China Aluminum Extrusions: Screen Door Parts Packaged Separately Liable for AD/CV Duties
Door screen parts imported by Law St. Enterprises are not packaged together as a kit at the time of importation, and so are subject to antidumping and countervailing duties on aluminum extrusions from China (A-570-967/C-570-968), said the Commerce Department in a Sept. 12 final scope ruling. Because they need to be repackaged after importation to form a kit for building a disappearing screen door, they don’t qualify for the AD/CVD orders’ exclusion for finished goods kits, Commerce said.
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Disappearing screens are screens that are installed across doorways that can be retracted when they aren’t being used. Law St. Enterprises imports all of the parts necessary for assembling a disappearing screen: a housing, top track, bottom track, track protector, and side profile, among other things. None of the parts need more processing before assembly. They are all imported on the same customs entry, but are divided into packages based on the type of part (i.e., top tracks are in one package, housings in another, etc.). Law St. Enterprises then sends the parts to a distributor, Casper Disappearing Screen Systems, which repackages the parts into kits for assembling disappearing screens.
Some of the disappearing screen parts are made of hollow aluminum extrusions that are normally subject to AD/CV duties. But Law St. Enterprises argued the product qualifies for an exclusion from the scope of the orders for finished goods kits because it is a “packaged combination of parts that contains, at the time of importation, all of the necessary parts to fully assemble a final finished good and requires no further finishing or fabrication, such as cutting or punching, and is assembled ‘as is’ into such a finished product.”
Commerce disagreed, finding the disappearing screen parts are covered by the AD/CVD orders on aluminum extrusions from China. Although they may require no more assembly and can be assembled “as is” into a finished disappearing screen, they are not a “packaged combination of parts” containing all necessary parts for assembly “at the time of importation,” Commerce said. After they are imported, the packages must be opened and their contents recombined before they become disappearing screen kits ready for sale to the end user.
Email ITTNews@warren-news.com for a copy of this scope ruling.