New Trade Case on Imports of Steel Propane Cylinders from China, Taiwan and Thailand

By Mark R. Ludwikowski / May 23, 2018

New US antidumping (AD) and countervailing (CVD) duty investigations were filed on May 21, 2018 by Worthington Industries and Manchester Tank & Equipment Co. (petitioners) against imports of steel propane cylinders from China, Taiwan and Thailand.

Steel propane cylinders consist of steel cylinders for compressed or liquefied propane gas, meeting certain U.S. Department of Transportation requirements, and ranging from 2.5 pounds capacity (approximately 4-6 pound tare weight) to 40 pounds capacity (approximately 28-32 pound tare weight). 

The petition includes AD (less than fair value) allegations against China, Taiwan and Thailand, and CVD (unfair subsidy) allegations against China.

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 August 14, 2018 (CVD) and October 28, 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: Worthington Industries and Manchester Tank & Equipment Co.

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

Alleged AD and CVD margins:  Petitioner has alleged the following AD margins:

  • China –   from 60.33 percent to 100.66 percent
  • Taiwan –  from 27.19 percent to 62.48 percent
  • Thailand –  from 36.18 percent to 109.20 percent.

Petition has alleged CVD margins for China above de minimis.

Merchandise covered by the scope of the case: The merchandise covered by this investigation is steel cylinders for compressed or liquefied propane gas meeting the requirements of, or produced to meet the requirements of, U.S. Department of Transportation (“USDOT”) specifications 4BA or 4BW.  The subject imported propane cylinders may be certified to USDOT Specification 4BA or 4BW either before or after importation.  The subject steel propane cylinders are portable and range from 2.5 pounds capacity (approximate 28-32 tare weight) to 40 pounds capacity (approximate 28-32 pound tare weight).  Steel propane cylinders have a single port and may be imported assembled or unassembled (i.e. welded or brazed before or after importation), with or without all components (including collars, valves, tanks, foot rings, and overfill preventers), and coated or uncoated.  These petitions cover steel and valves suitable for use with barbeque grills, heaters, and recreational vehicles, among other uses.  Also included within the scope are parts of steel propane cylinders, unfinished propane cylinders, collars, and foot rings for steel propane cylinders.

Specifically excluded are steel propane cylinders with more than one port, designed for use with forklifts, commercial lawn movers, and other small industrial vehicles.  These excluded cylinders are typically elongated and have a full ring collar.  Also excluded are seamless steel propane cylinders and propane cylinders made of stainless steel (i.e. steel containing at least 10.5 percent chromium by weight and less than 1.2 percent carbon by weight), aluminum, and composite material.

The merchandise subject to these orders is properly classified under statistical reporting numbers 7311.00.0060 and 7311.00.0090 of the Harmonized Tariff Schedule of the United States (HTSUS).  Although the HTSUS statistical reporting numbers are provided for convenience and customs purposes, the written description of the merchandise 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.