Kaptan Demir Celik Endustrisi ve Ticaret A.S. v. United States

736 F. Supp. 3d 1318, 2024 CIT 116
United States Court of International Trade·Decided October 21, 2024·No. 23-00131·Published·Cited by 2 cases

Opinion

Slip Op. 24-

UNITED STATES COURT OF INTERNATIONAL TRADE

KAPTAN DEMIR CELIK ENDUSTRISI VE TICARET A.S.,

Plaintiff, and

ICDAS CELIK ENERJI TERSANE VE ULASIM SANAYI, A.S.,

Plaintiff-Intervenor, Before: Gary S. Katzmann, Judge v. Court No. 23-00131

UNITED STATES,

Defendant,

and

REBAR TRADE ACTION COALITION,

Defendant-Intervenor.

OPINION AND ORDER

[The court remands the Final 2020 Review for Commerce’s further explanation or reconsideration of both of the determinations that Kaptan challenges]

Dated: October 21, 2024

David L. Simon, Law Office of David L. Simon, PLLC, of Washington, D.C., argued for Plaintiff Kaptan Demir Celik Endustrisi ve Ticaret A.S. With him on the brief was Mark B. Lehnardt.

Jessica R. DiPietro, Leah N. Scarpelli, and Matthew M. Nolan, ArentFox Schiff LLP, of Washington, D.C., for Plaintiff-Intervenor Icdas Celik Enerji Tersane ve Ulasim Sanayi, A.S.

Kelley M. Geddes, Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, D.C., argued for Defendant the United States. With her on the briefs were Brian M. Boynton, Principal Deputy Assistant Attorney General, Patricia M. McCarthy, Director, L. Misha Preheim, Assistant Director. Of counsel on the briefs was W. Mitch Court No. 23-00131 Page 2

Purdy, Attorney, Office of the Chief Counsel for Trade Enforcement and Compliance, U.S. Department of Commerce, of Washington, D.C.

Maureen E. Thorston, Wiley Rein LLP, of Washington, D.C., argued for Defendant-Intervenor Rebar Trade Action Coalition. With her on the brief were Alan H. Price, John R. Shane, and Stephanie M. Bell.

Katzmann, Judge: In 2020, the government of Turkey exempted Plaintiff Kaptan Demir

Celik Endustrisi ve Ticaret A.S. (“Kaptan”)—a Turkish producer of steel concrete reinforcing bar

(“rebar”) 1—from a tax it normally imposes on certain transactions involving the exchange of

foreign currency. Meanwhile, Nur Gemicilik ve Ticaret A.S. (“Nur”), a shipbuilding company

affiliated with Kaptan, enjoyed rent-free industrial use of state-owned land. The U.S. Department

of Commerce (“Commerce”), in the 2020 administrative review of its countervailing duty order

on rebar from Turkey, determined both of these boons to be countervailable subsidies benefitting

Kaptan. See Steel Concrete Reinforcing Bar From the Republic of Turkey: Final Results of

Countervailing Duty Administrative Review and Rescission, in Part; 2020, 88 Fed. Reg. 34129

(Dep’t Com. May 26, 2023), P.R. 156 (“Final 2020 Review”) and accompanying memorandum,

Mem. from J. Maeder to L. Wang, re: Issues and Decision Memorandum for the Final Results of

the Countervailing Duty Administrative Review of Steel Concrete Reinforcing Bar from the

Republic of Turkey; 2020 (Dep’t Com. May 22, 2023), P.R. 152 (“IDM”). Commerce calculated

the value of these putative subsidies and issued equivalent ad valorem countervailing duties on

Kaptan’s imports of rebar into the United States. See Final 2020 Review at 34130.

