Fluid End Blocks: New AD/CVD Investigations Deadlines & Scope

The International Trade Commission will conduct a concurrent investigation to determine whether imports of dumped and illegally subsidized forged steel fluid end blocks are injuring U.S. industry. If the ITC finds no injury in its preliminary injury determinations, due Feb. 3, the investigations will immediately end. If Commerce finds dumping or illegal subsidization in the preliminary determinations of these investigations, currently due in March for CV duties and May for AD duties, it will set AD and/or CV duty cash deposit requirements for imports of merchandise subject to the investigation. If both Commerce and the ITC reach affirmative final determinations, Commerce will issue an AD and/or CV duty order making duties permanent and beginning a process of annual administrative reviews to set final assessments of AD/CV duties on importers and potentially change AD/CV duty cash deposit rates.

Fluid end blocks are currently covered by Section 301 tariffs when imported from China. Subheadings 7326.19.00, 7326.90.86 and 8413.91.90 are subject to a 25 percent duty, while subheadings 7218.91.00, 7218.99.00, 7224.90.00 and 7224.90.00 are subject to a 15% duty (set to fall to 7.5% at an as-yet-unannounced date (see 1912130035).

AD/CVD Respondent Selection

Commerce said it will pick respondents for its AD/CV investigations on Germany and Italy, as well as its CV duty investigation on China, based on responses to quantity and value questionnaires to each potential respondent. German, Italian and Chinese exporters that don't receive a quantity and value questionnaire can still submit one by obtaining a questionnaire from the Commerce website. Responses are due Jan. 21.

For its AD/CV duty investigations on India, Commerce intends to select Bharat Forge Limited and Ultra Engineers as the sole respondents.

Scope of the AD/CVD Investigations

The products covered by these investigations are forged steel fluid end blocks (fluid end blocks), whether in finished or unfinished form, and which are typically used in the manufacture or service of hydraulic pumps.

The term “forged” is an industry term used to describe the grain texture of steel resulting from the application of localized compressive force. Illustrative forging standards include, but are not limited to, American Society for Testing and Materials (ASTM) specifications A668 and A788.

For purposes of these investigations, the term “steel” denotes metal containing the following chemical elements, by weight: (i) iron greater than or equal to 60 percent; (ii) nickel less than or equal to 8.5 percent; (iii) copper less than or equal to 6 percent; (iv) chromium greater than or equal to 0.4 percent, but less than or equal to 20 percent; and (v) molybdenum greater than or equal to 0.15 percent, but less than or equal to 3 percent. Illustrative steel standards include, but are not limited to, American Iron and Steel Institute (AISI) or Society of Automotive Engineers (SAE) grades 4130, 4135, 4140, 4320, 4330, 4340, 8630, 15-5, 17-4, F6NM, F22, F60 and XM25, as well as modified varieties of these grades.

The products covered by these investigations are: (1) cut-to-length fluid end blocks with an actual height (measured from its highest point) of 8 inches (203.2 mm) to 40 inches (1,016.0 mm), an actual width (measured from its widest point) of 8 inches (203.2 mm) to 40 inches (1,016.0 mm), and an actual length (measured from its longest point) of 11 inches (279.4 mm) to 75 inches (1,905.0 mm); and (2) strings of fluid end blocks with an actual height (measured from its highest point) of 8 inches (203.2 mm) to 40 inches (1,016.0 mm), an actual width (measured from its widest point) of 8 inches (203.2 mm) to 40 inches (1,016.0 mm), and an actual length (measured from its longest point) up to 360 inches (9,144.0 mm).

The products included in the scope of these investigations have a tensile strength of at least 70 KSI (measured in accordance with ASTM A370) and a hardness of at least 140 HBW (measured in accordance with ASTM E10).

A fluid end block may be imported in finished condition (i.e., ready for incorporation into a pump fluid end assembly without further finishing operations) or unfinished condition (i.e., forged but still requiring one or more finishing operations before it is ready for incorporation into a pump fluid end assembly). Such finishing operations may include: (1) heat treating; (2) milling one or more flat surfaces; (3) contour machining to custom shapes or dimensions; (4) drilling or boring holes; (5) threading holes; and/or (6) painting, varnishing, or coating.

The products included in the scope of these investigations may enter under Harmonized Tariff Schedule of the United States (HTSUS) subheadings 7218.91.0030, 7218.99.0030, 7224.90.0015, 7224.90.0045, 7326.19.0010, 7326.90.8688 or 8413.91.9055. While these HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of the investigations is dispositive.

Comments on the scope of these investigations are due Jan. 28.

Investigations Timetable

*If the ITC makes a negative determination of injury, the investigations are terminated.

†These deadlines may be extended under the governing statute.

‡This will take place only in the event of Commerce Department final affirmative determinations.

+This will take place only in the event of Commerce and ITC final affirmative determinations.

The Commerce Department fact sheet on the initiation of these investigations is (here).

(See 1912230021 for a summary of the petition that requested this investigation.)

(Federal Register 01/15/20)