Commerce has preliminarily determined that such imports are not circumventing the antidumping (AD) order on stainless steel wire rod from Korea.

Commerce based its determination on the following factors which it considers in a circumvention analysis:

• Overall physical characteristics of the merchandise.  Commerce found that stainless steel wire and stainless steel wire rod are distinct products and are not interchangeable.
• Expectations of ultimate purchasers and use of the merchandise.  Commerce found that customers of stainless steel wire have different expectations from those of customers of stainless steel wire rod and that stainless steel wire has different uses than stainless steel wire rod.
• Channels of marketing and distribution.  Commerce found that stainless steel wire is generally marketed as a finished product (with the exception of stainless steel wire being used to produce fine wire products), whereas stainless steel wire rod is an intermediate product that can be used to produce other products (e.g. stainless steel wire, stainless steel bar, and stainless steel fasteners).
• Cost of modification / processing in the third country compared to the value of the imported merchandise.  Commerce found that such cost is minor.

Commerce intends to verify the information upon which it relied in making its preliminary determination, and it plans complete its investigation and issue its final determination by May 2023, although that date can be extended by 65 days.

If you have questions, please contact AWPA Counsel Fred Waite and Kim Young.