated tubular products, 2011-13, January to March 2013, and January to March 2014

* * * * * * *

148 With respect to production constraints, SeAH Steel Vina reported ***. Questionnaire response of 

SeAH Steel Vina, II-8.

149 Preliminary-phase questionnaire response of Hot Rolling Pipe Co., II-5a. Hot Rolling Pipe projected 

***.

150 Questionnaire response of SeAH Steel Vina Corporation, II-5. With respect to constraints on 

product shifting, SeAH Steel Vina identified ***. Questionnaire response of SeAH Steel Vina 

Corporation, II-9.

VII-22

 
VII‐23

SUBJECT COUNTRIES COMBINED

Table VII‐19 presents information on OCTG operations of the reporting producers and

exporters in the subject countries.

Table VII-19 

OCTG: Data for subject producers combined (mills only), 2011-13, January to March 2013, January to 

March 2014, and projected 2014 and 2015 

Item 

Actual experience Projections

Calendar year January to March Calendar year

2011 2012 2013 2013 2014 2014 2015

 Quantity (short tons)

Capacity 2,636,510 2,927,472 3,158,751 763,188 823,422 3,172,762 3,416,394

Production 1,824,751 2,070,961 2,240,494 516,412 627,941 2,267,643 2,487,157

End-of-period inventories 72,074 103,941 150,222 109,342 176,618 138,338 136,303

Shipments: 

 Internal consumption/ transfers 5,163 7,164 8,444 3,646 3,241 5,097 4,434

Home market shipments 245,134 270,045 344,662 72,767 86,024 382,707 525,774

Export shipments to: 

 United States 1,359,191 1,526,251 1,617,473 364,258 452,511 1,421,524 1,424,210

All other markets 212,791 235,637 225,880 70,339 59,769 471,367 542,181

Total exports 1,571,982 1,761,888 1,843,353 434,597 512,280 1,892,891 1,966,391

Total shipments 1,822,279 2,039,097 2,196,459 511,010 601,545 2,280,695 2,496,599

 Ratios and shares (percent) 

Capacity utilization 69.2 70.7 70.9 67.7 76.3 71.5 72.8

Inventories/production 3.9 5.0 6.7 5.3 7.0 6.1 5.5

Inventories/total shipments 4.0 5.1 6.8 5.3 7.3 6.1 5.5

Share of total shipments: 

 Internal consumption/ transfers 0.3 0.4 0.4 0.7 0.5 0.2 0.2

Home market shipments 13.5 13.2 15.7 14.2 14.3 16.8 21.1

Export shipments to: 

 United States 74.6 74.8 73.6 71.3 75.2 62.3 57.0

All other markets 11.7 11.6 10.3 13.8 9.9 20.7 21.7

Total exports 86.3 86.4 83.9 85.0 85.2 83.0 78.8

Total shipments 100.0 100.0 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires. 
VII‐24

U.S. INVENTORIES OF IMPORTED MERCHANDISE

Table VII‐20 presents data on U.S. importers’ reported inventories of OCTG.

Table VII-20 

OCTG: U.S. importers’ end-of-period inventories, 2011-13, January to March 2013, and January to 

March 2014 

* * * * * * * 

U.S. IMPORTERS’ OUTSTANDING ORDERS

The Commission requested that importers indicate whether they imported or arranged

for the importation of OCTG from subject sources after March 31, 2014. Table VII‐21 presents

U.S. import shipments of OCTG arranged for importation after March 31, 2014.  

Table VII-21 

OCTG: U.S. importers’ arranged imports, 2014 

* * * * * * * 
ANTIDUMPING OR COUNTERVAILING DUTY ORDERS IN THIRD-COUNTRY MARKETS

Exports of certain OCTG from Ukraine are subject to antidumping orders in the 

European Union (EU) and Russia.151 In the EU, exports of certain seamless pipes and tubes, 

including seamless iron and alloy casing and tubing, from Ukraine are subject to antidumping 

duties ranging from 12.3–25.7 percent.152 Effective September 9, 2012, Ukrainian OCTG 

producer Interpipe is subject to an antidumping duty rate of 13.8 percent.153 In Russia, 

Ukrainian exports of certain casing are reportedly subject to an antidumping duty rate of 18.9 

percent, while exports of certain tubing are subject to a rate of 19.9 percent.154 Russian 

antidumping duty orders ***.

155 On July 22, 2014, Canada initiated a preliminary injury inquiry 

on allegedly dumped and/or subsidized imports of certain oil country tubular goods from 

Taiwan, India, Indonesia, the Philippines, Korea, Thailand, Turkey, Ukraine, and Vietnam.156 In 

its prehearing brief, U.S. Steel noted that Brazil imposed antidumping duties on certain

seamless OCTG from Ukraine.157 However, the product in question appears to be seamless line

pipe and not OCTG.158

INFORMATION ON NONSUBJECT COUNTRIES

OCTG is produced in substantial quantities by pipe and tube producers throughout the 

world. The World Steel Association (WSA) publishes data on the global production of the larger 

151 In May 2014, OCTG producers in Canada reportedly filed an antidumping and countervailing duty 

petition again certain OCTG from India, Indonesia, the Philippines, Korea, Taiwan, Thailand, Turkey, 

Ukraine, and Vietnam. “Canadian OCTG Producers File Trade Case,” May 5, 2014; MBR, Seamless OCTG 

& Linepipe Market Tracker, June 2014, p. 4.

152 The scope of the orders includes certain iron and alloy casing and tubing classified under HS 

7304.29.

153 Official Journal of the European Union, Council Implementing Regulation (EU) No. 795/2012 of 

August 28, 2012, September 9, 2012. 154 U.S. Steel postconference brief, exh. 54 (“Medvedev decides not to extend quotas for Ukraine 

pipes,” Ukrinform, July 17, 2013). 155 ***. 156 Canadian International Trade Tribunal, “Notice of Commencement of Preliminary Injury Inquiry Oil 

Country Tubular Goods,” July 22, 2014. Includes “casing, tubing and green tubes made of carbon or alloy 

steel, welded or seamless, heat-treated or not heat-treated, regardless of end finish, having an outside 

diameter from 2 3/8 inch to 13 3/8 inches (60.3 mm to 339.7 mm), meeting or supplied to meet 

American Petroleum Institute (API) specification 5CT or equivalent and/or enhanced proprietary 

standards, in all grades, excluding drill pipe, pup joints, couplings, coupling stock and stainless steel 

casing, tubing or green tubes containing 10.5 percent or more by weight of chromium.” 157 Prehearing brief of petitioner U.S. Steel, p. 46.

158 Prehearing brief of petitioner U.S. Steel, exhibit 117 (“The pipes are used in oil and gas pipeline 

manufacturing.”); MBR, MBR Seamless OCTG & Linepipe Market Tracker, June 2014, p. 4.

VII-25

 
product groupings of all pipe and tube. As shown in tables VII-22 through VII-24, global pipe and 

tube production increased steadily between 2009 and 2011 as the global economy began to 

recover from the economic downturn in 2008 and 2009. China accounted for a substantial 

majority of production growth, particular for welded tubular products.

Table VII-22

Welded and seamless steel pipe and fittings: Global production, by region, 2009–12

Region

2009 2010 2011 2012

Quantity (1,000 short tons)

1

North America:

 United States 2,347 3,880 4,816 4,782

 Canada 1,680 2,679 2,800 2,999

 Mexico 1,290 1,516 1,411 1,644

 Subtotal 5,317 8,074 9,027 9,425

South America:

 Argentina (

2

) (

2

) (

2

) (

2

)

 Others 4 (

2

) (

2

) (

2

)

 Subtotal 4 (

2

) (

2

) (

2

)

EU (27):

 Germany 3,201 3,532 3,585 (

2

)

 Italy 2,884 3,347 3,611 (

2

)

 Spain 820 1,257 1,204 (

2

)

 Others 5,959 6,598 7,137 1,426

 Subtotal 12,864 14,733 15,537 1,426

CIS: 3

 Ukraine 1,725 2,022 2,538 2,402

 Others 7,248 10,527 11,614 11,445

 Subtotal 8,973 12,549 14,151 13,847

Asia:

 China 58,658 62,533 75,314 83,722

 India 1,715 2,083 1,989 2,218

 Japan 6,803 8,477 8,602 8,683

 Korea 4,307 5,352 5,592 6,240

 Philippines 64 55 99 109

 Taiwan 977 1,265 1,338 1,303

 Vietnam 626 742 806 854

 Others 1,388 1,467 1,336 1,515

 Subtotal 74,538 81,974 95,077 104,643

Others 295 310 299 270

Total 101,990 117,641 134,091 129,611

 1 The data presented in this table are for all pipe and tube and, as a result, are substantially overstated with respect to OCTG 

subject to these investigations.

 2 Not available.

 3 Belarus, Kazakhstan, Russia, and Ukraine.

Note.—Production data for 2013 are not available. Production data for 2012 are substantially understated since many countries, 

particularly EU member countries, did not report data for that year. Production data for Turkey are unavailable. Original data were 

published in metric tons, which were converted to short tons by multiplying by 1.102311. Because of rounding, figures may not add 

to the totals shown.

Source: World Steel Association, Steel Statistical Yearbook, 2013, table 24, p. 48.

VII-26
Table VII-23

Seamless steel pipe: Global production, by region, 2009–12

Region

2009 2010 2011 2012

Quantity (1,000 short tons)

1

North America:

 United States 1,053 1,919 2,443 2,383

 Canada 168 268 280 300

 Mexico 649 748 855 973

 Subtotal 1,870 2,937 3,578 3,656

South America:

 Argentina 553 859 936 (

2

)

 Others 4 (

2

) (

2

) (

2

)

 Subtotal 558 859 936 (

2

)

EU (27):

 Germany 1,058 1,415 1,508 (

2

)

 Italy 529 648 741 (

2

)

 Spain 172 278 304 (

2

)

 Others 1,871 2,260 2,653 1,780

 Subtotal 3,630 4,601 5,206 1,780

CIS: 3

 Ukraine 893 862 966 978

 Others 2,866 3,176 3,497 3,585

 Subtotal 3,759 4,038 4,462 4,562

Asia:

 China 24,019 26,647 28,560 31,082

 India (

2

) (

2

) (

2

) (

2

)

 Japan 1,811 2,364 2,512 2,428

 Korea 20 18 19 20

 Philippines (

2

) (

2

) (

2

) (

2

)

 Taiwan (

2

) (

2

) (

2

) (

2

)

 Vietnam (

2

) (

2

) (

2

) (

2

)

 Others (

2

) (

2

) (

2

) (

2

)

 Subtotal 25,849 29,029 31,091 33,530

Others (

2

) (

2

) (

2

) (

2

)

Total 35,665 41,463 45,273 43,529

 1 The data presented in this table are for all seamless steel pipe and tube and, as a result, are substantially overstated with 

respect to OCTG subject to these investigations.

 2 Not available.

 3 Belarus, Kazakhstan, Russia, and Ukraine.

Note.—Production data for 2013 are not available. Production data for 2012 are substantially understated since many countries, 

particularly EU member countries, did not report data for that year. Production data for Turkey are unavailable. Original data were 

published in metric tons, which were converted to short tons by multiplying by 1.102311. Because of rounding, figures may not add 

to the totals shown.

Source: World Steel Association, Steel Statistical Yearbook, 2012, table 25, p. 48; Steel Statistical Yearbook, 2013, table 25, p. 49.

VII-27
Table VII-24

Welded steel pipe: Global production, by region, 2009–12

Region

2009 2010 2011 2012

Quantity (1,000 short tons)

1

North America:

 United States 1,284 1,951 2,367 2,387

 Canada 1,511 2,411 2,520 2,700

 Mexico 640 767 755 669

 Subtotal 3,436 5,129 5,642 5,755

South America:

 Argentina (

2

) (

2

) (

2

) (

2

)

 Others (

2

) (

2

) (

2

) (

2

)

 Subtotal (

2

) (

2

) (

2

) (

2

)

EU (27):

 Germany 2,143 2,116 2,077 (

2

)

 Italy 2,368 2,698 2,884 (

2

)

 Spain 635 979 899 (

2

)

 Others 4,103 4,339 4,251 506

 Subtotal 9,248 10,132 10,110 506

CIS: 3

 Ukraine (

2

) 1,160 1,572 1,424

 Others (

2

) 7,351 8,117 7,859

 Subtotal (

2

) 8,511 9,689 9,284

Asia:

 China 34,640 35,886 46,755 52,640

 India (

2

) (

2

) (

2

) (

2

)

 Japan 4,464 5,492 5,452 5,618

 Korea 4,288 5,334 5,574 6,220

 Philippines 64 55 99 109

 Taiwan 977 1,265 1,338 1,303

 Vietnam 626 742 806 854

 Others 1,386 1,467 1,335 1,513

 Subtotal 46,445 50,241 61,359 68,258

Others 268 277 266 236

Total 59,397 74,290 87,066 84,039

 1 The data presented in this table are for all pipe and tube and, as a result, are substantially overstated with respect to OCTG 

subject to these investigations.

 2 Not available.

 3 Belarus, Kazakhstan, Russia, and Ukraine.

Note.—Production data for 2013 are not available. Production data for 2012 are substantially understated since many countries, 

particularly EU member countries, did not report data for that year. Production data for Turkey are unavailable. Original data were 

published in metric tons, which were converted to short tons by multiplying by 1.102311. Because of rounding, figures may not add 

to the totals shown.

Source: World Steel Association, Steel Statistical Yearbook, 2012, table 26, p. 49; Steel Statistical Yearbook, 2013, table 26, p. 50.

According to Metal Bulletin Research (MBR), global OCTG consumption rebounded after 

the global economic downturn in 2009, and was estimated at approximately 19 million short 

tons in 2011, the latest year for which estimates are available.159 In recent years, the growth in 

OCTG consumption has reportedly been driven by extensive new oil and gas developments in 

159 Metal Bulletin, “Metal Bulletin Research: OCTG Market—worth $33bn and growing,” June 10, 

2013; Metal Bulletin Research (“MBR”), “The Five Year Outlook for the Global OCTG Industry (Free 

Whitepaper), 2013.

VII-28

 
the United States and Canada, as well as in the Middle East and Asia.160 In addition, directional 

and horizontal drilling, as well as drilling in more challenging environments for sour grades of 

hydrocarbons, has led to greater demand for higher-value, heat-treated grades of OCTG.161

However, declining natural gas prices in the United States due to the natural gas boom

and ensuing domestic oversupply, coupled with a slowdown in the Chinese economy and the 

European debt crisis, reportedly tempered OCTG demand growth globally, leading to weaker 

global demand in 2012 compared with 2011. For instance, according to Metal Bulletin demand 

for OCTG in some regions actually declined in 2012, including in Latin America, the Middle East, 

and the CIS. OCTG consumption in other regional markets fared better, including the North 

American and European markets, where OCTG consumption grew by 10–15 percent in 2012 

compared to the previous year.162

More recently, demand for OCTG has reportedly rebounded, driven by continued oil and 

gas exploration and production activity globally. In the United States, growth in offshore 

drilling, as well as increased production of tight natural gas,163 has reportedly boosted demand 

for seamless OCTG. Looking forward, MBR expects expanded offshore exploration and 

development to continue to drive demand for OCTG.164 However, infrastructure bottlenecks in 

some parts of the country are affecting oil and gas production, leading to less consumption of 

OCTG in those areas. For instance, constraints to transporting oil and gas, including lack of 

storage space and bottlenecks in pipeline and rail transportation systems in the Marcellus and 

Bakken shale plays, are reportedly causing wells to be capped and drilling to be delayed until 

the oil and gas can be transported out. As a result, demand for seamless OCTG in these areas 

has reportedly declined.165

In the Middle East, demand for OCTG has reportedly increased in several countries, 

offsetting reduced demand in Saudi Arabia due to high levels of OCTG inventories there. For 

instance, OCTG demand in the United Arab Emirates is expected to increase substantially over 

the next 2-3 years. Abu Dhabi Oil Company has reportedly issued a tender to supply 

approximately 550,000 short tons of OCTG for 2016-2017, two thirds of which are casing and 

tubing with premium connections, reflecting drilling activity in offshore fields and onshore sour 

service fields that require those connections. Increased drilling in Kuwait and Oman is also 

reportedly driving OCTG demand in the region.166 Similarly, robust drilling activity in Iraq has 

made the country one of the fastest growing oil producers in the world, although recent 

160 Metal Bulletin, “Metal Bulletin Research: OCTG Market—worth $33bn and growing,” June 10, 

2013.

