MESSAGE NO: 2119206 DATE: 04 29 2002
CATEGORY: ADA TYPE: PRE
REFERENCE: REFERENCE DATE:
CASES: A - 351 - 832 - -
- - - -
- - - -

PERIOD COVERED: 04 15 2002 TO

LIQ SUSPENSION DATE:

TO: DIRECTORS OF FIELD OPERATIONS
PORT DIRECTORS

FROM: DIRECTOR, TRADE ENFORCEMENT & CONTROL

RE: PRELIMINARY DETERMINATION IN THE DUMPING INVESTIGATION OF
WIRE ROD FROM BRAZIL (A-351-832)



1. ON APRIL 15, 2002, THE DEPARTMENT OF COMMERCE PUBLISHED IN
THE FEDERAL REGISTER ITS PRELIMINARY DETERMINATION OF SALES
AT LESS THAN FAIR VALUE AND THE POSTPONEMENT OF THE FINAL
DETERMINATION IN THE ANTIDUMPING DUTY INVESTIGATION OF
CARBON AND CERTAIN ALLOY STEEL WIRE ROD FROM BRAZIL.

2. THE MERCHANDISE COVERED BY THESE INVESTIGATIONS IS CERTAIN
HOT-ROLLED PRODUCTS OF CARBON STEEL AND ALLOY STEEL, IN
COILS, OF APPROXIMATELY ROUND CROSS SECTION, 5.00 MM OR
MORE, BUT LESS THAN 19.00 MM, IN SOLID CROSS-SECTIONAL
DIAMETER.

SPECIFICALLY EXCLUDED ARE STEEL PRODUCTS POSSESSING THE
ABOVE-NOTED PHYSICAL CHARACTERISTICS AND MEETING THE
HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTSUS)
DEFINITIONS FOR (A) STAINLESS STEEL; (B) TOOL STEEL; (C)
HIGH NICKEL STEEL; (D) BALL BEARING STEEL; AND (E) CONCRETE
REINFORCING BARS AND RODS. ALSO EXCLUDED ARE (F) FREE
MACHINING STEEL PRODUCTS (I.E., PRODUCTS THAT CONTAIN BY
WEIGHT ONE OR MORE OF THE FOLLOWING ELEMENTS: 0.03 PERCENT
OR MORE OF LEAD, 0.05 PERCENT OR MORE OF BISMUTH, 0.08
PERCENT OR MORE OF SULFUR, MORE THAN 0.04 PERCENT OF
PHOSPHORUS, MORE THAN 0.05 PERCENT OF SELENIUM, OR MORE THAN
0.01 PERCENT OF TELLURIUM).

ALSO EXCLUDED FROM THE SCOPE ARE 1080 GRADE TIRE CORD
QUALITY WIRE ROD AND 1080 GRADE TIRE BEAD QUALITY WIRE ROD.
THIS GRADE 1080 TIRE CORD QUALITY ROD IS DEFINED AS: (I)
GRADE 1080 TIRE CORD QUALITY WIRE ROD MEASURING 5.0 MM OR
MORE BUT NOT MORE THAN 6.0 MM IN CROSS-SECTIONAL DIAMETER;
(II) WITH AN AVERAGE PARTIAL DECARBURIZATION OF NO MORE THAN
70 MICRONS IN DEPTH (MAXIMUM INDIVIDUAL 200 MICRONS); (III)
HAVING NO INCLUSIONS GREATER THAN 20 MICRONS; (IV) HAVING A
CARBON SEGREGATION PER HEAT AVERAGE OF 3.0 OR BETTER USING
EUROPEAN METHOD NFA 04-114; (V) HAVING A SURFACE QUALITY
WITH NO SURFACE DEFECTS OF A LENGTH GREATER THAN 0.15 MM;
(VI) CAPABLE OF BEING DRAWN TO A DIAMETER OF 0.30 MM OR LESS
WITH 3 OR FEWER BREAKS PER TON, AND (VII) CONTAINING BY
WEIGHT THE FOLLOWING ELEMENTS IN THE PROPORTIONS SHOWN: (1)
0.78 PERCENT OR MORE OF CARBON, (2) LESS THAN 0.01 PERCENT
OF ALUMINUM, (3) 0.040 PERCENT OR LESS, IN THE AGGREGATE, OF
PHOSPHORUS AND SULFUR, (4) 0.006 PERCENT OR LESS OF
NITROGEN, AND (5) NOT MORE THAN 0.15 PERCENT, IN THE
AGGREGATE, OF COPPER, NICKEL AND CHROMIUM.

THIS GRADE 1080 TIRE BEAD QUALITY ROD IS DEFINED AS: (I)
GRADE 1080 TIRE BEAD QUALITY WIRE ROD MEASURING 5.5 MM OR
MORE BUT NOT MORE THAN 7.0 MM IN CROSS-SECTIONAL DIAMETER;
(II) WITH AN AVERAGE PARTIAL DECARBURIZATION OF NO MORE THAN
70 MICRONS IN DEPTH (MAXIMUM INDIVIDUAL 200 MICRONS); (III)
HAVING NO INCLUSIONS GREATER THAN 20 MICRONS; (IV) HAVING A
CARBON SEGREGATION PER HEAT AVERAGE OF 3.0 OR BETTER USING
EUROPEAN METHOD NFA 04-114; (V) HAVING A SURFACE QUALITY
WITH NO SURFACE DEFECTS OF A LENGTH GREATER THAN 0.2 MM;
(VI) CAPABLE OF BEING DRAWN TO A DIAMETER OF 0.78 MM OR
LARGER WITH 0.5 OR FEWER BREAKS PER TON; AND (VII)
CONTAINING BY WEIGHT THE FOLLOWING ELEMENTS IN THE
PROPORTIONS SHOWN: (1) 0.78 PERCENT OR MORE OF CARBON, (2)
LESS THAN 0.01 PERCENT OF SOLUBLE ALUMINUM, (3) 0.040
PERCENT OR LESS, IN THE AGGREGATE, OF PHOSPHORUS AND SULFUR,
(4) 0.008 PERCENT OR LESS OF NITROGEN, AND (5) EITHER NOT
MORE THAN 0.15 PERCENT, IN THE AGGREGATE, OF COPPER, NICKEL
AND CHROMIUM (IF CHROMIUM IS NOT SPECIFIED), OR NOT MORE
THAN 0.10 PERCENT IN THE AGGREGATE OF COPPER AND NICKEL AND
A CHROMIUM CONTENT OF 0.24 TO 0.30 PERCENT (IF CHROMIUM IS
SPECIFIED).

