New U.S. Countervailing Duty Petition Targets Carbon and Alloy Steel Wire Rod from Algeria
The Petition
Charter Steel, Commercial Metals Company, Liberty Steel USA, Nucor Corporation, and Optimus Steel LLC (collectively, “Petitioners”) have filed a new petition with the U.S. Department of Commerce (“DOC”) seeking the imposition of countervailing duties (“CVD”) on imports of carbon and alloy steel wire rod (“CASWR” or “wire rod”) from Algeria. Petitioners allege that Algerian producers/exporters of subject merchandise benefit from countervailable subsidies provided by the Government of Algeria, and that those subsidies warrant the imposition of remedial duties under U.S. law.
This case is procedurally unusual and requires prompt attention. Because Algeria is not treated as a “Subsidies Agreement” country for purposes of the U.S. countervailing duty statute, the case proceeds primarily before the DOC, and there is no parallel injury determination by the U.S. International Trade Commission (“ITC”) at the preliminary stage. In practical terms, this means that the principal defense effort could be organized early before Commerce, including government and company responses to subsidy allegations, identification of relevant programs, and preparation for questionnaire responses and verification.
Wire rod is a hot-rolled intermediate steel product of circular or approximately circular cross section that typically is produced in nominal fractional diameters up to 47/64 inch (18.7 mm) and sold in irregularly wound coils, primarily for subsequent drawing and finishing by wire drawers. Wire rod sold in the United States is categorized by quality according to end use. End-use categories are broad descriptions with overlapping metallurgical qualities, chemistry, and physical characteristics.
Industrial quality wire rod currently accounts for the majority of CASWR consumed in the United States. It is primarily intended for drawing into industrial (or standard) quality wire that, in turn, is used to manufacture such products as nails, reinforcing wire mesh, and chain link fence. Industrial quality wire rods are generally manufactured from low- or medium-low- carbon steel. Other relatively large-volume qualities of wire rods consumed in the United States include high- and medium-high carbon and cold-heading quality. High- and medium-high carbon wire rods are intended for drawing into wire for such products as strand, upholstery spring, mechanical spring, rope, screens, and pre- stressed concrete wire. A cold-heading quality wire rod is used for wire that is typically formed without heating, such as for fasteners like bolts, screws, and rivets.
There have been numerous prior antidumping and countervailing duty petitions and proceedings involving wire rod, including orders on imports from Russia, Korea, South Africa, and other countries.
Scope of the Countervailing Duty Investigation
The following language describes the imported merchandise that the Petitioners intend to cover in these investigations:
The merchandise subject to this order covers certain hot-rolled products of carbon steel and alloy steel, in coils, of approximately circular cross section, less than 19.00 mm in actual solid cross-sectional diameter. Specifically excluded are steel products possessing the above-noted physical characteristics and meeting the Harmonized Tariff Schedule of the United States (HTSUS) definitions for (a) stainless steel; (b) tool steel; (c) high nickel steel; (d) ball bearing steel; or (e) concrete reinforcing bars and rods. Also excluded are free cutting steel (also known as free machining steel) products (i.e., products that contain by weight one or more of the following elements: 0.1 percent or more of lead; 0.05 percent or more of bismuth; 0.08 percent or more of sulfur; more than 0.04 percent of phosphorus; more than 0.05 percent of selenium; or more than 0.01 percent of tellurium). All products meeting the physical description of subject merchandise that are not specifically excluded are included in this scope.
The products under order are currently classifiable under subheadings 7213.91.3011, 7213.91.3015, 7213.91.3020, 7213.91.3093; 7213.91.4500, 7213.91.6000, 7213.99.0030, 7227.20.0030, 7227.20.0080, 7227.90.6010, 7227.90.6020, 7227.90.6030, and 7227.90.6035 of the HTSUS. Products entered under subheadings 7213.99.0090 and 7227.90.6090 of the HTSUS also may be included in this scope if they meet the physical description of subject merchandise above. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of this order is dispositive.
Key Facts
Petitioners: Charter Steel; Commercial Metals Company; Liberty Steel USA; Nucor Corporation; and Optimus Steel LLC.