161 Metal Bulletin, “MB Research View—OCTG: Market’s global value will hit $40bn by 2017,” 

November 22, 2012.

162 Metal Bulletin, “Metal Bulletin Research: OCTG Market—worth $33bn and growing,” June 10, 

2013.

163 “Tight” natural gas refers to natural gas found in impermeable rock or nonporous sandstone or 

limestone formations.

164 MBR, Seamless OCTG & Linepipe Market Tracker, May 2014, pp. 3-4. 

165 MBR, Seamless OCTG & Linepipe Market Tracker, June 2014, pp. 3-4.

166 MBR, Seamless OCTG & Linepipe Market Tracker, June 2014, p. 9.

VII-29

 
political turmoil has increased risk there.167 Demand for welded OCTG is reportedly also stable 

across the region, driven again by robust drilling activity.168

In China, the development of shale gas is expected to boost demand for seamless OCTG 

in the next decade, particularly for premium connections. Indeed, Chinese oil and gas producer 

Sinopec is reportedly planning to enter commercial production of China’s first major shale gas 

field. China National Petroleum Corporation also has reportedly tripled spending on shall gas 

development.169

Looking forward, MBR anticipates global growth in OCTG consumption to average about 

4 percent annually. According to MBR, Latin America and Africa will be areas of the fastest 

growth in OCTG consumption.170 Indeed, the development of Argentina’s Vaca Muerca shale 

deposits, one of the largest and most promising areas for oil and gas development in Latin 

America, could drive increased demand for OCTG in the region according to MBR.171 On the 

supply side, MBR expects North America to see the largest addition of new OCTG capacity in 

the next 3–5 years.172

Table VII-25 shows global reported exports of OCTG during 2011–13. China, Korea, and 

Japan collectively accounted for 47 percent of global OCTG exports in 2013. Tables VII-26 and 

VII-27 provide information on international rotary rig counts for the period 2011–13 and firsthalf 2014. The following section provides information on the leading nonsubject producers and 

exporters of OCTG to the United States; namely, Argentina, Canada, Germany, Japan, and 

Mexico.

167 Preston Publishing Co., Preston Pipe & Tube Company, June 2014, pp. 2 and 26.

168 MBR, Welded Linepipe & OCTG Market Tracker, April 2014, p. 8

169 MBR, Seamless OCTG & Linepipe Market Tracker, May 2014, pp. 10-11

170 Metal Bulletin, “MB Research View—OCTG: Market’s global value will hit $40bn by 2017,” 

November 22, 2012. 171 MBR, Seamless OCTG & Linepipe Market Tracker, May 2014, p. 5. 172 For a list of recent developments in the U.S. market, including OCTG capacity expansions, see 

section III of this report.

VII-30

 
Table VII-25

OCTG: Global exports by reporting countries, 2011–13

Country

Calendar year

2011 2012 2013

Quantity (short tons)

China 1,926,801 2,323,787 2,195,993

Korea 661,559 874,299 1,029,519

Japan 761,705 749,340 795,391

Mexico 497,643 538,475 637,113

United States 458,228 455,237 449,241

Argentina 454,571 443,437 415,038

Canada 418,174 416,268 319,064

Austria 251,029 247,590 279,815

Germany 200,104 312,457 262,399

Ukraine 266,547 296,928 262,163

France 256,618 240,819 258,355

Singapore 249,126 252,154 233,533

Brazil 60,206 118,861 230,019

Russia 228,716 238,530 161,819

Taiwan 110,334 118,039 129,084

Italy 89,063 141,400 127,376

Turkey 142,478 139,647 114,673

Indonesia 156,032 175,389 107,295

Romania 75,134 99,003 92,276

United Kingdom 52,683 67,897 77,844

India 82,370 52,945 63,936

Thailand 14,629 52,841 60,531

Czech Republic 53,142 59,168 56,948

Azerbaijan 105,867 53,997 54,306

Spain 47,770 51,271 45,404

Netherlands 16,017 20,333 32,004

Belgium 8,728 10,668 25,560

Colombia 61,219 63,522 19,902

Denmark 23,663 19,437 16,516

Malaysia 23,303 23,120 11,688

Iran 338 4,864 8,445

Georgia 0 896 8,031

Poland 4,618 5,147 5,045

Australia 4,488 7,036 3,095

Norway 10,016 3,322 3,093

Honduras 0 1 2,477

Peru 1,324 840 2,047

Belarus 2 245 1,773

Kazakhstan 68 370 1,387

Slovakia 168 1,545 804

New Zealand 12 47 678

South Africa 2,304 572 672

Hong Kong 93 86 594

Ireland 105 503 548

Table continued on next page.

VII-31
Table VII-25--Continued

OCTG: Global exports by reporting countries, 2011–13

Country

Calendar year

2011 2012 2013

Quantity (short tons)

Croatia 3,499 47 510

Kenya 441 131 445

Cote d'Ivoire 823 434 352

Bulgaria 36 100 304

Hungary 459 183 237

Lithuania 0 254 203

Ecuador 175 160 152

Sweden 395 130 111

Portugal 90 22 111

Switzerland 217 93 100

Philippines 29,337 3,146 86

Latvia 72 44 58

Ghana 91 309 47

El Salvador 18 110 40

Slovenia 60 22 35

Serbia 8 4 28

Greece 9 14 26

Cyprus 56 371 24

Chile 184 28 22

Mauritius 0 15 12

Senegal 188 1 12

Morocco 23 15 11

Costa Rica 142 12 7

Guatemala 160 91 6

Finland 7 9 6

Algeria 267 45 3

Venezuela 6 1 0

Egypt 253 144 0

Vietnam (

1

) (

1

) (

1

)

 Total 7,814,007 8,688,270 8,606,445 1 Not available. Reporting countries’ imports of OCTG from Vietnam totaled 61,805 short tons in 2011, 245,430 short tons in 2012, 

and 166,732 short tons in 2013.

Note.-- Original data were published in metric tons, which were converted to short tons by multiplying by 1.102311. Because of 

rounding, figures may not add to the totals shown.

Note.-- Global exports of OCTG reported by the Philippines are understated. In response to Commission questionnaires, Philippine 

producers reported exporting *** short tons in 2011, *** short tons in 2012, and *** short tons in 2013. See table VII-5.

Source: Global Trade Atlas (accessed June 4, 2014), HS subheadings 7304.29, 7305.20, 7306.29.

VII-32
Table VII-26

OCTG: Baker Hughes International Rotary Rig Count, by country or region, 2011–13

Country or region

Calendar year

2011 2012 2013

Average rig counts

Country:

 United States 1,875 1,919 1,761

 Canada 423 365 355

Region:

 Latin America 424 423 419

 Europe 118 119 135

 Africa 78 96 125

 Middle East 291 356 372

 Asia Pacific 256 241 246

 Total 3,465 3,518 3,412

Note.—Data include both onshore and offshore oil and gas rotary rigs.

Source: Baker Hughes International Rig Count, April 2014, found at http://phx.corporate-ir.net/phoenix.zhtml?c=79687&p=irolrigcountsintl, retrieved June 4, 2014.

Table VII-27

OCTG: Baker Hughes International Rotary Rig Count, by country or region, Jan.–March 2013 

through April–June 2014

Country or 

region

Calendar quarter

Jan.–March 

2013

April–June 

2013

July–Sept. 

2013

Oct.–Dec. 

2013

Jan.–March 

2014

April–June 

2014

Rig counts

Country:

 United States 1,758 1,761 1,769 1,757 1,780 1,852

 Canada 536 155 349 378 526 202

Region:

 Latin America 426 425 407 416 402 402

 Europe 134 133 140 133 135 149

 Africa 114 127 124 135 142 133

 Middle East 355 368 373 392 400 415

 Asia Pacific 245 252 241 245 258 249

 Total 3,569 3,221 3,403 3,456 3,644 3,401 1 Not available.

Note.—Data include both onshore and offshore oil and gas rotary rigs.

Source: Baker Hughes International Rig Count, June 2014, found at http://phx.corporate-ir.net/phoenix.zhtml?c=79687&p=irolrigcountsintl, retrieved July 23, 2014.

VII-33
Argentina

Although Argentina is South America’s largest natural gas producer, its natural gas 

production has declined over 10 percent from peak levels in 2006.173 Moreover, although 

domestic demand for energy has grown rapidly in recent years, oil and gas production in 

Argentina has declined, and consequently, the country increasingly relies on imports of both 

products to meet its domestic energy needs.174 Argentina possesses the third largest 

endowment of recoverable shale gas in the world, and there are numerous projects under 

development to exploit these resources.175 As of May 2014, Argentina had 105 active rotary oil 

and gas rigs.176 In 2013, Argentina was the sixth-largest exporter of OCTG (see table VII-25). 

The leading markets for Argentina’s exports of OCTG in 2013 were the United States, Saudi 

Arabia, and Venezuela (table VII-28).

According to ***177 and the American Petroleum Institute (API) Composite List,178 there 

are five known producers of OCTG in Argentina: Tenaris Siderca, M. Royo, Duralitte S.A., Formar 

S.A. and Tubhier. Tenaris Siderca is a wholly-owned subsidiary of Tenaris (Luxembourg),

a leading global tube producer, with an annual production capacity of over 900,000 short tons 

of seamless tubular products.179 Tenaris also has welded steel tube mills located in Buenos 

Aires and Santa Fe provinces, which together have an annual combined production capacity of 

430,000 short tons of welded steel tubes.180 Tubhier produces a small amount of welded 

carbon and low-alloy steel OCTG, line pipe, and standard pipe on its two mills in San Luis.181

173 Energy Information Administration (EIA), “Argentina Energy Profile,” July 24, 2012, found at 

http://www.eia.gov/countries/cab.cfm?fips=AR, retrieved July 22, 2013. 174 EIA, “Argentina Energy Profile,” July 24, 2012, found at 

http://www.eia.gov/countries/cab.cfm?fips=AR, retrieved July 22, 2013; EIA, “Argentina Country 

Analysis Note,” April 2014. 175 EIA, “Argentina Energy Profile,” July 24, 2012, found at 

http://www.eia.gov/countries/cab.cfm?fips=AR, retrieved July 22, 2013.

176 Baker Hughes Inc., International Rig Rotary Rig Count, found at http://phx.corporateir.net/phoenix.zhtml?c=79687&p=irol-rigcountsintl, retrieved June 6, 2014. 177 ***. 178 The API Composite List is a directory of 4,395 companies in 78 countries supplying the oil and 

natural gas industry. It includes licensing, registration, and product details of the organizations 

participating in the various API Certification Programs, including firms that are licensed for the API 5CT 

(oil and gas casing and tubing) Monogram. API Composite List, found at http://compositelist.api.org, 

retrieved July 23, 2014.

179 Tenaris is the parent company of U.S. OCTG producer Maverick Tube.

180 Tenaris Website, “Argentina Profile,” found at 

http://www.tenaris.com/en/tenarisworldwide/southamerica/argentina.aspx, retrieved on July 23, 2014.

181 Tubhier Website, “Company Profile,” found at http://www.tubhier.com.ar/, retrieved July 23, 

2013. 

VII-34

 
Table VII-28

OCTG: Argentina’s reported exports, 2011-2013

Country

Calendar year

2011 2012 2013

Quantity (short tons)

United States 132,273 143,632 215,817

Saudi Arabia 29,102 21,393 32,418

Venezuela 25,628 27,788 19,804

Ecuador 27,097 16,207 17,529

United Arab Emirates 21,211 15,500 14,836

Iraq 12,671 35,609 14,203

Indonesia 45,733 59,950 13,260

Nigeria 4,885 12,376 10,162

Italy 5,149 9,712 8,322

Bolivia 6,626 6,586 8,268

Congo 5,459 2,360 8,152

Romania 9,915 4,404 7,652

Chile 7,642 7,261 6,698

Egypt 17,121 9,474 6,636

Equatorial Guinea 6,089 11,644 6,435

Canada 27,996 6,997 4,184

Pakistan 842 2,399 3,247

China 2,071 563 2,801

Russia 3,463 3,347 2,224

Denmark 646 1,997 2,073

All other 62,951 44,238 10,314

 Total 454,571 443,438 415,038

Note.—Original data were published in metric tons, which were converted to short tons by multiplying by 1.102311. Because of 

rounding, figures may not add to the totals shown.

Source: Global Trade Atlas (accessed June 4, 2014), HS subheadings 7304.29, 7305.20, 7306.29.

Canada

Canada is the world's sixth-largest oil producer, and virtually all of its crude oil exports 

are destined for the United States.182 Canada holds a relatively small share of the world's 

proven natural gas reserves, yet is the fourth largest exporter of natural gas.183 As of April 

2014, Canada’s rig count was 204, down from 449 the previous month.184

In 2013, Canada was the seventh-largest exporter of OCTG (see table VII-25). The 

United States is the leading market for Canada’s exports of OCTG (table VII-29). Several 

Canadian companies produce casing and tubing. Some of these firms are owned by non182 EIA, “Canada Energy Profile,” December 10, 2012, found at 

http://www.eia.gov/countries/cab.cfm?fips=CA, retrieved July 22, 2013.

183 EIA, “Canada Energy Profile,” December 10, 2012, found at 

http://www.eia.gov/countries/cab.cfm?fips=CA, retrieved July 22, 2013.

184 Baker Hughes Inc., “Rig Count Overview and Summary Count,” found at http://phx.corporateir.net/phoenix.zhtml?c=79687&p=irol-rigcountsoverview, retrieved June 4, 2014. Canada’s rig count 

typically falls in the spring due to ground thawing, which makes moving drilling equipment more difficult 

to transport.

VII-35

 
Canadian parent companies, including Evraz North America (a subsidiary of Russian steel 

producer Evraz); Vallourec Canada (a subsidiary of France-based Vallourec Group and affiliate 

of U.S.-based Vallourec Star); Tenaris (Luxembourg), which owns U.S. OCTG producer Maverick; 

and JMC Steel Group, which owns EnergeX, a merger of JMC’s U.S. tubular assets and Canadian 

OCTG producer Lakeside Steel. In July 2013, Evraz North America announced plans to build a 

tubular production facility in Calgary by 2014, which will increase its heat-treatment capacity 

from 80,000 short tons to 200,000 short tons per year.

185 In January 2013, Vallourec Canada 

was created via a merger between Vallourec Tubes Canada, a pipe and tube producer, and VAM 

Canada, Inc., a manufacturer of threaded connections.186 JMC Steel Group Inc. (parent 

company of EnergeX) completed its acquisition of Lakeside Steel Corporation in April 2012.187 In 

2014, EnergeX announced plans to idle its OCTG mill (formerly Lakeside Steel) in Welland, 

Ontario and lay off its workers at the plant in response to market conditions and the “influx of 

unfairly traded OCTG imports into North America.”188

185 “Evraz to expand heat treat capacity at Calgary tubular plant by 150%,” ASM International, July 

2013; Evraz, Annual Report, 2013, p. 60. 

186 Preston Pipe and Tube Report, Volume 31, No. 1, January 2013, p. 22. 

187 JMC Steel Group, “JMC Steel Group Acquires Lakeside Steel Inc., Expanding Offering for Oil and 

Gas Industry,” April 3, 2012, found at http://www.jmcsteelgroup.com/press-release/jmc-steel-groupacquires-lakeside-steel-inc. 188 Metal Bulletin, “Energex Tube idles Ontario facility, lays off workers,” March 26, 2014; Furminger, 

“Energex Tube shutting down in Welland,” Welland Tribune, March 26, 2014.

