Tianjin Magnesium Int'l Co. v. United States

2026 CIT 28
United States Court of International Trade·Decided March 13, 2026·No. 25-00002·Published

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.

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 decision must be reasonably discernable to a reviewing court.”).

Finally, “the Court will not disturb an agency determination if its factual findings are reasonable and supported by the record as a whole, even if there is some evidence that detracts from the agency’s conclusion.” Shandong Huarong Gen. Corp. v. United States, 25 CIT 834, 837, 159 F. Supp. 2d 714, 718 (2001) (citing Heveafil Sdn. Bhd. v. United States, 25 CIT 147, 149 (2001)), aff’d sub nom. Shandong Huarong Gen. Grp. Corp. v. United States, 60 F. App’x 797 (Fed. Cir. 2003).

DISCUSSION

I. Legal framework 19 U.S.C. § 1677b(c)(1) provides that Commerce “shall determine the normal value of the subject merchandise” in an AD investigation that involves a non-market economy (“NME”) country “on the basis of the value of the factors of production [(“FOPs”)] utilized in producing the merchandise and to which shall be added an amount for general expenses and profit plus the cost of containers, coverings, and other expenses.” See Juancheng Kangtai Chem. Co. v. United States, Slip Op. 15-93, 2015 WL 4999476, at *2 (CIT Aug. 21, 2015).

In administrative proceedings that involve an NME country such as China, Commerce calculates the “normal value” of the subject merchandise by selecting surrogate data from one or several market economy countries that Commerce determines constitute the “best available information.” 19 U.S.C. § 1677b(c)(1); Heze Huayi Chem. Co. v. United States, 45 CIT __, __, 532 F. Supp. 3d 1301, 1309-10 (2021).

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