The U.S. International Trade Commission has released its administrative review on antidumping duties to be applied to ball bearings and parts from France, Germany, Italy, Japan, and the UK. The period under review is May 1, 2008 through April 30, 2009; 5251R9N7.

The ITC made four main findings: First, that sales have been made below normal value (dumped) by several companies. Second, that myonic GmbH should still be treated the same even though it has been acquired by Minebea (Japan). Third, it is rescinding the administrative review for several companies who withdrew their requests. Fourth, it will revoke duties on ball bearings from Barden/Schaeffler UK.

Dumping is found when a product is sold into the U.S. at a price lower than its manufactured cost of production. Sales in the company's home market are also taken into consideration.

By definition, bearings and parts includes inner race, outer race, cage, rollers, balls, seals, shields, and other components. Finished parts includes all of them. Unfinished parts are included if they have been heat treated or if heat treatment is not required. In other words, the only parts not covered by the order are parts which will be heat treated after import to the U.S.

The ITC's determination on finished bearings includes all bearings, regardless of size or precision or application.

Because a large number of companies requested reviews, the ITC could not complete the review if it looked at each one individually. Instead, the ITC has elected its option to review sample imports from several producers in each country:

France : SKF France and SNR
Germany : Schaeffler KG and myonic GmbH
Italy : Schaeffler Italia (formerly FAG Italia) and SKF Industrie SpA
Japan : NTN Corp. and NSK Ltd.
UK : Barden/Schaeffler UK and NSK Bearings Europe Ltd.

In addition, the ITC said the high volume of imports made it impossible for them to properly calculate the results of each transaction, so selected weeks have been examined.

Finally, in order to streamline its analysis, the ITC took other shortcuts such as combining results for similar bearings and markets, grouping cost structures across multiple items, adjusting for packing and delivery, setting upper and lower cutoff values for costs, and constructing values when there were no home market sales to compare.

Companies and products which don't receive individual reviews are then assigned duties the ITC calculates are representative, based on the results of the other companies. The ITC also makes adjustments for exports by customers the manufacturer didn't know were exporting, and other convoluted situations.

Duties can be revoked if a company proves it did not sell bearings at less than normal value for at least three years. Under that criteria, Barden/Schaeffler UK was able to get the ITC to revoke antidumping duties on bearings from Barden/Schaeffler UK.

The ITC assessed duties as follows:

Ball Bearings and Parts France, Germany, Italy, Japan, UK May 1, 2008 through April 30, 2009
Country / Company	Margin
France : SKF France	6.86 %
France : Microturbo SAS 6	6.86 %
Germany : myonic GmbH	21.72 %
Germany : Schaeffler KG	2.16 %
Germany : SKF GmbH	11.94 %
Italy : SKF Italy	13.04 %
Italy : Schaeffler Italia srl	1.94 %
Japan : JTEKT (formerly Koyo)	10.97 %
Japan : Makino Milling Machine Co. Ltd.	10.97 %
Japan : Mazda Motor Corp.	10.97 %
Japan : Nachi-Fujikoshi Corp.	10.97 %
Japan : Nissan Motor Co.	10.97 %
Japan : NSK Ltd.	8.48 %
Japan : NTN Corp.	13.46 %
Japan : Sapporo Precision, Tokyo Precision	10.97 %
Japan : Univance Corp.	10.97 %
Japan : Yamazaki Mazak Trading Corp.	10.97 %
UK : Barden/Schaeffler UK	0 %
UK : NSK UK	6.85 %
UK : SKF UK	6.85 %
UK : Timken UK, Timken Aerospace UK	6.85 %

These duties are now the most current for these bearings and will remain in place until further notice.

Ominously, the ITC said it will instruct Customs and Border Protection to liquidate duties 15 days after publishing these numbers. Companies involved have consistently and effectively filed injunctions against the liquidation instructions, challenging the ITC's 15-day rule in court. The U.S. Court of International Trade finds Commerce is not acting within the law by implementing such short notice.

As in the past, expect these findings to be appealed repeatedly and liquidation stopped. In fact, the ITC's previous review of these very same bearings has still not been resolved and continues to ping-pong back and forth between the ITC on remand from the U.S. Court of International Trade.

article: Trade court rebukes ITC again for ball bearing dumping investigation