New Trade Petitions Target Georgian and Indian Seamless Carbon and Alloy Steel Standard, Line, and Pressure Pipe

New Antidumping and Countervailing Duty Petitions

On October 15, 2026, U.S. producers filed antidumping (AD) petitions on seamless carbon and alloy steel standard, line, and pressure pipe (“SSLPP”) from Georgia and India as well as a countervailing duty (CVD) petition covering imports from India, with the Department of Commerce (“Commerce”) and the U.S. International Trade Commission (“ITC”). The petitions allege dumping margins of 41.03% to 63.57% for India and 113.87% to 281.24% for Georgia, as well as countervailable subsidies in India above the de minimis level. These figures are allegations; Commerce has not calculated any duty or cash deposit rates. If the investigations proceed and Commerce issues an affirmative preliminary determination, U.S. importers could face cash deposit requirements on covered entries as early as January 2027 for CVD and March 2027 for AD. These dates are preliminary and may change.

The subject merchandise—seamless carbon and alloy steel standard, line, and pressure pipe from Georgia and India—is used to transport liquids and gases in a wide range of industrial applications. Pressure pipe is commonly used in refineries, petrochemical and chemical plants, power generation facilities, and oil and gas distribution systems, while standard pipe is used in plumbing, heating, air conditioning, and fire protection systems. Seamless line pipe is used to transport oil, natural gas, and other fluids through pipeline networks. The petitions allege that imports from Georgia and India have increased significantly, gaining U.S. market share and underselling domestically produced SSLPP, causing material injury and threatening further injury to the U.S. industry.

The domestic industry has previously filed AD and/or CVD petitions covering imports of SSLPP from numerous countries, and AD and/or CVD orders currently remain in place on imports from China, the Czech Republic, Germany, Japan, Korea, Romania, Russia, and Ukraine.

Importers, retailers, distributors, and their Georgian and Indian suppliers should promptly compare their merchandise and supply chains now with the proposed scope. An affirmative preliminary finding could change landed costs and cash flow while orders and shipments are still in the pipeline. The agencies have not yet determined whether the domestic industry is injured or whether the alleged dumping and subsidies exist.

Proposed Product Scope

The petitions propose the following scope language. Commerce may revise the scope during the investigations:

The merchandise covered by these petitions is seamless carbon and alloy steel (other than stainless steel) pipes and redraw hollows, less than or equal to 16 inches (406.4 mm) in nominal outside diameter, regardless of wall-thickness, manufacturing process (e.g., hot finished or cold-drawn), end finish (e.g., plain end, beveled end, upset end, threaded, or threaded and coupled), or surface finish (e.g., bare, lacquered or coated). Redraw hollows are any unfinished carbon or alloy steel (other than stainless steel) pipe or “hollow profiles” suitable for cold finishing operations, such as cold drawing, to meet the American Society for Testing and Materials (ASTM) or American Petroleum Institute (API) specifications referenced below, or comparable specifications. Specifically included within the scope are seamless carbon and alloy steel (other than stainless steel) standard, line, and pressure pipes produced to the ASTM A-53, ASTM A-106, ASTM A-333, ASTM A-334, ASTM A-589, ASTM A-795, ASTM A-1024, and the API 51 specifications, or comparable specifications, and meeting the physical parameters described above, regardless of application, with the exception of the exclusions discussed below.

Specifically excluded from the scope of the orders are: (1) All pipes meeting aerospace, hydraulic, and bearing tubing specifications, including pipe produced to the ASTM A-822 standard; (2) all pipes meeting the chemical requirements of ASTM A-335, whether finished or unfinished; and (3) unattached couplings. Also excluded from the scope of the orders are (1) all mechanical, boiler, condenser and heat exchange tubing, except when such products conform to the dimensional requirements (i.e., outside diameter and wall thickness, of ASTM A53, ASTM A-106 or API 51 specifications). Also excluded from the scope of the orders are: (1) Oil country tubular goods consisting of drill pipe, casing, tubing and coupling stock; (2) all pipes meeting the chemical requirements of ASTM A-335 regardless of their conformity to the dimensional requirements of ASTM A-53, ASTM A-106 or API 5L; and (3) the exclusion for ASTM A335 applies to pipes meeting the comparable specifications GOST 550-75.

