School Specialty, LLC v. United States

2025 CIT 97
CourtUnited States Court of International Trade
DecidedJuly 31, 2025
Docket24-00098
StatusPublished

This text of 2025 CIT 97 (School Specialty, LLC 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
School Specialty, LLC v. United States, 2025 CIT 97 (cit 2025).

Opinion

Slip Op. 25-97

UNITED STATES COURT OF INTERNATIONAL TRADE

Court No. 24-00098

SCHOOL SPECIALTY, LLC, Plaintiff, v. UNITED STATES, Defendant, and DIXON TICONDEROGA COMPANY, Defendant-Intervenor.

Before: M. Miller Baker, Judge

OPINION

[The court sustains Commerce’s country-of-origin de- termination in part and remands in part.]

Dated: July 31, 2025

Nithya Nagarajan and Jamie L. Shookman, Husch Blackwell LLP, Washington, DC, on the briefs for Plaintiff.

Brian M. Boynton, Principal Deputy Assistant Attor- ney General; Patricia M. McCarthy, Director; Franklin E. White, Jr., Attorney; and Augustus Golden, Attor- ney, Commercial Litigation Branch, Civil Division, Ct. No. 24-00098 Page 2

U.S. Department of Justice, Washington, DC, on the brief for Defendant. Of counsel on the brief was Chris- topher Alan Kimura, Attorney, Office of Chief Counsel for Trade Enforcement and Compliance, U.S. Depart- ment of Commerce, Washington, DC.

Felicia Leborgne Nowels, Michael J. Larson, and Li X. Massie, Akerman LLP, Tallahassee, FL, on the brief for Defendant-Intervenor.

Baker, Judge: This case is about the making of pen- cils, a subject dear to the heart of one of the great econ- omists of the 20th century, Milton Friedman. 1 An im- porter challenges the Department of Commerce’s de- termination that pencils exported from the Philippines

1 Friedman and his wife and co-author famously used the

example of a humble pencil to illustrate “how voluntary ex- change enables millions of people to cooperate with one an- other.” Milton & Rose Friedman, Free to Choose 11 (1980). With the purchase of a single pencil, “we are exchanging a little bit of our services for the infinitesimal amount of ser- vices that each of the thousands [of people] contributed to- ward” its production. Id. at 12–13. They describe the log- ging in the Pacific Northwest; “millwork involved in con- verting the logs to slats”; the mining of graphite in Ceylon; the manufacture “of metal—the ferrule—near the top of the pencil”; the making of the eraser with seed oil from In- donesia, “known in the trade as the plug”; and the assem- bly of these components in Wilkes-Barre, Pennsylvania. Id. How did all this happen in the absence of “a central office [giving] orders to these thousands of people”? Id. at 13. “Adam Smith gave us the answer two hundred [and fifty] years ago.” Id. Ct. No. 24-00098 Page 3

are within the scope of an order imposing antidumping duties on such merchandise from China. As explained below, the court sustains the determination in part and remands in part for further proceedings.

I

An antidumping or countervailing duty order’s “de- scription of the subject merchandise” defines the prod- ucts it covers. 19 U.S.C. § 1673e(a)(2). In issuing such decrees, Commerce’s practice is to “describe[୻] the prod- uct ‘within the scope of the order’ by reference to its ‘technical characteristics’ and ‘country of origin’ . . . .” BYD (H.K.) Co. v. United States, Slip Op. 25-60, at 3, 2025 WL 1420318, at *1 (CIT 2025) (cleaned up and quoting Canadian Solar, Inc. v. United States, 918 F.3d 909, 913 (Fed. Cir. 2019)), appeal pending, No. 25-1937 (Fed. Cir.).

The nature of the global marketplace and the “ever- changing varieties” of commodities available naturally prompt questions “as to whether a particular product is subject to” such orders. Saha Thai Steel Pipe Pub. Co. v. United States, 101 F.4th 1310, 1315 (Fed. Cir. 2024) (citing 19 C.F.R. § 351.225(a)). By regulation— the statute provides no such mechanism—a producer, importer, or other interested party uncertain about whether a product falls within an order’s ambit may ask the Department for a ruling to clarify the decree’s Ct. No. 24-00098 Page 4

terms. See 19 C.F.R. § 351.225(c)(1). Such a proceeding is called a “scope inquiry.” Id. § 351.225(a). 2

In a scope inquiry, Commerce may need to “deter- mine the country of origin” of the merchandise at is- sue. Id. § 351.225(j). To do so, it “may” conduct a “sub- stantial transformation analysis” to identify the fin- ished product’s country of origin. Id. § 351.225(j)(1). 3

In that exercise, the Department “may . . . con- sider[୻] relevant factors that arise on a case-by-case ba- sis, including” (i) whether “the processed downstream product is a different class or kind of merchandise than the upstream product,” (ii) the “physical charac- teristics . . . of the product,” (iii) the “intended end-use of the downstream product,” (iv) the “cost of produc- tion/value added of further processing in the third country,” (v) the “nature and sophistication of process- ing in” that nation, and (vi) the “level of investment”

2 “This device is roughly analogous to the procedure by which a party uncertain of its rights or obligations may seek a declaratory judgment in federal court.” Fedmet Res. Corp. v. United States, Slip Op. 24-136, at 3 n.1, 2024 WL 5088294, at *1 n.1 (CIT 2024) (citing 28 U.S.C. § 2201). 3 The Department has discretion not to apply its substan-

tial transformation test when it determines that this anal- ysis is “not appropriate.” See 86 Fed. Reg. 52,300, 52,321. In those cases, it can apply a “different, reasonable test.” Id.; cf. Canadian Solar, 918 F.3d at 919 (“Commerce pro- vided ‘good reasons for’ departing from the substantial transformation test . . . .”) (quoting FCC v. Fox Television Stations, Inc., 556 U.S. 502, 515 (2009)). Ct. No. 24-00098 Page 5

there. 19 C.F.R. § 351.225(j)(1)(i)–(vi). It “also may consider” where the product’s “essential component” is made or where its “essential characteristics” are im- parted. Id. § 351.225(j)(2). These “listed factors are not exhaustive, because Commerce must retain the flexi- bility to adjust its . . . analysis when the facts on the record warrant” doing so. 86 Fed. Reg. at 52,321.4

In making a country-of-origin determination, the Department “is not bound by the determinations of any other agency,” including Customs and Border Pro- tection rulings. Id. § 351.225(j). Even so, such deci- sions are another “type of evidence for Commerce to consider,” SolarWorld Americas, Inc. v. United States, 910 F.3d 1216, 1225 (Fed. Cir. 2018)—or, in the judi- cial vernacular, persuasive authority.

II

In 1994, the Department issued an antidumping duty order covering pencils from China. 59 Fed. Reg. 66,909. It applies to “certain cased pencils of any shape or dimension which are writing and/or drawing

4 As a result, Commerce has sometimes applied “different

iterations of [its] substantial transformation analysis.” Id. (internal quotation marks omitted). Ct. No. 24-00098 Page 6

instruments that feature cores of graphite or other ma- terials encased in wood and/or man-made materials . . . .” Id. 5

School Specialty, LLC, is a pencil importer. Appx000012. In 2023, it asked Commerce to declare that the order—which is still in effect—does not cover its pencils exported by a Philippine producer. Appx000007–000239. 6

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