China Metal Lockers: Commerce Set to Add Another Gun Safe Exemption From AD/CV Duties
The Commerce Department is set to exempt more gun safes from its antidumping and countervailing duty orders on metal lockers from China (A-570-133/C-570-134), it said in a notice announcing the initiation and expedited preliminary results of a changed circumstances review.
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Tractor Supply requested the exemption for its TS12-30 and TS20-30 gun safes, and List Industries and Tennsco, the petitioners in the original AD/CVD investigations, filed comments in support of partially revoking the orders.
If Commerce finalizes the new exemption, it would add the following language to the scope of the AD/CVD orders (in addition to a current exemption with different requirements for gun safes):
“The scope also excludes gun safes meeting each of the following requirements:
(1) Shall be able to fully contain firearms and provide for their secure storage.
(2) Shall have a locking system consisting of at minimum a mechanical or electronic combination lock with a lock body that is integrated into the door of the safe. The mechanical or electronic combination lock utilized by the safe shall have at least 10,000 possible combinations consisting of a minimum three numbers, letters, or symbols.
(3) Bolt work shall consist of a minimum of three steel locking bolts of at least 1/2-inch diameter that intrude from the door of the safe into the body of the safe or from the body of the safe into the door of the safe, which are operated by a separate handle and secured by the lock.
(4) The exterior walls (inclusive of the floor and top) shall be constructed of a minimum 14-gauge thick steel and shall be lined with one or more layers of fire-retardant gypsum board bonded, affixed with brackets or otherwise securely attached to the exterior walls. The fire retardant gypsum board shall be at least 15 mm in thickness for a single layer or shall sum to at least 19 mm in thickness where multiple layers are combined together.
(5) Doors shall be constructed of a minimum of one layer of 14-gauge steel lined with a minimum of one layer of 15 mm thick, fire-retardant gypsum board bonded, affixed with brackets or otherwise securely attached to the door. The doors shall fit into jambs equipped with a fire seal fitted completely around the door frame consisting of a hydrated sodium silicate encapsulated in a plastic film or sleeve that, when heat-activated by temperatures of over 210 degrees, expands to cover the space between the jambs and door, providing a barrier to prevent the intrusion of flames, gas, or smoke into the safe.
(6) Door hinges shall be protected to prevent the removal of the door. Protective features include but are not limited to: hinges not exposed to the outside, interlocking door designs, dead bars, jeweler’s lugs and active or inactive locking bolts.
(7) The excluded safe must be imported in the fully assembled condition.”
Tractor Supply requested, and List and Tennsco supported, retroactive application for the new exclusion, so if Commerce adopts the exclusion in the final results of this review then the partial revocation will apply back to the date the AD/CVD orders on metal lockers were issued on Aug. 20, 2021.