MAYER.

BROWN
Mayer Brown LLP
1999 K Street, NW
Washington, DC 20006-1 101
Main Tel +1 202 263 3000

MainFax+l 2022633300

June 30, 2016

www.mayerbrown.com

Matthew J. McConkey
Direct Tel +1 202 263 3235
Direct Fax 202-263 5365
mmcconkev@ maverbrown.com

VIA ELECTRONIC FILING

& HAND DELIVERY
The Honorable Penny Pritzker
Secretary of Commerce
Attention: Enforcement and Compliance
APO/Dockets Unit, Room 18022
U.S. Department of Commerce
14th Street and Constitution Avenue, NW
Washington, DC 20230

VIA HANI) DELIVERY

The Honorable Lisa R. Barton
Secretary
U.S. Intemational Trade Commission
500 E Street, SW
Room, lI2A
V/ashington, DC 20436

DOC Inv. Nos. A-533-871, A-475-835,

A-469 -81 5 and C-533 -87 2
USITC Inv. Nos.:701-TA- /731-TATotal Pages: 3078
Investigation

PUBLIC VERSION
Business Proprietary Information Deleted
at Pages: I-3, I- I 3-I- 15, I-23, I-24, I-26, I-

27, r-29, I-31, II-1, rr-2, rr-4, II-5, II-6,

ITT-2, IIT-4-III-6, III-9, IV-2, IV-5, thc
Exhibit Lists for Volume III and IV and
Exhibits I-Il,I-12,I-15, I-15, II-1, 11-5b,
II-5c, II-8, II-1I,lI-I2, III-1, III-8, III-11III-13, TTI-17, ITI-23, IIT-24, IV-l, IV-sb,
IV-8, IV-9, IV-l3 and IV-l9.
Re

Petitions for the Imposition of Antidumping Duties on Imports of Finished Carbon

Steel Flanges from India, haly and Spain and Countervailing Duties on Imports

from India
Dear Secretary Pritzker and Secretary Barton:
On behalf of Weldbend Corporation ("'Weldbend") and Boltex Mfg. Co., L.P. ("Boltex")

(collectively "the petitioners"), we respectfully submit to the U.S. Deparlment of Commerce ("the
Mayer Brown LLP operales in combination with other Mayer Brown entities with offices in Europe and Asia
and is associated with Tauil & Chequer Advogados, a Brazilian law partnership.
1208298'79

The Honorable Penny Pritzker

The Honorable Lisa Barton
June 30, 2016
Page 2

Department") and the U.S. International Trade Commission ("the Commission") the enclosed
petitions for the imposition of antidumping duties on U.S. imports of finished carbon steel flanges

from lndia, Italy and Spai4 and countervailing duties on imports from lndia. \Meldbend and Boltex
are engaged in the manufacture arid production of the domestic like product in the United States and

thus are interested parties withinthe meaning

of

19

U.S.C. 1677 (9XC).

The petitions are organized as follows:

o

Volume I

General Information and Injury;

:

Volume II
o

- Antidumping

Volume III

- Antidumping

Volume IV

Volume V

Allegations for India;

Allegations for ltaly;

Antidumping Allegations for Spain;

Corurtervailing Allegations for India.
: Pursuant

to section 35t.202(c) of the Department's

regulations and section 207 .10(a) of the Commission's regulations, we certiff that the petitions and
j.

all required copies were filed today with both the Department and the Commission. Volumes I thru
Volume IV of the petitions are being filed electronically on the Department's ACCESS filing
system. However, Volume V and the accompanying exhibits are being filed manually with the

.:

Department. An original and nine paper copies of the business proprietary version and an original
plus two paper copies of the ipublic version of the narrative portions of each volume along, with
CDs containing the associated business proprietary and public version exhibits, are being filed
manually at the Commrsslon.

720829879

The Honorable Penny Pritzker

The Honorable Lisa Barton
June 30, 2016
Page 3

Request for Confide{rtial Treatment: Pursuant to paragraphTTT(b)(l) of the Tariff Act

1930, as amended, 19 U.S,C. $

1677(bxl),

of

sections 351.105(c),351.202(d) and 351.304 ofthe

Department's regulations, and 201.6 of the Commission's regulations, petitioners request

':

proprietary treatment for certain information in the petitions, which we designate by placing it

within brackets. The nature of the information, and the basis for this request is as follows

Paee or

Nature of Information

Exhibit

VOLUME I _ COMMON ISSUES AND INJURY

Domestic Industry Operations, Trade and Financial Data

Pages 3, 13, 14, 15, 23, 24, 26, 27,

29,31, Exhibits

l-ll,l-12;

I-14, I-15,

I-15-A.I-15-8.

VOLUME

II.

ANTIDUMPING ALLEGATIONS FOR INDIA

I,2,4,5,6, Exhibits II-1, il5b,II.5c, II-8, II-l I,lI-12.

Pages

Confidential Sources of Information

VOLUME III - ANTIDUMPING ALLEGATIONS F'OR ITALY

2,4,5,6, Exhibit List;
Exhibits III-1, ilI-8, III-11, lIl-12,
III-23.
Exhibits III- 1 3, lll-17, III-24
Pages

Confidential Sources of Information

Information Related to Production Costs

VOLUME IV - AITIDUMPING ALLEGATIONS FOR SPAIN

Pages 1, 5, Exhibit List, Exhibits

1,IV-sb,IV-8.

IV-

Confidential Sources of Information

Exhibits IV-9, IV-13, IV-19.

All of the above information

..:

Information Related to Production Costs

is proprietary and not otherwise available to the public, or is

information that directly would lead to or disclose proprietary information. V/e tther represent

7208298'.79

The Honorable Penny Pritzker

The Honorable Lisa Barton
June 30,2016
Page 4

that disclosure of such infonnion would cause substantial harm to the competitive position of the
'

petitioners, and would impair the ability of the Department and the Commission to obtain
!

comparable information in the future in fulfillment of their statutory functions. A public version of
:

the petitions has been prepared and is being filed simultaneously with this submission pursuant to
section 351.304(c)(l) of the Department's regulations and section 201.S(d) of the Commission's

regulations.

Pursuant to paragraph

351.304(bxlxi) of the Department's regulations, the petitioners

agree

.:
to permit disclosure of all proprietary information under an properly executed administrative
protective order ("APO'). The petitioners, however, reserve the right to comment on all APO
applications prior to any requested disclosure, or to withdraw information in the event that the
agency declines to afford proprietary treatment to any information.
]

Certifications: V/elattach to this letter all appropriate certifications required by the

regulations. These include the verification that information substantially identical to the above-

:'

claimed proprietary information is not available to the public in accordance with 19 C.F.R.

201.6(bx3)(iii), or would otherwise reveal proprietary information. Also attached are the requisite
company and counsel certifications regarding the completeness and accuracy of the information
,.

contained in the petitions.

720829879

The Honorable Penny Pritzker

The Honorable Lisa Barton
June 30, 2016
Page

If you have any qugstions congeming these petitions, please contact the undersigned,

Respectfrrlly

BROWN LLP
999K Sfeet, NW
Washington, DC 20006
(202)263-3000
Weldbend Corportion and
Boltex lt4fg. Co. L.P.
Counsel

720829879

for

CERTIFICATIO

OF'COI]NSEI,

I, Matthew J. McConkey of Mayer Brown LLP, counsel to V/eldbend Corporation and

Boltex Mfg. Co., having been duly sworn on this 30th day of June, 2016, do hereby certify,
pursuant to 19 C.F.R. $ 201.6(bx3xiii) of the Commission's rules, that to the best of my

knowledge and beliet information substantially identical to that for which proprietary treatment
has been requested in this submission is not available to the general public.

Further, in accordance with 19 C.F.R. $ 207.3(a), I hereby certify that (1) I have read the
attached submission, and (2) to the best of my knowledge, the information contained in this

document is accurate and complete

J. McConkey

MAYER BROWN LLP

1999 K Street, NVy'
'Washington,
DC2

District of Columbia: SS
Subscribed and swom before me this
30th day of June, 2016

V
otary Public

My Commission expires

t.r

rr

720829879

:.,

REPRESENTATIVB CERTIFICATION
I, Matthew McConkey, with Mayer Brown LLP, counsel to Weldbend Corporation and

Boltex Mfg. Co., certify that I have read the attached June 30, 2015 Petitons for the Imposition of
Antidumping Dutes on Imports of Finished Carbon Steel Flangesfrom India, Italy and Spain and
Countervaling Dutes on Imports from India (Inv. Nos. A-533-871 , A-475-835, A-469-815 and

c-s33-812)..
In my capacity as counsel of this submission, I certify that the information contained in

this submission is accurate and complete to the best of my knowledge. I am aware that U.S. law

(including, but not limited to, l8 U.S.C. 1001) imposes criminal sanctions on individuals who
knowingly and willfully make material false statements to the U.S. Government. In addition, I
am aware that, even if this submission may be withdrawn from the record of the AD/CVD
proceeding, the U.S. Department of Commerce may preserve this submission, including a
business proprietary submission, for purposes of determining the accuracy of this certification.

I certify that

a copy of

this signed certification will be filed with this submission to the

U.S. Department of Commerce.

Dated: June 30,2016

Matthew M

720829879

COMPANY CERTIFICATION
I, James J. Coulas, Jq prsident, currently employed by Weldbend Corporation, certify
that I prepared or otherwise supervised the preparation of the attachcd June 30, 2015, Pelilions

r the Impostion of ntidumpng Dutes on Imports of Finished Carbon Steel Flangesfrom India,
Italyand Span and CountervailngDuties on Importsfrom Inda (Inv. Nos. A-533-871, A-47583s, 4469-81 5 and C-533-872).

I certiff that the public information and any business proprictary inforrnation

of

Wetdbend containcd in this submission is accurate and cornplete to the best of my knowledge. I
am aware that the information contained in this submission rnay be subject to verification or
.

corroboration (as appropriate) by the U.S. Department of Commerce. I am also aware that U.S.

law'(including, but not limited to, l8 U.S.C. l00l) imposes criminal sanctions on individuals
who knowingly and willfully make material false staternents to thc U,S. Governmcnt. In
addition, I am awarc that, even if this submission may be withdrawn from the record of the

AD/CVD procccding, the U.S. Department of Commerce may preserve this submission,
including a business proprietary submission, for purposes of determining the accuracy of this
certification.
I certify that a copy of this signed certification will be filcd with this submission lo the
U.S- Departmcnt of Commerce.

Signaturc

Datc: June 30, 2016

7l0l{29879

COMPANY CERTIF'I CTIO N

I, Frank Bemobich, president, cumently employed by Boltex Mf. Co., certify that I
prepared or othsnvise supen/isecl the preparation of the attached June 30, 2015 Petitons

r the

Imposition of Antdumping Dutes on Imports of Finishert Carbon Steel Fkutges fi'ont Inrla, Italy
anrl Spain und Cottntervailing Dutes on hnporfrom

Intlitr(lnv. Nos, A-533-871, A-475-835, A-

469-81 5 and C-533-872).

I certify that the public information and any business proprietary information of Boltex
contained in this subrnission is accurate and complete to the best of my knowledge. I am alvare
that the information contained in this subrirission may be subject to verification or coroboration
(as appropriate) by the U.S. Department of Commerce.

I am also aware that U.S. law (including,

but not lirnited to, 18 U.S.C. 1001) imposes criminal sanctions on individuals who knowingly
and

willfully

make material false statements to the U.S. Government. In addition, I am av/are

that, even if this submission may be withdrarvn from the recorcl ofthe AD/CVD proceeding, the
U.S. Dcparrment of Comrnerce may peserve this submisson, including

a business

proprietary

subrission, for purposes of determining the ccuracy of this certification-

I cerlify that

a copy of this signed certification

U.S. Department of Comnerce.

Sign

Date: June 30, 2016

1208218,19

will

o-e

filed with this submission to the

PUBLIC VERSION

DOC Investigation Nos. A-533-871, A-475-835,

A-469-815 AND C-533-872

ITC Investigation Nos.701-TA- , and

731-TA-_

Total No. ofPages: 135

AD/CVD Operations
Petitioners' Business Proprietary Information for
Which Proprietary Treatment Has Been Requested Deleted at
Pages: I-3, I-13-I-15,1-23,I-24,1-26,1-27,

Exhibits

l-ll,l-12,I-14

I-29 and I-31 and at

and I-15

BUSINESS PROPRIETARY DOCUMENT

MAY BE RELEASED UNDER APO

BEFORE THE
INTERNATIONAL TRADE ADMINISTRATION OF THE
U.S. DEPARTMENT OF COMMERCE
AND THE
U.S. INTERNATIONAL TRADE COMMISSION

ANTIDUMPING AND COUNTERVAILING DUTY PETITIONS

,
VOLUME I
:
COMMON ISSUES AND INJURY
FINISHED CARBON STEEL FLANGES FROM INDIA,ITALY, AND SPAIN
PETITIONERS:
WELDBEND CORPORATION & BOLTEX MFG. CO., L.P.

