A-570-601 

POR: 6/1/2016 – 5/31/2017 

Proprietary Document Public Version 

E&C/Office II: IB 

August 24, 2017 

MEMORANDUM TO: Melissa G. Skinner 

Director, Office II 

 Antidumping and Countervailing Duty Operations 

THROUGH: Shawn Thompson 

 Program Manager, Office II 

 Antidumping and Countervailing Duty Operations 

FROM: Ibrahim Baig 

 International Trade Compliance Analyst, Office II 

 Antidumping and Countervailing Duty Operations 

RE: 30th Administrative Review of the Antidumping Duty Order on 

Tapered Roller Bearings and Parts Thereof, Finished and 

Unfinished, from the People’s Republic of China 

SUBJECT: Selection of Respondents for Individual Review 

I. Summary 

On August 1, 2017, the Department of Commerce (the Department) initiated an administrative 

review of the antidumping duty order on tapered roller bearings and parts thereof, finished and 

unfinished (TRBs) from the People’s Republic of China (PRC).1

 The period of review (POR) is 

June 1, 2016, through May 31, 2017. 

The administrative review covers 24 companies.2 Due to the large number of companies for 

which a review has been initiated, we find that it is not practicable to calculate an individual 

weighted-average dumping margin for each of these companies. The Department’s resources 

reasonably permit individual examination of two respondents, and, thus, we recommend limiting 

the number of respondents to the two exporters accounting for the largest volume of subject 

merchandise during the POR. 

 

1 See Initiation of Antidumping and Countervailing Duty Administrative Reviews, 82 FR 35749 (August 1, 2017) 

(Initiation Notice). 

2

 The Initiation Notice unintentionally excluded the company Honour Lane Shipping Ltd. (Honour Lane), for which 

a review was requested by the petitioners. We are including Honour Lane in the total number of companies for 

which the review was initiated and will list Honour Lane in the next initiation notice, set to publish on or about 

September 1, 2017. 

Barcode:3611035-01 A-570-601 REV - Admin Review 6/1/16 - 5/31/17 

Filed By: Andrew Medley, Filed Date: 8/24/17 10:46 AM, Submission Status: Approved
2 

Background: 

On June 15, 1987, the Department published in the Federal Register the antidumping duty order 

on TRBs from the PRC.3

 On June 7, 2017, the Department published a notice of opportunity to 

request an administrative review of the TRBs Order.

4

 In June 2017, we received timely requests 

for review from The Timken Company, the petitioner in this proceeding, and from numerous 

exporters and importers of subject merchandise. The Department initiated an administrative 

review of the TRBs Order on 23 listed companies on August 1, 2017.5 

In the Initiation Notice, the Department notified the public that it may limit the number of 

respondents for individual examination in this administrative review and that, in such case, the 

Department intends to select respondents based on U.S. Customs and Border Protection (CBP) 

data for entries of subject merchandise into the United States during the POR. On August 3, 

2017, the Department released CBP import data under administrative protective order (APO) to 

all interested parties with APO access and requested comments on the CBP import data and 

respondent selection in this review.6 On August 8, 2017, the Department received timelysubmitted comments on the CBP import data from the petitioner. In its comments, the petitioner 

stated that the Department should select Changshan Peer Bearing Co., Ltd (CPZ/SKF) and 

Luoyang Bearing Corp. Group (Luoyang) as mandatory respondents because they were the 

largest exporters of TRBs during the POR.7 

II. Respondent Selection 

For the reasons set forth below, we determine that it is not practicable to examine each exporter 

of TRBs from the PRC for which an administrative review has been initiated. 

Issue 1: Limiting Examination to a Reasonable Number of Companies 

Applicable Legal Provisions 

Section 777A(c)(1) of the Tariff Act of 1930, as amended (the Act), directs the Department to 

calculate an individual weighted-average dumping margin for each known exporter and producer 

of the subject merchandise. However, section 777A(c)(2) of the Act states: 

 

3 See Notice of Antidumping Duty Order: Tapered Roller Bearings and Parts Thereof, Finished or Unfinished, 

From the People’s Republic of China, 52 FR 22667 (June 15, 1987) (TRBs Order). 

