Precision Components, Inc. v. United States

2025 CIT 20
CourtUnited States Court of International Trade
DecidedFebruary 25, 2025
Docket23-00218
StatusPublished

This text of 2025 CIT 20 (Precision Components, Inc. 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
Precision Components, Inc. v. United States, 2025 CIT 20 (cit 2025).

Opinion

Slip Op. 25-20

UNITED STATES COURT OF INTERNATIONAL TRADE

PRECISION COMPONENTS, INC.,

Plaintiff, Before: Joseph A. Laroski, Jr., Judge v. Court No. 23-00218 UNITED STATES,

Defendant,

OPINION

[Denying Plaintiff’s Motion for Judgment on the Agency Record and sustaining the U.S. Department of Commerce’s determination interpreting the scope of the antidumping duty order on tapered roller bearings from China.]

Dated: February 25, 2025

David J. Craven, Craven Trade Law LLC, of Chicago, IL, argued for plaintiff Precision Components, Inc.

Geoffrey M. Long, Senior Trial Counsel, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, DC, argued for defendant United States. With him on the brief were Brian M. Boynton, Principal Deputy Attorney General, Patricia M. McCarthy, Director, L. Misha Preheim, Assistant Director. Of counsel was Jesus N. Saenz, Attorney, Office of the Chief Counsel for Trade Enforcement & Compliance, U.S. Department of Commerce.

Laroski, Judge: This action is a challenge to the final scope ruling of the U.S.

Department of Commerce (“Commerce”) regarding certain low-carbon steel blanks

(the “merchandise”) imported from the People’s Republic of China (“China”) by

Precision Components, Inc. (“Precision”). Commerce’s final scope ruling found that

the merchandise is covered by the antidumping duty order on tapered roller Court No. 23-00218 Page 2

bearings, including finished and unfinished parts thereof, from China. Final Scope

Ruling on Precision Components, Inc.’s Low-Carbon Steel Blanks, P.R. 22 (Sept. 19,

2023) (“2023 Scope Ruling”); see also Antidumping Duty Order on Tapered Roller

Bearings and Parts Thereof, Finished and Unfinished, from the People’s Republic of

China, 52 Fed. Reg. 22,667 (June 15, 1987), as amended, Tapered Roller Bearings

from the People’s Republic of China; Amendment to Final Determination of Sales at

Less than Fair Value and Antidumping Duty Order in Accordance with Decision

Upon Remand, 55 Fed. Reg. 6,669 (Feb. 26, 1990) (the “Order”). Commerce

concluded that the merchandise falls within the scope of the Order based on its

consideration of interpretive sources specified by 19 C.F.R. 351.225(k)(1), including

a 2020 scope ruling regarding steel blanks imported by Precision. Final Scope

Ruling on Precision Components, Inc.’s Green Machined but Not Heat-Treated

Components, P.R. 10 (“2020 Scope Ruling”). Precision brought this action against

the United States (the “Government”) to challenge Commerce’s final scope ruling.

Based on Commerce’s alleged failure to reach a decision regarding the merchandise

that is supported by substantial evidence and otherwise in accordance with law,

Precision moves for judgment on the agency record and asks the court to remand

proceedings to Commerce. The Government opposes Precision’s motion and asks

the court to sustain Commerce’s final scope ruling. For the reasons detailed below,

the court agrees with the Government. Plaintiff’s Motion for Judgment on the

Agency Record is denied, and Commerce’s determination is sustained. Court No. 23-00218 Page 3

BACKGROUND

I. The Order

On June 15, 1987, Commerce issued the Order. See Antidumping Duty

Order; Tapered Roller Bearings and Parts Thereof, Finished or Unfinished, from

the People’s Republic of China, 52 Fed. Reg. 22,667 (June 15, 1987); 2023 Scope

Ruling; 2020 Scope Ruling at 1. In the Order and later scope inquiries involving

products imported by Precision, Commerce has described the scope, in part, as

“tapered roller bearings and parts thereof, finished and unfinished, from China.”

2023 Scope Ruling at 6; 2020 Scope Ruling at 2.

II. Scope Inquiry Proceedings

A. 2020 Scope Ruling: Green-Machined but Not Heat-Treated

In 2020, Precision requested that Commerce issue a scope ruling on cups,

cones, and rollers that are silver metallic in color and green-machined, but not heat-

treated, at the time of importation into the United States (the “2020 merchandise”).

See Scope Ruling Application, P.R. 10 at 1 (Feb. 6, 2020) (“2020 Application”); 2020

Scope Ruling at 1–2. After considering comments from interested parties,

Commerce performed an extensive analysis of the interpretive sources specified by

section 351.225(k)(1) and the factors specified by subsection (k)(2). 2020 Scope

Ruling at 3–12. Commerce concluded that the 2020 merchandise was within the

scope of the Order. Id. at 11. Court No. 23-00218 Page 4

In reaching its conclusion, Commerce first reasoned there was sufficient

ambiguity between the plain language of the Order, a related final determination of

the International Trade Commission (“ITC”), and related scope rulings to require

consideration of the factors set forth in section 351.225(k)(2). Id. at 7–11. Noting its

obligations under that provision, Commerce then evaluated (a) the physical

characteristics of the 2020 merchandise, (b) its ultimate uses, (c) the expectations of

the ultimate purchasers, (d) the channels of trade, and (e) the manner of advertising

and display, concluding that each of these factors supported a finding that the

products were within the scope. Id. at 8–11.

Concerning physical characteristics, Commerce noted that, notwithstanding

Precision’s characterization of heat treatment as a transformative process, the 2020

merchandise already had the physical characteristics of unfinished tapered roller

bearings (“TRBs”) or parts thereof. Id. at 8. In Commerce’s words, even prior to

heat treatment, the 2020 merchandise was “very close to [its] final form.” Id.

With respect to the remaining factors, Commerce observed that Precision had

failed to articulate any scenario in which the 2020 merchandise would be imported

and subsequently processed for an end-use other than the manufacture of TRBs. Id.

at 8–10. Consequently, Commerce concluded none of the factors suggested the 2020

merchandise was anything other than an “unfinished TRB[].” Id. at 11.

Finally, Commerce bolstered its conclusion by highlighting two scope

inquiries concerning unfinished bearing parts subject to the antidumping order on Court No. 23-00218 Page 5

TRBs from Japan, which had been initiated based on the same petitions that gave

rise to the Order. Id. at 10 (referring to Memorandum, “TRBs from Japan -

American NTN Bearing Manufacturing corporation (ANBM) Scope Request on

Green Turned Rings,” (Green Rings Memorandum) (May 16, 1989) and

Memorandum, “Final Affirmative Determination in Scope Inquiry on Antidumping

Duty Order on Tapered Roller Bearings and Parts Thereof from Japan,” (Rough

Forgings Memorandum) (Jan. 26, 1995)). The products at issue in these prior scope

rulings, in Commerce’s view, were analogous to the 2020 merchandise because they

were “destined to become fully finished TRBs” and “sold through the same channels

of trade [with] the same end-use expectations.” Id.

Commerce issued its final scope ruling on June 12, 2020. Id. at 1. Precision

did not challenge the ruling.

B. 2023 Scope Ruling: Low-Carbon Steel Blanks

In 2023, Precision requested another scope inquiry under the Order, this time

identifying the products in question as “low-carbon steel blanks” (the “2023

merchandise”).

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2025 CIT 20, Counsel Stack Legal Research, https://law.counselstack.com/opinion/precision-components-inc-v-united-states-cit-2025.