Simeon M. Kriesberg
Matthew J. McConkey
Fabian Rivelis
Sr. International Trade Advisor

MAYER BROWN LLP

1999 K STREET, N,W.
Washington, D.C,20006
(202)263-3000
Counsel to l(eldbend Corporation &
Boltex Mfg. Co., L.P.

June 30,2016
71990s499

TABLE OF CONTENTS
Page

I.

COMMON ISSUES

A.
B.

Contact Information for the Petitioners (19 C.F.R. $ 351.202(bX1)....'

Identity of the Industry on Whose Behalf the Petitions Are Filed (19
C.F.R. $ 207.11(bx2)Xii); le C.F.R. $ 351.202(bX2)

C.

Information Relating to Industry Support for the Petitions (19 C.F.R. 4

J

D.

E.

Previous Requests for Import Relief for the Merchandise (19 C.F.R.
3 s r .202(b)(4)) ...,.......

1.

Section 201 Proceedings....

Section 701 and 731 Proceedings

3.

Other Forms of Import Relief ............

Description of the Merchandise and Requested Scope of Investigation (19

c.F.R. $ 3s1.202(bxs))
1

Requested Scope of Investigations

Technical Characteristics, Production Process, and Uses............,.....

U.S. Tariff Classification .......,.....

II

The Names of the Subject Countries and the Name of Any Intermediate
Country Through Which the Merchandise Is Transshipped (19 C.F.R.

.11

$ 3s 1.202(bX6))...,...,.......

G.

Producers and Exporters of the Subject Merchandise (19 C.F.R.

.,.,,.,... 12

3st.202(b)(7xixA))

351.202(bX8)

H.

Volume and,Value of Imports (19 C.F.R. $

I.

Names and Addresses of U.S. Importers (19 C.F.R. $ 207 .1 1(b)(2)(iii);

c.F.R. $ 3s1.202(bxe))

.............'12
13

T.

INFORMATION RELATED TO SALES AT LESS THAN FAIR VALUE AND

COUNTERVAILABLE SUBSIDIES

I4

III

THE DOMESTIC FLANGES INDUSTRY HAS BEEN MATERIALLY

INJURED BY REASON OF LINFAIRLY TRADED IMPORTS OF FLANGES
FROM INDIA,ITALY AND SPAIN.......

l4

.l

71990s499

A.

Introduction,..........

t4

B.

The Domestic Like Product Mirrors the Scope of the Petition........

t6

C.

The Domestic Industry Consists of All U.S. Producers of Flanges.

t8

D.

Subject Imports Surpass the Statutory Negligibility Threshold ......

l8

}
TABLE OF'CONTENTS
(continued)
Page

The Commission Should Cumulate Imports From the Three Subject

Countries In Analyzing the Effects of the Unfair Imports.....

a. .

Imports From All Subject Countries Are Fungible...................... 19

b. ,

All

c.
d. '

e.
F

Subject Imports Compete in the Same Geographic

Markets

20

Subject Imports Are Sold Through the Same Channels of

Distribution ....

20

Subject Imports Are Simultaneously Present in the U.S

Market..

20

Conclusion

2t

Cumulated Imports From the Subject Countries Are Causing Material

Injury to the Domestic Flange Industry

1.

..,,21

The Volume of Imports From the Subject Countries Is Significant

,',,.,,..',,22
and Increasing ..................

a.
b

2.

,,' 19

The Volume of Imports Is Significant and Increasing in

Absolute Terms....

22

Subject Imports Have Increased Significantly as a Share of

the U.S. Market......

23

Unfairly Traded Imports from the Subject Countries Have Had an

Injurious Impact on Domestic Producer Prices for Flanges

23

Import Prices of Flanges Have Declined Over the POI and

Have Undersold Domestically-Produced Flanges by
...............23
Substantial

a.

Margins

b.

Unfairly Traded Imports Have Caused Suppression and

Depression of U.S. Prices of Flanges......

24

Identification of Flange Products for Which Petitioners

Request Collection of Price Data..

25

Unfairly Traded Imports Have Had an Injurious Impact on the

Domestic Flange Industry..

25

c.
3.

a.'
:

b.

Declines in Domestic Industry Production, Capacity

Utilization, and U.S. Shipments.

26

Petitioners' Declining Operating Income Demonstrates the

Injurious Impact of the Substantial Volumes of Low-Priced
Imports from Subj ect Countries................

..27

Imports from the Subject countries...

,,28

c.

1l
'719905499

TABLE OF CONTENTS
(continued)
Page

4.

G.

Subject Imports Threaten Additional Material Injury to the Domestic

Industry ........................

1.
2.

.30

Subject Imports Threaten Domestic Producers with Additional

Material Injury.

.30

b.

The Domestic Flange Industry Is Vulnerable to Material

Injury from the Subject Imports.....

.3l

The Subject Imports Have Significantly Increased in

Volume and Market Share

.31

c.

The Subject Imports Have Demonstrable Adverse Price

Effects That Are Likely to Continue................ ..........32

d.

The Subject Country of India Encourages Exportation of

Subj ect Merchandise Through Countervailable Subsidies .......... 32

e.

Subject Producers Have Significant Volumes of New and

Unused Capacity, Indicating the Likelihood of Substantial
Increased Imports.....

f.

Summary...

.33
34

CONCLUSION

34

lll
'n9905499

.29

The Commission Should Cumulate Subject Imports for Purposes

of lts,Threat Analysis

a.

IV

.29

Conclusion

PUBLIC VERSION

These petitions are filed on behalf of the U.S. industry producing finished carbon steel

flanges ("flanges"). The petitioners in this case are Weldbend Corporation ("'Weldbend") and

Boltex Mfg. Co., L.P. ("Boltex") (collectively "Petitioners"). These two companies account for
the majority of flange production in the United States and, therefore, represent the U.S. industry

producing flanges within the meaning of sections 702(c)(a) and732(c)(4) of the Tariff Act of
1930, as amended (the "Act").1
Petitioners allege that flanges, which are more fully described in Section 1.E., infra, from

India, Spain and Italy are being, or are likely to be, sold in the United States at less than fair
value within the meaning of section 73 1 ( I ) of the Act.2 Petitioners further allege that the
Government of India is providing countervailable subsidies with respect to the manufacture,

production, and export of flanges within the meaning of section 701(a)(1) of the Act.3
Petitioners also allege that the unfairly traded imports are a cause of material injury to the U.S.

industry producing flanges and threaten to cause further material injury if remedial action is not

taken. Petitioners, therefore, request that antidumping duties be imposed on flanges from India,
Spain and Italy in an amoirnt equal to the amount by which the normal value exceeds the export

price or constructed export price of the merchandise. Petitioners also request that countervailing
duties be imposed on imports of flanges from India in an amount equal to the net countervailable
subsidy.
These petitions set forth relevant information reasonably available to Petitioners and are

filed in conformity with the requirements of section35l.202 of the regulations of the U.S.

l9 U.S.C. $$ 1671a(cX4), 1673a(c)(4).

19 U,S.C. $ 1673. Se also, Exhibit I-15.
le U.S.C. $ 1671(aXl).

719905499

PUBLIC VERSION

Department of Commerce (i'6.*erce" or "the Department") and section 207

.ll

of the

o'Commission").4
regulations of the U.S. International Trade Commission (ooITC" or

I.

COMMON ISSUES

A.

Contact Information for the Petitioners (19 C.F.R. $ 351.202(bxl))

Petitioners are companies that produce the domestic like product in the United States.
Petitioners are therefore domestie interested parties with the meaning of 19 U.S.C. $ 1677(9) and
19 C.F.R. $ 351.102(b). The two Petitioners in this case are:

Weldbend Corporation
6600 South Harlem Ave.
Argo,IL 60501-1930

Boltex Mfg. Co., L.P.

4901Oates Road

'Weldbend purchases flange forgings that it then processes into finished flanges, while Boltex

produces its own flange forgings, which it then either processes into finished flanges or sells to
.

other U.S. companies that process the flange forging into finished flanges. The only other
domestic company that is'known to have any meaningful domestic flange forging operations is

Ameri-Forge. See Exhibit I-15. As such, the rest of the domestic industry primarily purchases
flange forgings and processes them into finished flanges.

Neither Weldbend nor Boltex imports the subject merchandise, nor are either of them

affiliated with any importers or exporters of the subject merchandise.

l9 C.F.R. $$ 351.202;and207,ll

2
7r990s499

PUBLIC VERSION

B.

Identty of the Industry on \ilhose Behalf the Petitions Are Filed (19 C.F.R.
$ 207.11(bX2)Xii); le c.F.R. $ 3s1.202(bX2))

These petitions are filed on behalf of the U.S, industry that produce flanges.

Exhibit I-1

contains contact information for known flange producers in the United States. The list

of

domestic producers of flanges is based on general industry knowledge, Internet research, and the
declarations of the presidents for both Weldbend and Boltex. See Exhibit

I-2. Based on the best

:l

information available to Petitioners, Exhibit I-1 identifies all known producers of the domestic
like product in the United States.

C.

Information Relating to Industry Support for the Petitions (19 C.F.R.

3s1.202(bX3))
The statute requires that "the domestic producers or workers who support the petition
account for at least 25 percent of the total production of the like product.5 In addition, the statute
requires that "the domestic producers or workers who support the petition account for more than
50 percent of the production of the domestic like product produced by the portion of the industry

expressing support for or opposition to the petition."6

Petitioners, as U.S. producers that are known to be in support of the petition, surpass both
the 25 percent and 50 percent thresholds for industry support established in the statute. The

combined volume of Petitioners' production of flanges in 2015 was

] pounds. As

identified in Exhibit I-1 there arc 12 additional domestic producers of flanges. However,
company-specific production data for those 12 additional domestic producers are not available to
Petitioners, nor do Petitioners know of any source of information (public or otherwise) for that

data. However, as set forth in the affidavits at Exhibit I-2, Petitioners are quite confident that

le U.S.C. $ 167Ia(c)G)(AXi) and 19 U.S.c. $ 1673a(cXaXAXi).

le U.S.C. $ 1671a(cXa)(AXii) and le U.S.C. $ 1673a(c)(a)(Axi.

J
'n9905499

PUBLIC VERSION

they represent more than250/o of total domestic production of flanges. See also Exhibit I-15 for
a calculation of how Petitioners meetthe

25 and 50 percent rules. Indeed, as set forth in Exhibit

I-15, Petitioners easily met both the 25 and 50 percent rules.

D

Previous Requests for Import Relief for the Merchandise (19 C.F.R.
3s1.202(bX4))

1.

Section 201 Proceedings

The domestic industry previously sought relief from serious injury suffered as a result

of

surges in imports of certain steel products, including carbon and alloy steel flanges, pursuant to

section 201 of the Trade Acl of 1974 ("Section 201") (19 U.S.C. 2251).
On June 22,200I,,.the Commission initiated a safeguard investigation under section 201,

following receipt of

a request

from the USTR covering certain steel products, including carbon

and alloy steel flanges. On July

26,200I,the Commission also received

resolution adopted by

the Committee on Finance of the U.S. Senate ("Finance Committee") requesting that the

Commission investigate certain steel imports under section 2017 The Commission consolidated
the investigation requested by the Finance Committee with the Commission's previously

instituted investigation.

On Decem ber 20,2001,the Commission issued its determination and remedy

recommendations. The Commission reached an affrrmative determination with respect to certain

steel products, including flanges.e

It recommended an additional

13 perce nt ad

valorem duty on

flanges in the first year of relief, to be reduced to a 10 percent ad valoremduty in the second

Consolidation of Senate Finane Committee Resolution Requesting a Section 201 Investigation with the
Investigation Requested by the United States Trade Representative on June 22. 2001, 66 Fed. Reg. 44,158 (USITC

Aug,22,2001).

I
e

See id.
See Steel,Inv, No. TA-201'-7'3,USITC

Plb.3479 (Dec,2001), Vol.I at l.

4
7t9905499

PUBLIC VERSION

year of relief, 7 percent ad valorem dty in the third year of relief, and 4 percent ad valorem duty

in the fourth year of relief.lo

.'

On March 5,2})2'"Frsident George W. Bush announced safeguard measures covering

10 different product categories

--- including flanges

for which the Commission made

affirmative determinations or was evenly divided. Presidential ProclamationTS2gimplemented

the safeguard measures, principally in the form of tariffs and tariff-rate quotas, effective March

20,2002,which were originally intended to last for

a period

of three years and one day.lr

The President also instructed the Secretary of the Treasury and the Secretary

of

Commerce to establish a system of import licensing to facilitate the monitoring of imports

of

certain steel products.12 The purpose of the import monitoring system was to provide steel
producers, consumers, importers, and the general public with accurate and timely information on
anticipated imports of certain steel products. The system required licenses for imports of certain
steel products that were covered under the President's safeguard action.l3 On December 4, 2003,

President Bush terminated the increased tariffs under the safeguard measure.la The import

licensing system, however, remained in place through March 21,2005, and continues in

modified form at this time.ls

ro
tr
t2
t'
t4

ft.

at2.

