New AD/CVD Petitions: Overhead Door Counterbalance Torsion Springs from China and India - Harris Sliwoski LLP

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Adams Lee

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On October 29, 2024, new antidumping (AD) and countervailing duty (CVD) petitions were filed against imports of Overhead Door Counterbalance Torsion Springs from China and India. Overhead door springs are helical steel springs with tightly wound coils that typically are used to raise and lower overhead doors, such as garage doors, warehouse doors, and trailer doors.

The petition was filed by three U.S. producers, IDC Group, Inc., Iowa Spring Manufacturing Inc., and Service Spring Corp. who claim to account for 75% of domestic production.

These AD/CVD investigations will be conducted by two federal agencies. The International Trade Commission (“ITC”) will investigate whether the subject imports have materially retarded the establishment of the domestic industry. The U.S. Department of Commerce (“DOC”) will investigate whether the subject imports are being sold to the United States at less than fair value (“dumping”) or benefit from unfair government subsidies. Both agencies have to make affirmative findings of material retardation (ITC) or of dumping or subsidies (DOC) in order for AD/CVD duties to be imposed on the subject imports.

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:

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:

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.

Petitioner calculated the following estimated dumping margins

China: 685.93% – 787.30%

India: 104.57% – 124.86%

Petitioner did not provide any specific subsidy margin calculations.

Petitioner included a list of companies that it believes are producers and exporters of the subject merchandise. See attached list of Overhead Door Springs exporters here.

Petitioner included a list of companies that it believes are U.S. importers of the subject merchandise. See attached list of Overhead Door Springs importers here.

October 29, 2024 – Petitions filed

November 18, 2024 – DOC initiates investigation

November 19, 2024 – ITC Staff Conference

December 13, 2024 – ITC preliminary determination

March 28, 2025 – DOC CVD preliminary determination (assuming extended deadline) (1/22/25 – unextended)

May 27, 2025 – DOC AD preliminary determination (assuming extended deadline) (4/7/25 – unextended)

October 9, 2025 – DOC final determination (extended)

November 23, 2025 – ITC final determination (extended)

November 30, 2025 – DOC AD/CVD orders issued (extended)

Adams Lee

Adams Lee has more than twenty years’ experience providing strategic advice and legal guidance on complex international trade and administrative regulatory matters to US and foreign companies, trade associations, and foreign governments. He advises companies in a broad range of industries on international trade remedy and trade policy issues.Adams brings a wealth of knowledge to Harris Sliwoski’s international trade practice. He is adept at quickly evaluating strategic options and developing the best comprehensive legal approach in light of relevant policy and case law. Beyond achieving significant DOC and ITC results that improve his clients’ competitive position, Adams helps them understand complex trade issues so they can make well-informed business decisions.

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