4 See Antidumping or Countervailing Duty Order, Finding, or Suspended Investigation; Opportunity To Request 

Administrative Review, 82 FR 26441 (June 7, 2016). 

5 See Initiation Notice, 82 FR at 35751. As noted above, the Initiation Notice unintentionally excluded Honour 

Lane. We correct this omission and include Honour Lane in the next initiation notice, set to publish on or about 

September 1, 2017. 

6 See Memorandum, “2016-2017 Antidumping Duty Administrative Review: Tapered Roller Bearings and Parts 

Thereof, Finished and Unfinished, from the People’s Republic of China: Release of Customs Entry Data from the 

U.S. Customs and Border Protection,” dated August 3, 2017 (AR 30 CBP Data Memo). 

7 See Petitioner’s Letter, “Administrative Review of the Antidumping Duty Order on Tapered Roller Bearings and 

Parts Thereof, Finished and Unfinished, from the People’s Republic of China (06/01/16-05/31/17): The Timken 

Company’s Respondent Selection Comments,” dated August 8, 2017, at 2-3. 

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Filed By: Andrew Medley, Filed Date: 8/24/17 10:46 AM, Submission Status: Approved
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If it is not practicable to make individual weighted average dumping margin 

determinations... because of the large number of exporters or producers involved in 

the investigation or review, the administering authority may determine the weighted 

average dumping margins for a reasonable number of exporters or producers by 

limiting its examination to: 

(A) a sample of exporters, producers, or types of products that is statistically valid 

based on the information available to the administering authority at the time 

of selection, or 

(B) exporters or producers accounting for the largest volume of the subject 

merchandise that can be reasonably examined. 

In considering what constitutes a large number of producers and exporters as part of selecting 

respondents for this antidumping duty administrative review, the Department carefully considers 

its resources, including its current and anticipated workload and deadlines coinciding with those 

in the applicable segment of the proceeding in question. 

Analysis: 

As noted above, section 777A(c)(1) of the Act directs the Department to calculate an individual 

weighted-average dumping margin for each known exporter and producer of the subject 

merchandise. However, where it is not practicable to examine all known producers and 

exporters of subject merchandise “because of the large number of exporters and producers 

involved in the investigation or review,” section 777A(c)(2) of the Act gives the Department the 

authority to determine weighted-average dumping margins for a reasonable number of exporters 

or producers by limiting its examination through either a sampling of exporters, producers, or 

types of products, or selecting the exporters or producers accounting for the largest volume of 

subject merchandise that can reasonably be examined. 

The Department carefully considered its available resources, the number of exporters or 

producers subject to this review, and the complexities expected to arise in this review. Based on 

this analysis, we find that there are a large number of companies to review individually and that 

it would not be “practicable” in this administrative review to determine an individual weightedaverage dumping margin for each exporter or producer for which a review was initiated. 

Reviewing all exporters or producers would require significant resources because it would 

require the Department to analyze each company’s corporate structure, accounting and selling 

practices, and production information. Given our current and anticipated workload, this office 

does not have the resources to examine all exporters or producers of the subject merchandise 

initiated for review. This office is conducting numerous investigations and reviews in concurrent 

antidumping and countervailing duty proceedings, each of which consumes a substantial amount 

Barcode:3611035-01 A-570-601 REV - Admin Review 6/1/16 - 5/31/17 

Filed By: Andrew Medley, Filed Date: 8/24/17 10:46 AM, Submission Status: Approved
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of resources and constrains the number of analysts assigned to the instant case.8

 Additionally, 

other offices within Enforcement and Compliance do not have additional resources to assist 

Office II with its workload. Accordingly, the Department has reasonably determined, based on 

its available resources, that there are a large number of companies involved in the review and 

that it is not practicable to calculate individual weighted-average dumping margins for all 

respondents under review. 

Recommendation: 

Consistent with section 777A(c)(2) of the Act, given the large number of exporters or producers 

of TRBs from the PRC, and the Department’s current resource constraints, we recommend 

limiting the individual examination of the exporters or producers of subject merchandise in this 

review. 

