MTD Prods. Inc. v. United States

2023 CIT 34
United States Court of International Trade·Decided March 16, 2023·No. 21-00264·Published

Opinion

Slip Op. 23-34

UNITED STATES

COURT OF INTERNATIONAL TRADE

Court No. 21-00264

MTD PRODUCTS INC.,

Plaintiff,

v.

UNITED STATES,

Defendant,

and

BRIGGS & STRATTON, LLC,

Defendant-Intervenor.

Before: M. Miller Baker, Judge

OPINION

[The court denies Plaintiff’s motion for judgment on the agency record and instead grants judgment for Defendant and Defendant-Intervenor.]

Dated: March 16, 2023

Alex Schaefer, Crowell & Moring LLP of Washington, DC, argued for Plaintiff. With him on the briefs was Michael Bowen.

Henry N.L. Smith, Office of the General Counsel, U.S. International Trade Commission of Washington, DC, argued for Defendant. With him on the brief was

Andrea C. Casson, Assistant General Counsel for Litigation .

Cliff Long, King & Spalding LLP of Washington, DC, argued for Defendant-Intervenor. On the brief for Defendant -Intervenor was Stephen J. Orava.

Baker, Judge: In this case stemming from antidumping and countervailing duty investigations of small vertical shaft engines from China, a domestic importer challenges the International Trade Commission ’s finding that a surge in imports shortly before duties took effect warranted retroactive application of such duties. For the reasons set out below, the court sustains the Commission’s determination.

I

Under the Tariff Act of 1930, as amended, the Commerce Department ordinarily imposes antidumping and countervailing duties prospectively. See 19 C.F.R. § 351.206(a) (explaining that antidumping and countervailing duties normally apply to entries of merchandise “made on or after the date on which the Secretary first imposes provisional measures (most often the date on which notice of an affirmative preliminary determination is published in the Federal Register)”); see also 19 U.S.C. §§ 1671b(d)(2)(B) (countervailing duties ), 1673b(d)(2)(B) (antidumping duties).

But the statute also contains a procedure allowing for retroactive application of duties in certain situa-

tions. If the petitioner whose allegations sparked the investigation alleges “critical circumstances,” the Department must also determine whether “there have been massive imports of the subject merchandise over a relatively short period.” 19 U.S.C. §§ 1671d(a)(2) (countervailable subsidies), 1673d(a)(3) (dumping).

If Commerce finds such critical circumstances, the Commission must then determine whether the imports in question “are likely to undermine seriously the remedial effect” of the order to be issued. Id. §§ 1671d(b)(4)(A)(i) (countervailable subsidies), 1673d(b)(4)(A)(i) (dumping). In making that determination , the Commission must consider

(I) the timing and volume of the imports,

(II) a rapid increase in inventories of the imports , and

(III) any other circumstances indicating that the remedial effect of the [countervailing or antidumping ] duty order will be seriously undermined .

Id. §§ 1671d(b)(4)(A)(ii), 1673d(b)(4)(A)(ii).

If the Commission finds that the surge in imports is likely to undermine the remedial effect of the countervailing duty and antidumping orders, duties may be imposed retroactively. The procedure varies depending on the facts of any given case, but as relevant here,

the duties may apply retroactively “to unliquidated entries of merchandise entered, or withdrawn from warehouse , for consumption on or after 90 days before the date on which suspension of liquidation was first ordered .” Id. §§ 1671b(e)(2)(A), 1671d(c)(4), 1673b(e)(2)(A), 1673d(c)(4). The mechanism’s purpose is to prevent clever importers from circumventing impending antidumping and countervailing duties by rushing in their shipments before the duties take effect . See H.R. Rep. 96–317, 96th Cong., 1st Sess. at 63 (1979).

II

A

Briggs & Stratton, LLC, is an American producer of “small vertical shaft engines.” Such engines are typically used in lawn mowers, pressure washers, and other outdoor power equipment. Appx2306–2307. In 2020, Briggs & Stratton petitioned the Commission and Commerce for relief against alleged Chinese dumping of these engines, which the company asserted injured domestic industry.

In response, the Commission opened both antidumping and countervailing duty investigations to determine whether a domestic industry was injured by imports of such engines from China “that are alleged to be sold in the United States at less than fair value and alleged to be subsidized by the Government of China.” Small Vertical Shaft Engines from China;

Institution of Anti-Dumping and Countervailing Duty Investigations and Scheduling of Preliminary Phase Investigations, 85 Fed. Reg. 16,958, 16,958 (ITC Mar. 25, 2020). Commerce likewise found the petition sufficient to justify launching investigations. Certain Vertical Shaft Engines Between 99cc and up to 225cc, and Parts Thereof from the People’s Republic of China: Initiation of Countervailing Duty Investigation, 85 Fed. Reg. 20,667, 20,667 (Dep’t Commerce Apr. 14, 2020); Certain Vertical Shaft Engines Between 99cc and up to 225cc, and Parts Thereof from the People’s Republic of China: Initiation of Less-Than-Fair-Value Investigation, 85 Fed. Reg. 20,670 (Dep’t Commerce Apr. 14, 2020). MTD Products Inc., a domestic importer of small vertical shaft engines from China, participated in these proceedings before both agencies.

Shortly after the agencies began the investigations, Briggs & Stratton filed an amended petition alleging that critical circumstances existed. See Certain Vertical Shaft Engines Between 99cc and up to 225cc, and Parts Thereof from the People’s Republic of China: Preliminary Affirmative Determination of Critical Circumstances , in Part, in the Countervailing Duty Investigation , 85 Fed. Reg. 68,851, 68,851 (Dep’t Commerce Oct. 30, 2020) (discussing Briggs & Stratton’s critical circumstances allegation).

B

In both the antidumping and countervailing duty investigations, Commerce preliminarily found critical

circumstances existed as to imports of certain (but not all) small vertical engines from China. Certain Vertical Shaft Engines Between 99cc and up to 225cc, and Parts Thereof, from the People’s Republic of China: Preliminary Affirmative Determination of Sales at Less Than Fair Value, and Preliminary Affirmative Determination of Critical Circumstances, in Part, 85 Fed. Reg. 66,932, 66,933 (Dep’t Commerce Oct. 21, 2020) (antidumping duty); 85 Fed. Reg. at 68,851–52 (countervailing duty).

In its final determinations, Commerce continued to find that critical circumstances existed for imports of small vertical engines from a group of related entities known as the “Zongshen Companies” (collectively, Zongshen) and, in the antidumping duty investigation, for the China-wide entity. 1 Certain Vertical Shaft Engines Between 99cc and up to 225cc, and Parts Thereof, from the People’s Republic of China: Final Affirmative Determination of Sales at Less Than Fair Value and Final Determination of Critical Circumstances, in Part, 86 Fed. Reg. 14,077, 14,078 (Dep’t Commerce Mar. 12, 2021) (antidumping duty); Appx1210 (countervailing duty).

1For an overview of the “country-wide rate” applicable in non-market economy matters, such as those involving China, see Hung Vuong Corp. v. United States, 483 F. Supp. 3d 1321, 1340–41 (CIT 2020).

C

For its part, the Commission found “that imports subject to Commerce’s affirmative critical circumstances determinations in the antidumping and countervailing duty investigations are likely to undermine seriously the remedial effect of the antidumping and countervailing duty orders.” Small Vertical Shaft Engines from China, 86 Fed. Reg. 22,975, 22,975 n.2 (ITC Apr. 30, 2021).

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