'

ld.
The Department of Commerce published regulations establishing such a system on December 31,2002.
See Steel lmport Mo4itorine and Analysis System. 70 Fed. Reg. 12,133 (Dep't Commerce Mar. 11, 2005).
See Presidential Proclarnation 7741 of December 4. 2003. To Provide for the Termination of Action Taken

With Regard to Imports of Ce4ai Steel Products" 68 Fed. Reg. 68,483, 68,484 (Dec. 8, 2003).

rs

See Steel Import Monitoring and Analysis System. 70 Fed. Pieg.72,373 (Dep't Commerce Dec. 5, 2005).

5
719905499

PUBLIC VERSION

2,

Section 701 and 731 Proceedings

To Petitioners' knowledge, carbon steel flanges have not been subject to previous
antidumping and/or countervailing duty investigations under sections 702 and732 of the Trade

Act of 1930, as amended (the "Act") (19 U.S.C. $$ 1671a and I673a). As such, currently, there
are no antidumping duty orders on carbon steel flanges from India, Spain and

ltaly, and no

countervailing duty order on carbon steel flanges from India.

While there are orders against various fitting products, including Carbon Steel Butt-V/eld
Pipe Fittings, fittings are different products, and have different uses from the flanges that are
covered by these petitions. Put simply, a weld fitting is a connection joined by the process

of

welding the ends of the fitting to pipe or any other type of structure that needs a solid connection.

A flange is only welded in one area. However, the biggest difference is that flanges have holes
in the flange portion of the product that is to be joined with another flange or valve or other type
of connection with the same bolting pattem.

3.

Other Forms of Import Relief

Petitioners have not sought import relief under section 337 of the Act (19 U.S.C. $ 1337),
'

section 232 of the Trade Expansion Act of 1962 (19 U.S.C. $ 1862), or section 301 of the Trade

Act of lg74 (Ig U.S.C.

$ 2411),

with respect to the merchandise that is the subject of these

petitions.

E.

Description of the Merchandise and Requested Scope of Investigation (19

c.F.R. $ 3s1.202(bxs))

l.

Requested Scope of Investigations

The imported merchandise that Petitioners intend to cover in these investigations are
:l

finished carbon steel flanges, which are classified in the HTSUS under subheadings
7307.9L 5010 and7307.91.5050. A full description of the scope of these investigations is
6
719905499

PUBLIC VERSION

contained in Exhibit

I-3. As noted, the product

covered is carbon steel flanges. Flanges can

also be made of alloy steel, stainless steel and other types of metals, but those are not covered by
:

these

petitions.
2.

Technical Characteristics, Production Process, and Uses

A flange is a product for connecting pipes, valves, pumps and other equipment to form

piping system. It also provides easy access for cleaning, inspection or modification. Flanges
are usually welded or screwed. Flanged joints are made by bolting together two flanges with a
gasket between them to provide a seal. The material of a flange is basically dictated by the

choice of the pipe, as in most cases a flange is of the same material as the pipe. As such, this
makes, for example, alloy steel flanges different from carbon steel flanges, or stainless steel

flanges. Although the word "flange" generally refers to the actual raised rim or lip of a fitting,
many flanged plumbing fittings are themselves known as 'flanges,' The basic types of flanges
are
i

Weld neck

V/eld neck flanges are circumferentially welded at the neck where the integrity of the butt
welded area can be easily examined by radiography. The bores of both pipe and flange
match, which reduces turbulence and erosion inside the pipeline. The weld neck is
therefore durable in,critical applications. It is designed to be joined to a piping system
by butt welding. It is preferred for high stress applications. The neck, or hub, transmits
stresses from the base of the h-ub to the wall thickness at the butt weld, providing
important reinforcement of the flange.

7
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PUBLIC VERSION

Slip-on

Slip-on flanges are fitted over the pipe. Slip-on flanges are easy to use in fabricated
applications. Therflange is slipped over the pipe and then welded both inside and outside
to provide sufficient:strength and prevent leakage.
o

Socket Weld

This is similar to a slip-on flange, but the bore is counter-bored to accept pipe. The
diameter of the rernaining bore is the same as the inside diameter of the pipe. The flange
is attached to the pipe by a fillet weld around the hub of the flange. An optional interval
weld may be applied in high stress applications. This flange's biggest use is in high
pressure systems suh as hydraulic and steam lines.
a

Threaded

Threaded flange are,referred to as either threaded or screwed. They are used to connect
other threadedcomponents in low pressure, non-critical applications. This is similar to
slip-on flanges, buf lhe bore is threaded, thus enabling assembly without welding. The
lack of welding limits this flange's application to relatively low pressure piping systems.

I
719905499

PUBLIC VERSION

Lap Joint

A lap joint is used in low pressure applications because it is easily assembled and aligned.
A lap joint is similar to a slip-on flange, but it has a radius at the intersection of the bore
and the flange face to accommodate alap stub end. The face on the stub end forms the
gasket fce on the flange. This type of flange is used in applications where sections of
piping systems need to be dismantled quickly and easily for inspection or replacement.
o

Blind

Blind flanges are used to blank off pipe lines, valves and pumps. They can also be used
as an inspection cover. This is a flange without a bore and is used to shut off a piping
system or vessel opening. It also permits easy access to vessels or piping systems for
inspection purposes. Blind flanges can be supplied with or without hubs at the
manufacturers option. It is sometimes referred to as a "blanking flange."
a

Rin ttt typ e

:;

Ring type joint flanges are used to ensure a leak-proof flange connection at high
pressures. A metal ring is compressed into a hexagonal groove on the face of the flange
to make the seal.

9
719905499

PUBLIC VERSION

Weld-neck and slip-ons are the most common types of flanges. There are also other types of
"special" flanges, which include:
o

Orifice

Long welding neck

'W el do

Expander
Reducing
Spectacle '
Groove & Tongue
Flat Face Flanges'
Raised Face Flanges

o
a

o
a
o

fl ange/lll

po

fl an g

However, the sales volumes/values of these specialty flanges are very small in relation to the
more common types such as weld-neck, slip-on, threaded, and so forth.
Steel flanges typical'ly have the following pressure ratings
1

50#

300#
400#
600#
900#
1 500#
2s00#

With 150# and 300# being the most common. The most common facings on machined flanges
are
a
a

a
o

Flat face
Raised face
Tongue and Groove
Ring Joint
,

Flanges normally come with 4

-,8-,

12- or 16-bolt holes.

Flanges are manufactured in many difTrent types of materials, such as alloy steel,
stainless steel, cast iron, aluminum, brass ,btonze,plastic, and others. However, the most

common material is forged carbon steel, produced in accordance with ASTM 4105. Flanges are

l0
719905499

PUBLIC VERSION

generally produced in accordance with ASME 816.5, in a number of standard dimensions. A

description of the production process for flanges is provided at Exhibit I-4.

A substantial

share of flange production is consumed in the

oil and

gas industry as

connection components for pipes, valves, and pumps used to produce oil and gas. The remainder

is sold to the chemical, wind, pharmaceutical, and other industries as connection components in
piping systems.
As set forth in the scope language at Exhibit 1-3, the scope of this investigation does not
cover flange forgings, which are carbon steel forgings that have not been subject to any further
processing (other than heat treatment).

3.

U.S.

Tariff ClassifTcation

Finished carbon steel flanges are currently classifiable in the following HTSUS
subheading

s:

7307 .91.501

and 7307 .91 .5050. Although the HTSUS subheadings are provided

for convenience and U.S.:Customs & Border Protection purposes, the written description of the
merchandise under investigation is dispositive. Excerpts from the current HTSUS are attached
as

Exhibit I-5. The most-favored nation duty rate for imports under the identified HTSUS

subheadings is 5.5 percent ad valorem. The

tariff numbers are provided for the convenience of

the U.S. Government and do not define the scope of the petitions.

F.

The Names of the Subject Countries and the Name of Any Intermediate
Country Through Which the Merchandise Is Transshipped (19 C.F.R.
s 3s1.202(bxo)

The flanges that are the subject of these petitions are produced in, and exported from,

India, Spain and Italy. Petitioners have no knowledge that the subject merchandise is currently
being transshipped from these countries through any third country to the United States.

11
719905499

PUBLIC VERSION

G.

Producers and Exporters of the Subject Merchandise (19 C.F..R.

3s1.202(b)(7XiXA)

A list of known producers and exporters of flanges from India is provided in Exhibit I-6.
A list of known producers and exporters of flanges from Spain is provided in Exhibit I-7. A list
of known producers and exporters of flanges from Italy is provided in Exhibit

I-8. In compiling

these exhibits, Petitioners relied upon Internet research and general market knowledge. See

Exhibit I-2.
Information reasonably available to Petitioners does not allow the identification of the
proportion of total exports to the United States accounted for during the most recent l2-month
period by the producers listed in F.'.xhibits

l-6rl-7

and

I-8.

Petitioners believe, however, that the

companies listed in Exhibits I-6,1-7, and I-8 account for substantially all exports of the subject
merchandise to the United States from the subject countries.

Similarly, information reasonably available to Petitioners does not allow the calculation
of production capacity, production output, etc. of the producers listed in Exhibits l-6rl-7 and I-

8.

Indeed, Petitioners are simply unaware of any data source (public or otherwise) for that

information.

H.

Volume and Value of Imports (19 C.F.R. $ 351.202(bX8))

The volume and value of U.S. imports of flanges from each subject country are presented
at

Exhibit I-9 for calendar years

source for these data is the

2013

,20l4,and 2015, as well

as the

first quarter of 2016.16 The

official import statistics published by the U.S. Department of

Commerce. The import data at Exhibit I-9 are provided on both an FOB and a CIF basis.

t6

Import information was:obtained through the ITC's DataWeb.

12
'n9905499

PUBLIC VERSION

These petitions cover the subject merchandise from India, Spain and

ltaly. The next

largest import sources are China, Germany and Korea, whose 2015 shipments were:

China

7307.9t.5010

16,509,095

7307.9t.5050

5,658,608

9,694,rr3

11,656,987

26,203,208

7307.91.50r0

3,925,62r

7,489,440

7307.91.5050

1,419,337

3,045,909

5,243,958

10,535,349

7307.91.5010

377,393

1,673,569

7307.91.50s0

2,609,047

6,699,839

2,985,440

8,373,408

Total
Korea

Total
Germany

Total

Value

Quantity
5,998,379

Names and Addresses of U.S. Importers (19 C.F'.R. $ 207.11(b)(2)(iii); C.F.R.

$ 3s1.202(bxe))

Based on information reasonably available to Petitioners, a list of known and suspected

importers of flanges from the subject countries is provided in Exhibit I-10. This list was

compiled from general knowledge of the market, Internet research and PIERS data. Petitioners
have undertaken their best fforts in preparing

Exhibit I-10.

Indeed, in addition to providing the

names and addresses, we were able to locate emails andlor phone numbers for each importer.

Petitioners believe, however, that there may be a number of importers of flanges from the
subject countries that cannot be identified from publicly available information. Accordingly,
Petitioners respectfully request that the Department obtain this information from U.S. Customs
:l

and Border Protection, as Petitioners do not have access to this information.

Petitioners do not have any direct knowledge as to whether any of the other identified
domestic producers of flanges (Exhibit I-1) import the subject merchandise, or flange forgings

into the United States. Neither Petitioner imports finished flanges. However, I

13
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PUBLIC VERSION

II.

INF'ORMATION RELATED TO SALES AT LESS THAN FAIR VALUE AND

COUNTERVAILABLE SUBSIDIES
Information related to allegations of less'than-fair-value sales from India, Spain, and Italy

is provided in Volumes II (India),,

il

(Italy) and IV (Spain) of these petitions. Information

related to the countervailable subsidies provided by the Government of India with respect to the
:

manufacture, production, and export of flanges is provided in Volume V of these petitions.

uI.

THE DOMESTIC T'LANGES INDUSTRY HAS BEEN MATERIALLY INJURED

BY REASON OF UNFAIRLY TRADED IMPORTS OF F'LANGES FROM INDIA,
ITALY AND SPAIN

A.

Introduction

Dumped and subsidized imports of flanges from India, Spain, and Italy have already
caused material injury to the domestic industry

and threaten the domestic industry with even

more injury going forward.lT The volume of subject imports increased by 27 percent between

2014 and2015,while U.S. demand for flanges decreased bV

I percent.

See

Exhibit I-11.

Subject imports captured this increase in market share at the expense of the domestic producers.

Although subject import market share decreased slightly in the first quarter of 2016 as compared

to 2015, it remained [ ]:percentage points higher than in 2014. Id.