Foreign Producers/Exporters and U.S. Importers: The petition identifies, among others, the following Algerian producers/exporters: Algerian Qatari Steel, The National Long Products Processing Company (ENTPL), and Tosyali Algérie. Companies and government stakeholders connected to these entities may assume that early coordination could be necessary if the case is initiated.
CVD margin: Petitioners alleged the following CVD margin:
- Algeria: CVD margin above de minimis. Petitioners allege that countervailable subsidies provided to Algerian producers/exporters are above de minimis, which is sufficient under U.S. law to support initiation and further investigation if the DOC finds the petition adequately supported.
The Investigation
This proceeding will be conducted principally by the DOC. Because Algeria is not treated as a “Subsidies Agreement” country under the relevant U.S. statute, the ITC is not required to make a material injury determination in this case. The practical result is that the central issues will be addressed before the DOC, including the existence, specificity, and benefit of the subsidy programs alleged in the petition.
If the DOC initiates the case, it is expected to issue questionnaires to the Government of Algeria and to the principal Algerian producers/exporters identified in the petition. The DOC will then decide whether alleged subsidy programs are countervailable and, if so, calculate a preliminary subsidy rate. If the DOC issues an affirmative preliminary determination, U.S. importers will be required to post estimated cash deposits on future entries of subject merchandise. Under the current schedule, the preliminary CVD determination is expected on or about June 30, 2026, although that date may shift during the proceeding.
The petition’s subsidy allegations are broad. Among other things, it alleges that Algerian producers may benefit from investment-law incentives, reduced corporate tax treatment, export-related tax exemptions, electricity and natural gas for less than adequate remuneration, hydrogen-related support, government purchases of steel for more than adequate remuneration, policy lending and loan guarantees, and certain alleged transnational subsidies involving Chinese financing, equipment, and construction services. These are allegations only at this stage, but they underscore the importance of organizing a prompt and comprehensive response.
Next Steps
Given the compressed statutory deadlines in U.S. countervailing duty proceedings, Algerian producers/exporters and relevant government stakeholders could begin preparing immediately. As practical first steps, affected parties should:
- Confirm whether their exported products fall within the proposed scope
- Identify the legal entities involved in production, export, and sale to the United States
- Preserve and organize information concerning sales, production, ownership, financing, tax treatment, utility usage, and government support programs
- Prepare for possible DOC questionnaires and follow-up requests shortly after initiation
- Coordinate early between the company side and the relevant government authorities so that factual positions are presented consistently and accurately.
For government stakeholders, this case also warrants early attention because the petition expressly alleges a range of government programs and may require formal questionnaire responses from the Government of Algeria.
A schedule of approximate key dates is below.
Approximate Key Dates*
Because this is a DOC-centered proceeding, these dates should be treated as planning dates for government and company preparation, even though the schedule may shift.
| Countervailing Duty Investigation | ||
| Event | No. of Days | Date of Action |
| Petition Filed | 0 | 4/6/2026 |
| DOC Initiation Date | 20 | 4/27/2026 |
| DOC Q&V Questionnaires | 44 | 5/20/2026 |
| DOC Preliminary CVD Determination | 85 | 6/30/2026 |
| Request for a DOC Hearing | 122 | 8/6/2026 |
| DOC Final CVD Determination | 160 | 9/13/2026 |
| DOC CVD Publication of Order | 212 | 11/4/2026 |
*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
If you have questions regarding the content of this alert, please contact any member of Clark Hill’s International Trade Practice:
- Mark Ludwikowski (mludwikowski@clarkhill.com; 202.640.6680)
- Kevin Williams (kwilliams@clarkhill.com; 312.985.5907)
- Kelsey Christensen (kchristensen@clarkhill.com; 202-230-9889)
- Aristeo Lopez (alopez@clarkhill.com; 202.552.2366)
- Ashley Gifford (agifford@clarkhill.com; 202.640.6655)
- Laura M. Quesada (Lquesada@clarkhill.com; 202.240.0170)
- Amal Sheheen (asheheen@clarkhill.com; 202.552.2354)
- Onjoly Purification (Opurification@clarkhill.com; 202.552.2361)
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