China Aluminum Extrusions: ITA Issues Split Decision on Scope of Boat & Deck Ladders
A product can meet the “finished goods” or “finished goods kit” scope exclusions from the antidumping and countervailing duty orders on aluminum extrusions from China (A-570-967 / C-570-968) only if it includes integral non-aluminum extrusion components, said the International Trade Administration in a March 22 scope ruling. Asia Sourcing Corp.’s boat ladders, that have plastic components other than fasteners, are excluded from the scope of the AD/CV duty orders, said the ITA. But ASC’s dock ladders and strip door mounting brackets that, as imported, lack any non-aluminum extrusion parts besides fasteners, are included in the scope and subject to the orders.
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ASC requested the scope ruling for 105 products. The ITA was only able to rule on six of them, because of insufficient information provided about the others, the agency said.
ASC’s boat ladders consisted of aluminum extrusion hand railings with plastic steps. One version was imported as a kit, along with fasteners, in a single box. The other was imported as a finished boat ladder, and only included fasteners for attachment to the boat, again in a single box.
The three dock ladder models, both finished and in kits, consisted of hand railings and steps made from aluminum extrusions. The only non-aluminum extrusion components were fasteners. Similarly, while the strip door mounting brackets were designed to attach to plastic parts, the plastic components were imported separately. As such, the mounting brackets only included aluminum extrusion components as entered.
Examining the language of the scope, as well as previous scope rulings, the ITA said that to qualify for the finished goods or finished goods kits exemptions, a product must contain non-aluminum extrusion parts besides fasteners. The two boat ladder models had plastic steps, so met the requirements of the exclusions. However, the dock ladder models, as well as the mounting brackets, were entirely made from aluminum extrusions, and thus qualified as “aluminum extrusions,” subject to the scope of the AD/CV duty orders.
Email ITTNews@warren-news.com for a copy of the scope ruling.