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Trade Enforcement Efforts Are Paying Off

I am happy to report that things are going well for us in our ongoing trade case against Chinese extruders.  The Seventh Administrative Review has commenced, scope issues and  results are falling our way, and we continue to make progress in our trade enforcement efforts. 

Mandatory respondents are being confirmed for the Seventh Administrative Review.  We have asked the Department of Commerce to select at least one curtain wall and one door threshold exporter.  This helps us in the review and in the scope challenges involving both of those end uses.  Furthermore, we plan to maintain our position that the other elements that make up a curtain wall unit or door threshold, which are subsidized like the extrusions, be subject to the review.  Winning this argument keeps the rates high.  As a reminder, the current countervailing duty is 20% and the anti-dumping rate is 86% for a total duty of 106%.  This grueling process will go on for a few months with the final results due December of 2019.

We have three key scope issues in focus.  We continue to await a date for the latest appeal in the curtain wall case.  Having won (again) the last round, some of those petitioners decided to appeal (again).  More to come about this issue once we hear from the courts.  We have asked the courts to reconsider its position in its appliance handle ruling.  We await their reply.  While we do not want to lose this business to the Chinese, it is important to know that the precedent behind the decision is very important.  We didn’t get what we wanted in the courts decision on this case.  So, we are asking them to reconsider.   More to come on this, as well.  Finally, the door threshold case continues to move forward.  There are three importers that have wreaked havoc in this area, and all three of them are now included in this case.  Confidence is very high we will win, since door thresholds are expressly mentioned as subject merchandise in our original orders.  That can’t be changed, so there is no way for them to win – in my opinion.  I expect fireworks around this issue once the decision comes.

Trade enforcement efforts have paid off.  We now have three "transshippers", which we have reported to Customs.  Also, Customs has asked the AEC to hold another seminar with key port employees from around the country.  We did this last year, and it was a huge success.  The more we invest in the education of port officers, the more violations they will catch. 

I am also very pleased to announce that Carrie Owens, the head of the Enforce and Protect Act at Customs, will be presenting at the AEC fall Management Conference, September 11-13 in Chicago (open to members only).  You will NOT want to miss this and the chance to meet Carrie.  We will also have a breakout session focusing on trade enforcement.  If you suspect someone is evading orders or want to hear more details about AEC’s efforts and results in this area, be sure to attend this session.

In closing, I am happy to communicate that all is well on the trade front.  We are focusing our efforts in the tasks at hand.  We are fully engaged in the trade enforcement aspect of defending our orders by using the old adage, “The best defense is a good offense!”  Thank you for your continued support!  Have a great summer!

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