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Trade Enforcement Group Identifies Possible ADD/CVD Circumvention of Aluminum

The Aluminum Association Trade Enforcement Group* has introduced a recent filing to the Commerce Department over possible countervailing of 4017 aluminum alloy imports from China. The increase in 4017 aluminum imports has the association and trade experts questioning whether or not China is dodging antidumping and countervailing (ADD/CVD) orders previously imposed on 3003 and 3105 aluminum sheet, originating from China.  Since ADD/CVD orders were imposed in 2017, imports of 3003 and 3105 from China have declined drastically, whilst US imports of 4107 have increased from zero to over eleven million tons in just the last five years alone (S&P Global). The Aluminum Association claims “Chinese exporters and producers have been marketing and selling increasing volumes of 4107 aluminum sheet as substitutes for 3003 and 3105 alloy aluminum sheet. The heavily overlapping chemistries of alloys 4107 and 3003/3105 indicate that Chinese exporters and producers are simply seeking a “work-around” or the unfair trade orders.”

The secretary of commerce has initiated a statement over the “conversion of 3xxx-series alloy aluminum sheet to 4017 alloy aluminum sheet constitutes a “minor alteration” under 19 U.S.C. § 1677j(c). As a result, the Department should initiate a minor alterations inquiry to address the circumvention of the orders and should determine that 4107 aluminum sheet is subject to merchandise.” These imports have been found to be used in the same applications as aluminum sheet manufactured form aluminum alloy 3003.

The Commerce Department is expected to evaluate the Aluminum Associations recent claim in the upcoming weeks to determine whether or not action is required.

If you have any questions about this issue or any other trade related topic please contact Allyn at

*The Aluminum Association develops global trade standards, practices and expertise for companies that make 70% of aluminum and aluminum products shipped to North America.

Contributor: Lindsay Swanson


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