VII-36

 
Table VII-29

OCTG: Canada’s reported exports, 2011–13

Country

Calendar year

2011 2012 2013

Quantity (short tons)

United States 410,871 412,867 314,263

Mexico 2,059 1,150 3,818

Venezuela 7 0 289

Cuba 486 243 278

France 1,097 623 218

Burkina Faso 1 0 28

Argentina 19 0 25

Angola 0 0 21

Australia 13 30 18

United Arab Emirates 285 34 9

Qatar 0 0 9

Russia 132 2 8

China 257 338 8

Vietnam 0 28 8

Kazakhstan 2 18 8

Mauritania 0 0 8

Brazil 101 4 7

Cote d Ivoire 0 0 6

Algeria 0 0 4

Gabon 0 0 4

All other 2,844 929 28

 Total 418,175 416,266 319,063

Note.—Original data were published in metric tons, which were converted to short tons by multiplying by 1.102311. Because of 

rounding, figures may not add to the totals shown.

Source: Global Trade Atlas (accessed June 4, 2014), HS subheadings 7304.29, 7305.20, 7306.29.

Germany

Germany is the largest energy consumer in Europe, and imports nearly all of its oil and

natural gas. Oil is Germany’s primary source of energy, accounting for 38 percent of Germany’s 

total primary energy consumption in 2011.189 In addition, Germany has no liquefied natural gas 

terminals, so it must import gas via pipeline exclusively from Russia, Norway, or other European 

countries.190 As of May 2014, Germany has 3 rigs.191 Nonetheless, Germany is the largest OCTG 

producer and exporter in Europe. In 2013, Germany was the ninth-largest global exporter 

(down from eighth position in 2012) and the largest European exporter of OCTG (see table VII25). The leading markets for Germany’s exports of OCTG in 2013 were the United States, 

Indonesia, and the United Kingdom (table VII-30).

There are several OCTG producers in Germany, including V&M Deutschland, a subsidiary 

of Vallourec Group (France) and affiliate of U.S. OCTG producer Vallourec Star; Benteler 

189 EIA, “Germany Energy Profile,” May 30, 2013, EIA, “Germany Country Analysis Note,” April 2014.

190 EIA, “Germany Energy Profile,” May 30, 2013.

191 Baker Hughes Inc., International Rotary Rig Count, found at http://phx.corporateir.net/phoenix.zhtml?c=79687&p=irol-rigcountsintl, retrieved July 17, 2014.

VII-37

 
Steel/Tube, which in 2012 announced plans to build a $900 million seamless OCTG mill in 

Caddo, Louisiana (slated for completion in 2015);192 and TPS Technitube Rohrenwerke.

Table VII-30

OCTG: Germany’s reported exports, 2011–13

Country

Calendar year

2011 2012 2013

Quantity (short tons)

United States 81,967 192,896 125,148

Indonesia 11,908 12,501 21,558

United Kingdom 14,548 21,050 15,079

Saudi Arabia 13,847 4,470 14,619

France 12,592 15,117 11,406

Iraq 9,763 5,413 9,485

Canada 713 2,175 9,451

United Arab Emirates 269 1,316 9,157

Angola 6,103 12,499 5,147

Brazil 0 1,606 4,363

Egypt 476 3,517 3,807

Azerbaijan 2,039 3,957 3,768

India 43 153 3,374

Netherlands 3,142 6,551 2,849

Mauritania 0 0 2,638

Nigeria 5,965 2,517 2,155

Qatar 0 957 2,059

Kazakhstan 1,942 1,607 1,927

Belize 2,880 1,704 1,876

Russia 2,546 1,128 1,544

All other 29,359 21,322 10,989

 Total 200,104 312,457 262,399

Note.—Original data were published in metric tons, which were converted to short tons by multiplying by 1.102311. Because of 

rounding, figures may not add to the totals shown.

Source: Global Trade Atlas (accessed June 4, 2014), HS subheadings 7304.29, 7305.20, 7306.29.

Japan

Japan is the world’s largest importer of liquefied natural gas and the third largest 

importer of oil.193 Japan relies almost solely on imports to meet its oil needs, and oil imports 

account for about 42 percent of its broader energy needs.194 With only 1 active rig as of May 

2014, Japan has very limited domestic fossil fuel-based energy resources. 195 As a result, Japan 

exports almost all of its OCTG production. Japan was the third-largest global exporter of OCTG 

in 2013 (see table VII-25). The leading markets for Japan’s exports of OCTG in 2013 were the 

United States, Saudi Arabia, and the United Arab Emirates (table VII-31).

192 Preston Pipe and Tube Report, Vol. 30, No. 11, November 2012, p. 25. 

193 EIA, “Japan Energy Profile,” June 4, 2012; EIA, “Japan Country Profile,” October 29, 2013.

194 EIA, “Japan Energy Profile,” June 4, 2012.

195 Baker Hughes Inc., “International Rig Rotary Rig Count,” found at http://phx.corporateir.net/phoenix.zhtml?c=79687&p=irol-rigcountsintl, retrieved June 4, 2014.

VII-38

 
Japanese OCTG producers include Nippon Steel Sumitomo Metals (NSSM) Corporation 

(as the result of a merger between Nippon Steel and Sumitomo Metal Industries in 2012), JFE 

Steel Corporation, Tenaris NKK Tubes, a subsidiary of Tenaris (Luxembourg) and affiliate of U.S. 

OCTG producer Maverick; and Maruichi Steel Tube. According to ***, NSSM’s combined annual 

production of tubular products is almost 8 million short tons (4.3 million short tons at Nippon 

Steel and 3.3 million short tons at Sumitomo Metal Industries). Tenaris NKK Tubes has an 

annual steel tube capacity of 280,000 short tons.196 Maruichi Steel Tube has an annual steel 

tube capacity of 1,323,000 short tons.197

Table VII-31

OCTG: Japan’s reported exports, 2011–13

Country

Calendar year

2011 2012 2013

Quantity (short tons)

United States 125,731 186,479 137,524

Saudi Arabia 76,349 51,314 112,338

United Arab Emirates 88,100 44,986 100,423

Singapore 24,126 15,901 45,165

Norway 85,420 67,164 40,547

Malaysia 60,787 62,508 30,579

Kuwait 39,367 11,514 28,243

Oman 4,666 46,559 27,310

Australia 27,388 20,855 26,861

Russia 14,692 11,568 25,197

Vietnam 14,687 22,995 23,375

China 32,430 24,899 20,286

Brunei Darussalam 14,316 22,625 18,164

Canada 14,881 17,014 17,931

Indonesia 22,741 16,589 17,679

United Kingdom 18,487 15,824 14,821

Brazil 9,156 6,073 13,367

India 7,990 3,469 12,421

Iraq 21,196 23,661 9,787

Netherlands 6,856 10,417 9,678

All other 52,341 66,927 63,695

 Total 761,707 749,339 795,390

Note.—Original data were published in metric tons, which were converted to short tons by multiplying by 1.102311. Because of 

rounding, figures may not add to the totals shown.

Source: Global Trade Atlas (accessed June 4, 2014), HS subheadings 7304.29, 7305.20, 7306.29.

196 Tenaris NKK Tubes, “Company Profile,” found at 

http://www.tenaris.com/shared/documents/files/CB48.pdf, retrieved July 23, 2013; ***. 197 ***.

VII-39

 
Mexico

Mexico remains one of the ten largest oil producers in the world, even while its oil 

production has been steadily decreasing since 2004.198 Development of Mexico’s shale gas 

resources is slow despite Mexico’s considerable natural gas resources.199 Consequently, 

Mexico must rely on U.S. natural gas imports and liquefied natural gas from other countries to 

satisfy increasing domestic demand.200 As of May 2014, Mexico has 85 active rigs.201 Mexico is 

the fourth-largest global exporter of OCTG (see table VII-25). The leading markets for Mexico’s 

exports of OCTG in 2013 were the United States, Saudi Arabia, and Canada (table VII-32).

The large majority of Mexico’s OCTG production is seamless casing and tubing. The 

largest of Mexico’s OCTG producers is Tenaris TAMSA (“TAMSA”), a wholly-owned subsidiary of 

Tenaris (Luxembourg) and affiliate of U.S. OCTG producer Maverick. In May 2013, TAMSA 

opened a new seamless tube rolling mill in Veracruz, Mexico, with an annual production 

capacity of 450,000 short tons.202 According to ***, TAMSA’s annual seamless production 

capacity is 860,000 short tons.203 VAM Mexico, a subsidiary of Vallourec (France) and affiliate 

of U.S. OCTG producer Vallourec Star, produces couplings and provides threading services for 

OCTG at its Veracruz facility.204

198 EIA, “Mexico Energy Profile,” October 17, 2012; EIA, “Mexico Country Profile,” April 24, 2014.

199 EIA, “Mexico Energy Profile,” October 17, 2012.

200 EIA, “Mexico Energy Profile,” October 17, 2012.

201 Baker Hughes Inc., International Rig Rotary Rig Count, found at http://phx.corporateir.net/phoenix.zhtml?c=79687&p=irol-rigcountsintl, retrieved June 4, 2014.

202 “Tenaris opens a new rolling mill in Mexico,” New Europe Online, July 22, 2013, found at 

http://www.neurope.eu/article/tenaris-opens-new-rolling-mill-mexico. 203 ***. 204 VAM USA Website, “Facilities,” found at http://www.vam-usa.com/company-facilities.aspx, 

retrieved July 23, 2013. 

VII-40

 
Table VII-32

OCTG: Mexico’s reported exports, 2011–13

Country

Calendar year

2011 2012 2013

Quantity (short tons)

United States 201,598 158,786 157,251

Saudi Arabia 29,895 13,654 84,536

Canada 58,666 102,006 69,992

Ecuador 15,667 27,183 59,089

Colombia 67,546 42,937 45,811

Iraq 9,439 35,516 25,078

Angola 8,287 10,094 18,480

Egypt 7,139 10,100 14,812

Venezuela 9,697 18,390 13,525

Argentina 2,557 11,148 13,404

Italy 6,771 7,014 13,093

Nigeria 3,067 3,985 11,968

Libya 671 2,210 11,761

Romania 2,048 3,997 9,819

Kazakhstan 5,126 2,875 9,737

Russia 6,572 15,678 8,655

Denmark 3,243 4,752 8,268

Norway 9,986 15,107 6,668

United Arab Emirates 5,561 9,990 6,476

Indonesia 108 398 5,672

All other 43,997 42,655 43,012

 Total 497,642 538,476 637,109

Note.—Original data were published in metric tons, which were converted to short tons by multiplying by 1.102311. Because of 

rounding, figures may not add to the totals shown.

Source: Global Trade Atlas (accessed June 4, 2014), HS subheadings 7304.29, 7305.20, 7306.29.

Recent OCTG operations in select nonsubject countries

Staff requested that U.S. producers provide a statistical profile of their related OCTG 

operations in nonsubject countries. These operations account for a substantial portion of the 

OCTG production in several of the leading nonsubject countries supplying the United States 

with OCTG. Broader information concerning major suppliers’ operations was presented in 

tables VII-22 through VII-24 and VII-28 through VII-32.

Reported data for Canada includes data for four producers: Algoma & Prudential, 

related to U.S. producer Maverick; EnergeX Tube, related to U.S. producer EnergeX; Evraz Inc. 

NA Canada, related to U.S. producer Evraz; and Welded Tube of Canada Corp., related to U.S. 

producer Welded Tube. In 2013, the reporting Canadian producers had *** short tons of 

capacity to produce OCTG, and produced *** short tons, resulting in a capacity utilization rate 

of *** percent. Reporting Canadian producers shipped *** short tons to their home market, 

and exported *** short tons (accounting for *** percent of total shipments). 

Reported data for Russia includes data for one producer, OAO TMK, related to U.S. 

producer TMK IPSCO. In 2013, the reporting Russian producer’s capacity to produce OCTG 

approached *** short tons, and *** short tons were produced, resulting in a capacity utilization 

of *** percent. The reporting Russian producer shipped *** short tons to its home market, and 

exported *** short tons (accounting for *** percent of total shipments).

VII-41
Reported data for Argentina includes data for one producer, Siderca, related to U.S. 

producer Maverick. In 2013, the reporting Argentinian producer had *** short tons of capacity 

to produce OCTG, and produced *** short tons, resulting in a capacity utilization of ***

percent. The reporting Argentinian producer shipped *** short tons to its home market, and 

exported *** short tons (accounting for *** percent of total shipments).

Reported data for Brazil includes data for two producers: Apolo Tubulars, related to U.S. 

producer U.S. Steel and Vallourec Brazil, related to U.S. producer Vallourec. In 2013, the 

reporting Brazilian producers had *** short tons of capacity to produce OCTG, and produced 

*** short tons, resulting in a capacity utilization of *** percent. Reporting Brazilian producers 

shipped *** short tons to their home market, and exported *** short tons (accounting for ***

percent of total shipments).

Reported data for Colombia includes data for one producer, TuboCaribe, related to U.S. 

producer Maverick. In 2013, the reporting Colombian producer had *** short tons of capacity 

to produce OCTG, and produced *** short tons, resulting in a capacity utilization of ***

percent. The reporting Colombian producer shipped *** short tons to its home market, and 

exported *** short tons (accounting for *** percent of total shipments).

Reported data for France includes data for two producers: Vallourec France, related to 

and Vallourec Oil France, both related to U.S. producer Vallourec. In 2013, the reporting French 

producers had *** short tons of capacity to produce OCTG, and produced *** short tons, 

resulting in a capacity utilization of *** percent. Reporting French producers shipped *** short 

tons to their home market, and exported *** short tons (accounting for *** percent of total 

shipments).

Reported data for Germany includes data for one producer, Vallourec Deutschland, 

related to U.S. producer Vallourec. In 2013, the reporting German producer had *** short tons 

of capacity to produce OCTG, and produced *** short tons, resulting in a capacity utilization of 

*** percent. The reporting German producer shipped *** short tons to its home market, and 

exported *** short tons (accounting for *** percent of total shipments).

Reported data for Indonesia includes data for one producer, PT Citra Tubindo TBK, 

related to U.S. producer Vallourec. In 2013, the reporting Indonesian producer had *** short 

tons of capacity to produce OCTG, and produced *** short tons, resulting in a capacity 

utilization of *** percent. The reporting Indonesian producer shipped *** short tons to its 

home market, and exported *** short tons (accounting for *** percent of total shipments).

Reported data for Italy includes data for one producer, Dalmine, related to U.S. 

producer Maverick. In 2013, the reporting Italian producer had *** short tons of capacity to 

produce OCTG, and produced *** short tons, resulting in a capacity utilization of *** percent. 

The reporting Italian producer shipped *** short tons to its home market, and exported ***

short tons (accounting for *** percent of total shipments).

Reported data for Japan includes data for one producer, NKK Tubes, related to U.S. 

producer Maverick. In 2013, the reporting Japanese producer had *** short tons of capacity to 

produce OCTG, and produced *** short tons, resulting in a capacity utilization of *** percent. 

The reporting Japanese producer shipped *** short tons to its home market, and exported ***

short tons (accounting for *** percent of total shipments).

VII-42
Reported data for Mexico includes data for one producer, TAMSA, related to U.S. 

producer Maverick. In 2013, the reporting Mexican producer had *** short tons of capacity to 

produce OCTG, and produced *** short tons, resulting in a capacity utilization of *** percent. 

The reporting Mexican producer shipped *** short tons to its home market, and exported ***

short tons (accounting for *** percent of total shipments).

Reported data for Oman includes data for one producer, TMK Gulf International Pipe 

Industry L.L.C., related to U.S. producer TMK IPSCO. In 2013, the reporting Omani producer had 

*** short tons of capacity to produce OCTG, and produced *** short tons, resulting in a 

capacity utilization of *** percent. The reporting Omani producer shipped *** short

tons to its home market, and exported *** short tons (accounting for *** percent of total 

shipments).

