U.S. producers file new trade case against imports of freight rail couplers from the Czech Republic and India

The Coalition of Freight Coupler Producers (“Petitioner” or “CFCP”) 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 duty (“CVD”) on imports of Freight Rail Couplers (“FRCs”) from Czechia and India. Petitioner alleged that these imports are being sold at less than fair value, also known as dumped, in the U.S. market, and are also unfairly subsidized by their respective governments.

FRCs are a mechanical device used to connect freight rail cars; these are the linking mechanisms between rail cars that make up the chain of a train. As such, each railcar usually has two couplers, one in the front of the car and one in the back of the car. FRCs have two main parts, knuckles and coupler bodies, but they can also have additional features. When one or both knuckles are open and rail cars are pushed together, the device couples automatically. The force of the two cars moving against each other causes the knuckle to latch into the closed position, and a lock falls into place to secure the coupled rail cars. FRCs connect two rail cars securely, while still allowing for some flexibility during movement. When a train brakes, the FRCs help to absorb shocks from the movement.

Please see below for the full text of the proposed scope for investigations.

Key Facts

Petitioner: Coalition of Freight Coupler Producers

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: Petitioner alleged the following AD and CVD margins:

• Czechia: AD margins from 52.69% to 166.67% ad valorem, and a CVD margin above de minimis.
• India: AD margins from 23.07% to 419.55% ad valorem, and a CVD margin above de minimis.

The Investigation

The U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) will conduct the investigations. The ITC will determine if there is a reasonable indication that the imports are injuring or threatening to injure the U.S. industry. The DOC will then determine whether imports are being dumped or unfairly subsidized and will calculate corresponding AD and CVD margins that importers will need to pay on their entries.

Importers will be required to deposit the calculated 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 Oct. 16 (CVD) and Dec. 31 (AD). Importers should be aware that entries may be subject to cash deposits before these dates if the DOC finds that there is a surge of imports after the petitions were filed.

Next Steps

All U.S. importers and foreign producers are advised to prepare as soon as possible due to the strict statutory deadlines in these cases. If this product is of interest to you, please contact Clark Hill’s international trade team so that we can provide you with additional information.

A schedule of approximate key dates is attached below.

The Scope

Petitioner requested that the scope of the merchandise subject to investigation be defined as follows:

The scope of this investigation covers certain freight railcar couplers (also known as “fits” or “assemblies”) and parts thereof. Freight railcar couplers are composed of two main parts, namely knuckles and coupler bodies but may also include other items (e.g., coupler locks, lock lift assemblies, knuckle pins, knuckle throwers, and rotors). The parts covered by the investigation include: (1) E coupler bodies; (2) E/F coupler bodies; (3) F coupler bodies; (4) E knuckles; (5) F knuckles; as set forth by the Association of American Railroads (AAR). The freight rail coupler parts are included within the scope of the investigation when imported individually.

Subject freight railcar couplers and parts are included within the scope whether finished or unfinished, whether imported individually or with other subject or nonsubject parts, whether assembled or unassembled, whether mounted or unmounted, or if joined with nonsubject merchandise, such as other nonsubject parts or a completed railcar. Finishing includes, but is not limited to, arc washing, welding, grinding, shot blasting, heat treatment, machining, and assembly of various parts. When a subject coupler or subject parts are mounted on or to other nonsubject merchandise, such as a railcar, only the coupler or subject parts are covered by the scope.

The finished products covered by the scope of this order meet or exceed the AAR specifications of M-211, “Foundry and Product Approval Requirements for the Manufacture of Couplers, Coupler Yokes, Knuckles, Follower Blocks, and Coupler Parts,” and/or AAR M-215 “Coupling Systems,” or other equivalent domestic or international standards (including any revisions to the standard(s)).

The country of origin for subject couplers and parts thereof, whether fully assembled, unfinished or finished, or attached to a railcar, is the country where the subject coupler parts were cast or forged. Subject merchandise includes coupler parts as defined above that have been further processed or further assembled, including those coupler parts attached to a railcar in third countries. Further processing includes, but is not limited to, arc washing, welding, grinding, shot blasting, heat treatment, painting, coating, priming, machining, and assembly of various parts. The inclusion, attachment, joining, or assembly of nonsubject parts with subject parts or couplers either in the country of manufacture of the in-scope product or in a third country does not remove the subject parts or couplers from the scope.

The couplers that are the subject of this investigation are classifiable in the Harmonized Tariff Schedule of the United States (HTSUS) statistical reporting numbers 8607.30.1000, 8607.30.1010, 8607.30.1050, and 8607.30.1090. Unfinished subject merchandise may also enter under HTSUS statistical reporting number 7326.90.8688. Subject merchandise attached to finished railcars may also enter under HTSUS statistical reporting numbers 8606.10.0000, 8606.30.1000, 8606.91.0000, 8606.92.0000, 8606.99.0130, 8606.99.0160, or under subheading 9803.00.50. Subject merchandise may also be imported under HTSUS statistical reporting number 7325.99.5000. These HTSUS subheadings are provided for convenience and customs purposes only; the written description of the scope of this investigation is dispositive.

Approximate Key Dates*

Antidumping Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	7/23/2025
DOC Initiation Date	20	8/13/2025
DOC Separate Rate Applications	41	9/3/2025
DOC Q&V Questionnaires	44	9/5/2025
ITC Preliminary Determination	45	9/6/2025
DOC Preliminary AD Determination	160	12/31/2025
DOC Final AD Determination	235	3/15/2026
ITC Final AD Determination	280	4/29/2026
DOC AD Publication of Order	287	5/6/2026
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	7/23/2025
DOC Initiation Date	20	8/13/2025
DOC Q&V Questionnaires	44	9/5/2025
ITC Preliminary Determination	45	9/6/2025
DOC Preliminary CVD Determination	85	10/16/2025
Request for a DOC Hearing	122	11/22/2025
DOC Final CVD Determination	160	12/31/2025
ITC Final CVD Determination	205	2/13/2026
DOC CVD Publication of Order	212	2/20/2026

Contact Clark Hill

If you have any questions regarding the content of this alert, please contact Mark Ludwikowski (mludwikowski@clarkhill.com; 202-640-6680), Kevin Williams (kwilliams@clarkhill.com; 312-985-5907), Aristeo Lopez (alopez@clarkhill.com; 202-552-2366), Kelsey Christensen (kchristensen@clarkhill.com; 202-640-6670), Laura M. Quesada (lquesada@clarkhill.com; 202-240-0170), or other members of Clark Hill’s International Trade Business Unit.

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