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Anti-dumping (ADD) and Countervailing Duty (CVD) cases have always created problems for importers. Occasionally instituting very significant additional duties and a lack of certainty for the estimated duties tendered upon release, they play havoc with buying and pricing decisions. Some cases are more problematic than others, like the new ADD case covering aluminum extrusions from fifteen of our trading partners (China, Columbia, Dominican Republic, Ecuador, India, Indonesia, Italy, South Korea, Malaysia, Mexico, Taiwan, Thailand, Turkey, UAE, and Vietnam).

While an active case (A570-967) already exists for certain extruded aluminum products from China, this new case expands the affected countries and the scope of the case itself. In addition to extruded aluminum shapes and forms, this case “covers aluminum extrusions that are imported with non-aluminum components, whether assembled at the time of importation or unassembled, that are a part of subassembly of a larger product or system.” Merchandise that is comprised, other than fasteners, solely of aluminum extrusions, whether assembled or unassembled, falls under the scope of the case.

Under A570-967 the Department of Commerce issued over one hundred scope rulings to determine if specific products were covered; many items which were found to not be under the scope of the original case will likely be under the scope of the expanded case. The wording under the scope for “extrusions that are imported with non-aluminum components” is opening the door for more products to be affected.

The scope does exclude assembled or packaged to be assembled merchandise containing non-extruded aluminum components, other than fasteners, that is not a part or subassembly of a larger product or system and “that is used as imported, without undergoing after importation any processing, fabrication, finishing, or assembly or the addition of parts or material, regardless of whether the additional parts or materials are interchangeable.” In other words, a completely finished, standalone product that has components of a product other than extruded aluminum fasteners is not a part of this equation. Products made from certain aluminum alloys as defined in the scope are excluded, as is certain defined extruded rectangular wire. Chinese goods covered by A570-967 are excluded from the new case.

In addition to the ADD case, four of the affected countries (China, Indonesia, Mexico, and Turkey) also have a related CVD case underway. Importers of products that include extruded aluminum should be aware of this case and the possible impact on their shipments. Information on this case can be found on the ITA website and their ACCESS page. Note that you will need to set up a login for the ACCESS site.

 

Best Regards,

Sam McClure, LCB

Director of Compliance & Customs Services

 

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Meet one of CVI’s Customs Brokerage & Compliance experts, Sam McClure:

Sam serves as Director, Compliance and Customs Services for CVI. He serves as CVI’s corporate compliance officer and is responsible for overseeing all aspects of our Customs related services, including growth.

Sam started his career in 1977 with Waters Shipping Company in Charlotte, NC. He began as a document runner, soon becoming a leader in operations and customer service for the branch. Sam, along with Linda Masten, founded Central Carolina Shipping Inc. in 1983 as an independent Customs Brokerage firm where he served as Vice President for 26 years. Sam and Linda grew Central Carolina into a successful and highly respected member of the Carolinas trade community. When Charlotte opened their local chapter of the IFFCBA Sam was part of the organizing group and he headed the Customs committee for several years. Sam obtained his Customs Brokers License in 1984 and remained with Central Carolina until the company was acquired by CVI in 2009.

At CVI, Sam has held several positions in both the operations and sales departments. As an expert in U.S. Customs regulations, Sam is often called upon on to provide guidance to importers on Customs compliance issues. He makes regular presentations on matters related to importation and broader regulatory compliance.

– Sam McClure, LCB, Director of Compliance & Customs Services, CVI
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