United Steel, Paper and Forestry, Rubber, Mfg., Energy, Allied Industrial and Serv. Workers Int'l Union, AFL-CIO, CLC v. United States

2025 CIT 72
CourtUnited States Court of International Trade
DecidedJune 9, 2025
Docket24-00165
StatusPublished

This text of 2025 CIT 72 (United Steel, Paper and Forestry, Rubber, Mfg., Energy, Allied Industrial and Serv. Workers Int'l Union, AFL-CIO, CLC 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
United Steel, Paper and Forestry, Rubber, Mfg., Energy, Allied Industrial and Serv. Workers Int'l Union, AFL-CIO, CLC v. United States, 2025 CIT 72 (cit 2025).

Opinion

Slip Op. 25-72

UNITED STATES COURT OF INTERNATIONAL TRADE

UNITED STEEL, PAPER AND FORESTRY, RUBBER, MANUFACTURING, ENERGY, ALLIED INDUSTRIAL AND SERVICE WORKERS INTERNATIONAL UNION, AFL- CIO, CLC,

Plaintiff, Before: Jennifer Choe-Groves, Judge v. Court No. 24-00165 UNITED STATES,

Defendant, and

CHENG SHIN RUBBER U.S.A. INC.,

Defendant-Intervenor.

OPINION AND ORDER

[Remanding the U.S. Department of Commerce’s final scope ruling on Cheng Shin’s temporary-use spare tire.]

Dated: June 9, 2025 Court No. 24-00165 Page 2

Roger B. Schagrin, Nicholas J. Birch, and Alessandra A. Palazzolo, Schagrin Associates, of Washington, D.C., for Plaintiff United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO, CLC. Christopher T. Cloutier, Elizabeth J. Drake, Jeffrey D. Gerrish, Justin M. Neuman, Luke A. Meisner, Nicholas Phillips, Saad Y. Chalchal, and William A. Fennell also appeared.

Franklin E. White, Jr., Assistant Director, and Sosun Bae, Senior Trial Counsel, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, D.C., for Defendant United States. With them on the brief were Brett A. Shumate, Acting Assistant Attorney General, and Patricia M. McCarthy, Director. Of counsel on the brief was Danielle V. Cossey, Attorney, Office of the Chief Counsel for Trade Enforcement and Compliance, U.S. Department of Commerce, of Washington, D.C. Isabelle Aubrun and Shanni Alon also appeared.

Jeffrey M. Winton, Michael J. Chapman, Amrietha Nellan, and Vi N. Mai, Winton & Chapman PLLC, of Washington, D.C., for Defendant-Intervenor Cheng Shin Rubber U.S.A. Inc.

Choe-Groves, Judge: Plaintiff United Steel, Paper and Forestry, Rubber,

Manufacturing, Energy, Allied Industrial and Service Workers International Union,

AFL-CIO, CLC (“Plaintiff” or “United Steel”) brought this action challenging the

final scope ruling on temporary-use spare tires (“T-type tires”) imported by Cheng

Shin Rubber Industry Co. Ltd., issued by the U.S. Department of Commerce

(“Commerce”). Summons, ECF No. 1; Compl. ¶ 1, ECF No. 6.

Commerce determined that Cheng Shin’s T-type tire was not covered by the

scope of the antidumping duty order on passenger vehicles and light truck tires

imported from Taiwan. Final Scope Ruling on the Antidumping Duty Order on

Passenger Vehicle and Light Truck Tires from Taiwan: Request by Cheng Shin Court No. 24-00165 Page 3

Rubber Ind. Co. Ltd., A-583-869 (Aug. 5, 2024) (Final Scope Ruling), PR 151; see

also Passenger Vehicle and Light Truck Tires From the Republic of Korea,

Taiwan, and Thailand (“Order”), 86 Fed. Reg. 38,011 (Dep’t of Commerce July

19, 2021) (antidumping duty orders and amended final affirmative antidumping

duty determination for Thailand).

Before the Court is Plaintiff’s Rule 56.2 Motion for Judgment on the Agency

Record (“Plaintiff’s Motion”), in which Plaintiff argues that Commerce erred in

finding that Cheng Shin’s T-type tires were not covered by the Order. Pl.’s R. 56.2

Mot. J. Agency R. (“Pl.’s Mot.”) & Pl.’s Mem. Supp. Pl.’s Mot. J. Agency R.