 √ 

__________ ____________ 

Agree Disagree 

Issue 2: Selection of Respondents for Examination

Applicable Statutory Provision 

Section 777A(c)(2) of the Act gives the Department discretion to limit the number of exporters 

or producers individually examined if it is not practicable to examine all exporters and producers 

involved an administrative review.9 Section 777A(c)(2) of the Act gives the Department the 

authority to limit its examination through either a statistically valid sampling of exporters, 

producers, or types of products, or by selecting the exporters or producers accounting for the 

largest volume of the subject merchandise that can reasonably be examined. The Statement of 

Administrative Action accompanying the Uruguay Round Agreements Act (the SAA) interprets 

this provision to mean that the authority to select respondents, whether by using a “statistically 

valid” sample or by examining respondents accounting for the largest volume of subject 

merchandise, rests exclusively with the Department.10

 

8

 Examples include, but are not limited to: 100- to 150-Seat Large Civil Aircraft from Canada, Low Melt Polyester 

Staple Fiber from Korea and Taiwan; Tapered Roller Bearings from Korea; Silicon Metal from Kazakhstan and 

Norway; Carbon and Alloy Steel Wire Rod from Belarus and the United Kingdom; Frozen Warmwater Shrimp from 

India; TRBs from the PRC; Drawn Stainless Steel Sinks from the PRC; Narrow Woven Ribbons from the PRC and 

Taiwan; Large Residential Washers from Mexico and Korea, Anticircumvention Inquiry of Uncoated Paper from 

Australia, Brazil, Indonesia, Portugal, and the PRC; and Welded Line Pipe from Korea and Turkey. 

9 See also 19 CFR 351.204(c). 

10 See SAA, H.R. Doc. No. 103-316, vol. 1 at 872 (1994). 

Barcode:3611035-01 A-570-601 REV - Admin Review 6/1/16 - 5/31/17 

Filed By: Andrew Medley, Filed Date: 8/24/17 10:46 AM, Submission Status: Approved
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Arguments by the Petitioner 

The petitioner requests that the Department select CPZ/SKF and Luoyang as mandatory 

respondents because they were the two respondents with the largest volume of entries of subject 

merchandise during the POR.11 

Analysis: 

In cases where the Department limits its examination of respondents, section 777A(c)(2) of the 

Act provides the Department with discretion to choose respondents for individual examination 

by selecting either a statistically-valid sample or the exporters or producers accounting for the 

largest volume of subject merchandise that can reasonably be examined. No party has argued 

that the Department should select respondents in this administrative review pursuant to 

777A(c)(2)(A) of the Act, (i.e., based on sampling). Therefore, we are selecting respondents 

accounting for the largest volume of subject merchandise that can be reasonably examined, 

consistent with section 777A(c)(2)(B) of the Act. 

After an analysis of the data received, consideration of the comments submitted by the petitioner, 

and an assessment of available resources for conducting this review, including our current and 

anticipated workload and the complexities anticipated to arise in this case, we recommend 

limiting our examination to two companies accounting for the largest volume of entries of 

subject merchandise during the POR, according to CBP data. An individual examination of the 

two largest exporters or producers by volume of entries of subject merchandise during the POR 

will allow us to balance our resource constraints and capture the largest volume of subject 

merchandise in this administrative review that can be reasonably examined. See Attachment. 

In considering the CBP data in conjunction with the information which has been submitted 

regarding eligibility for separate rates, the two companies, in alphabetical order, which account 

for the largest volume of subject merchandise during the POR are CPZ/SKF and Luoyang.

Recommendation: 

Considering the factors described above, we recommend selecting the two exporters or producers 

accounting for the largest volume of subject merchandise as our mandatory respondents in this 

administrative review, in accordance with section 777A(c)(2)(B) of the Act. Specifically, we 

recommend selecting, in alphabetical order, CPZ/SKF and Luoyang for individual review. 