Reported data for Romania includes data for two producers: Silcotub, related to U.S. 

producer Maverick and TMK-ARTROM S.A., related to U.S. producer TMK IPSCO. In 2013, the 

reporting Romanian producers had *** short tons of capacity to produce OCTG, and produced 

*** short tons, resulting in a capacity utilization of *** percent. Reporting Romanian producers 

shipped *** short tons to their home market, and exported *** short tons (accounting for ***

percent of total shipments).

Reported data for the United Kingdom includes data for one producer, Vallourec Oil & 

Gas UK, related to U.S. producer Vallourec. In 2013, the reporting UK producer had *** short 

tons of capacity to produce OCTG, and produced *** short tons, resulting in a capacity 

utilization of *** percent. The reporting UK producer shipped *** short tons to its home 

market, and exported *** short tons (accounting for *** percent of total shipments).

VII-43

APPENDIX A

FEDERAL REGISTER NOTICES 

A-1

The Commission makes available notices relevant to its investigations and reviews on its 

website, www.usitc.gov. In addition, the following tabulation presents, in chronological order, 

Federal Register notices issued by the Commission and Commerce during the current 

proceeding.

Citation Title Link

78 FR 41421

July 10, 2013

Certain Oil Country Tubular Goods 

From India, Korea, Philippines, Saudi 

Arabia, Taiwan, Thailand, Turkey, 

Ukraine, and Vietnam; Institution of 

Antidumping and Countervailing Duty 

Investigations and Scheduling of 

Preliminary Phase Investigations

http://www.gpo.gov/fdsys/pkg/FR2013-07-10/pdf/2013-16515.pdf

78 FR 45502

July 29, 2013 Certain Oil Country Tubular Goods 

From India and Turkey: Initiation of 

Countervailing Duty Investigations

http://www.gpo.gov/fdsys/pkg/FR2013-07-29/pdf/2013-18165.pdf

78 FR 45505

July 29, 2013 Certain Oil Country Tubular Goods 

from India, the Republic of Korea, the 

Republic of the Philippines, Saudi 

Arabia, Taiwan, Thailand, the 

Republic of Turkey, Ukraine, and the 

Socialist Republic of Vietnam: 

Initiation of Antidumping Duty 

Investigations

http://www.gpo.gov/fdsys/pkg/FR2013-07-29/pdf/2013-18164.pdf

78 FR 77421

December 23, 

2013

Certain Oil Country Tubular Goods 

From India: Preliminary Affirmative 

Countervailing Duty Determination 

and Alignment of Final Determination 

With Final Antidumping 

Determination

http://www.gpo.gov/fdsys/pkg/FR2013-12-23/pdf/2013-30559.pdf

A-3
Citation Title Link

78 FR 77420

December 23, 

2013

Certain Oil Country Tubular Goods 

From the Republic of Turkey: 

Preliminary Negative Countervailing 

Duty Determination and Alignment of 

Final Determination With Final 

Antidumping Determination

http://www.gpo.gov/fdsys/pkg/FR2013-12-23/pdf/2013-30563.pdf

79 FR 10493, 

February 25, 

2014

Certain Oil Country Tubular Goods 

From India: Preliminary 

Determination of Sales at Less Than 

Fair Value, Preliminary Affirmative 

Determination of Critical 

Circumstances, in Part, and 

Postponement of Final Determination

http://www.gpo.gov/fdsys/pkg/FR2014-02-25/pdf/2014-04106.pdf

79 FR 10480, 

February 25, 

2014

Certain Oil Country Tubular Goods 

From the Republic of Korea: Negative 

Preliminary Determination of Sales at 

Less Than Fair Value, Negative

Preliminary Determination of Critical 

Circumstances and Postponement of 

Final Determination

http://www.gpo.gov/fdsys/pkg/FR2014-02-25/pdf/2014-04110.pdf

79 FR 10491, 

February 25, 

2014

Certain Oil Country Tubular Goods 

From the Republic of the Philippines: 

Preliminary Affirmative 

Determination of Sales at Less Than 

Fair Value, Negative Preliminary 

Determination of Critical 

Circumstances, and Postponement of 

Final Determination

http://www.gpo.gov/fdsys/pkg/FR2014-02-25/pdf/2014-04093.pdf

79 FR 10489, 

February 25, 

2014

Certain Oil Country Tubular Goods 

From Saudi Arabia: Preliminary 

Determination of Sales at Less Than 

Fair Value, and Postponement of Final 

Determination

http://www.gpo.gov/fdsys/pkg/FR2014-02-25/pdf/2014-04102.pdf

A-4
Citation Title Link

79 FR 10487, 

February 25, 

2014

Certain Oil Country Tubular Goods 

From Thailand: Preliminary 

Determination of Sales at Less Than 

Fair Value, and Postponement of Final 

Determination

http://www.gpo.gov/fdsys/pkg/FR2014-02-25/pdf/2014-04096.pdf

79 FR 10495, 

February 25, 

2014

Certain Oil Country Tubular Goods 

From Taiwan: Affirmative Preliminary 

Determination of Sales at Less Than 

Fair Value and Postponement of Final 

Determination

http://www.gpo.gov/fdsys/pkg/FR2014-02-25/pdf/2014-04088.pdf

79 FR 18667, 

April 3, 2014 Certain Oil Country Tubular Goods 

From Taiwan: Amended Preliminary 

Negative Determination of Sales at 

Less Than Fair Value and 

Postponement of Final Determination

http://www.gpo.gov/fdsys/pkg/FR2014-04-03/pdf/2014-07485.pdf 

79 FR 10482, 

February 25, 

2014

Certain Oil Country Tubular Goods 

From Ukraine: Preliminary 

Determination of Sales at Less Than 

Fair Value, Negative Preliminary 

Determination of Critical 

Circumstances, and Postponement of 

Final Determination

http://www.gpo.gov/fdsys/pkg/FR2014-02-25/pdf/2014-04101.pdf

79 FR 10478, 

February 25, 

2014

Certain Oil Country Tubular Goods 

From the Socialist Republic of 

Vietnam: Preliminary Determination 

of Sales at Less Than Fair Value, 

Affirmative Preliminary 

Determination of Critical 

Circumstances, in Part, and 

Postponement of Final Determination

http://www.gpo.gov/fdsys/pkg/FR2014-02-25/pdf/2014-04036.pdf

A-5
Citation Title Link

79 FR 18667,

April 3, 

2014

Certain Oil Country Tubular Goods 

From Taiwan: Amended Preliminary 

Negative Determination of Sales at 

Less Than Fair Value and 

Postponement of Final Determination

http://www.gpo.gov/fdsys/pkg/FR2014-04-03/pdf/2014-07485.pdf

79 FR 19122,

April 7,

2014

Certain Oil Country Tubular Goods 

From India, Korea, Philippines, Saudi 

Arabia, Taiwan, Thailand, Turkey, 

Ukraine, and Vietnam; Scheduling of 

the Final Phase of Countervailing Duty 

and Antidumping Investigations

http://www.gpo.gov/fdsys/pkg/FR2014-04-07/pdf/2014-07568.pdf

79 FR 41981,

July 18,

2014

Final Determination of Sales at Less

Than Fair Value and Final Negative

Determination of Critical

Circumstances: Certain Oil Country

Tubular Goods From India

http://www.gpo.gov/fdsys/pkg/FR2014-07-18/pdf/2014-16868.pdf

79 FR 41986

July 18,

2014

Certain Oil Country Tubular Goods 

From Saudi Arabia: Final

Determination of Sales at Less Than

Fair Value1

http://www.gpo.gov/fdsys/pkg/FR2014-07-18/pdf/2014-16867.pdf

79 FR 41979

July 18,

2014

Certain Oil Country Tubular Goods

From Taiwan: Final Determination of

Sales at Less Than Fair Value

http://www.gpo.gov/fdsys/pkg/FR2014-07-18/pdf/2014-16861.pdf

79 FR 41978

July 18,

2014

Certain Oil Country Tubular Goods

From Thailand: Final Determination of

Sales at Less Than Fair Value

http://www.gpo.gov/fdsys/pkg/FR2014-07-18/pdf/2014-16866.pdf

79 FR 41983

July 18,

2014

Certain Oil Country Tubular Goods

From the Republic of Korea: Final

Determination of Sales at Less Than

Fair Value and Negative Final

Determination of Critical

Circumstances

http://www.gpo.gov/fdsys/pkg/FR2014-07-18/pdf/2014-16874.pdf

A-6
79 FR 41976

July 18,

2014

Certain Oil Country Tubular Goods

From the Republic of the Philippines:

Final Determination of Sales at Less

Than Fair Value and Negative Final

Determination of Critical

Circumstances

http://www.gpo.gov/fdsys/pkg/FR2014-07-18/pdf/2014-16865.pdf

79 FR 41971

July 18,

2014

Certain Oil Country Tubular Goods

From the Republic of Turkey: Final

Determination of Sales at Less Than

Fair Value and Affirmative Final

Determination of Critical

Circumstances, in Part

http://www.gpo.gov/fdsys/pkg/FR2014-07-18/pdf/2014-16873.pdf

79 FR 41973

July 18,

2014

Certain Oil Country Tubular Goods

From the Socialist Republic of

Vietnam: Final Determination of Sales

at Less Than Fair Value and Final

Affirmative Determination of Critical

Circumstances

http://www.gpo.gov/fdsys/pkg/FR2014-07-18/pdf/2014-16862.pdf

79 FR 41959,

July 18,

2014

Suspension of Antidumping

Investigation: Certain Oil Country

Tubular Goods From Ukraine

http://www.gpo.gov/fdsys/pkg/FR2014-07-18/pdf/2014-16876.pdf

79 FR 41969

July 18,

2014

Certain Oil Country Tubular Goods

From Ukraine: Final Determination of

Sales at Less Than Fair Value and

Final Negative Determination of 

Critical Circumstances

http://www.gpo.gov/fdsys/pkg/FR2014-07-18/pdf/2014-16875.pdf

1 The Department of Commerce in a document dated August 11, 2014, amended its final 

determination in the investigation concerning certain oil country tubular goods from Saudi 

Arabia. 

Source: https://www.federalregister.gov/

A-7

APPENDIX B

LIST OF HEARING WITNESSES

B-1

CALENDAR OF PUBLIC HEARING

Those listed below appeared as witnesses at the United States International Trade 

Commission’s hearing:

Subject: Certain Oil Country Tubular Goods from India, Korea, 

Philippines, Saudi Arabia, Taiwan, Thailand, Turkey, 

Ukraine, and Vietnam

Inv. Nos.: 701-TA-499-500 and 731-TA-1215-1223 (Final)

Date and Time: July 15, 2014 - 9:30 a.m.

Sessions were held in connection with these investigations in the Main hearing Room 

(Room 101), 500 E Street, S.W., Washington, DC.

CONGRESSIONAL APPEARANCES:

The Honorable Sherrod Brown, United States Senator, Ohio

The Honorable Robert P. Casey, Jr., United States Senator, Pennsylvania

The Honorable Amy Klobuchar, United States Senator, Minnesota

The Honorable Pat Toomey, United States Senator, Pennsylvania

The Honorable Peter J. Visclosky, U.S. Representative, 1st District, Indiana

The Honorable Spencer Bachus, U.S. Representative, 6th District, Alabama

The Honorable Mike Doyle, U.S. Representative, 14th District, Pennsylvania

The Honorable Tim Murphy, U.S. Representative, 18th District, Pennsylvania

The Honorable Rick Crawford, U.S. Representative, 1st District, Arkansas

B-3
EMBASSY WITNESSES:

Embassy of the Republic of Turkey

Washington, DC

Tuba Hatipoglu, Commercial Counselor

Embassy of Ukraine

Washington, DC

 

 Ihor Baranetskyi, Head of Economic Department

OPENING REMARKS:

Petitioners (Roger B. Schagrin, Schagrin Associates)

Respondents (Donald B. Cameron, Morris, Manning & Martin, LLP)

In Support of the Imposition of

 Antidumping and Countervailing Duty Orders:

Schagrin Associates

Washington, DC

on behalf of

Boomerang Tube

Energex Tube, a division of JMC Steel Group

Tejas Tubular Products

TMK IPSCO

Vallourec Star, L.P.

Welded Tube USA, Inc.

The United Steel, Paper and Forestry, Rubber,

Manufacturing, Energy, Allied Industrial,

and Service Workers International Union (“USW”)

Gregg Eisenberg, President and Chief Executive Officer, 

Boomerang Tube

Randy Boswell, President, Energex Tube, a division of JMC 

Steel Group

Bob Okrzesik, Vice President of Marketing, Energex Tube, 

a division of JMC Steel Group

Maximo Tejeda, President and Chief Executive Officer, 

Tejas Tubular Products

David Mitch, President and Chief Executive Officer, 

TMK IPSCO

B-4
In Support of the Imposition of 

 Antidumping and Countervailing Duty Orders (continued):

Scott Barnes, Senior Vice President and Chief Commercial

Officer, TMK IPSCO

Skip Herald, Managing Director – North America,

Vallourec USA

Ronny Clark, General Manager – Sales and Marketing,

Vallourec Star, L.P.

Robert “Butch” Mandel, President, Welded Tube

Leo Gerard, International President, USW

Steve Tait, President, Pipeco

Roger B. Schagrin )

John W. Bohn ) – OF COUNSEL

Paul W. Jameson )

Wiley Rein LLP

Washington, DC

on behalf of

Maverick Tube Corporation (“Maverick”)

Guillermo Vogel, Board Member and Vice President of

Finance, Tenaris S.A.

Germán Curá, President and Chief Executive Officer, 

Maverick; and Managing Director, Tenaris North America

Brad Lowe, Director, Maverick; and President, Tenaris Global 

Services (USA) Inc.

Dr. Michael Whinston, Professor of Economics, Massachusetts

Institute of Technology

Dr. Seth Kaplan, Senior Economic Advisor, Capital Trade, Inc.

Alan H. Price )

) – OF COUNSEL

Robert E. DeFrancesco, III )

B-5
In Support of the Imposition of 

 Antidumping and Countervailing Duty Orders (continued):

Skadden, Arps, Slate, Meagher & Flom LLP

Washington, DC

on behalf of

United States Steel Corporation

Mario Longhi, President and Chief Executive Officer, 

United States Steel Corporation

David J. Rintoul, Senior Vice President – Tubular Business,

United States Steel Corporation

George H. Thompson, Jr., Vice President – Tubular Commercial,

United States Steel Corporation

In Support of the Imposition of 

 Antidumping and Countervailing Duty Orders (continued):

Scott M. Dorn, General Manager – Tubular Marketing, U.S.

Steel Tubular Products, Inc.

William M. Buono, Director OCTG Marketing, U.S. Steel 

Tubular Products, Inc.

John B. Shoaff, President, Sooner Pipe, LLC

Scott DuBois, President, Premier Pipe, LLC

Steve Miller, Co-Chief Executive Officer, Cinco

Pipe & Supply

James C. Hecht )

) – OF COUNSEL

Stephen P. Vaughn )

B-6
In Opposition to the Imposition of

 Antidumping and Countervailing Duty Orders:

Morris, Manning & Martin, LLP

Washington, DC

on behalf of

Borusan Mannesmann Boru Sanayi ve Ticaret Anonium Sirketi

Çayirova Boru Sanayi ve Ticaret A.S.

Yücel Boru lthalat-Ihracat ve Pazarlama A.S.

Tosçelik Profil ve Sac Endustrisi A.S.

Tosyali Dis Ticaret A.S.

and

AJU Besteel Co., Ltd.

Husteel Co., Ltd.

Hyundai HYSCO

Nexteel Co., Ltd.

SeAH Steel America, Inc.

Husteel USA, Inc.

Hyundai HYSCO USA, Inc.

SeAH Steel America, Inc.

Semih Ozmen, President and Chief Executive Officer, Borusan

Mannesmann Boru Sanayi ve Ticaret Anonium Sirketi

Buddy Brewer, President and Chief Executive Officer, Borusan 

Mannesmann Pipe US Inc.

Kirk Murray, Vice President and General Manager, Pan Meridian

Tubular

Chuck Scianna, President, Sim-Tex, L.P.

Dong-Heui Pi, Manager, Marketing Strategy Team, Hyundai

HYSCO Ltd.