(“Pl.’s Br.”), ECF Nos. 22, 23. Defendant United States (“Defendant” or

“Government”) and Defendant-Intervenor Cheng Shin Rubber U.S.A. Inc.

(“Defendant-Intervenor” or “Cheng Shin”) oppose Plaintiff’s Motion. Def.’s Resp.

Pl.’s Mot. J. Agency R. (“Def.’s Br.”), ECF Nos. 26, 27; Br. Def.-Interv. Cheng

Shin Resp. Pl.’s R. 56.2 Mot. J. Agency R. (“Def.-Interv.’s Br.”), ECF Nos. 29, 30.

Plaintiff filed a reply brief. Pl.’s Reply Br., ECF No. 31. For the following

reasons, the Court remands Commerce’s Final Scope Ruling.

1 Citations to the administrative record reflect the public record (“PR”), ECF No. 33. Court No. 24-00165 Page 4

ISSUES PRESENTED

The Court reviews the following issues:

1. Whether United Steel failed to exhaust its administrative remedies before

challenging the final scope ruling in this Court.

2. Whether Commerce abused its discretion when it declined to issue a

preliminary scope ruling.

3. Whether Commerce’s interpretation of the scope of the Order changed

the meaning of the Order and was otherwise not in accordance with law.

4. Whether Commerce failed to consider evidence on the record that

showed Cheng Shin’s T-type tires fit passenger vehicles or light trucks.

BACKGROUND

On July 19, 2021, Commerce issued an antidumping duty order on passenger

vehicle and light truck tires from the Republic of Korea, Taiwan, and Thailand.

Order, 86 Fed. Reg. at 38,011. The Order covered new passenger and light truck

tires that “have, at the time of importation, the symbol ‘DOT’ on the sidewall,

certifying that the tire conforms to applicable motor vehicle safety standards.” Id.

at 38,012. The Order specified that tires with “P” and “LT” prefixes and tires with

“LT” suffix are expressly covered by the scope of the Order, regardless of their Court No. 24-00165 Page 5

intended use. 2 Id. The Order also explained that:

all tires that lack a “P” or “LT” prefix or suffix in their sidewall markings, as well as all tires that include any other prefix or suffix in their sidewall markings, are included in the scope, regardless of their intended use, as long as the tire is of a size that fits passenger cars or light trucks. Sizes that fit passenger cars and light trucks include, but are not limited to, the numerical size designations listed in the passenger car section or light truck section of the Tire and Rim Association Year Book, as updated annually. The scope includes all tires that are of a size that fits passenger cars or light trucks, unless the tire falls within one of the specific exclusions set out below.

Id.

Cheng Shin requested a scope ruling confirming that its T-type tires

were outside the scope of the Order. Cheng Shin’s Request for Scope

Ruling (“Scope Ruling Request”) at 23, PR 12. In its request, Cheng Shin

explained to Commerce that its “T-type tire is a ‘mini’ spare tire that does

not meet the size or regulatory requirements for regular-service on passenger

cars or light trucks.” Id. at 4.

Commerce initiated a scope inquiry on April 11, 2024 and set the deadline

for interested parties to submit comments for May 13, 2024. Initiation of Cheng

Shin Scope Inquiry, PR 3; Notice of Scope Ruling Applications Filed in

2 The “P” prefix “[i]dentifies a tire intended primarily for service on passenger cars[,]” and the “LT” prefix “[i]dentifies a tire intended primarily for service on light trucks.” Order, 86 Fed. Reg. at 38,012. The “LT” suffix “[i]dentifies light truck tires for service on trucks, buses, trailers, and multipurpose passenger vehicles used in nominal highway service.” Id. Court No. 24-00165 Page 6

Antidumping and Countervailing Duty Proceedings, 89 Fed. Reg. 35,796 (Dep’t of

Commerce May 2, 2024). United Steel filed its entry of appearance on May 6,

2024. Entry of Appearance, United Steel, Paper and Forestry, Rubber,

Manufacturing, Energy, Allied Industrial and Service Workers International Union,

AFL-CIO, CLC, PR 6.

The May 13, 2024 deadline for interested parties to submit comments on the

scope proceeding lapsed without comment from United Steel. On June 17, 2024,

United Steel requested that Commerce issue a preliminary determination on the

scope ruling so that the Parties would have an opportunity to review and comment

on the proposed reasoning and determination. Petitioner’s Request for a

Preliminary Determination, PR 12.

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2025 CIT 72, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-steel-paper-and-forestry-rubber-mfg-energy-allied-industrial-cit-2025.