The price effects of subject imports are also signifrcant. Subject imports are
interchangeable with the domestic like product

as shown by the

factthat subject imports have

already taken significant market share from U.S. producers. Information reasonably available to
the Petitioners indicates that the surge in market share was accomplished through systematic

underselling. The combination of underselling by subject imports and a decline in U.S. demand
contributed to a decline in pricing over the period of investigation ("POI"). Subject imports

t7

Because Weldbend arid Boltex account for more fhan 50Yo of domestic production of the subject carbon
steel flanges (see Exhibit I-15), the refer to them as either "Petitioners," "the domestic producers," the "U.S,

producers," or "the domestic industry,"'

t4
719905499

PUBLIC VERSION

suppressed and depressed prices for the domestic like product, under increasingly unfavorable
demand conditions.

Subject imports have had a significant harmful impact on the domestic industry. Due to
increased import penetration and underselling by imports, virtually all of the Petitioners' trade
and financial indicators have declined. See

Exhibit I-11. In addition to being subject to lower

demand, the domestic industry has increasingly lost market share due to the underselling by
'

subject imports. Domestic producers

] from 2013 to 2014, with a I

] in their market share. However, in 2015, U.S. producers' U.S. shipment volume was
just over t

I This t
corresponded to a

I percentage point decline for U.S. producers from 2014 to 2015

] percentage point market share increase for subject imports, which also

took market share from non-subject imports. In the first quarter of 2076, subject import volume
and share declined only slightly, and retained almost all of the market share gained in 2015.

The increasing volumes of low-priced imports that continually undercut U.S. producer
prices resulted in significant financial deterioration of the U.S. industry. The decline in U.S.

producers' U.S. sales volume and value reflect the combination of

prices, and largely explain the

the

ratio

] in operating profit from 2013 to 2015, and

] in Jan.-M ar.,2016. The domestic producers' operating income to net sales

]fromt lpercentin2013to[ ]percentin2015andtoalossof[

percent in January-March, 2016. See Exhibit I-11. The causal link between imports and U.S.

producers' financial performance is fuither corroborated by significant instances of lost sales and
revenues provided by the domestic producers. See

l5
71990s499

Exhibitl-12.

PUBLIC VERSION

Thus, the domestic industry has suffered material injury by reason of the subject imports,
as manifested

in market shate lost to the unfair imports, depressed and suppressed U.S. prices,

and the resulting deterioration in key trade and financial indicators.

Subject imports also threaten the domestic industry with further material injury. Because

its financial performance was adversely affected by the subject imports during the POI, the
.l

domestic flange industry is cunently vulnerable to injury by imports. The rapid and dramatic
increase in the market share of subject imports demonstrates the ability of the subject imports to
enter the U.S. market rapidly, and in large quantities. The subject imports have also had

demonstrable negative price effects, as the rising market share of subject imports forced
domestic producers to lower their prices in an attempt to avoid further loss of market share and
capacity utilization. Producers of flanges in the subject countries have both substantial capaciy
and substantial excess capacity.ls This substantial unused capacity

will allow them to increase

exports to the United States even further. Taken together, these factors

will make it difficult,

if

not impossible, for the domestic flange industry to generate the level of profit necessary to fund
research and development and to make capital investments needed to remain competitive unless

trade relief is granted. Indeed, as shown further below, the statutory factors that the Commission
is required to consider demonstrate that subject imports threaten the domestic industry with

further material injury. In the absence of trade relief, subject imports will continue pouring into
this market, causing additional harm to the U.S. industry.

B.

The Domestic Like Product Mirrors the Scope of the Petition

The statute defines the domestic like product as

ooa

product which is like, or in the

absence of like, most similar in characteristics and uses with, the article subject to an

It

See

Exhibit

1-2

T6
719905499

PUBLIC VERSION

investigation.le The Commission generally considers a number of factors in defining the like
product, including physicallcharactsristics and uses, interchangeability, channels of distribution,
customer and producer perceptions, common manufacturing facilities, production processes and
employees, and, where appropriate, price. See,

gg, Nippon Steel Corp. v. United

States, 19 CIT

450,455 (1995). No single factor is dispositive and the Commission's decision regarding the
appropriate like product is a factual determination made on a case-by-case basis. The

Commission looks for clear defining lines between products, but disregards minor variations.
The domestic like product here is identical to the definition of the subject merchandise
and also consists of finished flanges.
example,
Taking the seven common flange types identified in section I.E.2 above' as an
size, etc., they all
while each flange type may be in a different configuration in terms of shape,

they are all used as flanges

have the same physical characteristic of being made of carbon steel,
(to distributors
(as explained above), they are all sold in the same channels of distribution

and

by customers and
in fact to the same distributors), they are all universally known and identified
facilities, using the
producers alike as being flanges, they are all made in the same manufacturing
was a petitioner in the case
same production processes and employees. Indeed, Weldbend
covers, in relevant part:
against Carbon Steel Butt Weld Pipe Fittings. The scope in that case
.,carbon steel butt-weld pipe fittings, having an inside diameter of less than 14 inches"

'"

Like

and to best recollection of

flanges, butt-weld pipe fittings come in a variety of shapes and sizes,

Weldbend, were found to be a single like product'

l9

1e

u.s.c. $ 1677(lo).

t7
719905499

PUBLIC VERSION

C.TheDomesticlndustryConsistsofAllU.S.ProducersofFlanges
SectionTTl(4XA).oftheActdefinestherelevantindustryasthe.oproducetsasawholeof
of a domestie like product
producers whose co[ective output
those
or
product,
like
a domestic
product'"2. Based on the
domestic production of the
the totar
constitutes a major proportion of

consists of all
above, the domestic industry
domestic rike product defined

u's'

producers of

flanges

D.SubjectlmportsSurpasstheStatutoryNegligibilityThreshold
Importsofflangesfromlndia,spain,andltaly,onanindividualcountrybasis,surpass
from a subject country
by the statute' By law' imports
the negligibility threshold established
such
for less than three percent of all
account
that
product
like
corresponding to a domestic
for which dataarc
during the most recent 12 months
states
united
the
to
merchandise imported
import volumes from
are deemed negligible.2t u.s.
petition
the
of
filing
the
available preceding
(May 2015 through April 2016)'
most recent l2 month period
the
during
countries
the subject
1 below'
imports' are set forth in Table
and their percentage of total

TABLE

Flanges for May 2015 - April2016

U.S. Imports of Carbon Steel
ofT otal

tons

58

15

11
1

I'9

20

le u.s.c, $ 1677(4XA)'

2l

le u.s.c. $ 16??(24XAXi)
18

719905499

Imports

PUBLIC VERSION
a

Accordingly, imports of flanges from each of the three subject countries are not negligible within
the meaning of 19 U.S.C.,$ 1677(24)( )(i).

E.

The Commission Should Cumulate Imports From the Three Subject

Countries,In Analyzing the Effects of the Unfair Imports

Section 771(7XGXi) of the Act requires the Commission to cumulatively assess the

volume and effect of imports of the subject merchandise from all countries with respect to which
petitions were filed underlsecti on 732(b)on the same day, if such imports compete with each
other and with the domestic like product in the United States.22 The statutory factors mandating
a cumulative analysis are met in this case.

Specifically, petitions against flange imports from India, Spain, and ltaly are being filed
simultaneously. Further, none of the statutory exceptions to cumulation applies in this

"use.t3

Thus, provided there is evidence of a reasonable overlap in competition, cumulation of subject

imports is mandatory.

An examination of the factors traditionally considered by the Commission to determine

whether a reasonable overlap of competition exists demonstrates that each factor is met in this
case

a. '

Imports From All Subject Countries Are Fungible

Flange imports from India, Spain, and Italy Spain are generally substitutable with each
other and with the domestio like product. Imports from each of the subject countries are
generally made by the same processes on similar equipment, and generally have the same
chemical and physical properties, as the domestic like product.2a

22

le U,S.c. $ 1677(7XgXi).

23

le U.S.C. $ 1677(TXeXii).
See Exhibit l-2.

24

t9
719905499

PUBLIC VERSION

b.

All Subject Imports Compete in the Same Geographic Markets

Imports from each of the subject countries compete with imports from the other subject
countries and with the domestic trike product throughout the U.S. market. Exhibit I-13 shows

significant overlap among the subject countries with respect to the ports into which they entered
the United States in 2015iand the first quarter of 2016. For example, ports of entry where

,:

imports from all three sources were present during this period accounted for 83 percent of total
subject import volume during this period. Flanges produced in the United States and imported

from the subject countries are all currently sold nationwide.

c.

Subject Imports Are Sold Through the Same Channels of

Distribution
A large share of flanges, whether produced in the United States or imported, are sold
through distributors, rather than directly to end users. Based on its knowledge of competition in
the market, Petitioners believe that imports from each of the subject countries are purchased by
many, if not all, of the same distributors. See

Exhibitl-2.

Subject imports are capturing market

share from the domestic industry, providing compelling evidence that some customers have

switched their purchases from the domestic like product to subject imports. This factor also
supports cumulation of the subject imports.
r'

d.

Subject Imports Are Simultaneously Present in the U.S.

Market
Imports of flanges from each of the subject countries entered the United States in every
year during the POI. See Exhibit

I-9. Domestically-produced flanges

also have been available

in the U.S. market throughout the POI. Thus, this factor provides further evidence that subject
imports are competing with each other and the domestic like product.

20
719905499

PUBLIC VERSION

Conclusion
Both domestically-produced and imported flanges, whether imported from India, Spain,
or Italy, are fungible products that are produced to standard industry specifications and compete

directly against one another. Imports from each of the subject countries and the domestic
product are sold through the same distribution channels, primarily to distributors, and are sold in

'.

the same geographic markets. Imports from each subject country and U.S.-produced flanges

:,

have been simultaneously present in the U.S. market in each of the POI years. Moreover, the

U.S. market for flanges is highly price-sensitive, with competition occurring between imports
and domestic producers for sales on the basis of

price. These factors collectively support the

conclusion that there is a reasonable overlap of competition between the subject imports and the
domestic like product within the meaning of the statute. Accordingly, the Commission should
cumulate imports of flanges from India, Spain, and ltaly in analyzing whether subject imports
have caused material injury to the domestic industry in this case.

F'.

Cumulated Imports From the Subject Countries Are Causing Material

Injury to the Domestic Flange Industry

In determining whether the domestic industry has been injured by reason of the imports
under investigation, the statute directs the Commission to consider: (1) the volume of imports

of

the subject merchandise; (2) the effect of imports of that merchandise on prices in the United
States for the domestic like product;

an

(3) the impact of imports of such merchandise on

domestic producers in the context of production operations within the United States. Information
reasonably available to Petitioners indicates unfairly traded imports from India, Spain and Italy
have been, and continue to be, a cause of material injury to the domestic industry producing

flanges

2l
719905499

PUBLIC VERSION

The Volume of Imports

Increasing

rom the Subject Countries Is Significant and

In evaluating the volume of imports, the Commission must consider whether the volume
of imports of the merchandise,

otr

any increase in that volume either in absolute terms or relative

to production or consumption in the United States, is significant.2s In these investigations,

available data show that the volume of subject imports, both in absolute terms and relative to
l

U.S. consumption and production, is significant within the meaning of the relevant statutory

provlslon.
a.

The Volume of Imports Is Significant and Increasing in

Absolute Terms

The absolute volume of subject imports from India, Italy and Spain is significant.
Subject imports totaled 201,822 thousand pounds and accounted for over 81 percent of total steel
flange imports in 2015. Se Exhibit

I-9.

Subject imports also increased significantly over the

pOI. Atthough the volume of cumulated subject imports fell from

2013 to 2014, they increased

significantly from I5g,454thousand pounds in2014 to 20l,22thousand pounds in 2015, or by

nearly 27 percent, and increased over the POI.

Id. While subject import volume declined

on an

absolute basis between the interim periods, the volume of subject imports was still significant
and subject imports continued to account for the overwhelming majority of total imports.

Subject imports' share of total imports remained virtually unchanged at 81 percent in the interim

periods. Id. Further, the decline in subject import volume in interim 2016 in large part reflects a
significant decline in demand, and as discussed below, subject imports retained a significant
share of the market.

25

le u.s.c. $ 1677(7XCXi)

22
7t9905499

PUBLIC VERSION

Subject Imports Have Increased Signifcantly as a Share of the

U.S. Market

b.

The volume of subject imports is also significant relative to consumption. The increase

in subject import market share came at the expense of the domestic flange industry. The
domestic industry's share of the market fell by

while subject imports' share increased by

share of the U.S. market declined slightly in

] percentage points from 2014 to 2015,

I percentage points. Although subject imports'

interim 20I6,they retained almost all of the market

share gains made in 2015. That is, in January-March 2016 subject imports share of the U.S.

market was

] percentage points higher than in 2014, and U.S. producers' share of the

market was

] percentage points lower between these periods. These data establish that both

the volume of subject imports and the increase in imports were significant both absolutely and

relative to apparent consumption.

Z.

