BYD (H.K.) Co., Ltd. v. United States

2025 CIT 60
CourtUnited States Court of International Trade
DecidedMay 16, 2025
Docket23-00221
StatusPublished

This text of 2025 CIT 60 (BYD (H.K.) Co., Ltd. v. United States) is published on Counsel Stack Legal Research, covering United States Court of International Trade primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BYD (H.K.) Co., Ltd. v. United States, 2025 CIT 60 (cit 2025).

Opinion

Slip Op. 25-60

UNITED STATES COURT OF INTERNATIONAL TRADE

Court No. 23-00221

BYD (H.K.) CO., LTD., Plaintiff, and FLORIDA POWER & LIGHT COMPANY, Plaintiff-Intervenor, v. UNITED STATES, Defendant, and AUXIN SOLAR INC., Defendant-Intervenor.

Before: M. Miller Baker, Judge

OPINION

[Sustaining the Department of Commerce’s circum- vention determination.]

Dated: May 16, 2025

Craig A. Lewis, Nicholas W. Laneville, and Gregory M.A. Hawkins, Hogan Lovells US LLP, Washington, DC, on the briefs for Plaintiff. Ct. No. 23-00221 Page 2

Matthew R. Nicely, Daniel M. Witkowski, and Julia K. Eppard, Akin Gump Strauss Hauer & Feld LLP, Washington, DC, on the briefs for Plaintiff-Intervenor.

Brian M. Boynton, Principal Deputy Assistant Attor- ney General; Patricia M. McCarthy, Director; Re- ginald T. Blades, Jr., Assistant Director; and Stephen C. Tosini, Senior Trial Counsel, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, Washington, DC, on the brief for Defendant. Of coun- sel on the brief was Spencer C. Neff, Attorney, Office of Chief Counsel for Trade Enforcement and Compli- ance, U.S. Department of Commerce, Washington, DC.

Baker, Judge: Plaintiff BYD (H.K.) Co. challenges the Department of Commerce’s finding that solar cell imports from Cambodia circumvent antidumping and countervailing duty orders on such equipment made in China. As explained below, the court sustains the agency’s determination.

I

The Tariff Act of 1930, as amended, allows Com- merce to impose antidumping or countervailing duties on a “class or kind” of imported merchandise if it “finds that the merchandise reflects unfair pricing or unfair subsidization and the [International Trade] Commis- sion finds material injury to the domestic industry.” Canadian Solar, Inc. v. United States, 918 F.3d 909, 917 (Fed. Cir. 2019) (citing 19 U.S.C. §§ 1671(a)(1), 1673(1)). In imposing such duties, the Department Ct. No. 23-00221 Page 3

must “include ‘a description of the subject merchan- dise, in such detail as [it] deems necessary.’୻” Id. (em- phasis removed) (quoting 19 U.S.C. §§ 1671e(a)(2), 1673e(a)(2)). The statute “defines ‘subject merchan- dise’ as ‘the class or kind of merchandise that is within the scope of an investigation [or] an order under this subtitle.’୻” Id. (quoting 19 U.S.C. § 1677(25)). In prac- tice, Commerce describes the product “within the scope of the order[ ]” by reference to its “technical char- acteristics” and “country of origin” (sometimes re- ferred to in this opinion as the “source country”). Id. at 913.

The Department “typically determines country of origin based on the country where the merchandise is processed or manufactured.” Id. But in trade, as in war, the antagonist gets a vote. To avoid duties, a pro- ducer may “finish[ ] or assemble[ ]” its products “in a different country” using components manufactured in the source country. Bell Supply Co. v. United States, 888 F.3d 1222, 1228 (Fed. Cir. 2018). Whether the fi- nal product as exported from the third country is deemed to originate from the source country depends on whether it was “substantial[ly] transform[ed]” in the former. Id.

“A substantial transformation occurs where, as a result of manufacturing or processing steps, the prod- uct loses its identity and is transformed into a new product having a new name, character and use.” Id. (cleaned up) (quoting Bestfoods v. United States, Ct. No. 23-00221 Page 4

165 F.3d 1371, 1373 (Fed. Cir. 1999)). If such a trans- formation occurs, the third country becomes the coun- try of origin, and the product is out-of-scope. Id. at 1230. Otherwise, such goods are deemed to originate from the source country, meaning they’re in-scope. Id.

Even if substantially transformed in a third coun- try, the products finished or assembled there from source-country components are not necessarily home free, as it were. As relevant here, the statute’s anticir- cumvention provision, 19 U.S.C. § 1677j, authorizes— but does not require—Commerce to extend antidump- ing and countervailing duty orders to such articles when certain other conditions are satisfied. See id. § 1677j(b)(1); see also Bell Supply, 888 F.3d at 1230 (explaining that if the Department “applies the sub- stantial transformation test and concludes that the imported article has a country of origin different from the country identified in an AD or CVD order, then [it] can include such merchandise within the scope of [such an] order only if it finds circumvention under § 1677j”).

For there to be circumvention, imports “completed or assembled” in a third country from source-country components must be “of the same class or kind” as goods subject to the duty order. 19 U.S.C. § 1677j(b)(1)(A), (B). The “process of assembly or com- pletion” has to be “minor or insignificant.” Id. § 1677j(b)(1)(C). The value of the parts made in the source country must also be “a significant portion of Ct. No. 23-00221 Page 5

the total value” of the product as finally exported to this nation. Id. § 1677j(b)(1)(D). Finally, “action [must be] appropriate . . . to prevent” avoidance of duty or- ders. Id. § 1677j(b)(1)(E).

If Commerce finds those conditions satisfied, it must then determine whether to extend the orders to the third-country goods. In doing so, it must “take into account” certain considerations. Id. § 1677j(b)(3). As relevant here, they include any “affiliat[ion]” between the company doing the “assembl[y] or complet[ion]” and the manufacturer or exporter of source-country parts or components. Id. § 1677j(b)(3)(B).

In many anticircumvention cases, including this one, the crux of the controversy is the “minor or insig- nificant” condition under § 1677j(b)(1)(C). As to that question, Commerce must “take into account” certain factors regarding operations in the third country. They are “(A) the level of investment”; “(B) the level of re- search and development”; “(C) the nature of the pro- duction process”; “(D) the extent of production facili- ties”; and “(E) whether the value of the processing per- formed” there “represents a small proportion of the value of the merchandise imported into the United States.” Id. § 1677j(b)(2). “Commerce will evaluate each of these factors . . . , depending on the particular circumvention scenario. No single [one] will be control- ling.” Statement of Administrative Action Accompany- ing the Uruguay Round Agreements Act (SAA), H.R. Ct. No. 23-00221 Page 6

Doc. 103–316, vol. 1, at 893, 1994 U.S.C.C.A.N. 4040, 4216. 1

II

In 2012, Commerce issued orders imposing anti- dumping and countervailing duties on solar cells made in China. 2 See 77 Fed. Reg. 73,018; 77 Fed. Reg. 73,017. A decade later, domestic producer Auxin Solar Inc. asked the Department to investigate whether

1 The SAA is an “authoritative expression” of the statute’s

meaning. 19 U.S.C. § 3512(d). 2 In technical jargon, the orders cover “crystalline silicon

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