1 “௘‘Rebar,’ which is a portmanteau of ‘reinforcing’ and ‘bar,’ refers to rods of steel that are embedded into concrete as a means of strengthening the resulting structure.” Kaptan Demir Celik Endustrisi ve Ticaret A.S. v. United States (“Kaptan I Remand”), 47 CIT __, __ n.1, 666 F. Supp. 3d 1334, 1336 n.1 (2023) (citations omitted). Court No. 23-00131 Page 3

Kaptan, in a Motion for Judgment on the Agency Record, 2 now challenges two aspects of

the Final 2020 Review. See Pl.’s Mot. for J. on the Agency R., Nov. 13, 2023, ECF No. 29 (“Pl.’s

Br.”). First, Kaptan challenges Commerce’s determination that the foreign currency exchange tax

exemption is “specific”—which, as explained below, is a statutory requirement for

countervailability. Second, Kaptan challenges Commerce’s estimation of the value of the

government-owned land that Nur used for free. Defendant the United States (“the Government”)

and Defendant-Intervenor Rebar Trade Action Coalition (“RTAC”), a group of U.S.-based rebar

producers, oppose Kaptan’s motion. See Gov’t Br.; Def.-Inter.’s Br.

The court remands both challenged aspects of the Final 2020 Review for Commerce’s

further explanation or reconsideration.

BACKGROUND

The court assumes familiarity with Kaptan’s challenges to prior Commerce determinations

in relation to the countervailing duty order on Turkish rebar and subsequent administrative reviews

thereof, including the background recounted in Kaptan Demir Celik Endustrisi ve Ticaret A.S. v.

United States (“Kaptan I”), 47 CIT __, 633 F. Supp. 3d 1276 (2023), and in Kaptan I Remand, 47

CIT __, 666 F. Supp. 3d 1334. A summary of the background most relevant to this particular

2 Plaintiff-Intervenor Icdas Celik Enerji Tersane ve Ulasim Sanayi A.S. (“Icdas”) is also a Turkish producer-importer of rebar that is subject to countervailing duties pursuant to the Final 2020 Review. Icdas has filed a Motion for Judgment on the Agency Record of its own, requesting that “[t]o the extent that Commerce recalculates Kaptan’s rate as a result of this litigation, it must redetermine the “all-others” rate applied to Icdas in accordance with the statute.” Pl.-Inter.’s Mot. for J. on the Agency R. at 3, Nov. 13, 2023, ECF No. 30 (“Pl.-Inter.’s Br.”). This request is effectively unopposed, see Def.’s Resp. to Pl.’s Mot. for J. on the Agency R. at 19, Jan. 29, 2024, ECF No. 33 (“Gov’t Br.”); Def.-Inter.’s Resp. to Pl.’s Mot. for J. on the Agency R. at 25–26, Jan. 29, 2024, ECF No. 31 (“Def.-Inter.’s Br.”), and the court accordingly instructs Commerce to recalculate Icdas’s rate as necessary to reflect any potential changes made to Kaptan’s on remand. Court No. 23-00131 Page 4

case is below.

I. Legal and Regulatory Framework

The Tariff Act of 1930, as amended, provides for the imposition of countervailing duties

on imported merchandise where Commerce finds that “the government of a country or any public

entity within the territory of a country is providing, directly or indirectly, a countervailable subsidy

with respect to the manufacture, production, or export of” that merchandise. 19 U.S.C.

§ 1671(a)(1); see also id. §§ 1671e, 1675(1) (providing for Commerce’s issuance of a

countervailing duty order and conduct of annual administrative reviews thereof). Countervailable

subsidies must be “specific,” and may include financial contributions in the form of a foreign

government’s “foregoing or not collecting revenue that is otherwise due, such as granting tax

credits or deductions from taxable income.” Id. § 1677(5)(D)(ii). This, in turn, includes cases

where “goods or services are provided for less than adequate remuneration,” which “shall be

determined in relation to prevailing market conditions for the good or service being provided or

the goods being purchased in the country which is subject to the investigation or review.” Id.

§ 1677(5)(E)(iv).

Commerce’s regulations provide a more detailed framework for the measurement of

“adequate remuneration”:

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Kaptan Demir Celik Endustrisi ve Ticaret A.S. v. United States, 736 F. Supp. 3d 1318, 2024 CIT 116 (cit 2024).

736 F. Supp. 3d 1318 (Kaptan Demir Celik Endustrisi ve Ticaret A.S. v. United States) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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