US AD/CVD order record · dataset entry, not legal advice.
Source: Federal Register · data retrieved 2026-10-16T15:35:05Z
The products covered by the Orders are certain seamed (welded or brazed), non-refillable steel cylinders meeting the requirements of, or produced to meet the requirements of, U.S. Department of Transportation (USDOT) Specification 39, TransportCanada Specification 39M, or United Nations pressure receptacle standard ISO 11118. A full description of the scope of the Orders is provided in the Preliminary Decision Memorandum. Scope of the Circumvention Inquiry This circumvention inquiry covers non-refillable cylinders meeting the requirements of, or produced to meet the requirements of, USDOT Specification 39, TransportCanada Specification 39M, or United Nations pressure receptacle standard ISO 11118 with a water capacity between 100 cubic inches (1.6 liters) and 299 cubic inches (4.9 liters) produced in China and exported to the United States. Statutory and Regulatory Framework Section 781(c) of the Act, provides that Commerce may find circumvention of an AD or CVD order when merchandise of the same class or kind as subject merchandise has been ``altered in form or appearance in minor respects . . . whether or not included in the same tariff classification.'' Section 781(c)(2) of the Act provides an exception that ``{p{time} aragraph 1 shall not apply with respect to altered merchandise if the administering authority determines that it would be unnecessary to consider the altered merchandise within the scope of the {order{time} .'' While the Act is silent as to what factors to consider in determining whether alterations are properly considered ``minor,'' the legislative history of this provision indicates that there are certain factors that should be considered before reaching a circumvention determination. In conducting a circumvention inquiry under section 781(c) of the Act, Commerce has generally relied upon ``such criteria as the overall physical characteristics of the merchandise, the expectations of the ultimate users, the use of the merchandise, the channels of marketing and the cost of any modification relative to the total value of the imported products.'' Concerning the allegation of minor alteration under section 781(c) of the Act and 19 CFR 351.226(j), Commerce examines such factors as: (1) overall physical characteristics; (2) expectations of ultimate users; (3) use of merchandise; (4) channels of marketing; and (5) cost of any modification relative to the value of the imported products. Each inquiry is highly dependent on the facts on the record and must be analyzed in light of those specific facts. Thus, along with the five factors enumerated above, Commerce may also consider the circumstances under which the products enter the United States, including, but not limited to, the timing of the entries and the quantity of merchandise entered during the circumvention review period. See Carbon and Certain Alloy Steel Wire Rod from Mexico: Initiation of Anti-Circumvention Inquiry of Antidumping Duty Order, 83 FR 5405 (February 7, 2018) (citing S. Rep. No. 71, 100th Cong., 1st Sess. 100 (1987)). Id.; see also Deacero S.A. de C.V. v. United States, 817 F.3d 1332 (Fed. Cir. 2016). See, e.g., Certain Uncoated Paper from Australia, Brazil, the People's Republic of China, Indonesia, and Portugal: Affirmative Preliminary Determination of Circumvention of the Antidumping and Countervailing Duty Orders, 82 FR 26778 (June 9, 2017), and accompanying Preliminary Decision Memorandum at ``IV. Statutory and Regulatory Framework.'' Id.; see also, e.g., Affirmative Preliminary Determination of Circumvention of the Antidumping Duty Order on Certain Cut-to- Length Steel Plate from the People's Republic of China, 74 FR 33991, 33992-93 (July 14, 2009); Brass Sheet and Strip from West Germany; Negative Preliminary Determination of Circumvention of Antidumping Duty Order, 55 FR 32655 (August 10, 1990), unchanged in Brass Sheet and Strip from Germany; Negative Final Determination of Circumvention of Antidumping Duty Order, 56 FR 65884 (December 19, 1991); and Small Diameter Graphite Electrodes from the People's Republic of China: Initiation of Anticircumvention Inquiry, 77 FR 37873 (June 25, 2012). Preliminary Determination We preliminarily determine that non-refillable cylinders with water capacities between 100 and 299 cubic inches and non-refillable cylinders with water capacities between 300 and 1,526 cubic inches are not dissimilar in terms of overall physical characteristics of the merchandise, the expectations of the ultimate users, the use of the merchandise, channels of marketing, and the timing and circumstances under which Jinhua Sinoblue Machinery Manufacturing Co., Ltd. (Jinhua Sinoblue) and Ningbo Eagle Machinery & Technology Co., Ltd. (Ningbo Eagle) exported the non-refillable cylinders with water capacities between 100 and 299 cubic inches. Because we find that the merchandise subject to this inquiry is not dissimilar to subject merchandise, we preliminarily determine that the non-refillable cylinders at issue constitute merchandise ``altered in form or appearance in minor respects'' from in-scope merchandise, within the meaning of section 781(c)(1) of the Act. Also, we preliminarily determine that the affirmative circumvention finding should be applied on a country-wide basis. For a full description of the methodology underlying our conclusions, see the Preliminary Decision Memorandum.
Scope text quoted verbatim from the Federal Register notice. Scope text retrieved: 2026-10-19T16:17:45Z. Record last fetched: 2026-10-16T15:35:05Z. Verify against the official notice before relying on it.
| HTSUS (dotted) | 8-digit | Description (USITC reference) |
|---|---|---|
| 7310.29.00 | 73102900 | Other |
| 7311.00.00 | 73110000 | Containers for compressed or liquefied gas, of iron or steel |
Quoting this shipment? Estimate its landed rate in the US tariff calculator, set up change alerts in a free ExportSonar account, or compare plan limits and pricing.
At a glance
The antidumping and countervailing measure covers Non-Refillable Steel Cylinders, imported from China. Case number C-570-127 is one of 540 active orders tracked in the database and was established 2023-11-21; the described product range determines which ten-digit lines inherit the cash-deposit obligation. Scope language in the Federal Register document controls.
As of dataset vintage 2026-10-16T16:09:24Z, yes: importers entering covered goods post a cash deposit at the current rate until Commerce's next administrative review publishes revised margins in the Federal Register. Deposit rates can change every review cycle, so confirm the latest Federal Register notice before you quote a figure to your customs broker.
These HTS headings are recorded in the case linkage: 7310.29.00, 7311.00.00. Confirm the exact ten-digit code against the published scope language, because product descriptions rather than codes alone define the legal boundary of the order, and scope rulings occasionally widen or narrow which lines inherit the deposit obligation.
Primary sources: Federal Register — C-570-127 · USITC Harmonized Tariff Schedule — republished with provenance by exportsonar.com