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Wheels Imported by Vision Wheel Not Subject to AD/CVD on Chinese-Origin Steel Trailer Wheels

Eighty-three models of passenger vehicle and light truck wheels imported by Vision Wheel are outside the scope of antidumping duty and countervailing duty orders on steel trailer wheels 12- to 16.5-inch in diameter from China, the Commerce Department found in a Dec. 29 scope ruling. Though they appear to meet the definition of subject merchandise in the plain language of the scope, Vision’s products aren’t trailer wheels, the department decided.

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The AD/CVD orders cover wheels that are “generally for road and highway trailers and other towable equipment, including, inter alia, utility trailers, cargo trailers, horse trailers, boat trailers, recreational trailers, and towable mobile homes,” Commerce said.

The plain language of the orders doesn’t exclude Vision’s wheels, the department said. But the orders’ description of subject merchandise “generally for road and highway trailers and other towable equipment,” it said, as well as prior rulings and primary source material from the orders’ investigations, indicate light truck and passenger vehicle wheels shouldn’t be covered by them.

It said that, during the investigations, Commerce was asked to amend the orders’ language to explicitly clarify that the orders didn’t apply to non-trailer wheels. The department refused, but only due to “enforceability concerns regarding end use language and the administrative burden of a certification process,” it said. Commerce also cited the fact that there hadn’t been a definition of “non-trailer” provided during the investigation, it said. But the department “determined to review requests for exclusions” of non-trailer wheels “on a case-by-case basis,” it said.

Further, it said, the orders’ petitions described subject merchandise as distinguishable from trailer wheels by “some physical differences,” such as mounting and carrying capacity.

The physical characteristics of Vision’s products -- including hub bore size, offset, load rating, and bolt pattern -- demonstrate that they are non-trailer wheels and thus excluded from the orders, the department said.

It said that each of the 83 wheel models, except for one, “are distinguishable from subject trailer wheels with respect to at least one of the above-listed factors.” That final wheel model, however, could be excluded from the orders based on marketing and ultimate purchasers’ expectations, it said.