U.S. Producer Files New Trade Case Against Imports of Large Diameter Graphite Electrodes from China and India

The Petitions

LDGE Fair Trade Coalition and its individual members (“Petitioner”) has filed new petitions with the U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) seeking the imposition of antidumping (“AD”) and countervailing duties (“CVD”) on imports into United States of large diameter graphite electrodes (“LDGEs”) from China and India.

The Petitioner alleges that imports of LDGEs are being dumped in the U.S. market by being sold for less than fair value and that these imports are injuring the domestic producers. The imported products subject to these petitions are LDGEs –  which are products exceeding 425 millimeters (16.7 inches) in nominal or actual diameter and sold with or without a graphite pin joining system.

LDGEs are cylindrical forms of artificial graphite that are produced primarily from thermal graphitization of hydrocarbon materials: calcined petroleum needle coke or calcined pitch needle coke, and coal tar pitch. LDGEs are used to conduct electricity for the purpose of generating sufficient heat to melt scrap metal, iron ore, and other raw materials in the process of making or refining steel or other metals.

Scope of the Investigation

The following language describes the imported merchandise that Petitioners intend to cover in these investigations:

The merchandise covered by these petitions includes all large diameter graphite electrodes of any length, whether or not finished, of a kind used in furnaces, with a nominal or actual diameter exceeding 425 millimeters (16.7 inches), and whether or not attached to a graphite pin joining system or any other type of joining system or hardware. The merchandise covered by these petitions also includes graphite pin joining systems for large diameter graphite electrodes, of any length or diameter, whether or not finished, of a kind used in furnaces, and whether or not the graphite pin joining system is attached to, sold with, or sold separately from, the large diameter graphite electrode. Unfinished large diameter graphite electrodes are graphitized electrodes that have not undergone final machining. For purposes of this investigation, the country of origin is determined by the country of graphitization.

Excluded from the scope of these petitions are large diameter graphite electrodes that are subject to the existing antidumping duty order on Small Diameter Graphite Electrodes from the People’s Republic of China. See Antidumping Duty Order: Small Diameter Graphite Electrodes from the People’s Republic of China, 74 Fed. Reg. 8,775 (Dep’t Commerce Feb. 26, 2009) (“SDGE China AD Order”). Certain merchandise may be subject to the SDGE China AD Order as the result of prior or future affirmative anticircumvention and/or scope determinations. In the case of graphite electrodes entering the United States determined to be subject to the SDGE China AD Order, such order controls. In the case of graphite electrodes entering the United States meeting the scope definition of these petitions and not covered by the scope of the SDGE China AD Order, the scope of these petitions controls.

Large diameter graphite electrodes and graphite pin joining systems for large diameter graphite electrodes that are covered by these petitions are currently classified under the Harmonized Tariff Schedule of the United States (“HTSUS”) statistical reporting number 8545.11.0020. Merchandise covered by these petitions may also enter under HTSUS statistical reporting numbers 3801.10.5090 or 3801.90.0050. The HTSUS numbers are provided for convenience and customs purposes, but the written description of the scope is dispositive.

Key Facts

Petitioner: LDGE Fair Trade Coalition and its individual members

Foreign Producers/Exporters and U.S. Importers:  Please contact Clark Hill’s international trade team for a listing of individual importers and exporters named in the petitions.

AD/CVD margins: Petitioners alleged the following AD and CVD margins:

• China: AD margin from 36.82% to 146.41%, ad valorem, and a CVD margin above de minimis.
• India: AD margin from 42.92% to 74.02%, ad valorem, and a CVD margin above de minimis.

The Investigation

The DOC and the ITC will conduct parallel investigations. The ITC will first determine if there is a reasonable indication of material injury or threat of injury to the U.S. industry. The DOC will then determine whether imports are being dumped or unfairly subsidized and will calculate corresponding AD and CVD duty margins that importers will need to pay on their entries.

If the DOC issues an affirmative preliminary determination, importers will be required to deposit the estimated AD/CVD duties on their imports as of the date that the DOC publishes its affirmative preliminary determination in the Federal Register. In this case, the DOC’s preliminary determinations are currently expected by May 20, 2026 (CVD) and Aug. 3, 2026 (AD), although the schedule is subject to change. Importers should be aware that cash deposits may apply earlier if the DOC finds that there is a surge of imports after the petitions were filed.

Next Steps

Given the strict statutory deadlines, governing AD and CVD investigations, U.S. importers and foreign producers are advised to prepare as soon as possible.

A schedule of approximate key dates is below.

Approximate Key Dates*

Antidumping Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	2/24/2026
DOC Initiation Date	20	3/16/2026
DOC Separate Rate Applications	41	4/6/2026
DOC Q&V Questionnaires	44	4/9/2026
ITC Preliminary Determination	45	4/10/2026
DOC Preliminary AD Determination	160	8/3/2026
DOC Final AD Determination	235	10/19/2026
ITC Final AD Determination	280	12/1/2026
DOC AD Publication of Order	287	12/8/2026
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	02/24/2026
DOC Initiation Date	20	3/16/2026
DOC Q&V Questionnaires	44	4/9/2026
ITC Preliminary Determination	45	4/10/2026
DOC Preliminary CVD Determination	85	5/20/2026
Request for a DOC Hearing	122	6/26/2026
DOC Final CVD Determination	160	8/3/2026
ITC Final CVD Determination	205	9/17/2026
DOC CVD Publication of Order	212	9/24/2026

* 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 this development is of interest to your business or if you have questions regarding the content of this alert, please contact any member of Clark Hill’s International Trade Practice for additional details and strategic guidance.

• 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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