Unfairly Traded Imports from the Subject Countries Have Had an

Injurious,Impact on Domestic Producer Prices for Flanges

The low-priced, dumped and subsidized imports subject to this proceeding have had

significant negative price effects on the domestic flange industry. Price underselling by unfairlytraded imports of flanges from India, Spain, and Italy have significantly depressed and
suppressed the prices at

wlich domestic producers have sold flanges during the POI.

a,

'

Import Prices of Flanges Have Declned Over the POI and

Have Undersold Domestically-Produced Flanges by
Substantial Margins

Evidence reasonably available to Petitioner indicates that the increase in market share by
the subject imports coincided with significant underselling by subject imports, which serves as

important evidence that subject imports have had negative price effects. Based on the lost sale
and lost revenue examples, import prices show declines over the POI, as well as widespread and

23
719905499

PUBLIC VERSION

significant underselling of U.S. producers' prices. See Exhibit I-12. This underselling by
imports from subject counJries caused U.S. producers to lose substantial sales and to reduce
prices, causing loss of revenue.

b. ;

Unfairly Traded Imports Have Caused Suppression and

Depression of U.S. Prices of Flanges

The volume gains by producers from India, Italy and Spain in the U.S. flange market
have been achieved by underselling the prices of U.S. producers. Underselling by unfairly

traded imports of flanges has significantly suppressed and depressed the prices at which
domestic producers sell flanges. Because of the wide variety of flange types sold, average unit
values on a $/lb basis for total shipments may not be indicative of price trends, as these changes
can also reflect product mix changes. However, information assembled by Petitioners for a

specific high-volume flange specification shows that on a per-piece basis, prices have declined

from 2013 levels. See Exhibit I- 14. These price declines occurred as subject imports continued
to enter the U.S. market and materially undersold the domestic producers' prices. Moteover,
U.S. producers also experienced price suppression, as their COGS to sales ratio I

I over the POI,'with

the highest level being in interim 2016. See

Exhibit I-11. The

price depression and suppression exerted by the subject imports on domestic producers' ptices,
combined with volume losses as subject imports gained market share, led to a deterioration of
U.S. producers' profitability levels, and U.S. producers experienced operating I

24
7t9905499

PUBLIC VERSION

c.

Idntification of Flange Products for \ilhich Petitioners

Request Collection of Price Data

Pursuant to Section 207.11(bx2)(iv) of the Commission's regulations, 19 C.F.R.

$

207,11(bX2Xiv), Petitioners reommend that the Commission collect pricing data on the

following carbon steel flan$e products on a per-piece basis:

PRODUCT

1:

4 inch, 150 classo Raised Face, \ileld neck standard flange

(4 1s0 RF WN STD)

PRODUCT

2:

6 inch, 1'50 class, Raised Face, rileld neck standard flange

(6 1s0 RF WN STD)

PRODUCT

3:

3 inch, 150 class, Raised Face, Weld neck standard flange

(3 1s0 RF'\ilN STD)

PRODUCT

4:

6 inch, 150 class, Raised Faceo Slip On standard llange

(6 150 RF Slip on)

PRODUCT

5:

2 inch, 150 class, Raised Face, Threaded standard flange

(2 1s0 Rr THD)

PRODUCT

6:

16 inch 150 class, Raised Face, Weld neck standard flange

(16 1s0 RF

\ilN STD)

These price descriptors represent large-volume and representative types flanges sold in the

United States during the POI and also are believed to represent specifications sold for subject
imports.26 Accordingly, these are the appropriate products for the Commission's analysis and
comparison of U.S. producer and import prices.

3.

Unfairly Traded Imports Have Had an Injurious Impact on the

Domestic Flange Industry

The domestic flange industry has suffered material injury by reason of the subject

imports, as manifested in sales lost to the unfair imports and suppressed and depressed U.S.

26

Because of the large numbpr of flange types sold, the coverage of total shipments will necessarily be
relatively low based on using only six pricing product specifications.

25
719905499

PUBLIC VERSION

prices, resulting in the deteriorati'on of key trade and financial indicators. Subject imports have
undersold domestically-produced flanges, resulting in price suppression and depression, lost
sales, and financial deterioration, as evidenced in Petitioners' inadequate and I

] operating margins over the POI. These

data, as described in more detail below,

demonstrate a causal linklbetween the unfairly traded imports and the material injury being
suffered by the U.S. industry producing flanges.

a, ;

Declines in Domestic Industry Production, Capacify

Utilization, and U.S. ShiPments

From 2013 to 2015,the subject imports had a negative impact on the domestic industry,
as demonstrated

and

by

profitability. Production

commercial shipments
workers
See

] production, capacity utilization, shipments, prices, employment,

Exhibit

] (l

[
I

I-ll.

] thousand pounds ([

(l

]), the value of

]), the number of production

l), and hours worked

I percent'

Although declining demand had some effect on the U.S. industry in2015,

1)
competition from subject imports clearly had a material adverse effect, as demonstrated by:

the domestic industry's loss of market share to subject imports; 2) underselling and declining
U.S. prices; and 3) lost sales and revenues.
The domestic industry's condition for all indicia continued to decrease in interim 2016.

Although subject imports share of the u.s. market

] in this period (as compared

to 2015), subject imports' share of the market was still significantly higher than in 2013 and

20i4,and continued to exert price pressufe on U'S. producers, leading to a I

].
domestic production of flanges

] percent, and capacity utilization

26
719905499

Between the interim Periods, the

] percent,

PUBLIC VERSION

its lowest level of the POI. See Exhibit I-11. The value of the domestic industry's commercial
shipments

] percent between the interim periods, and employment and hours

worked also continued to

] percent and

] percent, respectively. Id. The [

capacity utilization caused by the displacement of U.S. producer sales from unfairly-traded
subject imports demonstrates that Petitioners have ample capacity to supply finished flanges to
meet customers' requirements.
'

b.

Petitioners' Declining operating Income Demonstrates the

Injurious Impact of the Substantial Volumes of Low-Priced
Imports from Subject Countries

The deteriorating financial performance of the domestic flange industry reflects the

combination of adverse volume and price effects resulting from competition from unfairly traded
imports from the subject countries. Before the market share increase in subject imports that
began in 2015, the domestic industry had experienced operating profit margins

of I

]. However, in 2015, subject import volume and market shares

surged, and the U.S. industry experienced

of

], declines

]'

margin was about

In 2015 the industry's operating profit

] its level in the prior two years, and in interim 20I6,the U.S. industry

continued to experience anemic sales volumes as subject imports' share of the market remained

high, and combined with price declines from 2015 levels, operating profits were
a

margin of

2015.27 See

] percent,'compared to the t

], with

] percent operating margin experienced in

Exhibit I-11.

27

The signihcant decline in volume also led to higher unit fixed costs, which contributed to the declines in
gross and operating profits on a unit and margin basis.

27
719905499

PUBLIC VERSION

The financial deterioration of the domestic flange industry is directly related to

declining sales prices and revenue resulting from increased volumes of unfairly priced imports.

.'

c.

Petitioners Have Lost Sales and Revenues to Unfair Flange

Imports from the Subject countries

The existence of a,causal link between rising import market share and U.S. producers'

declining profits and market share is corroborated by the anecdotal lost sales and revenue
information collected and attached as Exhibitl-12. This exhibit identifies lost sales (and thus
loss revenue) to unfairly traded flange imports from the subject countries. Specifically,

it

consists of affidavits from the presidents of both Weldbend and Boltex about their companies'

lost sales to imports from the subject countries during the POI. This evidence of lost sales and
revenues ties the financial performance of the domestic industry to the injurious price and

volume of dumped and subsidized subject imports.

Unlike many other industries/products that are examined by the Commission, the
merchandise subject to these investigations is not sold by the manufacturers directly to end user

customers. Instead, flanges are by domestic and foreign producers to distributors, who then sell
to end users. The U.S. distributors purchase from both the domestic producers and the foreign
producers. As such, it is very difficult for Petitioners to obtain specific and direct facts of lost
sales

because

it is not in the interest of the distributors to disclose that information

(because

they buy from both sources). As such, Petitioners acted to the best of their ability, and indeed it
was difficult, for them to obtain the information provided in

Exhibitl'12'

In addition, Petitioners have completed the Lost Sales Template as specified in the
Commission's Handbook on Filing Procedures and includes those templates at Exhibit l'12

28
719905499

as

PUBLIC VERSION

well.

Each Petitioner hereby certifies that the template spreadsheet

will

also be submitted

electronically in the manner specified in the Commission's Handbook on Filing Procedures.

4.

Conclusion

All of the indicators:of material injury

are present in this case. The volume

of subject

imports was significant both absolutely and relatively, and their market penetration increased
dramatically over the POI. The subject imports reached their highest levels of market
penetration in 2015, and maintained close to this level in the first quarter of

20.

The subject

imports systematically undersold the domestic product, causing domestic prices to fall. The
domestic industry experienced

employment The U.S. industry also experienced

revenue, profitability, and

inventory levels and significant

G.

] in all indicia, including production, shipment volume,

[
[

] in its capacity utilization

] in its

rate.

Subject Imports Threaten Additional Material Injury to the Domestic

Industry
:

In addition to analyzing present material injury, the statute requires the Commission to
determine whether the domestic industry is threatened with material injury by reason of the

unfair imports.2s In making this determination, the Commission is directed to examine a number

of factors specified in the statute, including, interalia,

(l)

an increase in foreign producers'

productive capacity or existing unused capacity; (2) a significantrate of increase of the volume
or market penetration of the subject imports; and (3) the likelihood that imports of the subject
merchandise are entering at prices that will have a significant depressing or suppressing effect on
domestic prices.2e As indicated below, there is ample evidence that imports of flanges from the

28
29

le u.s.c. $1677(7XF).
le u.s.c. $ 1677(7XFX

29
7t9905499

PUBLIC VERSION

subject countries also present a threat of massive and imminent further material injury to the
domestic industry.

1.

The Commission Should Cumulate Subject Imports for Purposes of

ItsiThreat Analysis

The statute provides that in evaluating the threat of material injury, the Commission may

cumulatively assess the volume and price effects of imports of the subject merchandise from all
countries with respect to which the petitions were filed on the same day

"if

such imports compete

with each other and with domestic like products in the United States market."3O As these
petitions cover all of the subject countries, the first requirement is met. Further, as demonstrated
above, all subject imports compete with each other and with the domestic like product in the U.S.

market. Thus, the statutory requirements for cumulation in a threat investigation have been
satisfied.

2.

Subject Imports Threaten Domestic Producers with Additional

Material Injury

In determining whether subject imports threaten a domestic industry with material injury,
the Commission must consider a number of factors, including

A significant rate of increase of the volume or market penetration of imports of

o
o
o

the subject merchandise (as addressed above);

Price effects of the subject imports;
The nature of any countervailable subsidies; and
Existing unused production capacity or potential increases in production capacity
in the exporting countrY.''

In this case, all of these factors support an affirmative threat determination' The Commission
should find that the domestic industry is vulnerable, and that the subject imports threaten the
domestic flange industry with material injury.
30

3t

re u.s.c. $ 1677(7XI.I).
1e

u.s.c. $ 1677(7XFXi),
30

719905499

PUBLIC VERSION

a.

The Domestic Flange Industry Is Vulnerable to Material

Injury from the Subject Imports

The starting point for the Commission's assessment of threat is the question of whether
:

the domestic industry is vulnerable to material injury by reason of the subject imports.32 To
assess

vulnerability, the Commission will consider the various indicators of performance for the

industry. The Commission gives special weight to the industry's performance at the end of the
POI.33

The domestic flange industry is extremely vulnerable to further material injury by reason

of the subject imports. As explained above, U.S. producers are experiencing a significant loss of
domestic market share, and significant
and reductions in gross and operating
due to the declines in the

oil and

] in capacity utilization, employment levels,

profits. Indeed, the domestic industry is also vulnerable

gas industries in the United States, which has resulted in a

decline in demand for flanges in 2015 and into 2016. As such, the increasing and significant
losses to imports, at a time of declining overall demand, makes the increasing loss of market
share

untenable.

Accordingly, the Commission should determine that the domestic flange industry is
vulnerable to material injury by reason of the subject imports.

b.

The subject Imports Have Significantly Increased in volume

and Market Share

The Act provides thatooasignificant rate of increase of the volume or market penetration

of imports of the subject mrchandise" shall be considered in determining whether the domestic

32

See Seamless Refined Cbpper and Tube from China and Mexico. Inv. Nos. 731-TA-l174'1175
lf inat,UStrc fuU. 4l% atZ+ Nv. ZOtO) ("seamless Refined Copper and Tube from China and Mexico") at 34i
ertan Seamless Carbon and Ailp) Steel Standard. Line" and Pressure Pipe from China. Inv, Nos. 701-TA-469 and
73 1-TA- I 168 (Final), USITC Pub. 4 190 at 27 -28 (Nov. 2010).

33

Seamless Reflrned Copper and Tube from China and Mexico. USITC Pub' 4193 at34.

31
't9905499

PUBLIC VERSION

industry is threatened with material injury from the subject imports,3a In this case, there have
been dramatic increases in both the volume and the market penetration of subject imports over

the

POI.
c.

