Tianjin Magnesium Int'l Co. v. United States

2026 CIT 28
CourtUnited States Court of International Trade
DecidedMarch 13, 2026
Docket25-00002
StatusPublished

This text of 2026 CIT 28 (Tianjin Magnesium Int'l 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
Tianjin Magnesium Int'l Co. v. United States, 2026 CIT 28 (cit 2026).

Opinion

Slip Op. 26-28

UNITED STATES COURT OF INTERNATIONAL TRADE

TIANJIN MAGNESIUM INTERNATIONAL CO., LTD. AND TIANJIN MAGNESIUM METAL CO., LTD.,

Plaintiffs, Before: Timothy M. Reif, Judge

v. Court No. 25-00002

UNITED STATES,

Defendant.

OPINION AND ORDER

[Sustaining in part and remanding in part Commerce’s Final Results.]

Dated: March 13, 2026

David J. Craven, Craven Trade Law LLC, of Chicago, IL, for plaintiffs Tianjin Magnesium International Co., Ltd. and Tianjin Magnesium Metal Co., Ltd.

Kyle S. Beckrich, Trial Counsel, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, D.C., for defendant United States. With him on the brief were Brett A. Shumate, Assistant Attorney General, Patricia M. McCarthy, Director and Reginald T. Blades, Jr., Assistant Director. Of counsel was Paul Thornton, Attorney, Office of Chief Counsel for Trade Enforcement and Compliance, U.S. Department of Commerce, of Washington, D.C.

* * *

This action concerns the final results of the U.S. Department of Commerce

(“Commerce”) in the administrative review of the antidumping (“AD”) order on pure

magnesium from the People’s Republic of China (“China”) for the period of review

(“POR”) May 1, 2022, through April 30, 2023. Pure Magnesium from the People’s

Republic of China: Final Results of Antidumping Duty Administrative Review; 2022-2023 Court No. 25-00002 Page 2

(“Final Results”), 89 Fed. Reg. 100,967 (Dep’t of Commerce Dec. 13, 2024), PR 121,

and accompanying Issues and Decision Memorandum (“IDM”) (Dep’t of Commerce

Dec. 6, 2024), PR 117.

Tianjin Magnesium International Co., Ltd. and Tianjin Magnesium Metal Co., Ltd.

(collectively, “plaintiffs”) challenge certain aspects of the Final Results in a motion for

judgment on the agency record pursuant to U.S. Court of International Trade (“USCIT”)

Rule 56.2. Mot. Pursuant to Rule 56.2 Mot. of Pls. for J. on the Agency R. (“Pls. Mot.”),

ECF No. 17. Specifically, plaintiffs request that the court remand to Commerce for

reconsideration of its selection of Türkiye as the primary surrogate country and rejection

of Bulgaria. See Mem. of Law in Supp. of the Rule 56.2 Mot. of Pls. for J. on the

Agency R. (“Pls. Br.”), ECF No. 17-1.

For the reasons discussed below, the court sustains in part and remands in part

Commerce’s Final Results.

BACKGROUND

On May 12, 1995, Commerce issued the AD order on pure magnesium from

China. Notice of Antidumping Duty Orders: Pure Magnesium from the People’s

Republic of China, the Russian Federation and Ukraine; Notice of Amended Final

Determination of Sales at Less than Fair Value: Antidumping Duty Investigation of Pure

Magnesium from the Russian Federation, 60 Fed. Reg. 25,691 (Dep’t of Commerce

May 12, 1995).

On July 12, 2023, Commerce initiated the administrative review at issue here.

Initiation of Antidumping and Countervailing Duty Administrative Reviews, 88 Fed. Reg.

44,262 (Dep’t of Commerce July 12, 2024), PR 6. Court No. 25-00002 Page 3

On September 25, 2023, Commerce placed the Surrogate Country List (“SC

List”) on the record. Mem. from Commerce to Interested Parties Pertaining to

Interested Parties: Surrogate Value Mem. (Sept. 25, 2023), attach., PR 25. Commerce

described the SC List as “a non-exhaustive list of countries that Commerce has

determined, based on per capita Gross National Income (GNI), is [sic] at the same level

of economic development as China.” Id. at 1. Commerce solicited comments “on the

list as a starting point for surrogate country selection . . . and to propose for

consideration other countries that are at a level of economic development comparable

to China.” Id. The SC List contained the following six countries: Romania, Chile,

Bulgaria, Costa Rica, Malaysia and Türkiye. Id., attach.

On June 5, 2024, Commerce issued the Preliminary Results. Pure Magnesium

from the People’s Republic of China: Preliminary Results of Antidumping Duty

Administrative Review; 2022-2023 (“Preliminary Results”), 89 Fed. Reg. 48,149 (Dep’t

of Commerce June 5, 2024), PR 92, and accompanying Preliminary Decision

Memorandum (“PDM”) (Dep’t of Commerce May 30, 2024), PR 86. Commerce selected

preliminarily Türkiye as the primary surrogate country. PDM at 12.

On December 13, 2024, Commerce issued the Final Results. See Final Results.

Commerce continued to select Türkiye as the primary surrogate country. IDM at cmt. 1.

On January 6, 2025, plaintiffs filed summons in the instant action. Summons,

ECF No. 1. On January 27, 2025, plaintiffs filed their complaint. Compl., ECF No. 8.

On June 5, 2025, plaintiffs moved for judgment on the agency record pursuant to

USCIT Rule 56.2. Pls. Mot. Court No. 25-00002 Page 4

JURISDICTION AND STANDARD OF REVIEW

28 U.S.C. § 1581(c) grants to this Court “exclusive jurisdiction of any civil action

commenced under section 516A or 517 of the Tariff Act of 1930.”

Section 516A of the Tariff Act of 1930 provides that in an action under 19 U.S.C.

§ 1516a(a)(2), the court will hold unlawful any determination, finding or conclusion that

is “unsupported by substantial evidence on the record, or otherwise not in accordance

with law.” 1 19 U.S.C. § 1516a(b)(1)(B)(i).

Substantial evidence constitutes “‘such relevant evidence as a reasonable mind

might accept as adequate to support a conclusion,” but it requires “more than a mere

scintilla.” Universal Camera Corp. v. NLRB, 340 U.S. 474, 477 (1951) (quoting Consol.

Edison Co. of N.Y. v. NLRB, 305 U.S. 197, 229 (1938)). For a reviewing court to “fulfill

[its] obligation” to determine whether a determination of Commerce is supported by

substantial evidence and in accordance with law, Commerce is required to “examine the

record and articulate a satisfactory explanation for its action.” CS Wind Viet. Co. v.

United States, 832 F.3d 1367, 1376 (Fed. Cir. 2016) (quoting Yangzhou Bestpak Gifts &

Crafts Co. v. United States, 716 F.3d 1370, 1378 (Fed. Cir. 2013)).

Even so, the court will “uphold a decision of less than ideal clarity if the agency’s

path may reasonably be discerned.” Motor Vehicle Mfrs. Ass’n of U.S., Inc. v. State

Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983) (quoting Bowman Transp., Inc. v. Ark.-

Best Freight Sys., Inc., 419 U.S. 281, 286 (1974)); see also NMB Sing. Ltd. v. United

States, 557 F.3d 1316, 1319 (Fed. Cir. 2009) (“Commerce must explain the basis for its

1 Further citations to the Tariff Act of 1930 are to Title 19 of the U.S. Code, 2018 edition. Court No. 25-00002 Page 5

decisions; while its explanations do not have to be perfect, the path of Commerce’s

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