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CAFC Says Solar Panel Mounts Don't Qualify For Finished Goods AD/CVD Exclusion

The Court of Appeals for the Federal Circuit in a March 2 opinion upheld a Court of International Trade ruling that found solar panel mounts made by appellant China Custom Manufacturing do not qualify for the "finished merchandise" exclusion from…

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the antidumping and countervailing duty orders on aluminum extrusions from China. Judges Pauline Newman, Raymond Chen and Tiffany Cunningham ruled that the matter is "governed squarely" by the Federal Circuit's ruling in Shenyang Yuanda Aluminum Indus. Eng'g Co. v. U.S., where the court said that a "part or subassembly ... cannot be a finished product." CCM had admitted that its mounts are parts of its solar panel mounting system.