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New Trade Case on Imports of Rubber Bands from Thailand, China and Sri Lanka

February 5, 2018

New U.S. antidumping (AD) and countervailing duty (CVD) petition was filed on January 30 against imports of rubber bands from Thailand, China and Sri Lanka.  

Based on the petition, rubber bands (also known as an elastic band or gum band) are loops of vulcanized rubber, usually ring shaped and commonly used to hold multiple objects together, including papers, fruit and vegetables, pieces of equipment and other items. Rubber bands are sold in a variety of sizes across an array of industries, such as stationary, paper and packaging, newspapers, agricultural, retail, government and post office, advertising.

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 25, 2018 (CVD) and July 9, 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: Alliance Rubber Co., of Hot Springs, AK.  

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:

Thailand – 60.82%

China – 27.16%

Sri Lanka – 48.63%

Petitioner has also alleged CVD margins above de minimis based on various subsidy programs from the governments of Thailand, China and Sri Lanka.  

Petitioner has claimed that one of the key reasons for filing the trade case is the recent decision by Staples, Inc., to switch its supply of rubber bands from Petitioner to an exporter based in Thailand.

Merchandise covered by the scope of the case:

The products subject to these investigations are bands made of bands made of vulcanized rubber, with a flat length, as measured end-to-end by the band lying flat, no less than 1/2 inch and no greater• than 10 inches; with a width, which measures the dimension perpendicular to the length, of at least 3/64 inch and no greater than 2 inches; and a wall thickness from .020 inch to .125 inch. Vulcanized rubber has been chemically processed into a more durable material by the addition of sulfur or other equivalent curatives or accelerators. Subject products are included regardless of color or inclusion of printed material. The scope includes vulcanized rubber bands which are contained or otherwise exist in various forms and packages, such as, without limitation, vulcanized rubber bands included within a desk accessory set or other type of set or package, and vulcanized rubber band balls, but excludes Bedford Elastitags®, and bands that are being used at the time of import to fasten an imported product.

Merchandise covered by these proceedings is currently classified in the Harmonized Tariff System of the United States (“HTSUS”) under sub-heading 4016.99.35.10 (Rubber Bands Made of Vulcanized Rubber, Except Hard Rubber, of Natural Rubber). This HTSUS subheading is provided for convenience and customs purposes; the written description of the scope of these proceedings is dispositive.

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

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