Jim Dougan, Vice President, Economic Consulting Service, LLC

Julie C. Mendoza )

Donald B. Cameron ) – OF COUNSEL

R. Will Planert )

B-7
In Opposition to the Imposition of

 Antidumping and Countervailing Duty Orders (continued):

Arent Fox LLP

Washington, DC

on behalf of

Duferco Steel Inc. (“Duferco”)

Jubail Energy Services Company (“JESCO”)

John Blomberg, Director of Pipe and Tube, Duferco SA

John M. Gurley ) – OF COUNSEL

Hogan Lovells US LLP

Washington, DC

on behalf of

Interpipe and North American Interpipe (“Interpipe”)

Fadi Hraibi, Chief Commercial Officer, Interpipe

Mark S. McConnell )

Craig A. Lewis ) – OF COUNSEL

Wesley V. Carrington )

Steptoe & Johnson LLP

Washington, DC

on behalf of

ILJIN Steel Corporation (“ILJIN”)

Richard O. Cunningham )

) – OF COUNSEL

Joel D. Kaufman )

Grunfeld, Desiderio, Lebowitz, Silverman, & Klestadt LLP

Washington, DC

on behalf of

Boly Pipe Co. Ltd. (“Boly”)

Francis J. Sailer )

Ned H. Marshak ) – OF COUNSEL

Brandon M. Petelin )

B-8
In Opposition to the Imposition of

 Antidumping and Countervailing Duty Orders (continued):

DeKieffer & Horgan, PLLC

Washington, DC

on behalf of

HLD Clark Steel Pipe Co., Inc. (“HLD Clark”)

Gregory S. Menegaz ) 

 ) – OF COUNSEL

 Judith L. Holdsworth )

Vorys, Sater, Seymour and Pease LLP

Washington, DC

on behalf of

C&F International Incorporated (“C&F”)

Frederick P. Waite )

) – OF COUNSEL

Kimberly R. Young )

Law Offices of Nithya Nagarajan, LLC

Bethesda, MD

on behalf of

Jindal SAW Ltd.

Nithya Nagarajan ) – OF COUNSEL

REBUTTAL/CLOSING REMARKS:

Petitioners (Alan H. Price, Wiley Rein LLP and Stephen Vaughn, Skadden, 

Arps, Slate, Meagher & Flom LLP) 

Respondents (Donald B. Cameron and Julie C. Mendoza, Morris, Manning &

Martin, LLP; Richard O. Cunningham, Steptoe & Johnson LLP; and

Mark S. McConnell, Hogan Lovells US LLP)

-ENDB-9

C‐1

APPENDIX C

SUMMARY DATA

Table C-1

OCTG: Summary data concerning the U.S. market, 2011-13, January to March 2013, and January to March 2014

Jan-Mar

2011 2012 2013 2013 2014 2011-13 2011-12 2012-13 2013-14

U.S. consumption quantity:

Amount...................................................................... 5,975,616 6,958,567 6,978,687 1,605,438 1,840,854 16.8 16.4 0.3 14.7

Producers' share (fn1).............................................. 52.5 48.7 53.5 54.2 51.6 1.1 (3.8) 4.9 (2.6)

Importers' share (fn1):

India....................................................................... *** *** *** *** *** *** *** *** ***

Korea...................................................................... *** *** *** *** *** *** *** *** ***

Philippines............................................................. 0.4 1.0 1.1 0.7 1.0 0.7 0.6 0.1 0.2

Saudi Arabia.......................................................... *** *** *** *** *** *** *** *** ***

Taiwan subject....................................................... *** *** *** *** *** *** *** *** ***

Thailand................................................................. 0.1 0.5 0.5 0.2 0.6 0.4 0.4 0.0 0.4

Turkey.................................................................... 2.4 2.2 1.9 1.5 1.9 (0.4) (0.2) (0.3) 0.3

Ukraine................................................................... *** *** *** *** *** *** *** *** ***

Vietnam.................................................................. 0.9 3.2 2.1 2.0 0.1 1.1 2.2 (1.1) (1.8)

Subtotal subject sources..................................... *** *** *** *** *** *** *** *** ***

Taiwan Chang Hung nonsubject........................... *** *** *** *** *** *** *** *** ***

All other nonsubject sources.................................. *** *** *** *** *** *** *** *** ***

Subtotal nonsubject sources............................... *** *** *** *** *** *** *** *** ***

Total imports.................................................... 47.5 51.3 46.5 45.8 48.4 (1.1) 3.8 (4.9) 2.6

U.S. consumption value:

Amount...................................................................... 9,428,496 11,139,529 10,095,576 2,373,975 2,603,764 7.1 18.1 (9.4) 9.7

Producers' share (fn1):

U.S. mills' U.S. shipments..................................... 56.1 52.7 57.8 57.3 56.3 1.7 (3.4) 5.1 (1.0)

U.S. processors' toll revenue/incremental value... 1.7 2.0 2.6 2.6 2.7 0.9 0.3 0.7 0.1

Total U.S. producer contributions....................... 57.8 54.6 60.4 59.9 59.0 2.6 (3.1) 5.8 (0.9)

Importers' share (fn1):

India....................................................................... *** *** *** *** *** *** *** *** ***

Korea...................................................................... *** *** *** *** *** *** *** *** ***

Philippines............................................................. 0.2 0.6 0.6 0.4 0.5 0.4 0.4 0.0 0.1

Saudi Arabia.......................................................... *** *** *** *** *** *** *** *** ***

Taiwan subject....................................................... *** *** *** *** *** *** *** *** ***

Thailand................................................................. 0.1 0.4 0.4 0.2 0.6 0.3 0.3 0.0 0.4

Turkey.................................................................... 1.4 1.3 1.1 0.9 1.1 (0.3) (0.1) (0.2) 0.2

Ukraine................................................................... *** *** *** *** *** *** *** *** ***

Vietnam.................................................................. 0.6 1.8 1.2 1.1 0.1 0.6 1.2 (0.6) (1.0)

Subtotal subject sources..................................... *** *** *** *** *** *** *** *** ***

Taiwan Chang Hung nonsubject........................... *** *** *** *** *** *** *** *** ***

All other nonsubject sources.................................. *** *** *** *** *** *** *** *** ***

Subtotal nonsubject sources............................... *** *** *** *** *** *** *** *** ***

Total imports.................................................... 42.2 45.4 39.6 40.1 41.0 (2.6) 3.1 (5.8) 0.9

U.S. importers' U.S. Imports from:

India:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Korea:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Philippines:

Quantity.................................................................. 23,933 69,757 73,969 12,030 17,794 209.1 191.5 6.0 47.9

Value...................................................................... 21,542 64,567 60,391 9,784 13,739 180.3 199.7 (6.5) 40.4

Unit value............................................................... $900 $926 $816 $813 $772 (9.3) 2.8 (11.8) (5.1)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Saudi Arabia:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Taiwan subject:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Thailand:

Quantity.................................................................. 6,135 31,833 33,741 3,424 11,911 450.0 418.9 6.0 247.9

Value...................................................................... 8,053 43,815 39,752 4,593 16,280 393.6 444.1 (9.3) 254.5

Unit value............................................................... $1,313 $1,376 $1,178 $1,341 $1,367 (10.2) 4.9 (14.4) 1.9

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Turkey:

Quantity.................................................................. 140,806 151,576 133,773 24,217 34,158 (5.0) 7.6 (11.7) 41.0

Value...................................................................... 133,698 144,280 114,981 22,481 29,012 (14.0) 7.9 (20.3) 29.1

Unit value............................................................... $950 $952 $860 $928 $849 (9.5) 0.2 (9.7) (8.5)

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Ukraine:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Table continued next page

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)

Calendar year January to March

Reported data

Calendar year

Period changes

C-3
Table C-1--Continued

OCTG: Summary data concerning the U.S. market, 2011-13, January to March 2013, and January to March 2014

Jan-Mar

2011 2012 2013 2013 2014 2011-13 2011-12 2012-13 2013-14

U.S. importers' U.S. Imports from.--Continued

Vietnam:

Quantity.................................................................. 56,697 219,997 144,871 31,876 2,757 155.5 288.0 (34.1) (91.4)

Value...................................................................... 53,923 201,905 119,291 26,414 3,144 121.2 274.4 (40.9) (88.1)

Unit value............................................................... $951 $918 $823 $829 $1,140 (13.4) (3.5) (10.3) 37.6

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Subject sources:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Taiwan Chang Hung nonsubject:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

All other nonsubject sources:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Nonsubject sources:

Quantity.................................................................. *** *** *** *** *** *** *** *** ***

Value...................................................................... *** *** *** *** *** *** *** *** ***

Unit value............................................................... *** *** *** *** *** *** *** *** ***

Ending inventory quantity...................................... *** *** *** *** *** *** *** *** ***

Total imports:

Quantity.................................................................. 2,839,740 3,570,796 3,242,306 734,735 890,275 14.2 25.7 (9.2) 21.2

Value...................................................................... 3,981,070 5,053,876 3,997,131 952,338 1,067,990 0.4 26.9 (20.9) 12.1

Unit value............................................................... $1,402 $1,415 $1,233 $1,296 $1,200 (12.1) 1.0 (12.9) (7.4)

Ending inventory quantity...................................... 401,502 614,953 626,089 583,630 532,202 55.9 53.2 1.8 (8.8)

U.S. mills:

Average capacity quantity......................................... 4,925,253 5,181,573 5,804,450 1,374,216 1,478,139 191 17.9 5.2 12.0 7.6

Production quantity................................................... 3,329,004 3,587,613 4,107,433 995,468 1,064,678 193 23.4 7.8 14.5 7.0

Capacity utilization (fn1)........................................... 67.6 69.2 70.8 72.4 72.0 219 3.2 1.6 1.5 (0.4)

U.S. shipments:

Quantity.................................................................. 3,135,876 3,387,771 3,736,381 870,703 950,579 229 19.1 8.0 10.3 9.2

Value...................................................................... 5,286,771 5,867,506 5,833,652 1,359,773 1,466,007 230 10.3 11.0 (0.6) 7.8

Unit value............................................................... $1,686 $1,732 $1,561 $1,562 $1,542 231 (7.4) 2.7 (9.9) (1.2)

Export shipments:

Quantity.................................................................. 173,398 209,086 258,589 44,839 83,823 200 49.1 20.6 23.7 86.9

Value...................................................................... 306,292 360,066 359,637 74,504 107,397 201 17.4 17.6 (0.1) 44.1

Unit value............................................................... $1,766 $1,722 $1,391 $1,662 $1,281 227 (21.3) (2.5) (19.2) (22.9)

Ending inventory quantity......................................... 357,030 319,151 365,485 382,283 375,999 244 2.4 (10.6) 14.5 (1.6)

Inventories/total shipments (fn1).............................. 10.8 8.9 9.1 10.4 9.1 247 (1.6) (1.9) 0.3 (1.4)

Production workers................................................... 5,976 7,135 6,891 6,760 7,092 205 15.3 19.4 (3.4) 4.9

Hours worked (1,000s)............................................. 13,017 15,059 16,015 3,913 3,973 206 23.0 15.7 6.3 1.5

Wages paid ($1,000)................................................ 369,492 451,581 507,746 110,092 129,040 207 37.4 22.2 12.4 17.2

Hourly wages (dollars per hour)............................... $28.39 $29.99 $31.70 $28.13 $32.48 11.7 5.6 5.7 15.4

Productivity (short tons per 1,000 hours).................. 255.7 238.2 256.5 254.4 268.0 251 0.3 (6.8) 7.7 5.3

Unit labor costs......................................................... $110.99 $125.87 $123.62 $110.59 $121.20 253 11.4 13.4 (1.8) 9.6

Net sales:

Quantity.................................................................. 3,306,386 3,602,983 4,010,042 929,328 1,032,178 494 21.3 9.0 11.3 11.1

Value...................................................................... 5,590,347 6,235,687 6,229,566 1,450,989 1,591,597 498 11.4 11.5 (0.1) 9.7

Unit value............................................................... $1,691 $1,731 $1,553 $1,561 $1,542 523 (8.1) 2.4 (10.2) (1.2)

Cost of goods sold (COGS)...................................... 4,536,410 5,158,130 5,411,229 1,248,276 1,420,597 502 19.3 13.7 4.9 13.8

Gross profit of (loss)................................................. 1,053,937 1,077,557 818,337 202,713 171,000 503 (22.4) 2.2 (24.1) (15.6)

SG&A expenses........................................................ 412,811 463,714 506,639 115,314 124,365 506 22.7 12.3 9.3 7.8

Operating income or (loss)....................................... 641,126 613,843 311,698 87,399 46,635 507 (51.4) (4.3) (49.2) (46.6)

Capital expenditures................................................. 705,202 632,842 370,660 86,680 41,216 624 (47.4) (10.3) (41.4) (52.5)

Unit COGS................................................................ $1,372 $1,432 $1,349 $1,343 $1,376 525 (1.6) 4.3 (5.7) 2.5

Unit SG&A expenses................................................ $125 $129 $126 $124 $120 527 1.2 3.1 (1.8) (2.9)

Unit operating income or (loss)................................ $194 $170 $78 $94 $45 565 (59.9) (12.1) (54.4) (52.0)

COGS/sales (fn1)..................................................... 81.1 82.7 86.9 86.0 89.3 536 5.7 1.6 4.1 3.2

Operating income or (loss)/sales (fn1)..................... 11.5 9.8 5.0 6.0 2.9 565 (6.5) (1.6) (4.8) (3.1)

Table continued next page

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)

Reported data Period changes

Calendar year January to March Calendar year

C-4
Table C-1--Continued

OCTG: Summary data concerning the U.S. market, 2011-13, January to March 2013, and January to March 2014

Jan-Mar

2011 2012 2013 2013 2014 2011-13 2011-12 2012-13 2013-14

U.S. non-toll and toll processors combined:

Average capacity quantity......................................... 674,376 996,876 1,093,280 257,642 320,084 62.1 47.8 9.7 24.2

Production quantity................................................... 512,674 693,525 783,266 175,046 235,359 52.8 35.3 12.9 34.5

Capacity utilization (fn1)........................................... 76.0 69.6 71.6 67.9 73.5 (4.4) (6.5) 2.1 5.6

U.S. shipments:

Quantity.................................................................. 499,623 681,109 789,499 176,275 222,560 58.0 36.3 15.9 26.3

Value...................................................................... 326,851 441,562 485,012 109,891 125,054 48.4 35.1 9.8 13.8

of which U.S. value-added.................................. 160,655 218,147 264,793 61,864 69,767 64.8 35.8 21.4 12.8

Ending inventory quantity......................................... *** *** *** *** *** *** *** *** ***

Inventories/US shipments (fn1)................................ *** *** *** *** *** *** *** *** ***

Production workers................................................... 1,510 1,802 2,019 1,915 2,245 33.7 19.3 12.0 17.2

Hours worked (1,000s)............................................. 4,178 5,539 6,084 1,440 1,755 45.6 32.6 9.8 21.9

Wages paid ($1,000)................................................ 52,423 73,735 83,953 19,649 22,809 60.1 40.7 13.9 16.1

Hourly wages (dollars per hour)............................... $12.55 $13.31 $13.80 $13.65 $13.00 10.0 6.1 3.7 (4.8)

Productivity (short tons per 1,000 hours).................. 122.7 125.2 128.7 121.6 134.1 4.9 2.0 2.8 10.3

Unit labor costs......................................................... $102.25 $106.32 $107.18 $112.25 $96.91 4.8 4.0 0.8 (13.7)

Net sales:

Quantity.................................................................. 503,168 688,332 812,781 184,441 232,520 61.5 36.8 18.1 26.1

Value...................................................................... 333,361 460,658 493,428 113,935 129,463 48.0 38.2 7.1 13.6

Cost of goods sold or tolled (COGST)...................... 251,196 367,135 382,976 89,344 96,942 52.5 46.2 4.3 8.5

Gross profit of (loss)................................................. 82,165 93,523 110,452 24,591 32,521 34.4 13.8 18.1 32.2

SG&A expenses........................................................ 39,144 49,103 51,517 10,905 13,011 31.6 25.4 4.9 19.3

Operating income or (loss)....................................... 43,021 44,420 58,935 13,686 19,510 37.0 3.3 32.7 42.6

Capital expenditures................................................. 79,029 45,544 44,266 11,667 5,098 (44.0) (42.4) (2.8) (56.3)

COGST/sales (fn1)................................................... 75.4 79.7 77.6 78.4 74.9 2.3 4.3 (2.1) (3.5)

Operating income or (loss)/sales (fn1)..................... 12.9 9.6 11.9 12.0 15.1 (1.0) (3.3) 2.3 3.1

Notes: See Part IV for discussion of how the processors' toll revenue/incremental value was calculated.

fn1.--Reported data are in percent and period changes are in percentage points.

fn2.--Not applicable.

