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Routine Matters - But Not Ordinary

 This month, we will discuss active matters in our case and a brief look ahead. As we look forward to 2021, several pending key decisions will help define the kind of environment we are likely to face as we transition into a new administration. While some of these matters look routine, the underlying precedent in our case that they represent is anything but ordinary. 

Kingtom has been selected as the sole mandatory respondent in the 9th Administrative Review on the Anti-Dumping side. Kingtom recently changed their import status and became the importer of record in shipments into the U.S. over the summer. During this time, we have seen imports climb. The administrative review process is an excellent opportunity for us to make the case they should be subject to the Chinese duties. Meanwhile, an EAPA from Ta Chen against Kingtom is in its final stages. A decision is imminent, and should Ta Chen prevail, our case against them will be strengthened.

The Aluminum Extruders Council (AEC) recently participated in a Zoom Meeting with the Department of Commerce (DOC) this month about the door threshold appeal. In this matter, the Department of Commerce made the decision that door thresholds were covered by our orders and subject to the duties. The lower court judge disagreed with the DOC, thus setting up the appeal. Since this was the DOC’s decision, it is theirs to defend. So, the purpose of our call to them was to persuade them that this is an important matter, and we need the DOC to mount a full-throated defense of their decision. As is customary in these situations, we will be supporting the DOC in this matter to help them win. We all thought the call with the DOC went very well, and we expect them to fight this decision on our behalf.

In the CCM Solar Mount Appeal, CCM appealed the final scope ruling. We intervened on August 10, 2020. A briefing schedule has been set and is as follows: CCM’s opening brief is expected December 4, 2020, and the government’s response brief is due February 22, 2021. Our response brief as defendant-intervenor is due March 24, 2021. Commerce had issued a final scope ruling in the CCM solar mount case on May 14, 2020, finding that the solar mounts constitute subassemblies covered by the scope. We aim to participate in this case along with the DOC. This is a critical ruling for us, not only because of the volume this market represents to our industry, but because the key precedent established by declaring solar mounting systems not a final finished product will pay dividends for us in other sub-assembly cases.

Once the pandemic hit, imports began to slow - in some cases, quite dramatically. However, since markets have opened across the world over the summer, we are once again seeing an increase in imports. The AEC delayed action in this matter until we started seeing activity again and fielding reports of suspicious activity. We are monitoring this situation closely. Once we get through renewals and have a better sense of the financial resources we will have, we will be able to put our plan of attack together. If you have any questions or comments related to this, please do NOT hesitate to contact me, Jeff Henderson, directly. Thank you all for your continued support!


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