Subject seamless standard, line, and pressure pipe are normally entered under Harmonized Tariff Schedule of the United States (HTSUS) subheadings 7304.19.1020, 7304.19.1030, 7304.19.1045, 7304.19.1060, 7304.19.5020, 7304.19.5050, 7304.31.6050, 7304.39.0016, 7304.39.0020, 7304.39.0024, 7304.39.0028, 7304.39.0032, 7304.39.0036, 7304.39.0040, 7304.39.0044, 7304.39.0048, 7304.39.0052, 7304.39.0056, 7304.39.0062, 7304.39.0068, 7304.39.0072, 7304.51.5005, 7304.51.5060, 7304.59.6000, 7304.59.8010, 7304.59.8015, 7304.59.8020, 7304.59.8025, 7304.59.8030, 7304.59.8035, 7304.59.8040, 7304.59.8045, 7304.59.8050, 7304.59.8055, 7304.59.8060, 7304.59.8065, and 7304.59.8070. The HTSUS subheadings and specifications are provided for convenience and customs purposes; the written description of the scope is dispositive.

Alleged Margins and Potentially Affected Companies

The petitions identify certain Georgian and Indian producers and exporters and U.S. importers. Being named does not establish that a company’s products are covered; being absent from the lists does not establish that they are excluded. Companies should review their merchandise and supplier relationships against the proposed scope. Clark Hill can provide the lists identified in the petitions.

The petitioners allege the following margins. Commerce will calculate any applicable deposit rates during its investigations:

• India: alleged AD margins of 41.03% to 63.57%; alleged CVD subsidies above de minimis, without a proposed numerical CVD rate.
• Georgia: alleged AD margins of 113.87% to 281.24%.

How the Investigations Proceed

The ITC will first decide whether there is a reasonable indication of material injury or threat of material injury to the U.S. industry. A negative preliminary injury determination would terminate the investigations. If the ITC’s finding is affirmative, Commerce will investigate dumping and subsidization and calculate any AD and CVD rates. Final duties require affirmative final determinations from both agencies.

If the investigations continue, Commerce’s preliminary CVD and AD determinations are estimated for January 8, 2027, and March 24, 2027, respectively. Following an affirmative preliminary determination, cash deposits generally begin on covered entries as of publication of that determination in the Federal Register. If critical circumstances are found, suspension of liquidation and cash deposit requirements may apply retroactively to entries made up to 90 days before that publication. The dates are estimates and may be extended; the petitioners’ alleged margins are not the deposit rates.

What Importers and Georgian and Indian Suppliers Should Do Now

U.S. importers should compare specifications, species, dimensions, and processing history for each product with the proposed scope; identify the manufacturer and exporter; and map open orders and expected entry dates. Review landed cost and cash flow scenarios using possible AD and CVD deposits, without treating the petitioners’ estimates as the eventual rates.

Georgian and Indian producers and exporters should preserve product, sales, and production records, identify related companies, and, in the case of India, maintain records relating to subsidy programs to prepare for possible Commerce questionnaires. In an AD investigation for Georgia, timely separate rate applications may be important for exporters seeking a rate distinct from the Georgia-wide rate. The agency’s initiation notice and subsequent questionnaires will set actual filing deadlines.

Both sides should review pricing and duty allocation terms in supply contracts and decide promptly whether to present product scope or injury arguments. The indicative schedule below is subject to agency notices and extensions.

Approxímate Key Dates*
Antidumping Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	10/15/2026
DOC Initiation Date	20	11/4/2026
DOC Separate Rate Applications	To be set	To be announced
DOC Q&V Questionnaires	To be set	To be announced
ITC Preliminary Determination	45	11/30/2026
DOC Preliminary AD Determination	160	3/24/2027
DOC Final AD Determination	235	6/7/2027
ITC Final AD Determination	280	7/22/2027
DOC AD Publication of Order	287	7/29/2027
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	10/15/2026
DOC Initiation Date	20	11/4/2026
DOC Q&V Questionnaires	To be set	To be announced
ITC Preliminary Determination	45	11/30/2026
DOC Preliminary CVD Determination	85	1/8/2027
DOC Hearing Request Deadline (if applicable)	To be set	To be announced
DOC Final CVD Determination	160	3/24/2027
ITC Final CVD Determination	205	5/10/2027
DOC CVD Publication of Order	212	5/17/2027

 

* All deadlines are approximate and are subject to change throughout the course of an investigation. Deadlines that fall on a weekend or Federal holiday are extended to the next business day, as shown above. Contact Clark Hill for current updates and details.

Contact Clark Hill

For help assessing product coverage, response obligations, or import planning, contact Clark Hill’s International Trade team:

• Kevin Williams (kwilliams@clarkhill.com; 312.985.5907)
• Kelsey Christensen (kchristensen@clarkhill.com; 202.230.9889)
• Ashley Gifford (agifford@clarkhill.com; 202.640.6655)
• Aristeo Lopez (alopez@clarkhill.com; 202.552.2366)
• Amal Sheheen (asheheen@clarkhill.com; 202.552.2354)
• Onjoly Purification (opurification@clarkhill.com; 202.552.2361)

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