And Our Survey Says ..... Results of Our AD/CVD Benchmark Survey

February 3, 2015

We wish to thank everyone that took part in our November 2014 benchmarking survey on how importers address Antidumping and Countervailing duty (ADD/CVD) orders. 

We received a total of 53 responses. The majority of respondents (41%) had an annual import dollar value of between $100 million and $500 million. The next highest percentage (32%) of respondents had an annual import value of $100 million or less, but we also had a few of the largest importers respond as well! (15% had an annual import value of over $1 billion.)

More than 63% of our respondents import electronics and machinery, and 63% responded that they import goods that are subject to ADD/CVD orders. The two most common orders cited were aluminum extrusions from China and bearings. Over 78% of respondents indicated that they monitor AD/CVD cases with internal company resources. For those that use external resources, 30% use a law firm, 25% use a consultant and almost 50% said “other”. The responses were almost evenly split with respondents (45%) indicated that their ADD/CVD program is monitored by one person and 41% indicating that they more than one person monitoring their ADD/CVD program. While almost 60% of respondents indicated that they have not seen an up-tick in CBP focus on ADD/CVD inquiries, one third of the respondents said that they had.

We had a good cross section of large and smaller companies’ response. Our interest was in how importers of electronics and machinery are dealing with the recent AD/CVD orders on aluminum extrusions from China, so we were pleased that the majority of respondents indicated that this was the category of products that they import. Looking at the data, it appears that more than half are aware that they have one or more ADD/CVD orders that apply to the products they import and that the most common ADD/CVD order referenced was the order on aluminum extrusions from China. We were also interested in knowing how these companies monitored ADD/CVD cases. The overwhelming majority indicated that this is an in-house function with one or more dedicated employees.

What conclusions can we draw from this? Many importers, including midsize importers of electronics and machinery are aware of their obligations to identify imports subject to ADD and CVD orders, including the case on aluminum extrusions from China, and much of the work to monitor and apply the orders are done in-house. While many indicated that they have not seen greater enforcement of AD/CVD orders by CBP, this is perhaps because they already have adequate ADD/CVD compliance programs in place.  

We appreciate your participation in our survey and hope that you will do so again. Click here to view the survey results (http://www.tuttlelaw.com/customs_material/add_survey.pdf). 

If you have questions this or other customs issues, please contact George Tuttle, III, at george.tuttle.iii@tuttlelaw.com or at (415) 986-8780.

George R. Tuttle, III, is an attorney with the Law Offices of George R. Tuttle in San Francisco.

The information in this article is general in nature, and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence, and may not be considered as such.

Copyright © 2015 by Tuttle Law Offices.

All rights reserved.  Information has been obtained from sources believed to be reliable.  However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.

 

 

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