China Aluminum Extrusions: Bushing Subparts from Kam Kiu Subject to AD/CV Duties
Kam Kiu’s subparts for metal bushings used in cars are subject to antidumping and countervailing duties on aluminum extrusions from China (A-570-967/C-570-968), said the Commerce Department Nov. 21 in a final scope ruling. The subparts do not meet the “finished goods kit” exclusion to the AD/CVD orders because they require further processing after importation, and only include aluminum extrusions otherwise subject to AD/CV duties, said Commerce.
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Kam Kiu’s subparts for metal bushings are used in automotive suspension systems. The subparts are produced from aluminum billets (covered by the scope of the AD/CVD orders) through an extrusion process. After importation, the subparts are grit-blasted to clean the surface and a paint primer is applied, followed by a coat of adhesive paint to facilitate the bonding of a rubber filler. The rubber filler is then added between the subparts. The subparts are then ready to be assembled into complete bushings and inserted into suspension systems.
Kam Kiu argued its subparts are fully-finished subcomponents of a larger whole that are “finished goods kits” excluded from AD/CVD duties. They require only minimal steps after importation to be installed, none of which change the form or substance of the subparts, Kam Kiu said.
Commerce, however, found the subparts are not subassemblies that meet the requirements of the finished goods kit exclusion. The subparts are unfinished when they're imported, requiring grit blasting, painting, and a rubber filler before they can be installed. Also, the subparts only consist of subject aluminum extrusions when they're imported. That means they can’t qualify for the finished goods kit exclusion, which requires the use of other materials for a good to qualify.
Email ITTNews@warren-news.com for a copy of this scope ruling.