',
.

The Subject Imports Have Demonstrable Adverse Price Effects

That Are Likely to Continue

The Act provides that, in determining whether the domestic industry is threatened with

material injury, the Commission should consider'owhether imports of the subject merchandise
are entering at prices that are likely to have a significant depressing or suppressing effect on

domestic prices, and are likely to increase demand for further imports."35 The discussion above
demonstrates that subject imports have had such effects. In particular, the rise in U.S. market
share taken by the subject imports has led to a sharp decline in prices for the domestic product.

import penetration, at prices substantially underselling

Given continuing high levels of

-subject

the domestic like product, it is likely that the fall in domestic prices will continue. Thus, this
statutory factor shows that the domestic industry is threatened with additional material injury

from subject imports.

d.

''

The Subject Country of India Encourages Exportation of

Subject Merchandise Through Countervailable Subsidies

As part of its threat analysis, the Commission must consider

"if

a countervailable subsidy

is involved" and, in particular, 'owhether the countervailable subsidy is a subsidy described in

Article 3 or 6.1" of the WTO Agreement on Subsidies and Countervailing Measur.t.36 Atticle
of the WTO Subsidies Agreement describes subsidies that are prohibited because they are

34
35

36

l9 U,S,C. $ 1677(7XF)((m) (emphasis added),

le u.s.c. $ 1677(7xF)((N).
1e

u,s.c. $ 1677(7xFX(.

32
719905499

PUBLIC VERSION

contingent upon export performance or upon the use of domestic over imported goods.37 As
demonstrated in these petitions, subject producers in India have received countervailable
subsidies, including export subsidies and import substitution subsidies. Among the more

significant of these are:

a

Export loans provided to carbon steel flange producers at preferential rates by

government authorities where receipt of the financing is contingent upon
exporting;
Preferential income tax treatment for carbon steel flange producers whose exports
constitute a certain portion of their overall sales;
Land for less than adequate remuneration provided to carbon steel flange
producers located in certain coastal industrial zones in order to promote exports;
Grants provided to carbon steel flange producers to assist in the development of
export markets, or to recognize export performance; and
Preferential income tax treatment for carbon steel flange producers that upgrade
their manufacturing operations with domestically manufactured equipment.

.. '
)

Subject Producers Have Signifcant Volumes of New and

Unused Capacity, Indicating the Likelihood of Substantial
Increased Imports

The Act provides that in making a threat determination, the Commission shall consider
ooany

existing unused production capacity or imminent, substantial increase in production

capacity in the exporting country indicating the likelihood of substantially increased imports."38
The Commission

will

also consider whether other export markets are available to the subject

producers that could absorb excess production.3e In this case, the availability of capacity for
increased exports to the United States weighs heavily in favor of a threat determination.a0
'i

3?

Agreement on Subsidies and Countervailing Measures (Apr. 15, 1994), Manakesh Agreement Establishing
the World Trade Organization, Annex l, 1867 U.N.T.S. 14 aI Art.3.

38
3s
40

u.s.c. $ l67z(7XF)(iXII).
19 u.s.c, $ 1677(7XFX(il).
19

g99 Chlorinated Isoc)Anurates from China and Japan. USITC Pub.4494 at 36; Polyethvlene Retail Carrier
Bags from Indonesia. Taiwan. and Vietnam. Inv. Nos. 701-TA-462 and 731-TA-1156-1158 (Final), USITC Pub.
4144 at 25 -26 (April 20 1 0).

JJ
7t9905499

PUBLIC VERSION

According to the o\ryner and president of Weldbend, as well as the president and chairman
of the board of Boltex, it is believed that the producers of flanges in India, Italy and Spain are
currently producing at levels well below their capacity. See Exhibit
demand caused by the decline in the
means that

I-2.

Indeed, the decline in

oil and gas industry @oth domestically and internationally),

it is simply not possible for the subject producers to be producing

at anywhere near

capacity. As a result, the subjeot producers have the ability to increase exports to the United
States significantly without encountering any capacity constraints. However,

it is simply not

possible for Petitioners to document the capacity or export capabilities of the foreign producers.

They simply do not have access to that information, and there is no known source of such
information (public or otherwise).

f. '

summary

The domestic flange industry is currently experiencing material injury as a result of

unfair imports from India, Italy and Spain. As difficult as the current situation may be, if recent
trends persist, the domesticrindustry is threatened with an even bleaker future. The subject
producers have demonstrated their ability to rapidly increase exports to the United States of

extremely low-priced flaiges that undersell domestic producers by substantial margins. In light
of the recent trends in pricing of urlfair imports, producers and exporters in India, Italy and Spain
are likely to continue their low-priced, high volume assault on the U.S. market absent the

restraining effects of antidumping and countervailing duty orders.

IV.

CONCLUSION
The information presented in these petitions provides evidence reasonably available to

Petitioners that imports of flanges from India, Spain and Italy are being sold in the United States
at less than fair value and that the Government of India is providing countervailable subsidies

34
7t9905499

PUBLIC VERSION

with respect to the manufacture, production, and export of flanges. These petitions further
provide evidence that the domestic industry producing flanges has been materially injured, and is
threatened with material injury, by reason of unfairly-traded imports. Accordingly, Petitioners
request that the U.S. Depafment of Commerce and the U.S. International Trade Commission

initiate antidumping duty investigations regarding imports of flanges from India, Italy and Spain
.

and a countervailing duty investigation regarding imports of flanges from India.

Respectfully

M. Kriesberg
J

abian Rivelis
Sr.

MAYER BROWN
Counsel to Weldbend Corporation &
Boltex Mfg. Co., L.P.

3s
7

t9905499

PROPRIETARY TREATMENT RE QUESTED

BUSINESS PROPRIETARY

EXHIBIT LIST
I

Known Domestic Producers

t-2

Affidavits on ldentification of Known Producers & Domestic Production, Etc.

I-3

Scope

t-4

Production

I-5

HTSUS

I-6

Indian Produoers

r-7

Spanish Producers

I-8

Italian Producers

I-9

US Import Statistics

I-10

US Importers

I I1

Injury Indicators

t-t2

Lost Sales Affidavits

I-13

Geographic Overlap

-r4

Pricing Data

I- 15

25%150% Rules

719905499

r-1

KNO-WN DOMESTIC PRODUCERS

Weldbend Corporatio n
6600 South Harlem Ave
Argo, IL 60501-1930
www.weldbend.cort
T: (708) s94 1700
Fax: (708) 458 0106
j

(P

etitioner)

coulas@weldbsnd. co.nl

Boltex Mfg. Co., LP (Petitioner)

4901 Oates Road

Houston, TX770l3
www.boltex.cqm
T: (713) 67s 9433
Fax: (713) 6726521
f berpobi ch@el teX;pom

Galperti Inc
160 Southbelt Industrial Dr
Houston, TX77047
T: (713) 433-0700
Faz: (713) 433-5580
s,lpra ail.@ g lp c.rt i.riircb rn

AFGlobal Corporation
945 Bunker Hill Road
Suire 500
Houston, TX77024
www.afslobalcoro.com
T:713-393-4200

Texas Flange
PO Box 2889
Pearland, TX 77588
www. txi s fl angg, c-qnl
T:281-741-1195
Fax: 281-484-8730
S al cs().tex a sfl a rt ge. c om

Piping Products,Inc.
1681 Kress St.
Houston, TX 77420
www,pipin qproducts.com
T: (713) 675 5374
Fax: (713) 675 7910

I of 3
720084884

Buffalo Flange,Inc.
P,O. Box 34890
Houston. TX77234-4890
.www, bufflo f Ian,ge, conl

r:

(713) e43 e600

Fax: (713) 943 9606

General Flange & Forge LLC

2381 Philmont Avenue
Suite #125

Huntingdon Valley, PA 19006

www. qeneral{lanqo.eom
T: (21s) 938 6909

Kerkau Manufacturing
1321 S Valley Center Dr
Bay City, MI48706
www,kefkrl.com.
T: (989) 686 0350
Fax: (989) 686 0399
bii*adbmis@"I<rrliirrr',jpjrn

Coastal Flange
1 1906 FM 529
Jersey Village, TX 77041
!aWW. oastal fl an ge. com
T: (800) 6439063
Fax: (713) 937 3471
saleg@coasiaifleR p;n

TRILAD flanges and fittings Inc.

7200 Mykawa Road
Houston, TX77033

www,tri-lad.com
T: (800) 969 ss6s
Fax: (713) 7991007
avela@allieclfit.com
swool ey@"all iedfit. corn

2 of3
720084884

Federal Flange
Physical Address:
4014 Pinemont
Houston, Texas 77018
P,O. Box 925097
Houston, Texas 7 7 292-5097
:www,
.- federalflnile;com
T: (713) 681 0606
Fax: (713) 681 3005
infot@fedefafft $r se;aonl

O"

Corporation

"r"rr"
7785F..
Little York Road

Houston, TX''17016

T: (832) 397 4290

Fax: (713) 635 4784
'vntas:l@dlf.trq.p.-omr

wooDco usA
P.O. Box 1261
Houston, Texas 77251 -L261

www,woodcousa.com
T: (713) 672 9491
Fax: (713) 6728768

$ofiot-ii$r o

3 of
720084884

T-2

\ryE,LDBEI{I)

DECLARATION OF JAMES J. COULAS JR. OF WELDBEND CORPORATION

I, James J. Coulas, Jr, owner and president of Weldbend Corporation (a Petitioner in this
action), hereby certify and affirm as follows:
Whereas,

1.
2,
3.
4.
5,
6.

My parents started Weldbend Corporation back in the late 1940's, and the
company has grown to become one of the largest, if not the largest, manufacturer
of finished carbon steel flanges in the United States.
I began working for the farnily business in 1967, and have thus been in the
finished carbon steel flanges business for over 49 years,
During my almost five decades in the finished carbon steel flanges business, I
have visited the facilities of several other domestic producers of finished carbon
steel flanges, and have visited foreign producers ofthe product in Spain, Italy, and
India.
On an almost weekly basis at its Argo, Illinois facility, Weldbend Corporation
hosts customers and end users of finished carbon steel flanges.
The number of companies producing finished carbon steel flanges is quite small,
and these companies are well-known to those in the industry.
To my knowledge, there is no public information on U.S. production capacity or
ouut of finished carbon steel flanges.

As a result of the above,

7,,

8,

9,

10.

11.

720570lt7.2

assisted in the preparation of Exhibit I-1 of the petition, which identifies known
domestic producers of finished carbon steel flanges, and I believe that the list of
14 companies identifies the vast majority of all finished carbon steel flange
producers in the United States.
The first two companies listed in Exhibit I-l of the petition are Weldbend and
Boltex Mfg. Co., and I am very conficlent that those two companies (the

Petitioners in this action) constitute well over 50% of domestic production of

finished carbon steel flanges,
I assisted in the preparation of Exhibits I-6,I-7, and I-8 of the petition, which
identify known producers of finished carbon steel flanges in (respectively) India,
Spain, and ltaly, and I believe that those lists identify the majority of finished
carbon steel flange producers in those respective countries.
There is no question in my mind that producers of finished carbon steel flanges in
Inclia, Spain, and Italy have enormous excess and unused production capacity.
The global clecline in the oil and gas industry will necessarily have resulted in
these procluccrs having cxccss ancl unused production capacity for frnished carbon
steel flanges.
Due to the nature of the flange business, we sell our product tlirough distributors
in tl,e United States, and imported product is sold through distributors as well. I
believe that imports from each of the sLrbject countries are often distributed
through the same companies.

t2.

We compete against imported product in all geographic markets in the United

States.

I declare that all stalcments made above re true and correct.

June 28, 2016

Date

12tJ570817.2

BOLTEX

Dnqlr\ttAliorN oti

ITITANK BERNOBICH OF IIOT,TEX MFG. CO.,

I, Flank Bernobich, president and chairman of the board of l3oltex Mfg, Co., L.P
('olloltex") (a Petitioner in this action), hereby certify and aff,rrm as follows:
Whereas,

Boltex began as a machining operation in 1989, and started forging its own line of
flanges in 1996.
2
3

I have been with Boltex since its inception, anc1, inch.rding my time at Boltex, I
have over 39 yeals ofexpelience in the carbon steel flanges busjness.
During my almost four decades in the carbon steel flanges business, I liavc visited
the facilities cf sevetal other dourestic producers of'lnished carbon steel langes,
and have visited frrreigu producers of the product in ltaly, India, Germany and
France.

4
5

l.he number of. companies proclucing flrnisl:ed. carbon steel flanges is quite small,
and these companics are well-known to those in the industry,
To my knowledge, there is no public information on U.S. procluction capacity or
output offinished carbon steel flanges,

As a result of the above.

-l

10.

11.

