Shanghai Tainai Bearing Co. v. United States

2024 CIT 143
CourtUnited States Court of International Trade
DecidedDecember 18, 2024
Docket23-00020
StatusPublished

This text of 2024 CIT 143 (Shanghai Tainai Bearing Co. 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
Shanghai Tainai Bearing Co. v. United States, 2024 CIT 143 (cit 2024).

Opinion

Slip Op. No. 24-143 UNITED STATES COURT OF INTERNATIONAL TRADE

SHANGHAI TAINAI BEARING CO., LTD. and C&U AMERICAS, LLC,

Plaintiffs,

and Before: Stephen Alexander Vaden, ZHEJIANG JINGLI BEARING Judge TECHNOLOGY CO., LTD., Court No. 1:23-cv-00020 (SAV) Plaintiff-Intervenor,

v.

UNITED STATES,

Defendant.

OPINION

[Sustaining the Department of Commerce’s Final Results and Denying Plaintiffs’ Motion for Judgment on the Agency Record.]

Dated: December 18, 2024

David J. Craven, Craven Trade Law LLC, of Chicago, IL, for Plaintiffs Shanghai Tainai Bearing Co., Ltd. and C&U Americas, LLC.

John J. Kenkel, International Trade Law Counselors, PLLC, of Alexandria, VA, for Plaintiff-Intervenor Zhejiang Jingli Bearing Technology Co., Ltd.

Geoffrey M. Long, Senior Trial Counsel, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, DC, for Defendant United States. With him on the brief were Brian M. Boynton, Principal Deputy Assistant Attorney General; Patricia M. McCarthy, Director, Commercial Litigation Branch; L. Misha Preheim, Assistant Director, Commercial Litigation Branch; Jesus N. Saenz, Court No. 1:23-cv-00020 Page 2

and Benjamin Juvelier, Of Counsel, U.S. Department of Commerce, Office of the Chief Counsel for Trade Enforcement & Compliance.

Vaden, Judge: Plaintiffs Shanghai Tainai Bearing Co., Ltd. and C&U

Americas, LLC (collectively Tainai) filed suit objecting to the Department of

Commerce’s (Commerce) resolution of the thirty-fourth administrative review of the

antidumping order on tapered roller bearings from China. Joined by Plaintiff-

Intervenor Zhejiang Jingli Bearing Technology Co., Ltd. (Jingli), Tainai brings

multiple claims of error against Commerce’s final determination. The Court finds

these claims unavailing. Commerce’s determination to apply a partial adverse

inference based on Tainai’s failure to cooperate to the best of its ability is supported

by substantial evidence. Its determination to exclude from U.S. price additional

revenue that Tainai invoiced as Section 301 duty payments is also supported by

substantial evidence. Tainai’s remaining claims raise similar legal issues to those

advanced in its challenge to the thirty-third administrative review so that the Court’s

legal reasoning in Shanghai Tainai Bearing Co. v. United States (Tainai I), 47 CIT

__, 658 F. Supp. 3d 1269 (2023), as applied to the facts of this case, leads the Court to

reject them as well. The Motion for Judgment on the Agency Record is DENIED,

and Commerce’s Final Results are SUSTAINED. Court No. 1:23-cv-00020 Page 3

BACKGROUND

Tainai is a Chinese manufacturer of tapered roller bearings.1 It purchases

components used in manufacturing tapered roller bearings from a network of

unaffiliated suppliers. See Tainai I, 47 CIT __, 658 F. Supp. 3d at 1284–85. Tapered

roller bearings are made from rollers, cages, cups, and cones. Rollers are steel

cylinders held together in a housing called a cage. Caged rollers are inserted between

two steel rings, allowing movement. The inner ring is the cone, and the outer ring is

the cup. The antidumping order on tapered roller bearings from China (the Order)

has been in place since June 15, 1987, and covers:

[T]apered roller bearings and parts thereof, finished and unfinished, from China; flange, take up cartridge, and hanger units incorporating tapered roller bearings; and tapered roller housings (except pillow blocks) incorporating tapered rollers, with or without spindles, whether or not for automotive use.