January to March Calendar year

C-5

(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)

Unit values for the combined stand-alone and toll processors data have not been provided due to differences in the nature of the data gathered from the two types of processors. Unit values of each group have been 

provided in the body of this report in their respective, non-combined data tables.

Reported data Period changes

Calendar year

APPENDIX D

U.S. PRODUCERS’ AND IMPORTERS’

SHIPMENTS AND IMPORTS OF OCTG BY TYPE

D-1

Table D-1

OCTG: U.S. importers' U.S. imports from India, by type, 2011-13, January to March 2013, and 

January to March 2014

* * * * * * *

Table D-2

OCTG: U.S. importers' U.S. imports from Korea, by type, 2011-13, January to March 2013, and 

January to March 2014

* * * * * * *

Table D-3

OCTG: U.S. importers' U.S. imports from the Philippines, by type, 2011-13, January to March

2013, and January to March 2014

* * * * * * *

Table D-4

OCTG: U.S. importers' U.S. imports from Saudi Arabia, by type, 2011-13, January to March 2013, 

and January to March 2014

* * * * * * *

Table D-5

OCTG: U.S. importers' U.S. imports from Taiwan (subject), by type, 2011-13, January to March 

2013, and January to March 2014

* * * * * * *

Table D-6

OCTG: U.S. importers' U.S. imports from Thailand, by type, 2011-13, January to March 2013, and 

January to March 2014

* * * * * * *

Table D-7

OCTG: U.S. importers' U.S. imports from Turkey, by type, 2011-13, January to March 2013, and 

January to March 2014

* * * * * * *

Table D-8

OCTG: U.S. importers' U.S. imports from Ukraine, by type, 2011-13, January to March 2013, and 

January to March 2014

* * * * * * *

Table D-9

OCTG: U.S. importers' U.S. imports from Vietnam, by type, 2011-13, January to March 2013, and 

January to March 2014

* * * * * * *

D-3
Table D-10

OCTG: U.S. producers’ U.S. shipments of OCTG, by type and end finish, 2013

Type

Threaded and coupled Threaded not coupled

Plain 

end

Coupling 

Proprietary stock Total

Not 

proprietary Proprietary

Not 

proprietary

Quantity (short tons)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 806,818

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 553,466

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 1,727,521

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 3,903,975

Value (1,000 dollars)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 944,565

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 903,604

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 2,977,589

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 6,109,989

Table continued on next page.

D-4
Table D-10 --Continued

OCTG: U.S. producers’ U.S. shipments of OCTG, by type and end finish, 2013

Type

Threaded and coupled Threaded not coupled

Plain 

end

Coupling 

Proprietary stock Total

Not 

proprietary Proprietary

Not 

proprietary

Unit value (dollars per short ton)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 1,171

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 1,633

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 1,724

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 1,565

Share of quantity by end finish (percent)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 100.0

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 100.0

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 100.0

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 100.0

1 Not applicable.

Source: Compiled from data submitted in response to Commission questionnaires.

D-5
Table D-11

OCTG: U.S. importers' U.S. shipments of OCTG from subject sources, by type and end finish, 2013

Type

Threaded and coupled Threaded not coupled

Plain 

end

Coupling 

Proprietary stock Total

Not 

proprietary Proprietary

Not 

proprietary

Quantity (short tons)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 1,037,784

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 209,235

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 175,315

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 1,551,952

Value (1,000 dollars)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 1,001,943

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 283,198

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 245,965

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 1,682,550

Table continued on next page.

D-6
Table D-11 --Continued

OCTG: U.S. importers' U.S. shipments of OCTG from subject sources, by type and end finish, 2013

Type

Threaded and coupled Threaded not coupled

Plain 

end

Coupling 

Proprietary stock Total

Not 

proprietary Proprietary

Not 

proprietary

Unit value (dollars per short ton)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 965

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 1,353

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 1,403

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 1,084

Share of quantity by end finish (percent)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 100.0

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 100.0

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 100.0

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 100.0

1 Not applicable.

Source: Compiled from data submitted in response to Commission questionnaires.

D-7
Table D-12

OCTG: U.S. importers' U.S. shipments of OCTG from nonsubject sources, by type and end finish, 2013

Type

Threaded and coupled Threaded not coupled

Plain 

end

Coupling 

Proprietary stock Total

Not 

proprietary Proprietary

Not 

proprietary

Quantity (short tons)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 140,368

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 207,754

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 685,331

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 1,224,036

Value (1,000 dollars)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 159,762

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 356,850

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 1,299,377

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 2,242,185

Table continued on next page.

D-8
Table D-12 --Continued

OCTG: U.S. importers' U.S. shipments of OCTG from nonsubject sources, by type and end finish, 2013

Type

Threaded and coupled Threaded not coupled

Plain 

end

Coupling 

Proprietary stock Total

Not 

proprietary Proprietary

Not 

proprietary

Unit value (dollars per short ton)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 1,138

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 1,718

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 1,896

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 1,832

Share of quantity by end finish (percent)

Below API/limited service *** *** *** *** *** *** ***

H-40 *** *** *** *** *** *** ***

J-55 *** *** *** *** *** *** 100.0

K-55 *** *** *** *** *** *** ***

M-65 *** *** *** *** *** *** ***

L-80 *** *** *** *** *** *** 100.0

C-95 *** *** *** *** *** *** ***

N-80, Type I *** *** *** *** *** *** ***

N-80, Type II *** *** *** *** *** *** ***

C-90 *** *** *** *** *** *** ***

T-95 *** *** *** *** *** *** ***

P-110 *** *** *** *** *** *** 100.0

Q-125 *** *** *** *** *** *** ***

Premium/proprietary *** *** *** *** *** *** ***

Total reported U.S. 

shipments *** *** *** *** *** *** 100.0

1 Not applicable.

Source: Compiled from data submitted in response to Commission questionnaires.

D-9
Table D-13

OCTG: U.S. importers' U.S. shipments of OCTG from India, by type and end finish, 2013

* * * * * * *

Table D-14

OCTG: U.S. importers' U.S. shipments of OCTG from Korea, by type and end finish, 2013

* * * * * * *

Table D-15

OCTG: U.S. importers' U.S. shipments of OCTG from Philippines, by type and end finish, 2013

* * * * * * *

Table D-16

OCTG: U.S. importers' U.S. shipments of OCTG from Saudi Arabia, by type and end finish, 2013

* * * * * * *

Table D-17

OCTG: U.S. importers' U.S. shipments of OCTG from Taiwan (subject), by type and end finish, 2013

* * * * * * *

Table D-18

OCTG: U.S. importers' U.S. shipments of OCTG from Thailand, by type and end finish, 2013

* * * * * * *

Table D-19

OCTG: U.S. importers' U.S. shipments of OCTG from Turkey, by type and end finish, 2013

* * * * * * *

Table D-20

OCTG: U.S. importers' U.S. shipments of OCTG from Ukraine, by type and end finish, 2013

* * * * * * *

Table D-21

OCTG: U.S. importers' U.S. shipments of OCTG from Vietnam, by type and end finish, 2013

* * * * * * *

D-10
E‐1

APPENDIX E   

QUARTERLY NONSUBJECT COUNTRY PRICE DATA

   

E‐3

Nonsubject pricing data was received for all products, but not for all countries for each

product.  In total, eight importers reported sales of these pricing products from nonsubject

sources, including imports from Argentina, Canada, Germany, Japan, and Mexico, as well as

imports from Chung Hung in Taiwan.  Importer price data accounted for *** percent of U.S.

imports from Taiwan (Chung Hung) over January 2011‐ March 2014. In addition, they cover ***

percent of U.S. imports from Argentina, *** percent of U.S. imports from Canada, *** percent

of U.S. imports from Germany, *** percent of U.S. imports from Japan, and *** percent of U.S.

imports from Mexico.   

When compared with prices of these specific OCTG products manufactured in the

United States, OCTG imported from nonsubject sources was priced lower than domestically

produced OCTG in 66 of 113 quarters of comparison (58.4 percent).  Specifically, OCTG

imported from Chung Hung in Taiwan was priced lower in 24 of 28 quarters (85.7 percent of

comparisons).  Imports from other nonsubject sources were priced lower than the domestic

product in just under half of the available comparisons (42 of 85 quarters).  In the relatively few

comparisons available, product from Germany, Japan, and Mexico were more often priced

higher than domestically produced OCTG (3 of 4 quarters, 5 of 6 quarters, and 9 of 13 quarters,

respectively). Further detail is included in table E‐1.

OCTG imported from subject sources was priced lower than OCTG imported from

nonsubject sources in 247 of 350 possible comparisons (70.6 percent). Further information is

provided in table E‐2.   

 
E‐4

Table E-1 

OCTG: Instances of nonsubject source underselling/overselling when compared with domestic 

prices, and the range and average margins, by source, January 2011-March 2014 

Nonsubject 

source

Number of 

quarters of 

underselling

Number of 

quarters of 

(overselling)

Margins of underselling Margins of (overselling)

Average 

(percent) 

Range (percent)

Average 

(percent)

Range (percent)

Min Max Min Max

 Taiwan 

(Chung Hung) 24 4 *** *** *** *** *** *** 

 Argentina 11 10 *** *** *** *** *** *** 

 Canada 25 16 *** *** *** *** *** *** 

 Germany 1 3 *** *** *** *** *** *** 

 Japan 1 5 *** *** *** *** *** *** 

 Mexico 4 9 *** *** *** *** *** *** 

 Subtotal 42 43 *** *** *** *** *** *** 

 Total 66 47 6.8 0.1 25.5 (16.7) (0.3) (52.9) 

Source: Compiled from data submitted in response to Commission questionnaires. 

Table E-2 

OCTG: Number of quarters that prices of domestic OCTG and OCTG imported from subject 

sources were lower and higher than nonsubject and zero-rate source product prices 

Comparison 

country 

Number of quarters: 

Higher prices for OCTG from 

nonsubject sources 

Lower prices for OCTG from 

nonsubject sources 

United States 47 66 

India 0 0 

Korea 47 25 

Philippines 32 13 

Saudi Arabia 10 8 

Taiwan 44 20 

Thailand 7 1 

Turkey 49 24 

Ukraine 21 3 

Vietnam 37 19 

 Total 247 103 

Source: Compiled from data submitted in response to Commission questionnaires. 

The underlying pricing and quantity data for the relevant nonsubject countries are

shown in tables E‐3 to E‐8 and in figures E‐1 to E‐6. These data are comparable to those

presented in tables V‐6 to V‐11.
E‐5

Table E-3 

OCTG: Weighted-average f.o.b. prices and quantities from nonsubject sources, product 1,1

 by 

quarters, January 2011-March 2014 

Period

Argentina Mexico 

Price (dollars per 

ton) Quantity (tons)

Price (dollars per 

ton) Quantity (tons)

2011: 

 Jan.-Mar. *** *** -- 0 

 Apr.-Jun. *** *** -- 0 

 Jul.-Sept. *** *** -- 0 

 Oct.-Dec. *** *** -- 0 

2012: 

 Jan.-Mar. *** *** -- 0 

 Apr.-Jun. *** *** -- 0 

 Jul.-Sept. *** *** -- 0 

 Oct.-Dec. *** *** -- 0 

2013: 

 Jan.-Mar. *** *** -- 0 

 Apr.-Jun. -- 0 -- 0 

 Jul.-Sept. *** *** *** *** 

 Oct.-Dec. *** *** *** *** 

2014: 

 Jan.-Mar. *** *** -- 0 1

 Product 1.-- Tubing, Grade L-80, 2 7/8" O.D., 6.5 lbs./ft., threaded and coupled, range 2, seamless. 

Source: Compiled from data submitted in response to Commission questionnaires.

 
E‐6

Table E-4 

OCTG: Weighted-average f.o.b. prices and quantities from nonsubject sources, product 2,1

 by 

quarters, January 2011-March 2014 

Period

Argentina Canada Mexico

Price (dollars 

per ton) 

Price (dollars 

per ton)

Price (dollars 

per ton)

Quantity 

(tons)

Price (dollars 

per ton) 

Quantity 

(tons)

2011: 

 Jan.-Mar. -- 0 *** *** -- 0 

 Apr.-Jun. -- 0 *** *** -- 0 

 Jul.-Sept. -- 0 -- 0 -- 0 

 Oct.-Dec. *** *** *** *** -- 0 

2012: 

 Jan.-Mar. *** *** *** *** -- 0 

 Apr.-Jun. -- 0 *** *** -- 0 

 Jul.-Sept. -- 0 *** *** -- 0 

 Oct.-Dec. *** *** *** *** -- 0 

2013: 

 Jan.-Mar. -- 0 *** *** -- 0 

 Apr.-Jun. -- 0 -- 0 -- 0 

 Jul.-Sept. -- 0 -- 0 -- 0 

 Oct.-Dec. *** *** -- 0 *** *** 

2014: 

 Jan.-Mar. -- 0 -- 0 -- 0 1

 Product 2.-- Tubing, Grade J-55, 2 3/8" O.D., 4.7 lbs./ft., threaded and coupled, range 2, welded. 

Source: Compiled from data submitted in response to Commission questionnaires.

 
E‐7

Table E-5 

OCTG: Weighted-average f.o.b. prices and quantities from nonsubject sources, product 3,1

 by 

quarters, January 2011-March 2014 

Period

Taiwan-Chung Hung Canada Mexico

Price (dollars 

per ton) 

Quantity

(tons)

Price (dollars 

per ton)

Quantity 

(tons)

Price (dollars 

per ton) 

Quantity 

(tons)

2011: 

 Jan.-Mar. *** *** *** *** -- 0 

 Apr.-Jun. *** *** *** *** -- 0 

 Jul.-Sept. *** *** *** *** -- 0 

 Oct.-Dec. *** *** -- 0 -- 0 

2012: 

 Jan.-Mar. *** *** -- 0 -- 0 

 Apr.-Jun. *** *** -- 0 -- 0 

 Jul.-Sept. *** *** *** *** -- 0 

 Oct.-Dec. *** *** -- 0 -- 0 

2013: 

 Jan.-Mar. *** *** *** *** -- 0 

 Apr.-Jun. *** *** *** *** -- 0 

 Jul.-Sept. *** *** -- 0 *** *** 

 Oct.-Dec. *** *** -- 0 *** *** 

2014: 

 Jan.-Mar. *** *** -- 0 -- 0 1

 Product 3.-- Casing, Grade J-55, 5 1⁄2" O.D., 17.0 lbs./ft., threaded and coupled, range 3, welded. 

Source: Compiled from data submitted in response to Commission questionnaires.