12.

assisted in the preparation ol'Exhibit I-1 of the petition, which identifies known
clomestic produccrs of finished carbon steel fl,anges, and I believe ilrat the list of
l4 companies identifies the vast nrajorty of all finished carbon steel flange

produccrs in the United States,

The first two companies listed in Exhibit I-1 of tire petition are Weldbend
Corporation and Bohex, and I aln very confident that those two conlpatries (the
Petitioners in this aclion) constitute wellover 50% of clomestic production of
fnishcd carbon steel flanges.
I assisted in thc preparation of Exhibils l-6, I-7 , and I-8 of the petition, which
identifo known producers of'finished carbon steel flanges in (respectively) lndia,
Spain, and ltaly, and I believe tbat those lists identify the majority of f,rnished
carbon steel flange producers in those respectivc coulrtries.
'l"here is no question thatproducers of finishecl carbou
steel flanges in lndia,
Spain, and ltaly have cnormous cxcess and unused production capacity. The
global decline in the oil and gas iuciustry will necessarily have lesultecl in these
proclucers havirrg exccss and unused production capacity for fnished carbou steel
fanges.
Dre to the nature ol'thc fange business, we sell our product through distributors
in the Ullitecl States, and impofled product is sold through clistributors as well. I
bclievc that iurporls fi'onr each of the sr"rtriect countries are olten clistributecl
thror,rglr tlre saurc conrpanics.
We compete irgainst ir-nportecl prochrct in all geograpliic markets in the IJnited
S{ates.

20i

51,9.1.1

I declare thal all statements made above are true and correct,

"96- 7//.
Date

;2(i 5 759,i.2

Ilernobich

r-3

SCOPE
The scope of this investigation covers finished carbon steel flanges. Finished carbon
steel flanges differ frorn unfinished carbon steel flanges (also known as carbon steel flange

forgings) in that they have undergone further processing afler forging, which can include
beveling, bore threading, center or step boring, face machining, recoining or resizing, taper
boring, machining ends or surfaces other than a gasket face, drilling bolt holes, and/or de-burrirrg
or shot blasting. Any one of these post-forging processes suffices to render the forging into

fnished carbon steel flange for purposes of these petitions. However, mere heat treatment of a
carbon steel flange forging (without any other further processing after forging) cloes not render
the forging into a finished carbon steel flange for putposes of these petitions.

While these finished carbon steel flanges are generally manufactured to specifcation
ASME 816.5 or ASME 816,41series A or series B, the scope is not limited to flanges produced
under those specifications. A1l types of finished carbon steel flanges are included in the scope,
regardless of pipe size (usually expressecl in inches of nominal pipe size), pressure class (usually
expressecl in pounds ofpressure, e.g., 150, 300,400, 600, 900, 1500, 2500, etc.), type offace

(e.g., flat face,

lap

full face, raised facc, ctc.), confguration (e.g., weld neck, slip on, socket weld,

joint, threaded, etc.), wall thickness (usually expressed in inches), and normalization or heat

treatment (which may not always be used). The carbon steel usecl to produce fnishcd carbotr
steel flanges includes, but is not limitecl to, carbon steel produced to ASTM 4105 and ASTM

4694 standards.
Finished carbon steel flanges are currently classified under subheading 7307 .91.5010 and
7307.91,5050 of the Harmonized Tariff Schedule of the Unitecl States (HTStlS). They may also
be entered under

7200349.0

IjTSUS subheading 1307.91.5030 and 7301.91.5070. 1'hc HTSUS

subheadings are provided for convenience and customs purposes; the written description of the
scope is dispositive.

720014910

DELARATION OF FRANKBERN.SBICH OF BOLTEX MFG. CO.

I, Frank Bemobich, president and chairman of the board of Boltex Mfg. Co., Ltd.
("Boltex") (a Petitioner in this action), hereby certify and affirm as follows:
1,

2.
J.

4.

Boltex began as a machining operation in 1989, and starled forging its own line of
flanges in 1996.
I have been with Boltex since its inception, and, including my time at Boltex, I
have over 39 years ofexperience in the carbon steel flanges business.
During my ahnost four decades in the finished carbon steel flanges business, I
have visited the facilities of several other domestic producers of finished carbon
steel flanges, and have visited foreign producers of the product in ltaly, Inclia,

Germany and France.

The production process of flanges is generally the same around the world.

Accordingly, I provide the below description of the production process for finished carbon steel
flanges:
5

6
7
8

9
10

ll

The first step of the process is to create a flange forging.

Forgings dies are prepared by machining tool steel into reverse profile shapes to
ultimately fonn the forged products.
Each forging press line may contain as many as 23 different processes to procluce
a single forged product.
Steel billet arives from the vendor; it is unloaded and sortecl by heat lot number
(see photo 1).
Heat lot numbers must be recorded and verified throughout the entire process to
ensure rnaterial traceability from steel producer to final end user.
The steel billet is then placed on a loading table (see photo 2) while inductive
heating ovens gradually inctease to the preset optimal forging temperature.
The billet is pushed through the ovens (see photo 3) via a series of rollers and
brought to the shearing press (see photo 4) where the length is gauged and finally
cut.

12

l3

l4
15.
16.
17

The cut billet piece is then pushed into the forging press where it is located on the
blocking station, the ploper grain orientation is checked and the operator signals
the press to block or break the piece into its pre forging shape (see photo 5).
This blocking operation also improves the mechanical propcrties of the material
being forged.
The "blocked" piece is then moved to the next set of forging dies (see photo 6)
where it is shaped to its approximate final appearance.
It is then conveyed to the trim press (see photo 7) where it receives it final
shaping and all excess material is trimmed off the part.
In larger forgings, where the excess material has tlie sufficient weight and size,
that material undcrgoes the same process once more to produce a second forging.
Once these parts are completely folged, the parts are loaded into steel containers
for controlled still air cooling and are sent to post forging heat treatrnent (see
photo 8).
Page 1 of 9

t208l8t

52

18,
79,
20,,
2L
22.

23.

24,,
25.

Post forging heat treatment (see photo 8) is requirecl for parts that must achieve
certain mechanical properties or grain structure to prevent failure during their

final use.
To be heat-treated, the items are stacked on pallets and placed in ovens where
they are heated to temperature, held or "soaked" for a predetermined period of
time. The parts are either still air cooled or immediately placed in a controlled
temperature (quenched) water tank where their temperature is rapidly reduced.
These parts are again allowed to cool to ambient temperature and then reloaded
into the ovens to be heat treated (tempered) another time to assure optimal
mechanical properties and material hardness is achieved. Once cooled these parts
are completed forgings (see photo 9).

The completed forgings are noril ready to be transformed from a forging to a

finished carbon steel flange,
The first step in the finishing process is the machine set up (see photo 10). This
involves setting up tooling in place so that the part can be safely and exactly
machined per the final specification and drawing. Tooling includes carbide
milling inserts, drilling bits, etc. A computer progfam is either created or
retrieved from archive to begin the machining process. This pro$am instructs the
machining center to move the tooling and the forging so that the part may be
consistently machined repeatedly. It also wams the operator if the part is out of
the dimensions and tolerances set up by the programmer. A complete inspection
of the first part is comPleted,
Each flange goes through a four stage machining process (see photo I 1). The face
and internal diameter (see photo 12) is machined first, then the back face and
outer diameter (seephoto 13), followed by drilling/deburring (see photo 14), and
the flange is then stamped for identification (see photo 15) for purposes of
traceability upon exiting the machine.
Once the flange is completely machined it is sent to the paint department for
coating (see photo 16) to prevent rusting during its shelf life'
Upon completion of the painting operation it is ready for final inspection (see

photo 17).

Photo 1 - Billets staged for forging

Page 2 of 9
720818r52

Photo 2-LoadingTable

Photo 3

- Inductive Heating Ovens

Photo 4 - Billet Shearing

Page 3 of 9
720818t52

Photo 5 - Blocking the Billet

Photo 6 - Forming the forging

Photo 7 - Trim press and completed forging

Page 4 of 9
720818152

Post forging heat treatment

Picture9-CompletedF

Photo l0 - Machine Set up & Programming

Page 5 of 9
7208r8r52

Photo 11

Forgings entering finishing machine

Photo 12 - First machining operation. Machining front fact and intemal diameter

Page 6 of 9
7208r8rs2

Photo 13 -Second

operati on. Machining back face and outer diameter

Photo 14 - Third operation. Drilling and Deburring

PageT
'720818152

of9

Photo l5

- Fourth operation, Marking and identification

Photo 16 - Painting

Page 8 of 9
720818t52

Photo

l7'-

Finlshed carbon stel,flang9$,eqdy forihiFient

I' declre tht,all,ltais"meril$, made abov qrp true and $ol,iS.ti

(-z/- zo/
atc

Page 9
?20il8t52

of9

r-5

Harmonized Tarlff Schedule of the United States (2016)

Annolated lor Slalistical Reporting Purposes

of
Quanlity

Subheding

XV
73"19
2

---mial

(for example, couplings, elbows, sleeves),

prpe

iron or steel:
Cast fittngs:
1

4.8%

Ol nonmalleable casl iron.-'.".;i,.:.:r;;:iit...;:.';i;!n;!;;i:rr

1.00

Secil

Free (4, AU, BH,

cA, cL, co, E, lL,

JO, KR, MA, MX,
OM, P, PA, PE,
SG)

30

For thrcaded pipe..................

dq

Other:
For cast-ron soil pipe............

kg

Other

I9

kg

Other:

45%
Free (4, AU, BH,
CA, CL, CO, E, IL,
JO, KR, MA, MX,
OM, P, PA, PE,

Ductile f ittings...,".'..:;;r;.',;!i

19.30

sG)
40

Grooved-end fittings (including grooved

cou plings )..,....

Other:
60

Threaded....,,...,,,..,,r.r,.rr,,i,,,1

70

Wilh mechanical, push-on (rubber

compression) or flanged joints attached.., kg

B5

Other................

..........,-.:..:. kg

6.2'/"

O1her....,...-.,..,.,..'.,-;',',..n:;

9.90

(A+, AU, BH,

CA, CL, CO, D, E,
IL, JO, KR, MA,
MX, OM, P, PA,
PE, SG)

kg

30
40

60
BO

Olher:
Grooved-end filtings (including grooved
couplings)........
Other:
Threaded.........,

kg
kg
kg

45%

Harmonized Tariff Schedule of the United States (2016)

Annotaled for Statislcal Reportng Purposes
XV
73-20

Article Description

Subheading
fix

Tube or pipe littings (for example, couplings, elbows,

of iron or steel: (con.)
Other, of slainless steel:

7307 (con.)

7307.21
7307.21

.1

0 00

'

Flanges:
Not machined, not tooled and not otherwise
processed af ter f or9in9,..............,.ir........'.,.........'

Free (A', AU, BH,

cA, cL, co, E, lL,
JO, KR, MA, MX,
OM, P, PA, PE,
SG)

Free (A', AU, B, BH, 45/"

CA, CL, CO, E, IL,
JO, KR, MA, MX,
OM, P, PA, PE,

.21.50 00

SG)

22
22-10 00
22.50 00

Threaded elbows, bends and sleeves:

Sleeves (couplings)...,,..,.,.

45%
Free (A, AU, B, BH,
cA, cL, co, E, lL,
JO, KR, MA, MX,
OM, P, PA, PE,

Other,.,.....:,.

SG)

00

Butt welding fittings.............

5Y"

Free (4, AU, B, BH, 45%

cA, cL, co, E, lL,
JO, KR, MA, MX,
OM, P, PA, PE,
SG)

.29.00

Othr,.,..,,,...,..

Free (4, AU, B, BH,

cA, cL, co, E, lL,
JO, KR, MA, MX,
OM, P, PA, PE,

sG)
30

Nipp1es..,.,....,..,.j;i.!...J,!:,r,rr,

90

ttror,.,

Harmonized Tariff Schedule of the United States (2016)

Annotaled for Statstical Reporting Purposes

XV
73-21

Artcle Descriplion

(for example, couplings, elbows, sleeves)

Tube or pipe f
of iron or steel: (con.)
Other:
Flanges:
307.91
Not machined, not tooled and not otherwse
processed after forging:
Of iron or nonalloy steel..................
1.10 00

3.3%

Free (4, AU, BH,

CA, CL, CO, E, IL,
JO, MA, MX, OM,
P, PA, PE, SG)
1.6% (KR)

91.30

00

Of alloy sleel (excepl stainless steel)..........

3.2%

ol

91.50

33%
Free (A', AU, BH,
CA, CL, CO, E, IL,
JO, MA, MX, OM,
P, PA, PE, SG)
1.6% (KF)
(A-, AU, B,
cA, cL, co, E, lL,
JO, MA, MX, OM,
P, PA, PE, SG)

7%(KR)
10

30

70
.92
10

30
92.90 00

With an inside diameter of less than 30 m

Of iron or nonalloy
Of alloy steel (except stainless steel)....
With an inside diameter of 360 mm of morei
Of iron or nonalloy stee|....".......................

Of alloy steel (except stainless steel).'

Threaded elbows, bends and sleeves:
5"k

Sleeves (coupl
Of iron or nonalloy steel
Of alloy steel (excepl stainless steel).....
Other....................