Tapered Roller Bearings and Parts Thereof, Finished and Unfinished, from the

People’s Republic of China: Final Results of Review; 2020-2021, 88 Fed. Reg. 1,359,

1,360 (Dep’t of Com. Jan. 10, 2023) (Final Results), and accompanying Issues and

Decisions Mem. (IDM) at 2, J.A. at 1,004, ECF No. 42. Tainai’s Motion for Judgment

on the Agency Record challenges the Final Results of the thirty-fourth administrative

review of the Order, covering imports from China from June 1, 2020 through May 31,

1 Shanghai Tainai Bearing Co., Ltd. brought its Motion together with another entity, C&U

Americas, LLC. Compl. ¶3, ECF No. 8. In earlier proceedings before this Court, Tainai failed to explain the relationship between itself and C&U Americas. See Shanghai Tainai Bearing Co. v. United States, 46 CIT __, 582 F. Supp. 3d 1299, 1308 (2022) (referring to the “recurring mystery” of the relationship between Shanghai Tainai Bearing Co. and C&U Americas and noting that Plaintiffs’ counsel declined the Court’s request to shed light on it). The Court therefore refers generally to Plaintiffs as Tainai. Court No. 1:23-cv-00020 Page 4

2021 (the Period of Review). Initiation of Antidumping and Countervailing Duty

Administrative Reviews, 86 Fed. Reg. 41,821, 41,825 (Dep’t of Com. Aug. 3, 2021).

I. The Disputed Administrative Review

On August 3, 2021, Commerce initiated a review of the Order. Id. at 41,821.

Commerce selected Tainai as a mandatory respondent. Issues and Decisions Mem.

accompanying the Preliminary Results (PDM) at 2, J.A. at 4,154 n.4, ECF No. 42.

Plaintiff-Intervenor Jingli was not selected for individual examination. Second Resp’t

Selection Mem. at 3, J.A. at 1,350, ECF No. 42. Commerce issued its initial

questionnaire to Tainai. Initial Questionnaire, J.A. at 1,353, ECF No. 42. It asked

Tainai to obtain factors of production information from its unaffiliated suppliers. Id.

at 1,406–11. Tainai submitted its response, but Commerce later found that “it does

not appear that Tainai made any attempt to request [factors of production]

information from its unaffiliated suppliers in response to the initial questionnaire,

nor did Tainai alert Commerce of any difficulties in obtaining accurate [factors of

production] information.” IDM at 8, J.A. at 1,010, ECF No. 42.

To calculate a proper dumping margin, Commerce needed complete factors of

production information from Tainai. When dealing with nonmarket economies like

China, Commerce does not typically accept the prices producers pay for inputs as

representing fair market value. Instead, Commerce must determine the value of the

subject merchandise “on the basis of the value of the factors of production utilized in

producing the subject merchandise” and then add “an amount for general expenses

and profit plus the cost of containers, coverings, and other expenses.” 19 U.S.C. § Court No. 1:23-cv-00020 Page 5

1677b(c)(1) (flush language). Commerce does this by using the costs for a producer of

similar merchandise located in a market economy country of comparable development

to the country being examined. 19 C.F.R. § 351.408(a)–(b) (“[Commerce] normally

will calculate normal value by valuing the nonmarket economy producers’ factors of

production in a market economy country.”). In other words, rather than accepting

that the price the non-market economy manufacturer paid represents the fair value

of the sum of (1) the cost of the product’s components; (2) general expenses and profit;

and (3) the cost of containers, coverings, and other expenses, Commerce constructs

this amount itself by determining a value for each individual input. 19 U.S.C. §

1677b(c)(1) (flush language). “Commerce values certain factors of production, such

as selling, general and administrative expenses, factory overhead, and profit, by

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