U.K. Carbon & Graphite Co. v. United States

931 F. Supp. 2d 1322, 2013 CIT 114, 2013 WL 4615014, 35 I.T.R.D. (BNA) 1993, 2013 Ct. Intl. Trade LEXIS 118
CourtUnited States Court of International Trade
DecidedAugust 29, 2013
DocketSlip Op. 13-114; Court 12-00242
StatusPublished
Cited by3 cases

This text of 931 F. Supp. 2d 1322 (U.K. Carbon & Graphite 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
U.K. Carbon & Graphite Co. v. United States, 931 F. Supp. 2d 1322, 2013 CIT 114, 2013 WL 4615014, 35 I.T.R.D. (BNA) 1993, 2013 Ct. Intl. Trade LEXIS 118 (cit 2013).

Opinion

OPINION & ORDER

CARMAN, Judge:

Plaintiff U.K. Carbon and Graphite Company, Ltd. (“Plaintiff’ or “UKCG”) contests the final determination by Defendant United States Department of Commerce (“Defendant” or “Commerce”) regarding the circumvention 1 inquiry related *1325 to the antidumping duty order covering small diameter graphite electrodes from the People’s Republic of China (“China”). See Small Diameter Graphite Electrodes From the People’s Republic of China: Affirmative Final Determination of Circumvention of the Antidumping Duty Order, 77 Fed.Reg. 47,596 (Aug. 9, 2012) {“Final Determination’’), Part 2, P.R. 2 76, and accompanying Issues and Decision Memorandum for the Final Determination of the Anticircumvention Inquiry (July 31, 2013) {“I & D Memo ”), Part 2, P.R. 73. The Court denies Plaintiffs motion for judgment on the agency record and sustains Defendant’s Final Determination.

Background

A. Antidumping Duty Order

The product at issue is small diameter graphite electrodes (“SDGE”). In 2009, Commerce imposed an antidumping duty order upon imports of SDGE from China. Antidumping Duty Order: Small Diameter Graphite Electrodes from the People’s Republic of China, 74 Fed.Reg. 8,775 (Feb. 26, 2009) (“AD Order” or “SDGE Order ”). The scope of the AD Order covers:

all small diameter graphite electrodes of any length, whether or not finished, of a kind used in furnaces, with a nominal or actual diameter of 400 millimeters (16 inches) or less, and whether or not attached to a graphite pin joining system or any other type of joining system or hardware. The merchandise covered by this order also includes graphite pin joining systems for small diameter graphite electrodes, of any length, whether or not finished, of a kind used in furnaces, and whether or not the graphite pin joining system is attached to, sold with, or sold separately from, the small diameter graphite electrode. Small diameter graphite electrodes and graphite pin joining systems for small diameter graphite electrodes are most commonly used in primary melting, ladle metallurgy, and specialty furnace applications in industries including foundries, smelters, and steel refining operations. Small diameter graphite electrodes and graphite pin joining systems for small diameter graphite electrodes that are subject to this order are currently classified under the Harmonized Tariff Schedule of the United States (“HTSUS”) subheading 8545.11.0000. The HTSUS number is provided for convenience and customs purposes, but the written description of the scope is dispositive.

Id. at 8,775.

B. Circumvention Inquiry

On October 12, 2010, domestic producers of SDGE — SGL Carbon LLC and Superi- or Graphite Company, Defendant-Intervenors in the instant case (collectively referred to as “Defendant-Intervenors” or “Petitioners”) — requested that Commerce conduct a scope or an anticircumvention inquiry on SDGE produced by UKCG from Chinese manufactured artificial/synthetic graphite forms. See Petitioners’ Request for Scope Review or Anticircumvention Inquiry (Oct. 12, 2010) {“Initiation Request ”), Part 1, P.R. 1. Petitioners alleged that UKCG was part of “an ongoing scheme to evade payment of anti-dumping duties under the SDGE Order” with Chinese producers. Id. at 1-2. Petitioners alleged that UKCG was first importing unfinished SDGE from China to the U.K. “for minor completion or assembly” then exporting to the U.S., thereby circumventing the AD Order duty assessment by improperly claiming the U.K. as *1326 the country of origin on entry papers. Id. at 2.

Petitioners asserted the SDGE that UKCG imported was “for every relevant purpose an unfinished graphite electrode subject to the antidumping duty order when it leaves China,” because “[a]ll of the physical, chemical and performance characteristics of an electrode have been given to the product in China.” Id. at 14. Petitioners explained that

[ijt is an electrode in unfinished form at that point, regardless of whether it is called a rod or an electrode. The rod or unfinished electrode needs only final finishing (sizing, threading, fitting ends of electrode with a graphite pin joining system, etc.) [which] are merely machining operations and do not impart the essential performance characteristics of the product.

Id. at 14 (emphasis added).

Commerce acknowledged that there was “substantial record evidence which may support the initiation of either” a scope inquiry or an anticircumvention inquiry. Small Diameter Graphite Electrodes From the People’s Republic of China: Initiation of Anti-Circumvention Inquiry, 76 Fed.Reg. 14,910, 14,912 (Mar. 18, 2011) (“Initiation Notice ”). Commerce decided that an anticircumvention inquiry was the more appropriate avenue given the “specificity” of the allegation to a single company and “certain record information as to the timing of the pattern of trade.” Id.

UKCG provided timely responses to Commerce’s information requests, and all parties submitted timely comments regarding surrogate country and surrogate value selection. Def.’s Mem. in Opp’n to PL’s R. 56.2 Mot. for J. upon the Agency Record (“Def.’s Opp’n”) at 5. Commerce also conducted a verification of UKCG’s questionnaire responses at two of its U.K. facilities during February 16-17, 2012. PL UKCG’s Mem. of Law in Supp. of Their R. 56.2 Mot. for J. on the Agency Record (“PL’s Mot.”) at 6, 38; Def.’s Opp’n at 5.

C. Preliminary Determination

In June 2012, Commerce subsequently issued a preliminary affirmative determination of circumvention. See Small Diameter Graphite Electrodes From the People’s Republic of China: Affirmative Preliminary Determination of Circumvention of the Antidumping Duty Order and Extension of Final Determination, 77 Fed.Reg. 33,405 (June 6, 2012) (“Preliminary Determination’’). In its Preliminary Determination, Commerce first found that the products exported by UKCG to the U.S. were completed or assembled in the U.K. from “unfinished” Chinese-origin inputs “subject to” the AD Order, based upon the scope language and product descriptions from the petition and the report of the International Trade Commission (“ITC”). Id. at 33,410-11; Small Diameter Graphite Electrodes from China, Inv. No. 731-TA-1143 (Final), ITC Pub. 4062 (Feb. 2009) (“ITC Report”). Commerce therefore determined that it was appropriate to use the surrogate value methodology from antidumping proceedings for non-market economy (“NME”) countries. Id. at 33,407-08.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hanon Sys. Alabama Corp. v. United States
2025 CIT 94 (Court of International Trade, 2025)
Fabuwood Cabinetry Corp. v. United States
469 F. Supp. 3d 1373 (Court of International Trade, 2020)
Fushun Jinly Petrochemical Carbon Co. v. United States
2016 CIT 25 (Court of International Trade, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
931 F. Supp. 2d 1322, 2013 CIT 114, 2013 WL 4615014, 35 I.T.R.D. (BNA) 1993, 2013 Ct. Intl. Trade LEXIS 118, Counsel Stack Legal Research, https://law.counselstack.com/opinion/uk-carbon-graphite-co-v-united-states-cit-2013.