April 20, 2020 – On April 16, 2020, Insteel Wire Products, Sumiden Wire Products Corporation, and Wire Mesh Corp. (“Petitioners”) filed petitions with the U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”).  Petitioners seek antidumping (“AD”) duties on imports of Prestressed Concrete Steel Wire Strand from Argentina, Colombia, Egypt, Indonesia, Italy, Malaysia, Netherlands, Saudi Arabia, South Africa, Spain, Taiwan, Tunisia, Turkey, Ukraine, and United Arab Emirates, as well as countervailing duties (“CVDs”) on imports from Turkey.

Under U.S. law, a domestic industry can petition the government to initiate an AD investigation into the pricing of an imported product to determine whether it is sold in the United States at less than fair value (i.e., “dumped”).  A domestic industry can also petition for the initiation of a CVD investigation into alleged subsidization of foreign producers by a foreign government.  Additional duties can be imposed if DOC determines that imported goods are “dumped” and/or subsidized and if the ITC also determines that the domestic industry is materially injured or threatened with such injury by reason of subject imports.

If the ITC and DOC make preliminary affirmative determinations, U.S. importers will be required to post cash deposits in the amount of the AD and/or CVD duties for all entries on or after the date DOC’s preliminary determination is published in the Federal Register.  The preliminary AD/CVD rates can change in the final DOC determination, especially if foreign producers and their governments participate fully in the investigations.


The merchandise covered by this Petition is prestressed concrete steel wire strand (“PC strand”). PC strand consists of multiple steel wires (non-stainless and non-galvanized) wound together to produce a strong, flexible product used to strengthen prestressed concrete structures.  PC strand includes all types, grades, and diameters, and both covered and uncovered product.

The petitions explain that product subject to these new cases is the same as the product currently subject to a 1978 order against Japan; 2004 orders against Brazil, India, Korea, Mexico, and Thailand; and 2010 orders against China – following a trend of multiple petitions on the same product from an expanding list of countries.

Foreign Producers and Exporters of Subject Merchandise

A list of foreign producers and exports, as identified by the Petitioners, is provided in Attachment 1

U.S. Importers of Subject Merchandise

A list of U.S. importers, as identified by the Petitioners, is provided in Attachment 2

Alleged Dumping Margins and Subsidy Rates

Petitioners allege the following dumping margins:

Argentina 60.40%
Colombia 85.95%
Egypt 29.91%
Indonesia 72.28%
Italy 30.61%
Malaysia 40.05%
Netherlands 30.86%
Saudi Arabia 194.40%
South Africa 155.10%
Spain 38.57%
Taiwan 23.89%
Tunisia 53.22%
Turkey 53.65%
United Arab Emirates 174.46% 
Ukraine 17.7 - 53.83%

No specific subsidy rates are included in the petition. 

DOC generally assigns the alleged dumping rates or adverse subsidy rates to exporters that fail to cooperate with the investigation.

Potential Trade Impact

According to the petition, $108 million of PC strand was imported into the United States in 2019, broken down by country as follows:

Malaysia  $26,090,500
Spain  $15,583,467
Turkey  $13,082,835
Italy  $10,185,049
Tunisia  $9,899,657
Colombia  $9,572,086
South Africa  $6,722,081
Indonesia  $5,379,607
Taiwan  $2,976,345
Argentina  $2,295,376
United Arab Emirates  $2,272,312
Netherlands  $1,619,809
Saudi Arabia  $1,378,312
Ukraine  $986,525
Egypt  $345,888

Estimated Schedule of Investigations

4/16/2020 – Petition filed
5/31/2020 – ITC preliminary injury determination
7/10/2020 – DOC preliminary CVD determination, if not postponed
9/13/2020 – DOC preliminary CVD determination, if fully postponed
9/23/2020 – DOC preliminary AD determination, if not postponed
11/12/2020 – DOC preliminary AD determination, if fully postponed
4/3/2021 – DOC final AD and CVD determinations, if both preliminary and final determinations are fully postponed
5/25/2021 – ITC final injury determination, if DOC’s determinations are fully postponed
6/1/2021 – AD/CVD orders published

In an effort to prevent the spread of the Coronavirus, DOC and ITC have issued revised procedures for AD/CVD proceedings.  Cases are proceeding along typical timelines, but neither agency is holding in-person hearings or conferences.

If you have any questions about the petitions, please contact the experienced attorneys in HHR’s international trade group.