THE DESIGNATION OF THE PRODUCTS AS "TIRE CORD QUALITY" OR
"TIRE BEAD QUALITY" INDICATES THE ACCEPTABILITY OF THE
PRODUCT FOR USE IN THE PRODUCTION OF TIRE CORD, TIRE BEAD,
OR WIRE FOR USE IN OTHER RUBBER REINFORCEMENT APPLICATIONS
SUCH AS HOSE WIRE. THESE QUALITY DESIGNATIONS ARE PRESUMED
TO INDICATE THAT THESE PRODUCTS ARE BEING USED IN TIRE CORD,
TIRE BEAD, AND OTHER RUBBER REINFORCEMENT APPLICATIONS, AND
SUCH MERCHANDISE INTENDED FOR THE TIRE CORD, TIRE BEAD, OR
OTHER RUBBER REINFORCEMENT APPLICATIONS IS NOT INCLUDED IN
THE SCOPE. HOWEVER, SHOULD PETITIONERS OR OTHER INTERESTED
PARTIES PROVIDE A REASONABLE BASIS TO BELIEVE OR SUSPECT
THAT THERE EXISTS A PATTERN OF IMPORTATION OF SUCH PRODUCTS
FOR OTHER THAN THOSE APPLICATIONS, END-USE CERTIFICATION FOR
THE IMPORTATION OF SUCH PRODUCTS MAY BE REQUIRED. UNDER
SUCH CIRCUMSTANCES, ONLY THE IMPORTERS OF RECORD WOULD
NORMALLY BE REQUIRED TO CERTIFY THE END USE OF THE IMPORTED
MERCHANDISE.

ALL PRODUCTS MEETING THE PHYSICAL DESCRIPTION OF SUBJECT
MERCHANDISE THAT ARE NOT SPECIFICALLY EXCLUDED ARE INCLUDED
IN THIS SCOPE.

THE PRODUCTS UNDER INVESTIGATION ARE CURRENTLY CLASSIFIABLE
UNDER SUBHEADINGS 7213.91.3010, 7213.91.3090, 7213.91.4510,
7213.91.4590, 7213.91.6010, 7213.91.6090, 7213.99.0031,
7213.99.0038, 7213.99.0090, 7227.20.0010, 7227.20.0020,
7227.20.0090, 7227.20.0095, 7227.90.6051, 7227.90.6053,
7227.90.6058, AND 7227.90.6059 OF THE HTSUS. ALTHOUGH THE
HTSUS SUBHEADINGS ARE PROVIDED FOR CONVENIENCE AND CUSTOMS
PURPOSES, THE WRITTEN DESCRIPTION OF THE SCOPE OF THIS
PROCEEDING IS DISPOSITIVE.

3. FOR FURTHER REPORTING PURPOSES THIS CASE HAS BEEN ASSIGNED
INVESTIGATION NUMBER A-351-832.

4. FOR IMPORTS OF CERTAIN CARBON AND STEEL WIRE ROD, THE
CUSTOMS SERVICE SHALL SUSPEND LIQUIDATIONS OF SUCH SHIPMENTS
ENTERED OR WITHDRAWN FROM WAREHOUSE, FOR CONSUMPTION ON OR
AFTER APRIL 15, 2002. EFFECTIVE APRIL 15, 2002, CUSTOMS
SHALL REQUIRE, FOR SUCH ENTRIES, A CASH DEPOSIT OR THE
POSTING OF A BOND EQUAL TO THE MARGIN SHOWN BELOW:

MFR/PRODUCER CUSTOMS ID MARGIN
EXPORTER NUMBER PERCENTAGE

COMPANHIA SIDERURGICA A-351-832-001 65.76
BELGO MINEIRA

ALL OTHERS A-351-832-000 65.76

5. IF THERE ARE ANY QUESTIONS REGARDING THIS MATTER BY CUSTOMS
OFFICERS, PLEASE CONTACT, VIA E-MAIL, THROUGH THE
APPROPRIATE SUPERVISORY CHANNELS, OTHER GOVERNMENT AGENCY
LIAISON, USING THE ATTRIBUTE "HQ OAB." THE IMPORTING PUBLIC
AND OTHER INTERESTED PARTIES SHOULD CONTACT VICKI SCHEPKER
OR CHRISTOPHER SMITH, OFFICE OF AD/CVD ENFORCEMENT, IMPORT
ADMINISTRATION, INTERNATIONAL TRADE ADMINISTRATION, U.S.
DEPARTMENT OF COMMERCE, AT (202) 482-1756 OR (202) 482-1442,
RESPECTIVELY.

6. THERE ARE NO RESTRICTIONS ON THE RELEASE OF THIS
INFORMATION.

PAUL SCHWARTZ