New Trade Case on Imports of Cast Iron Soil Pipe from China

By Mark R. Ludwikowski / Jan 31, 2018

New US antidumping (AD) and countervailing duty (CVD) petitions were filed on January 25 against imports of cast iron soil pipe from China.  

Cast iron soil pipe and fittings are used primarily in building construction for sanitary and storm drain, waste, and vent (DWV) piping applications. The product is installed in residential construction, hospitals, schools, and in commercial and industrial structures. According to the petition, the pattern of cast iron soil pipe shipments and sales is directly related to the pattern of building/construction activity.

The Department of Commerce and the International Trade Commission (ITC) will next determine whether to launch AD and/or CVD duty and injury investigations, respectively, on these products. Commerce will be responsible for calculating the ultimate AD/CVD margins on the imports, while the ITC will conduct a concurrent investigation to determine if the imports are injuring the U.S. industry. If Commerce finds dumping or unfair subsidization in its preliminary determinations, currently scheduled for April 20, 2018 (CVD) and July 5, 2018 (AD), importers will be charged the calculated duties upon the products’ entry in the U.S. market.

There are strict statutory deadlines associated with these proceedings and affected companies are advised to prepare as soon as possible. If this product is of interest to you, please let us know so that we can provide you with additional information as it becomes available.

The following are key facts about this trade case:

Petitioner: Cast Iron Soil Pipe Institute (CISPI). Members of CISPI include: AB&I Foundry of Oakland, CA; Charlotte Pipe & Foundry of Charlotte, NC; and Tyler Pipe, of Tyler, TX.

Foreign Producers/Exporters and US Importers: Please contact us for a listing of individual companies named in the petition.

Alleged AD and CVD margins: Petitioners have alleged the following AD margins: 238.13%

Petitioners have also alleged CVD margins above de minimis based on various subsidy programs from the government of China.  

Merchandise covered by the scope of the case: The merchandise covered by this investigation is cast iron soil pipe, whether finished or unfinished, regardless of industry or proprietary specifications, and regardless of wall thickness, length, diameter, surface finish, end finish, or stenciling. The scope of this investigation includes, but is not limited to, both hubless and hub and spigot cast iron soil pipe. Cast iron soil pipe is nonmalleable iron pipe of various designs and sizes. Cast iron soil pipe is generally distinguished from other types of nonmalleable cast iron pipe by the manner in which it is connected to cast iron soil pipe fittings.

Cast iron soil pipe is classified into two major types – hubless and hub and spigot. Hubless cast iron soil pipe is manufactured without a hub, generally in compliance with Cast Iron Soil Pipe Institute (“CISPI”) specification 301 and/or American Society for Testing and Materials (“ASTM”) specification A888. Hub and spigot pipe has one or more hubs into which the spigot (plain end) of a fitting is inserted. All pipe meeting the physical description set forth above is covered by the scope of this investigation, whether or not produced according to a particular standard.

The subject imports are currently classified in subheading 7303.00.0030 of the Harmonized Tariff Schedule of the United States (HTSUS): Cast iron soil pipe. The HTSUS subheading and specifications are provided for convenience and customs purposes only; the written description of the scope of this investigation is dispositive.

If you have any questions regarding the content of this alert, please contact Mark Ludwikowski (mludwikowski@clarkhill.com; 202-640-6680) or another member of Clark Hill's International Trade Practice Group.