 
E‐8

Table E-6 

OCTG: Weighted-average f.o.b. prices and quantities from nonsubject sources, product 4,1

 by 

quarters, January 2011-March 2014 

Period

Argentina Canada - API Canada - non-API2

Price (dollars 

per ton) 

Quantity 

(tons) 

Price (dollars 

per ton)

Quantity 

(tons)

Price (dollars 

per ton) 

Quantity 

(tons) Premium

2011: 

 Jan.-Mar. *** *** -- 0 -- 0 

 Apr.-Jun. -- 0 -- 0 -- 0 

 Jul.-Sept. *** *** -- 0 -- 0 

 Oct.-Dec. *** *** -- 0 -- 0 

2012: 

 Jan.-Mar. -- 0 *** *** -- 0 

 Apr.-Jun. -- 0 -- 0 *** *** *** 

 Jul.-Sept. -- 0 *** *** -- 0 

 Oct.-Dec. -- 0 *** *** *** *** *** 

2013: 

 Jan.-Mar. -- 0 *** *** -- 0 

 Apr.-Jun. -- 0 *** *** *** *** *** 

 Jul.-Sept. *** *** *** *** -- 0 

 Oct.-Dec. *** *** *** *** *** *** *** 

2014: 

 Jan.-Mar. -- 0 -- 0 -- 0 

Period

Mexico 

Price (dollars 

per ton)

Quantity 

(tons)

2011: 

 Jan.-Mar. *** *** 

 Apr.-Jun. *** *** 

 Jul.-Sept. *** *** 

 Oct.-Dec. *** *** 

2012: 

 Jan.-Mar. -- 0 

 Apr.-Jun. -- 0 

 Jul.-Sept. -- 0 

 Oct.-Dec. -- 0 

2013: 

 Jan.-Mar. -- 0 

 Apr.-Jun. -- 0 

 Jul.-Sept. *** *** 

 Oct.-Dec. *** *** 

2014: 

 Jan.-Mar. -- 0 1

 Product 4.-- Casing, Grade P-110, 5 1⁄2" O.D., 17.0 lbs./ft., threaded and coupled, range 3, seamless. 2

 Data were reported for product 4 that had a non-API standard connection (i.e., premium or proprietary). This data is separated from 

the API-standard connection data. These data are presented here, but not used for the calculation of quarterly comparison. 

Source: Compiled from data submitted in response to Commission questionnaires.

 
E‐9

Table E-7 

OCTG: Weighted-average f.o.b. prices and quantities from nonsubject sources, product 5,1

 by 

quarters, January 2011-March 2014 

Period

Taiwan- Chung Hung Canada Germany

Price (dollars 

per ton) 

Quantity 

(tons)

Price (dollars 

per ton)

Quantity 

(tons)

Price (dollars 

per ton) 

Quantity 

(tons)

2011: 

 Jan.-Mar. *** *** *** *** -- 0 

 Apr.-Jun. *** *** -- 0 -- 0 

 Jul.-Sept. *** *** *** *** -- 0 

 Oct.-Dec. *** *** -- 0 *** *** 

2012: 

 Jan.-Mar. *** *** -- 0 -- 0 

 Apr.-Jun. *** *** *** *** -- 0 

 Jul.-Sept. *** *** *** *** -- 0 

 Oct.-Dec. *** *** *** *** -- 0 

2013: 

 Jan.-Mar. *** *** *** *** -- 0 

 Apr.-Jun. *** *** -- 0 -- 0 

 Jul.-Sept. *** *** -- 0 -- 0 

 Oct.-Dec. *** *** -- 0 -- 0 

2014: 

 Jan.-Mar. *** *** *** *** -- 0 

Period

Japan 

Price (dollars 

per ton)

Quantity 

(tons)

2011: 

 Jan.-Mar. -- 0 

 Apr.-Jun. -- 0 

 Jul.-Sept. -- 0 

 Oct.-Dec. -- 0 

2012: 

 Jan.-Mar. -- 0 

 Apr.-Jun. -- 0 

 Jul.-Sept. -- 0 

 Oct.-Dec. -- 0 

2013: 

 Jan.-Mar. *** *** 

 Apr.-Jun. *** *** 

 Jul.-Sept. -- 0 

 Oct.-Dec. -- 0 

2014: 

 Jan.-Mar. -- 0 1

 Product 5.-- Casing, Grade J-55, 8 5/8" O.D., 32.0 lbs./ft., threaded and coupled, range 3, welded. 

Source: Compiled from data submitted in response to Commission questionnaires.

 
E‐10

Table E-8 

OCTG: Weighted-average f.o.b. prices and quantities from nonsubject sources, product 6,1

 by 

quarters, January 2011-March 2014 

Period

Taiwan- Chung Hung Canada Germany

Price (dollars 

per ton) 

Quantity 

(tons)

Price (dollars 

per ton)

Quantity 

(tons)

Price (dollars 

per ton) 

Quantity 

(tons)

2011: 

 Jan.-Mar. *** *** *** *** -- 0 

 Apr.-Jun. -- 0 *** *** -- 0 

 Jul.-Sept. -- 0 *** *** -- 0 

 Oct.-Dec. *** *** 1,319 2,740 -- 0 

2012: 

 Jan.-Mar. -- 0 *** *** -- 0 

 Apr.-Jun. -- 0 *** *** -- 0 

 Jul.-Sept. -- 0 *** *** -- 0 

 Oct.-Dec. -- 0 *** *** *** *** 

2013: 

 Jan.-Mar. -- 0 *** *** *** *** 

 Apr.-Jun. -- 0 *** *** -- 0 

 Jul.-Sept. -- 0 *** *** *** *** 

 Oct.-Dec. -- 0 *** *** -- 0 

2014: 

 Jan.-Mar. -- 0 *** *** -- 0 

Period

Japan Mexico

Price (dollars 

per ton)

Quantity 

(tons)

Price (dollars 

per ton)

Quantity 

(tons)

2011: 

 Jan.-Mar. -- 0 -- 0 

 Apr.-Jun. -- 0 -- 0 

 Jul.-Sept. *** *** -- 0 

 Oct.-Dec. *** *** -- 0 

2012: 

 Jan.-Mar. -- 0 -- 0 

 Apr.-Jun. -- 0 -- 0 

 Jul.-Sept. -- 0 -- 0 

 Oct.-Dec. -- 0 -- 0 

2013: 

 Jan.-Mar. *** *** -- 0 

 Apr.-Jun. -- 0 -- 0 

 Jul.-Sept. *** *** *** *** 

 Oct.-Dec. -- 0 *** *** 

2014: 

 Jan.-Mar. -- 0 -- 0 1

 Product 6.-- Casing, Grade J-55, 9 5/8" O.D., 36.0 lbs./ft., threaded and coupled, range 3, welded. 

 

Source: Compiled from data submitted in response to Commission questionnaires.

 
E‐11

Figure E-1 

OCTG: Weighted-average f.o.b. prices and quantities of domestic and nonsubject sources, 

product 1, by quarter, January 2011-March 2014 

* * * * * * *

Figure E-2 

OCTG: Weighted-average f.o.b. prices and quantities of domestic and nonsubject sources, 

product 2, by quarter, January 2011-March 2014 

* * * * * * *

Figure E-3 

OCTG: Weighted-average f.o.b. prices and quantities of domestic and nonsubject sources, 

product 3, by quarter, January 2011-March 2014 

* * * * * * *

Figure E-4 

OCTG: Weighted-average f.o.b. prices and quantities of domestic and nonsubject sources, 

product 4, by quarter, January 2011-March 2014 

* * * * * * *

Figure E-5 

OCTG: Weighted-average f.o.b. prices and quantities of domestic and nonsubject sources, 

product 5, by quarter, January 2011-March 2014 

* * * * * * *

Figure E-6 

OCTG: Weighted-average f.o.b. prices and quantities of domestic and nonsubject sources, 

product 6, by quarter, January 2011-March 2014 

* * * * * * *

APPENDIX F

ALLEGED EFFECTS OF IMPORTS ON CAPITAL AND INVESTMENT

F-1

The Commission requested that U.S. producers of OCTG describe any actual or potential 

negative effects of imports of OCTG from India, Korea, Philippines, Saudi Arabia, Taiwan, 

Thailand, Turkey, Ukraine, and Vietnam on their firms’ growth, investment, ability to raise 

capital, development and production efforts, or the scale of capital investments. Their 

responses are shown below.

Actual negative effects1

Boomerang Tube: ***.

Drill Pipe International: ***.

EnergeX Tube: ***.

Evraz Rocky Mountain: ***.

Laguna Tubular Products: ***.

Maverick: ***. 

Northwest Pipe: ***.

Paragon Industries: ***.

Tejas Tubular: ***.

Texas Steel Conversion: ***.

Texas Tubular: ***.

TMK IPSCO: ***.

U.S. Steel: ***.

Vallourec Star: ***.

Welded Tube: ***.

Anticipated negative effects1

Boomerang Tube: ***.

Drill Pipe International: ***.

EnergeX Tube: ***.

Evraz Rocky Mountain: ***.

Laguna Tubular Products: ***.

Maverick: ***. 

Northwest Pipe: ***.

Paragon Industries: ***.

Tejas Tubular: ***.

Texas Steel Conversion: ***.

Texas Tubular: ***.

TMK IPSCO: ***.

U.S. Steel: ***.

Vallourec Star: ***. 

Welded Tube: ***.

1 When asked whether the firm’s response differed by country, ***.

F-3

 

G‐1

APPENDIX G

KEY TABLES FOR POST‐SAUDI ARABIA AMENDED NEGATIVE DETERMINATION

G‐3

Table G-1 (updated table IV-2) 

OCTG: U.S. imports, by source, 2011-13, January to March 2013, and January to March 2014 

Item 

Calendar year January to March 

2011 2012 2013 2013 2014 

 Quantity (short tons) 

U.S. imports from.-- 

 India *** *** *** *** ***

 Korea *** *** *** *** ***

 Turkey 140,806 151,576 133,773 24,217 34,158

 Ukraine *** *** *** *** ***

 Vietnam 56,697 219,997 144,871 31,876 2,757

 5 country subtotal *** *** *** *** ***

 Philippines 23,933 69,757 73,969 12,030 17,794

 Taiwan (subject) *** *** *** *** ***

 Thailand 6,135 31,833 33,741 3,424 11,911

 3 country subtotal *** *** *** *** ***

 8 country subtotal *** *** *** *** ***

 Saudi Arabia *** *** *** *** ***

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

 Subtotal *** *** *** *** ***

 Total imports 2,839,740 3,570,796 3,242,306 734,735 890,275

 Share of quantity (percent) 

U.S. imports from.-- 

 India *** *** *** *** ***

 Korea *** *** *** *** ***

 Turkey 5.0 4.2 4.1 3.3 3.8

 Ukraine *** *** *** *** ***

 Vietnam 2.0 6.2 4.5 4.3 0.3

 5 country subtotal *** *** *** *** ***

 Philippines 0.8 2.0 2.3 1.6 2.0

 Taiwan (subject) *** *** *** *** ***

 Thailand 0.2 0.9 1.0 0.5 1.3

 3 country subtotal *** *** *** *** ***

 8 country subtotal *** *** *** *** ***

 Saudi Arabia *** *** *** *** ***

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

 Subtotal *** *** *** *** ***

 Total imports 100.0 100.0 100.0 100.0 100.0

Notes continued on following page. 
G‐4

Source: Official imports statistics of the U.S. Department of Commerce using HTS statistical reporting 

numbers 7304.29.1010, 7304.29.1020, 7304.29.1030, 7304.29.1040, 7304.29.1050, 7304.29.1060, 

7304.29.1080, 7304.29.2010, 7304.29.2020, 7304.29.2030, 7304.29.2040, 7304.29.2050, 7304.29.2060, 

7304.29.2080, 7304.29.3110, 7304.29.3120, 7304.29.3130, 7304.29.3140, 7304.29.3150, 7304.29.3160, 

7304.29.3180, 7304.29.4110, 7304.29.4120, 7304.29.4130, 7304.29.4140, 7304.29.4150, 7304.29.4160, 

7304.29.4180, 7304.29.5015, 7304.29.5030, 7304.29.5045, 7304.29.5060, 7304.29.5075, 7304.29.6115, 

7304.29.6130, 7304.29.6145, 7304.29.6160, 7304.29.6175, 7305.20.2000, 7305.20.4000, 7305.20.6000, 

7305.20.8000, 7306.29.1030, 7306.29.1090, 7306.29.2000, 7306.29.3100, 7306.29.4100, 7306.29.6010, 

7306.29.6050, 7306.29.8110, and 7306.29.8150 with adjustments based on data submitted in response 

to Commission questionnaires. Official import statistics reported through to December 2013 reflect 

revisions available as of July 2014. 

Table G-2 (updated table IV-8) 

OCTG: U.S. imports by source and share of imports, July 2012 through June 2013 

* * * * * * * 

Table G-3 (table IV-8 augmented) 

OCTG: Monthly U.S. imports, January 2011 through March 2014 

* * * * * * * 

Table G-4 (updated table IV-10 -- updated to exclude Saudi Arabia) 

OCTG: U.S. importers' U.S. subject imports, by type, 2011-13, January to March 2013, and January to 

March 2014

* * * * * * * 
G‐5

Table G-5 (updated and augmented table IV-10 – 5 non-negligible sources) 

OCTG: U.S. importers' U.S. imports from India, Korea, Turkey, Ukraine, and Vietnam, by type, 2011-13, 

January to March 2013, and January to March 2014 

Item 

Calendar year January to March 

2011 2012 2013 2013 2014 

 Quantity (short tons) 

Finished OCTG 138,991 180,633 161,081 38,424 12,035

Unfinished OCTG.-- 

 Not at API 64,442 87,555 69,468 14,073 18,638

At API but upgradeable 243,089 251,722 276,150 64,242 69,790

At final API but needs end 

finishing 598,506 866,438 873,854 239,006 153,003

All others 28,107 27,411 13,607 4,649 512

Subtotal, unfinished OCTG 934,144 1,233,126 1,233,079 321,970 241,943

Total U.S. shipments 1,073,135 1,413,759 1,394,160 360,394 253,978

 Value (1,000 dollars) 

Finished OCTG 197,250 235,182 190,477 48,386 14,004

Unfinished OCTG.-- 

 Not at API 68,157 98,110 63,159 12,483 16,762

At API but upgradeable 275,676 268,904 260,652 66,961 64,161

At final API but needs end 

finishing 630,593 881,402 792,826 218,912 133,743

All others 35,846 34,860 14,710 5,666 494

Subtotal, unfinished OCTG 1,010,272 1,283,276 1,131,347 304,022 215,160

Total U.S. shipments 1,207,522 1,518,458 1,321,824 352,408 229,164

 Unit value (dollars per short ton) 

Finished OCTG 1,419 1,302 1,182 1,259 1,164

Unfinished OCTG.-- 

 Not at API 1,058 1,121 909 887 899

At API but upgradeable 1,134 1,068 944 1,042 919

At final API but needs end 

finishing 1,054 1,017 907 916 874

All others 1,275 1,272 1,081 1,219 965

Subtotal, unfinished OCTG 1,081 1,041 917 944 889

Total U.S. shipments 1,125 1,074 948 978 902

 Share of quantity (percent) 

Finished OCTG 13.0 12.8 11.6 10.7 4.7

Unfinished OCTG.-- 

 Not at API 6.0 6.2 5.0 3.9 7.3

At API but upgradeable 22.7 17.8 19.8 17.8 27.5

At final API but needs end 

finishing 55.8 61.3 62.7 66.3 60.2

All others 2.6 1.9 1.0 1.3 0.2

Subtotal, unfinished OCTG 87.0 87.2 88.4 89.3 95.3

Total U.S. shipments 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires. 
G‐6

Table G-6 (updated and augmented table IV-10 -- 3 negligible sources) 

OCTG: U.S. importers' U.S. imports from Philippines, Taiwan (subject), and Thailand, by type, 2011-13, January to 

March 2013, and January to March 2014 

* * * * * * * 

Table G-7 (updated table IV-11 -- updated to include Saudi Arabia) 

OCTG: U.S. importers' U.S. imports from all nonsubject sources, by type, 2011-13, January to March 2013, and 

January to March 2014 

* * * * * * * 

Table G-8 (updated table IV-15) 

OCTG: U.S. shipments of domestic product, U.S. imports, and apparent consumption, 2011-13, January to March 

2013, and January to March 2014 

Period changes 

Item 

Calendar year January to March Calendar year 

JanMar 

2011 2012 2013 2013 2014 

2011

-13 

2011

-12 

2012

-13 

2013-

14 

 Quantity (short tons) 

