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October 29, 2024

New Antidumping Duty and Countervailing Duty Petitions on Overhead Door Counterbalance Torsion Springs From China and India

At a Glance

  • IDC Group, Inc., Iowa Spring Manufacturing, Inc., and Service Spring Corp filed antidumping duty petitions and countervailing duty petitions on overhead door counterbalance torsion springs from China and India.
  • Investigations related to these petitions could result in increased prices and/or decreased supply of overhead door counterbalance torsion springs.
  • The U.S. Department of Commerce is expected to begin investigations on November 18, 2024.

On October 29, 2024, a group of three U.S. manufacturers filed antidumping (AD) and countervailing duty (CVD) petitions on overhead door counterbalance torsion springs from China and India. The petitioners are IDC Group, Inc., Iowa Spring Manufacturing, Inc., and Service Spring Corp (collectively “Petitioners”).

The U.S. AD law imposes special tariffs to counteract imports that are sold in the United States at less than “normal value.” The U.S. CVD law imposes special tariffs to counteract imports that are sold in the United States with the benefit of foreign government subsidies. For AD/CVD duties to be imposed, the U.S. government must determine not only that dumping and/or subsidization is occurring, but also that there is “material injury” (or threat thereof) by reason of the dumped and subsidized imports. Importers are liable for any potential AD/CVD duties imposed. In addition, these investigations could impact purchasers by increasing prices and/or decreasing supply of overhead door counterbalance torsion springs.

Scope

Please note that this section was not written by our authors but is taken verbatim from the petition.

The merchandise covered by these investigations is helically-wound, overhead door counterbalance torsion steel springs (“overhead door counterbalance torsion springs”). Overhead door counterbalance torsion springs are helical steel springs with tightly wound coils that store and release mechanical energy by winding and unwinding along the spring's axis by an angle, using torque to create a lifting force in the counterbalance assembly typically used to raise and lower overhead doors, including garage doors, industrial rolling doors, warehouse doors, trailer doors, and other overhead doors, gates, grates, or similar devices. The merchandise covered by these investigations covers all overhead door counterbalance torsion springs with a coil inside diameter of 15.8 millimeters (“mm”) or more but not exceeding 304.8 mm (measured across the diameter from inner edge to inner edge); a wire diameter of 2.5 mm to 20.4 mm; a length of 127 mm or more; and regardless of the following characteristics:

  • wire type (including, but not limited to, oil-tempered wire, hard-drawn wire, music wire, galvanized or other coated wire);
  • wire cross-sectional shape (e.g., round, square, or other shapes);
  • coating (e.g., uncoated, oil- or water-based coatings, lubricant coatings, zinc, aluminum, zinc-aluminum, paint or plastic coating, etc.);
  • winding orientation (left-hand or right-hand wind direction);
  • end type (including, but not limited to, looped, double looped, clipped, long length, mini warehouse, Barcol, Crawford, Kinnear, Wagner, rolling steel or barrel ends); and
  • whether the overhead door counterbalance torsion springs are fitted with hardware, including but not limited to fasteners, clips, and cones (winding or stationary cones).

For purposes of the diameters referenced above, where the nominal and actual measurements vary, a product is within the scope if application of either the nominal or actual measurement would place it within the scope based on the definitions set forth above.

The steel torsion springs included in the scope of these investigations are produced from steel in which: (1) iron predominates, by weight, over each of the other contained elements; and (2) the carbon content is 2 percent or less, by weight.

Subject merchandise includes cones or other fittings attached to or entered with the subject overhead door counterbalance torsion springs. Subject merchandise also includes all subject overhead door counterbalance torsion springs entered as a part of overhead door kits, overhead door mounting or assembly kits, or as a part of a spring-operated motor assembly or as a part of a spring winder assembly kit for torsion springs. When counterbalance torsion springs are entered as a part of such kits, only the counterbalance spring and cones attached to or entered with the spring are within scope.

Subject merchandise also includes overhead door counterbalance torsion springs that have been further processed in a third country, including but not limited to cutting to length, attachment of hardware, cones or end-fittings, inclusion in garage door kits or garage door mounting or assembly kits, or any other processing that would remove the merchandise from the scope of these orders if performed in the country of manufacture of the in-scope overhead door counterbalance torsion springs.

All products that meet the written physical description are within the scope of these investigations unless specifically excluded. The following products are specifically excluded from the scope of these investigations:

  • leaf springs (slender arc-shaped length of spring steel of a rectangular cross-section);
  • disc springs (conical springs consisting of a convex disc with the outer edge working against the center of the disc);
  • extension springs (close-wound round helical wire springs that store and release energy by resisting the external pulling forces applied to the spring's ends in the direction of its length);
  • compression springs (helical coiled springs with open wound active coils (such open winding is also known as pitch) that are designed to compress under load or force); and
  • spiral springs (torsion springs wound as concentric spirals such as a clock spring or mainspring).

The products subject to these investigations are currently classified under Harmonized Tariff Schedule of the United States (HTSUS) subheadings 7320.20.5020, 7320.20.5045 and 7320.20.5060. They may also be classified under HTSUS subheading 8412.90.9085 if entered as parts of spring-operated motors. They may also be classified in HTSUS subheading 8412.80.1000 (spring-operated motors) if entered as part of a spring counterweight assembly for an overhead door. They may also be classified in HTSUS subheading 7308.90.9590, a basket category that includes metal garage doors entered with mounting accessories or assemblies. Although the HTSUS subheadings are provided for convenience and Customs purposes, the written description of the scope of these investigations is dispositive.

Estimated Dumping Margins

The Petitioners allege the following dumping margins exist:

  • China: 685.93% to 787.30%
  • India: 45.65% to 53.08%

Estimated Schedule of Investigations

The following is an estimated schedule of investigations by the U.S. Department of Commerce (DOC) and the U.S. International Trade Commission (ITC):

October 29, 2024 Petitions are filed.
November 18, 2024 DOC initiates investigations.
November 19, 2024 ITC staff conference (estimated).
December 13, 2024 Deadline for ITC preliminary injury determination.
January 22, 2025 Deadline for DOC preliminary CVD determination, if deadline is NOT postponed.
March 28, 2025 Deadline for DOC preliminary CVD determination, if deadline is fully postponed.
April 7, 2025 Deadline for DOC preliminary AD determination, if deadline is NOT postponed.
May 27, 2025 Deadline for DOC preliminary AD determination, if deadline is fully postponed.
October 9, 2025 Deadline for DOC final AD and CVD determinations, if all deadlines are fully postponed.
November 24, 2025 Deadline for ITC final injury determination, if all DOC deadlines are fully postponed.

The material contained in this communication is informational, general in nature and does not constitute legal advice. The material contained in this communication should not be relied upon or used without consulting a lawyer to consider your specific circumstances. This communication was published on the date specified and may not include any changes in the topics, laws, rules or regulations covered. Receipt of this communication does not establish an attorney-client relationship. In some jurisdictions, this communication may be considered attorney advertising.

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