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New Trade Case on Imports of Certain Brake Drums From the People’s Republic of China and Türkiye

June 21, 2024

New U.S. antidumping (“AD”) and countervailing duty (“CVD”) petitions were filed on June 20 by Webb Wheel Products, Inc. (the “Petitioner”) against imports of certain brake drums from the People’s Republic of China (“China”) and Türkiye.

The merchandise covered by these petitions consists of certain brake drums, which are components for the braking system in motor vehicles. The subject brake drums are used primarily, though not exclusively, on heavy-duty trucks and trailers. The subject brake drums are made of gray cast iron, weighing more than 50 pounds with an actual or nominal inside diameter of 14.75 inches or more but not over 16.6 inches for use in commercial vehicles. Please see below for the full text of the proposed scope for the investigations.

The Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) will conduct the investigations. Within the next 45 days, the ITC will determine if there is a reasonable indication that the imports are injuring or threatening to injure the U.S. industry. If the ITC finds that this standard is met, the cases will move to the DOC, which will calculate the preliminary AD and CVD margins.

The DOC’s preliminary determinations are currently expected by Sept. 13 (CVD) and Nov. 27 (AD). On the date of publication of DOC’s preliminary determinations, importers will be required to deposit the calculated duties upon the products’ entry into the U.S. market.

Importers should also be aware that entries may be subject to AD/CVD cash deposits 90 days before the DOC preliminary determinations if the DOC issues a finding of “critical circumstances,” meaning that imports increased by at least 15 percent following the filing of the petition compared to a similar period (typically three months) before the petition.

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. A schedule of approximate key dates is attached below.

The following are key facts about this trade case:

Petitioner: Webb Wheel Products, Inc.

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

AD/CVD margins: Petitioner alleged the following AD/CVD margins:

  • China: dumping margins of 300.83% ad valorem, and countervailing duty margins above de minimis;
  • Türkiye: dumping margins of 168.34% ad valorem, and countervailing duty margins above de minimis.

Merchandise covered by the scope of the case

The proposed scope of these investigations describes the subject merchandise as:

The merchandise subject to these petitions are certain brake drums made of gray cast iron, whether finished or unfinished, with an actual or nominal inside diameter of 14.75 inches or more but not over 16.6 inches, weighing more than 50 pounds. Unfinished brake drums are those that have undergone some turning or machining but are not ready for installation. Subject brake drums are included within the scope whether imported individually or with non-subject merchandise (for example, a hub), whether assembled or unassembled, or if joined with non-subject merchandise. When a subject drum is imported together with non-subject merchandise, such as, but not limited to, a drum-hub assembly, only the subject drum is covered by the scope.

Subject merchandise also includes finished and unfinished brake drums that are further processed in a third country or in the United States, including, but not limited to, assembly or any other processing that would not otherwise remove the merchandise from the scope of these investigations if performed in the country of manufacture of the subject brake drums. The inclusion, attachment, joining, or assembly of non-subject merchandise with subject drums either in the country of manufacture of the subject drum or in a third country does not remove the subject drum from the scope. The scope of this investigation does not include any products already covered by the AD and CVD Orders on certain chassis and subassemblies thereof from the People’s Republic of China (A-570-135; C-570-136).

The scope also excludes composite brake drums that contain more than 40% steel by weight, while certain brake drums that meet the above criteria and that contain 40% or less steel by weight are within the scope.

If you have any questions regarding the content of this alert, please contact Mark Ludwikowski (; 202-640-6680), Kevin Williams (; 312-985-5907), Aristeo Lopez (; 202-552-2366), Kelsey Christensen (; 202-640-6670), Sally Alghazali (; 202-572-8676), or other members of Clark Hill’s International Trade Business Unit.

Approximate Key Dates*
Antidumping Duty Investigation
Event No. of Days Date of Action
Petition Filed 0 6/20/2024
DOC Initiation Date 20 7/10/2024
ITC Preliminary Investigations**
Questionnaires Due 14 7/5/2024
Request to appear at Conference 18 7/8/2024
Conference 21 7/11/2024
Post-Conference Briefs 26 7/16/2024
ITC Vote 43 8/2/2024
ITC Preliminary Determination 45 8/5/2024
DOC Investigations
DOC Preliminary AD Determination 160 11/27/2024
DOC Final AD Determination 235 2/10/2025
ITC Final Investigations
ITC Final AD Determination 280 3/27/2025
DOC Final Investigations
DOC AD Publication of Order 287 4/3/2025
Countervailing Duty Investigation
Event No. of Days Date of Action
Petition Filed 0 6/20/2024
DOC Initiation Date 20 7/10/2024
ITC Determination of Reasonable Indication of Injury 45 8/5/2024
DOC Preliminary CVD Determination 85 9/13/2024
Submission of Factual Information to DOC 95 9/23/2024
Request for a DOC Hearing 122 10/21/2024
DOC Final CVD Determination 160 11/27/2024
ITC Final CVD Determination 205 1/13/2025
DOC CVD Publication of Order 212 1/21/2025

This publication is intended for general informational purposes only and does not constitute legal advice or a solicitation to provide legal services. The information in this publication is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this information without seeking professional legal counsel. The views and opinions expressed herein represent those of the individual author only and are not necessarily the views of Clark Hill PLC. Although we attempt to ensure that postings on our website are complete, accurate, and up to date, we assume no responsibility for their completeness, accuracy, or timeliness.

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