U.S. producers' U.S. shipments 3,135,876 3,387,771 3,736,381 870,703 950,579 19.1 8.0 10.3 9.2 

U.S. imports from.-- 

 India *** *** *** *** *** *** *** *** *** 

Korea *** *** *** *** *** *** *** *** *** 

Turkey 140,806 151,576 133,773 24,217 34,158 -5.0 7.6 -11.7 41.0 

Ukraine *** *** *** *** *** *** *** *** *** 

Vietnam 56,697 219,997 144,871 31,876 2,757 155.5 288.0 -34.1 -91.4 

5 country subtotal *** *** *** *** *** *** *** *** *** 

Philippines 23,933 69,757 73,969 12,030 17,794 209.1 191.5 6.0 47.9 

Taiwan (subject) *** *** *** *** *** *** *** *** *** 

Thailand 6,135 31,833 33,741 3,424 11,911 450.0 418.9 6.0 247.9 

3 country subtotal *** *** *** *** *** *** *** *** *** 

8 country subtotal *** *** *** *** *** *** *** *** *** 

Saudi Arabia *** *** *** *** *** *** *** *** *** 

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

Subtotal *** *** *** *** *** *** *** *** *** 

Total imports 2,839,740 3,570,796 3,242,306 734,735 890,275 14.2 25.7 -9.2 21.2 

Apparent U.S. consumption 5,975,616 6,958,567 6,978,687 1,605,438 1,840,854 16.8 16.4 0.3 14.7 

Table continued on next page. 
G‐7

Table G-8 (updated table IV-15)--Continued 

OCTG: U.S. shipments of domestic product, U.S. imports, and apparent consumption, 2011-13, January to March 

2013, and January to March 2014 

Period changes 

Item 

Calendar year January to March Calendar year 

JanMar 

2011 2012 2013 2013 2014 

2011

-13 

2011

-12 

2012

-13 

2013-

14 

 Value (1,000 dollars) 

U.S. producers' U.S. shipments.- 

 Mills' U.S. shipments 5,286,771 5,867,506 5,833,652 1,359,773 1,466,007 10.3 11.0 -0.6 7.8 

Processors' toll revenue/ 

 incremental value 160,655 218,147 264,793 61,864 69,767 64.8 35.8 21.4 12.8 

Total U.S. producer 

 contributions 5,447,426 6,085,653 6,098,445 1,421,637 1,535,774 12.0 11.7 0.2 8.0 

U.S. imports from.-- 

 India *** *** *** *** *** *** *** *** *** 

Korea *** *** *** *** *** *** *** *** *** 

Turkey 133,698 144,280 114,981 22,481 29,012 -14.0 7.9 -20.3 29.1 

Ukraine *** *** *** *** *** *** *** *** *** 

Vietnam 53,923 201,905 119,291 26,414 3,144 121.2 274.4 -40.9 -88.1 

5 country subtotal *** *** *** *** *** *** *** *** *** 

Philippines 21,542 64,567 60,391 9,784 13,739 180.3 199.7 -6.5 40.4 

Taiwan (subject) *** *** *** *** *** *** *** *** *** 

Thailand 8,053 43,815 39,752 4,593 16,280 393.6 444.1 -9.3 254.5 

3 country subtotal *** *** *** *** *** *** *** *** *** 

8 country subtotal *** *** *** *** *** *** *** *** *** 

Saudi Arabia *** *** *** *** *** *** *** *** *** 

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

Subtotal *** *** *** *** *** *** *** *** *** 

Total imports 3,981,070 5,053,876 3,997,131 952,338 1,067,990 0.4 26.9 -20.9 12.1 

Apparent U.S. consumption 9,428,496 11,139,529 10,095,576 2,373,975 2,603,764 7.1 18.1 -9.4 9.7 

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce statistics. Official import statistics 

reported through December 2013 reflect revisions available as of July 2014. 
G‐8

Table G-9 (updated table IV-16) 

OCTG: U.S. consumption and market shares, 2011-13, January to March 2013, and January to March 2014 

Period changes 

Item 

Calendar year January to March Calendar year 

JanMar 

2011 2012 2013 2013 2014 

2011

-13 

2011

-12 

2012

-13 

2013-

14 

 Quantity (short tons) 

Apparent U.S. consumption 5,975,616 6,958,567 6,978,687 1,605,438 1,840,854 16.8 16.4 0.3 14.7 

Market share based on quantity (percent) 

U.S. producers' U.S. shipments 52.5 48.7 53.5 54.2 51.6 1.1 -3.8 4.9 -2.6 

U.S. imports from.-- 

 India *** *** *** *** *** *** *** *** *** 

Korea *** *** *** *** *** *** *** *** *** 

Turkey 2.4 2.2 1.9 1.5 1.9 -0.4 -0.2 -0.3 0.3 

Ukraine *** *** *** *** *** *** *** *** *** 

Vietnam 0.9 3.2 2.1 2.0 0.1 1.1 2.2 -1.1 -1.8 

5 country subtotal *** *** *** *** *** *** *** *** *** 

Philippines 0.4 1.0 1.1 0.7 1.0 0.7 0.6 0.1 0.2 

Taiwan (subject) *** *** *** *** *** *** *** *** *** 

Thailand 0.1 0.5 0.5 0.2 0.6 0.4 0.4 0.0 0.4 

3 country subtotal *** *** *** *** *** *** *** *** *** 

8 country subtotal *** *** *** *** *** *** *** *** *** 

Saudi Arabia *** *** *** *** *** *** *** *** *** 

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

Subtotal *** *** *** *** *** *** *** *** *** 

Total imports 47.5 51.3 46.5 45.8 48.4 -1.1 3.8 -4.9 2.6 

Apparent U.S. consumption 52.5 48.7 53.5 54.2 51.6 1.1 -3.8 4.9 -2.6 

Table continued on next page. 
G‐9

Table G-9 (updated table IV-16)--Continued 

OCTG: U.S. consumption and market shares, 2011-13, January to March 2013, and January to March 2014 

Period changes 

Item 

Calendar year January to March Calendar year 

JanMar 

2011 2012 2013 2013 2014 

2011

-13 

2011

-12 

2012

-13 

2013-

14 

 Value ($1,000s) 

Apparent U.S. consumption 9,428,496 11,139,529 10,095,576 2,373,975 2,603,764 7.1 18.1 -9.4 9.7 

Market share based on quantity (percent) 

U.S. producers' U.S. shipments.- 

 Mills' U.S. shipments *** *** *** *** *** *** *** *** *** 

Processors' toll revenue/ 

 incremental value *** *** *** *** *** *** *** *** *** 

Total U.S. producer 

 contributions *** *** *** *** *** *** *** *** *** 

U.S. imports from.-- 

 India *** *** *** *** *** *** *** *** *** 

Korea *** *** *** *** *** *** *** *** *** 

Turkey 2.4 2.2 1.9 1.5 1.9 -0.4 -0.2 -0.3 0.3 

Ukraine *** *** *** *** *** *** *** *** *** 

Vietnam 0.6 1.8 1.2 1.1 0.1 0.6 1.2 -0.6 -1.0 

5 country subtotal *** *** *** *** *** *** *** *** *** 

Philippines 0.2 0.6 0.6 0.4 0.5 0.4 0.4 0.0 0.1 

Taiwan (subject) *** *** *** *** *** *** *** *** *** 

Thailand 0.1 0.4 0.4 0.2 0.6 0.3 0.3 0.0 0.4 

3 country subtotal *** *** *** *** *** *** *** *** *** 

8 country subtotal 14.3 16.3 15.8 16.6 16.0 1.4 1.9 -0.5 -0.5 

Saudi Arabia *** *** *** *** *** *** *** *** *** 

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

Subtotal *** *** *** *** *** *** *** *** *** 

Total imports 42.2 45.4 39.6 40.1 41.0 -2.6 3.1 -5.8 0.9 

Apparent U.S. consumption *** *** *** *** *** *** *** *** *** 

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce statistics. Official import statistics 

reported through December 2013 reflect revisions available as of July 2014. 
G‐10

Table G-10 (updated table V-13) 

OCTG: Instances of underselling/overselling and the range and average margins, all subject countries, 

grouped, January 2011-March 2014 

* * * * * * * 

Table G-11 (updated table VII-19 – updated to exclude Saudi Arabia) 

OCTG: Data for subject producers in India, Korea, Philippines, Taiwan, Thailand, Turkey, Ukraine, 

and Vietnam combined (mills only), 2011-13, January to March 2013, January to March 2014, and 

projected 2014 and 2015

* * * * * * * 

Table G-12 (updated and augmented table VII-19 – 5 non-negligible sources) 

OCTG: Data for subject producers in India, Korea, Turkey, Ukraine, and Vietnam combined (mills 

only), 2011-13, January to March 2013, January to March 2014, and projected 2014 and 2015

* * * * * * * 

Table G-13 (updated and augmented table VII-19 – 3 negligible sources) 

OCTG: Data for subject producers in Philippines, Taiwan, and Thailand combined (mills only), 

2011-13, January to March 2013, January to March 2014, and projected 2014 and 2015

* * * * * * * 

Table G-14 (updated table D-11--updated to exclude Saudi Arabia) 

OCTG: U.S. importers' U.S. shipments of OCTG from subject sources, by type and end finish, 2013

* * * * * * * 
G‐11

Table G-15 (updated and augmented D-11--5 non-negligible sources) 

OCTG: U.S. importers' U.S. shipments of OCTG from India, Korea, Turkey, Ukraine, and Vietnam, 

by type and end finish, 2013

Type 

Threaded and coupled Threaded not coupled 

Plain 

end 

Coupling 

stock Total 

Proprietary Not 

proprietary Proprietary Not proprietary 

 Quantity (short tons) 

Below API/limited service *** *** *** *** *** *** *** 

H-40 *** *** *** *** *** *** *** 

J-55 *** *** *** *** *** *** 927,354 

K-55 *** *** *** *** *** *** *** 

M-65 *** *** *** *** *** *** *** 

L-80 *** *** *** *** *** *** 177,130 

C-95 *** *** *** *** *** *** *** 

N-80, Type I *** *** *** *** *** *** *** 

N-80, Type II *** *** *** *** *** *** *** 

C-90 *** *** *** *** *** *** *** 

T-95 *** *** *** *** *** *** *** 

P-110 *** *** *** *** *** *** 141,573 

Q-125 *** *** *** *** *** *** *** 

Premium/proprietary *** *** *** *** *** *** *** 

Total reported U.S. shipments *** *** *** *** *** *** 1,357,238 

 Value (1,000 dollars) 

Below API/limited service *** *** *** *** *** *** *** 

H-40 *** *** *** *** *** *** *** 

J-55 *** *** *** *** *** *** 895,540 

K-55 *** *** *** *** *** *** *** 

M-65 *** *** *** *** *** *** *** 

L-80 *** *** *** *** *** *** 232,922 

C-95 *** *** *** *** *** *** *** 

N-80, Type I *** *** *** *** *** *** *** 

N-80, Type II *** *** *** *** *** *** *** 

C-90 *** *** *** *** *** *** *** 

T-95 *** *** *** *** *** *** *** 

P-110 *** *** *** *** *** *** *** 

Q-125 *** *** *** *** *** *** *** 

Premium/proprietary *** *** *** *** *** *** *** 

Total reported U.S. shipments *** *** *** *** *** *** 1,445,871 

Table continued on next page. 

 
G‐12

Table G-15 (updated and augmented D-11--5 non-negligible sources)--Continued 

OCTG: U.S. importers' U.S. shipments of OCTG from India, Korea, Turkey, Ukraine, and Vietnam, 

by type and end finish, 2013 

Type 

Threaded and coupled Threaded not coupled 

Plain 

end 

Coupling 

stock Total 

Proprietary Not 

proprietary Proprietary Not proprietary 

 Unit value (dollars per short ton) 

Below API/limited service *** *** *** *** *** *** *** 

H-40 *** *** *** *** *** *** *** 

J-55 *** *** *** *** *** *** 966 

K-55 *** *** *** *** *** *** *** 

M-65 *** *** *** *** *** *** *** 

L-80 *** *** *** *** *** *** 1,315 

C-95 *** *** *** *** *** *** *** 

N-80, Type I *** *** *** *** *** *** *** 

N-80, Type II *** *** *** *** *** *** *** 

C-90 *** *** *** *** *** *** *** 

T-95 *** *** *** *** *** *** *** 

P-110 *** *** *** *** *** *** 1,358 

Q-125 *** *** *** *** *** *** *** 

Premium/proprietary *** *** *** *** *** *** *** 

Total reported U.S. shipments *** *** *** *** *** *** 1,065 

 Share of quantity by end finish (percent) 

Below API/limited service *** *** *** *** *** *** *** 

H-40 *** *** *** *** *** *** *** 

J-55 *** *** *** *** *** *** 68.3 

K-55 *** *** *** *** *** *** *** 

M-65 *** *** *** *** *** *** *** 

L-80 *** *** *** *** *** *** 13.1 

C-95 *** *** *** *** *** *** *** 

N-80, Type I *** *** *** *** *** *** *** 

N-80, Type II *** *** *** *** *** *** *** 

C-90 *** *** *** *** *** *** *** 

T-95 *** *** *** *** *** *** *** 

P-110 *** *** *** *** *** *** 10.4 

Q-125 *** *** *** *** *** *** *** 

Premium/proprietary *** *** *** *** *** *** *** 

Total reported U.S. shipments *** *** *** *** *** *** 100.0 

Source: Compiled from data submitted in response to Commission questionnaires. 
G‐13

Table G-16 (updated and augmented D-11--3 negligible sources) 

OCTG: U.S. importers' U.S. shipments of OCTG from Philippines, Taiwan (subject), and Thailand, 

by type and end finish, 2013

* * * * * * * 

Table G-17 (updated D-12--updated to include Saudi Arabia) 

OCTG: U.S. importers' U.S. shipments of OCTG from nonsubject sources, by type and end finish, 

2013

* * * * * * * 

Table G-18 (updated table E-1) 

OCTG: Instances of nonsubject source underselling/overselling when compared with domestic 

prices, and the range and average margins, by source, January 2011-March 2014 

Nonsubject 

source

Number of 

quarters of 

underselling

Number of 

quarters of 

(overselling)

Margins of underselling Margins of (overselling)

Average 

(percent) 

Range (percent)

Average 

(percent)

Range (percent)

Min Max Min Max

 Taiwan 

(Chung Hung) 24 4 *** *** *** *** *** *** 

 Argentina 11 10 *** *** *** *** *** *** 

 Canada 25 16 *** *** *** *** *** *** 

 Germany 1 3 *** *** *** *** *** *** 

 Japan 1 5 *** *** *** *** *** *** 

 Mexico 4 9 *** *** *** *** *** *** 

 Saudi Arabia 9 4 *** *** *** *** *** *** 

 Subtotal 51 47 *** *** *** *** *** *** 

 Total 75 51 *** *** *** *** *** *** 

Note.-- When compared with prices of these specific OCTG products manufactured in the United States, OCTG 

imported from nonsubject sources (including Chung Hung in Taiwan and Saudi Arabia) was priced lower than 

domestically produced OCTG in 75 of 126 quarters of comparison (59.5 percent). 

Source: Compiled from data submitted in response to Commission questionnaires. 
G‐14

Table G-19 (updated table E-2) 

OCTG: Number of quarters that prices of domestic OCTG and OCTG imported from subject 

sources were lower and higher than nonsubject product prices 

Comparison 

country 

Number of quarters: 

Higher prices for OCTG from 

nonsubject sources 

Lower prices for OCTG from 

nonsubject sources 

United States 51 75 

India 9 4 

Korea 47 25 

Philippines 32 13 

Taiwan 44 20 

Thailand 12 2 

Turkey 49 24 

Ukraine 28 4 

Vietnam 39 9 

 Total 260 101 

Note.-- OCTG imported from subject sources was priced lower than OCTG imported from nonsubject sources 

(including Chung Hung in Taiwan and Saudi Arabia) in 260 of 361 possible comparisons (72.0 percent). 

Source: Compiled from data submitted in response to Commission questionnaires.