Any Coating for Artist Materials Makes Canvas Subject to AD Duties, Commerce Says
Canvas that is coated or primed to promote the adherence of artist materials such as paint or ink is subject to the antidumping duty order on artist canvas from China (A-570-899), regardless of the formula of the coating and whether it can be called “gesso,” the Commerce Department said in a scope ruling issued Sept. 29.
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The ruling concerned polyester fabrics imported by RV Print Factory that had been coated with ethylene-vinyl acetate to create a fabric called EVACPET. Amide lubricants, mineral oil, titanium dioxide, silicon dioxide and calcium carbonate were also included in the coating. The fabrics were coated on one side and imported in rolls of various lengths with no designs. The imported fabric may be framed or printed on as a décor.
The scope of the AD order on artist canvas covers canvases “that have been primed/coated,” where “priming/coating includes the application of a solution, designed to promote the adherence of artist materials, such as paint or ink, to the fabric.”
“The record evidence demonstrates that EVACPET is an artist canvas, as defined by the language of the scope,” Commerce said. “Specifically, EVACPET is primed/coated ‘for the purpose of converting a fabric into a canvas.’ The priming/coating ‘is required to stiffen the fabric … giving it the stiffness properties of a canvas’ and ‘provides whiteness and higher opacity to the translucent polyester fabric,’” the agency said.
While Commerce has previously found application of a gesso “is synonymous with priming/coating a canvas,” no specific gesso formula is the “exclusive priming/coating solution required of subject artist canvas,” Commerce said. “Notably, the scope language does not include the word ‘gesso’ or specify any limitations to the scope based on the particular formula of the priming/coating used.”
Evidence shows RV Print’s EVACMET coating is “for a graphical purpose and prepares the canvas to receive ink,” Commerce said. Commerce has previously found that printable canvases are subject to the scope of AD duties, and as “evidence suggests that the EVACPET primer/coating’s purpose is to prepare the canvas to receive ink printing,” Commerce found RV Print’s canvas subject to AD duties.