Seafood Exps. Ass'n of India v. United States

United States Court of International Trade·Decided September 4, 2026·No. 25-00031·Published

Opinion

Slip Op. 26-106

UNITED STATES

COURT OF INTERNATIONAL TRADE

Court No. 25-00031

SEAFOOD EXPORTERS ASSOCIATION OF INDIA, Plaintiff,

v.

UNITED STATES,

Defendant,

and

AD HOC SHRIMP TRADE ACTION COMMITTEE and

AMERICAN SHRIMP PROCESSORS ASSOCIATION,

Defendant-Intervenor.

Before: M. Miller Baker, Judge

OPINION

[Sustaining the International Trade Commission’s affirmative material-injury determination.]

Dated: September 4, 2026

Henry D. Almond, J. David Park, Lynn M. Fischer Fox, Kang Woo Lee, and Archana Rao P. Vasa, Arnold & Porter Kaye Scholer LLP, Washington, DC, on the briefs for Plaintiff.

Margaret D. Macdonald, General Counsel; Karl von Schriltz, Assistant General Counsel for Litigation; and John D. Henderson, Attorney-Advisor, Office of the General Counsel, U.S. International Trade Commission , Washington, DC, on the brief for Defendant.

Nathaniel Maandig Rickard, Zachary J. Walker, and Anjelika D. Jani, Picard Kentz & Rowe LLP, Washington , DC, on the brief for Defendant-Intervenor Ad Hoc Shrimp Trade Action Committee.

Roger B. Schagrin, Elizabeth J. Drake, and Nicholas C. Phillips, Schagrin Associates, Washington, DC, on the brief for Defendant-Intervenor American Shrimp Processors Association.

Baker, Judge: An Indian seafood exporters association challenges the International Trade Commission’s finding that domestic shrimp business suffered material injury from cheap imports subsidized by foreign governments. The group argues that the agency incorrectly defined the “domestic like product” to include frozen cooked shrimp, rather than just the raw variety . It also contends that the imports fill a “supply gap” that the domestic industry cannot serve, such that there can be no harm. For the reasons explained below , the court sustains the Commission’s determination .

I

To combat unfair trade practices, the Tariff Act of 1930, as amended, provides a mechanism for imposing remedial countervailing duties on imported merchandise subsidized by foreign governments. 19 U.S.C.

§ 1671(a). In that process, the Department of Commerce defines the foreign goods, “the subject merchandise ,” that it investigates. Hitachi Metals, Ltd. v. United States, 949 F.3d 710, 714 (Fed. Cir. 2020).

The Commission then has the task of determining whether American producers of a “domestic like product ” suffer material injury because of those imported goods. That term refers to “a U.S. product which is like, or . . . most similar in characteristics and uses[,] to the subject merchandise.” Id. (cleaned up).

Thus, the two agencies’ respective definitions of “subject merchandise” and “domestic like product” are “critical because they define both the scope of the investigations and the scope of any resulting trade relief, such as the assessment of . . . duties.” Full Member Subgrp. of Am. Inst. of Steel Constr., LLC v. United States, 81 F.4th 1242, 1249 n.1 (Fed. Cir. 2023) (citation omitted).

The statute instructs the Commission to use Commerce ’s definition of “subject merchandise” as the starting point for determining what the “domestic like product” is. The former agency “then conducts a sixfactor inquiry that evaluates whether the subject merchandise corresponds with a single domestic like product or” multiple ones. Hitachi, 949 F.3d at 715.

The six factors are “(1) physical characteristics and uses; (2) channels of distribution; (3) interchangeability ; (4) customer and producer perceptions; (5) common manufacturing facilities, production processes, and production employees; and where appropriate

(6) pricing.” Id. The Commission applies them on a case-by-case basis and no single one is dispositive. Jeld-Wen, Inc. v. United States, 567 F. Supp. 3d 1344, 1350 n.2 (CIT 2022).

Once the agency defines the domestic like product, it must determine whether the subject imports caused “material injury” to the relevant industry. This term “means harm which is not inconsequential, immaterial , or unimportant.” 19 U.S.C. § 1677(7)(A).

For that inquiry, the statute directs the Commission to consider the volume of imports of subject merchandise ; the effect those imports have on U.S. pricing for domestic like products; and the impact of such imports on U.S. producers of domestic like products. Id. § 1677(7)(B)(i)(I)–(III). For each of those three factors, the statute enumerates corresponding criteria the agency must also examine. Id. § 1677(7)(C)(i)–(iii).

II

This is one of a trilogy of cases in which foreign plaintiffs challenge the Commission’s finding that subsidized imports from Ecuador, India, and Vietnam materially injured the domestic shrimp industry. See 89 Fed. Reg. 102,163, Appx001354. The period of investigation was January 1, 2021, to March 31, 2024. Id.

Two aspects of the agency’s decision are relevant here: First, its definition of the domestic like product. Second, its rejection of the contention that imports filled a “supply gap” that U.S. fishermen could not satisfy .

A

The Commission stated that its first task was to define the domestic like product and, relatedly, the relevant industry. Appx001268. It acknowledged that it must accept Commerce’s definition of “subject merchandise ” (the imports under investigation) without modification. Appx001269 & n.11. Even so, it observed that description does not control the Commission’s like-product determination. Appx001268 & nn.11–13 (citing cases).

Here, Commerce’s definition of the subject merchandise was lengthy. See Appx001270–001272 (quoting 89 Fed. Reg. 85,498, 85,499–500). Suffice it to say that the Department’s investigation covered frozen warmwater shrimp, both wild-caught and farmed, and both cooked and raw. Appx001270–001271.

The domestic industry groups and the Indian exporters disagreed over whether the Commission’s domestic like product should include frozen cooked shrimp. Appx001273. The former advocated treating all frozen shrimp—cooked or raw—as a single domestic like product, while the latter favored defining cooked shrimp as something separate from raw. Id.

After reciting the parties’ arguments, the agency defined a single domestic like product that included the cooked variety. Appx001277. It considered the six factors as follows:

x As to physical characteristics and uses, it found that all in-scope frozen shrimp have similar physical characteristics, even if they are cooked, and have

“the same predominant end use,” i.e., they are food. Appx001278. “Although frozen cooked shrimp is sold already cooked and ready to eat (once thawed), as Indian Respondents emphasize, this does not establish a significant difference in physical characteristics or end uses from frozen raw shrimp.” Appx001278–001279.

x For manufacturing facilities, production processes, and employees, the Commission stated that the record showed a substantial overlap in the production processes for raw and cooked shrimp because they both undergo “the same initial processing steps.” Appx001279. But it found that production of cooked shrimp requires expensive specialized equipment, and it noted the Indian exporters’ evidence that cooked-shrimp producers need FDA approval and must adhere to strict hygiene standards. Id. The domestic industry, meanwhile, contended that some U.S. producers could prepare both cooked and raw frozen shrimp at the same facilities. Appx001279– 001280.

x The Commission said the record lacked specific evidence about channels of distribution. It noted that while the Indian exporters argued that cooked shrimp’s sale to retailers and grocery chains was a “distinct” channel, they also admitted that raw shrimp may be sold to the same channel, and the domestic petitioners presented evidence that retailers and major food service distributors carry both types. “Thus, there appears to be some overlap in channels of distribution between cooked shrimp and raw shrimp, and no evidence of a ‘distinct’

channel for cooked shrimp that does not include raw shrimp as well.” Appx001280.

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