 √ 

__________ ____________ 

Agree Disagree 

 

11 See AR 30 CBP Data Memo. See also the Attachment to this memorandum. 

Barcode:3611035-01 A-570-601 REV - Admin Review 6/1/16 - 5/31/17 

Filed By: Andrew Medley, Filed Date: 8/24/17 10:46 AM, Submission Status: Approved
6 

Issue 3: Voluntary Respondents 

Applicable Statutory Provision 

When the Department limits the number of exporters examined in an investigation, section 

782(a) of the Act directs the Department to calculate individual weighted-average dumping 

margins for companies not initially selected for examination who voluntarily provide 

information if: 1) the information is submitted by the due date specified for exporters initially 

selected for examination; and 2) the number of such companies voluntarily providing 

information is not so large that any additional individual examination of these companies would 

be unduly burdensome and inhibit the timely completion of the investigation.12 

Analysis 

The Department has received a request to be a voluntary respondent from GGB Bearing 

Technology (Suzhou) Co., Ltd. (GGB).13 If any company wishes to be considered as a voluntary 

respondent and meets the requirements of section 782(a) of the Act and 19 CFR 351.204(d), the 

Department will consider whether to examine it as a voluntary respondent later in the 

proceeding. 

Recommendation 

If a voluntary respondent meets the requirements of section 782(a) of the Act and 19 CFR 

351.204(d), we recommend evaluating the circumstances during the course of the review to 

determine whether we may examine another respondent in addition to the two mandatory 

respondents identified above. 

 √ 

__________ _______________ 

Agree Disagree 

_________________________________________ 

Melissa G. Skinner 

Director, Office II 

 Antidumping and Countervailing Duty Operations 

August 24, 2017 

_________________________________________ 

 Date 

 

12 Recent amendments to the Tariff Act of 1930 contained in Section 506 of the Trade Preferences Act of 2015, 

Public Law 114-27, apply to voluntary respondent determinations; see also Dates of Application of Amendments to 

the Antidumping and Countervailing Duty Law Made by the Trade Preferences Extension Act of 2015, 80 FR 46793 

(August 6, 2015) (explaining the dates of application for these amendments). 

13 See GGB’s August 3, 2017, Request for Voluntary Respondent Status Letter. 

Barcode:3611035-01 A-570-601 REV - Admin Review 6/1/16 - 5/31/17 

Filed By: Andrew Medley, Filed Date: 8/24/17 10:46 AM, Submission Status: Approved
Attachment 

Business Proprietary Information Subject to APO 

CBP Data, by Volume, for Companies Subject to This Review 

Exporter 

 Imports 

(Pieces) 

Percent 

of Total 

Apex Maritime Shanghai Co Ld [ ] 

Changshan Peer Bearing Co., Ltd [ ] 

CNH Industrial Italia SpA [ ] 

Crossroads Global Trading Co Ltd [ ] 

GGB Bearing Technology (Suzhou) Co., Ltd [ ] 

GSP Automotive Group Wenzhou Co., Ltd [ ] 

Hangzhou Hanji Auto Parts Co., Ltd [ ] 

Hangzhou Radical Energy-Saving Technology Co., Ltd [ ] 

Hangzhou Xiaoshan Dingli Machinery Co Ltd [ ] 

Honour Lane Shipping Ltd. [ ] 

Hubei New Torch Science & Technology Co Ltd [ ] 

Kinetsu World Express China Co Ltd [ ] 

Luoyang Bearing Corp. Group [ ] 

Ningbo Xinglun Bearing Import & Export Co Ltd [ ] 

Pacific Link Intl Freight Forwarding Co Ltd [ ] 

Shanghai Dizhao Industrial Trading Co Ltd [ ] 

Shanghai General Bearing Co., Ltd [ ] 

Thi Group Shanghai Ltd [ ] 

Wanxiang Group Corp [ ] 

Weifang Haoxin-Conmet Mechanical Products Co Ltd [ ] 

Yantai Huilong Machinery Parts Co Ltd [ ] 

Zhejiang Machinery Import & Export Corp [ ] 

Zhejiang Sihe Machine Co Ltd [ ] 

Zhejiang Zhaofeng Mechanical & Electronic Co., Ltd [ ] 

 [ ] 

Barcode:3611035-01 A-570-601 REV - Admin Review 6/1/16 - 5/31/17 

Filed By: Andrew Medley, Filed Date: 8/24/17 10:46 AM, Submission Status: Approved