Free (4, AU, B, BH,

cA, cL, CO, E, lL,
JO, KR, MA, MX,
OM, P, PA, PE,
SG)

Harmonized Tariff Schedule of the United States (2016)

Annotated lor Statstical Reporting Purposes
XV

73-22

ol

Article Descriptn

Subheading

Tube or.pipe fitlings (for example, couplings, elbows, sleeves)

iron or steel: (con.)
Other: (con.)
Butt welding littngs:
With an inside dameter of less lhan 360 mm:
Of iron or nonalloy sl|.............,....

7 (co

.93

6.2%

(A+, AU, B, BH, 45o/"

cA, cL, co, D, E,

IL, JO, MA, MX,
OM, P, PA, PE,
SG)

4.2%(KR)
10

40

Not machined, not tooled and not

otherwise processed af ter forging.......

kg

Other.......,...,..,..i..,i.i.......,.,..,......,.r,;.!i.

kg

Ol alloy steel (except stainless steel)........

(A, AU, B, BH,

9,"t

454

cA, cL, co, E, lL,

JO, MA, MX, OM,
P, PA, PE, SG)

7%(KR].
Free (4, AU, B, BH, 45%

With an inside diameler ol 360 mm or more........,.

.93.90

cA, cL, co, E, lL,

JO, MA, MX, OM,
P, PA, PE, SG)
2 e% (KR)

10

40
60

99.10 00

Of iron or nonalloy steel:

Not machined, not tooled and not
otherwise processed alter forging.......
Of alloy steel (except slainless steel).......
Other:
Not machined, not tooled and not otherwise
processed after lorging:
Of iron or nonalloy

kg

ks

Free (4, AU, BH,

25%

cA, cL, co, E, lL,

JO, KR, MA, MX,
OM, P, PA, PE,
SG)

99

00

Of alloy steel (except stainless steel).............

(A, AU, BH,

kg

33%

cA, cL, co, E, lL,

JO, KR, MA, MX,

4.3/"

Other,,..,..,..,.,.-.1i*.i,,r,P.:;',,i'rf ,,,/{,:.'

OM. P, PA, PE,

SG)
(A, AU, B, BH, 45/"
cA, cL, co, E, lL,
JO, KR, MA, MX,
OM, P, PA, PE,

sG)
Ol iron or nonalloy steel:
15

45
60

Nipples,,;.;..".,...;.....,....'..'..,..'r',",,.,'..,..

kg

Other.............................

kg
kg

Of alloy steel (except stainless steel)...

I-6

KNOWN INDIAN PRODUCERS OF FTANGES

F Rings and Bearing Races Ltd.

B-1, MAYAPURI INDUSTRIAL AREA,
NEW DELHI
DELHI lndia 110064

Uma Shanker Khandelwal Forging Limited

B-4L0
New Friends Colony
New Delhi- L10025 lndia
Tel: +0091-9811026487

Ph

: 9 1-1 L-2 8 L1,4458 / 251.3431 6

Fax: 91-LL-25135759

Fax: +0091. t1, 4628301.

www.uskfl.com
Corum Flange
708 DLF Galleria, DLF City Phase - lV,
Gurgaon, I22OO2, Haryana, lndia

Echjay Forgings Limited

603-604, Raheja Chambers,
213, Backbay Reclamation
Mumba400 021-, lndia
Tel: +91 (221 4077 00AO
Fax: + 91

Tel:+91" 1"24-4287243
http://www. corumfla nse:co m

(22)2283I83I

SHM (shinHeung Machinery)

MantriAvenue

wwwrechiy;com:

Pashan Panchwati
R.N. Gupta & Co. Ltd.
Unit-ll G.T Road, Tehsil Payal, Doraha

Pune 411008

Ludhia na-14142l.

TeI: +9L-20-326A-9544

INDIA A1

lndia
Tel: +009L-161-5246900

CHW Forge Pvt, [td.

Near Hapur Road Flyover, Maliwara
Ghaziabad - zOL 001., Uttar Pradesh, lndia
Phone +9L12O 4388000

Fax: +009 1-1 6t-501,17 47

www.rnqupta.sgm
ROLLWELL FORGE PVT. [TD.

Fax +91 120 4376971

5th Floor,

E-Ma il chw(chwforqe.com

Shree Guru Krupa Tower,

Nr. MotiTanki Chowk,

Norma (lndia) ttd.

Mr. Goutum Khandelwal

Shubhash Road,
RAJKOT 360 001 (Gujarat ) lndia
www. ro lULe I lfo rFe.co m

48, Site lV Sahibabad lndustrial Area, S,

Ghaziabad, Uttar Pradesh - 20101-0, lndia
Mobile Phone : +91-99L0046941",+91-

ma

rketine@rollwellfgfee.com

9810078360
lephone : +9I-\20-2895404
Fax No : +9L-11-51628301

HINDON FORGE PVT.LTD.

Te

C-T73, B.S.ROAD INDUSTRIAL AREA,

GHAZTABAD-20L001 (UP) rNDIA
Phone : +91-120- 2700924 / 935 / 27O1.0O1.
Fax : +91- I2O -2700935 / 2700924
h tt p://www.hi ndonforse. ne tlcontact. htm I

R. D. Forge

Contact Person :Mr, Gaurav Garg

Address : C-LL4, Bsr Road lndustrial Area
Ghaziabad - 201 001" (lndia)
Tel. : +(91")-9810905062
Fax : +(9 1)-( t2O)-27 02530
E-mail : info@rdforse.corn

CHW Forge

Near Hapur Road Flyover, Maliwara

Ghaziabad - 201 001, Uttar Pradesh, lndia
Phone +911,2O 4388000
Fax +9L tzo 4376971.
chw@chwforqe.com
http ://chwforee, com/sgt-in-touchl:

1"
7

20s637 58

of

KNOWN NDIAN PRODUCERS OF FLANGES

ATLENA GROUP
C-l-1.6, Phase-7, lndustrial Area,

SteelShape lndia
ManojSharma
+9L-8049462663
C-167/L, Site No. L, lndustrialArea, B, S. Road
Ghaziabad - 201009
Uttar Pradesh, lndia

Sas Nagar, Mohali, Punjab, lndia - 160055

Pho ne : +9L-17 2-4232229

Email lD:
business.developmenta llena @gmail.com
Website : WWW.allenaa utoindqs_tres.on

SUDHIR FORGINGS PVT. LTD.

Kanganwal Road, P.O. Juginana,G.T. Road

Mascot Metal Manufactuers

Office: A-L1", lndustrial Estate Near Exhibition
Ground, LT.l. Road Aligarh, U.P, lndia 202001
Email: info@ mascotmetal,com
Phone: +9L571,2400 600 /+91.57I 645 3433

Ludhiana-14LL20 lndia.
+9L-16L-25L101L, 2511000
htt p : //www,sudhi rforsi nss.co m/
The Punjab SteelWorks (PSW)
B-38, Mayapuri lndustrial Area, Phase 1,
New Delhi- 110064 (lndia)
+ 9L - 1L - 41013400 / 4L833668 / 41833778

Alloyed Steel
93, Bhandari street , Ground floor,
Room no. 3

pswfgree@Vahoo.conJ
h

tt

; { /WWW.

swfo rgg

Mumbai- 400 004

.

n 1o

r.n b'.a

nv," ri

Email : alloyedsteels@gmail.com
Tel :+9L- 22-66151.863 / 66151864

rof i .
I

psw.html

Mob:9867234437
Tirupati Forge
Survey No.92/L, Hadamtala lndustrial Area, Nr.
Shan Cement,
Rajkot Gondal National Highway, Vill,
Hadamtala,

RAAJ SAGAR STEELS

DIST. : RAJKOT (lNDlA)360 31-L

Phone: +91,-22-6659 5285, 6639 42L4

Fax:+91-22-2389 5037
inq u i ry@ raajsaga rstee ls, com

L63, Dr.M. G. Mahimtura Marg,

3rd Kumbharwada,
Mumbai-400 004 (lndia)

Telephone : +9L 9825093907

{o ft (trupirtifofFe.coN,

htto://www.tirunatiforee.coml
Rdvi Ratan Metal lndustries

Office No 15,2nd plot -30/34,

Gokuldham Chs, Kika Street
GulalwadiGirgaon
Mumbai-400 004 INDIA

C. D. lndustries

3, SOUTH OF cT ROAD, BRIA, Ghaziabad

201.009, Uttar Pradesh, lndia
Mr. PANKAJ AGARWAL (Director)

Tel: +91" - 22

Uma Shanker Khandelwal & Co.

B-4L0
New Friends Colony
New Delhi - 110025
0091 9811026487
info@uskfl.com

663941.41.

nfo ( ravirala nmeta

l.

export(arvirata nmetalindustr.ies.in
Falcon Valves and Flanges Private Limited
Plot No 4, lndira Niwas, Near Nandjyoth
lndustrial Estate, Safedpool, Sakinaka, Andheri Kurla Road, Mumbai, Maharashtra, lndia
http://www.tufind ia.com

http://www. uskfl.com/

2of3
720s637 58

Fax: +9L -22-22428002

infe@raviratanrnetalinduslries,in

KNOWN INDIAN PRODUCERS OF TLANGES

DN Forge lndustries
Hem Villa, 1,7, Bhakti Nagar Station Plot
Beside Ajit Engineering Works
Rajkot - 360001-

HEUBACH INTERNATIONAT

2L Manipar House, 1st floor, 1st Parsiwada

Lane, Mumbai
Tel: +91 22 6743 8446
Fax: +91 22 66581,621
E ma i I : heubachma hend r:a@gmai[ sosl

Gujarat, lndia

Rolex Fittings lndia Pvt. Ltd.

I47-A, Sant Sena Maharaj marg,

2nd Kumbharwada,
Mumbai-400 004 (lndia)
Tel:+9L-22-6636 3159, 2380

Sizer lndia
No. L5, Diamond lndustrial Estate No. L, ketki
Pada, Off. W. E, Highway, Dahisar East, Mumbai
- 400068, Maharashtra , lndia

4t2t

Fax:+9L-22-2389 33I1E

m aiI:

HEUBACH INTERNATIONAL

folifbie@Fnlail.ltr

We bsite:

Address:
2L Manipar House,

www.rolexfittings.net

lst floor, 1st Parsiwada

Lane, Mumbai-400 004

Phone:+91 22 6743 8446

Adinath lnternational
4,Sa nskar lndustra I Estate

Fax:+91" 22

Beside Kailash Estate

66581621

Email:heubachma hend ra @gma il.com

Near SP Ring Road, Odhav

mahendra@heubachint.com

Ahmedabad, Gujarat
lndia-382415

OM

65422528, 3O4I7 528

Fax: +91-79-22773764

Plot No.37, Tiny lndustrial Co-op Estate Ltd.,

Undri-Pisoli Road, Kondhwa (Bk),
Pune - 411048

Te I : +9 1-79-

ma i I : info@adj-04!h..eg"ln

Tele Fax: +9L-20-26931,L55

Tel. : +91-20 -64015634/ 60304040/6521.4040

Siddhagiri Metal&Tubes
1.61./L63 DR. M.G. Mahimture Marg
3rd Kumbharwada
Mumbai-400004
Maharashtra, lndia
Tel: +9L-22-2386 5529
Fax +9L-22-6610 9206
i

nfo

@ sid

EXPORTS

Email: sales@omexport,co.in

Kinnari Steel Corporation

24/ L, 2nd Carpenter Street
Cawasji Patel Tank, Mumbai, Maharashtra

400004,lndia
+9'J.-22- 2386 2246, +91-22- 6636 3675

dhiiii meta ls. co m

kslok@vsnl.net ;kinnaristeel @vsnl.net

Citizen MetalDepot
Shop No. G-3, Hararwala Bldg. Comp., Ardeshir
Dady Street,
Back to Jain Temple, Near Alankar Cinema,
S.V.P. Road,

Mumbai :400 O04, MAHARASHTRA, lNDlA.

Tel: +91-22 -2381.3109 / 6651 8794
+9L-22 - 6639 3593 / 6636 3435
Fax: +9!-22 - 6639 3593
E ma i I : exnorts(acitiigr_tworlds.com

3 of 3
-t20563'7

58

r-.7

KNOWN SPANISH PRODUCERS OF FLANGES

Ulma Piping
B" Zubillaga, 3 P.O. Box 14
20560 Oati (Gipuzkoa) Spain
Tel: +34 943 78 05 52
Fax: +34 943 78 18 08

www;ulm.aDiping.corq
Grupo Cunado
C/ Camino delOlivar, 2 (Esq. Calle Mxico)
28806 Alcal de Henares

(Madrid)
Tel.: +34 91887 87 00
Fax: +34 9t 887 87 33

wwwigruocunado.com
TUBACERO, S.L.

Carretera de la Unin, Km 3'2 s/n

30399 Cartagena
Murcia (Spain)
Tel: +34 968320032 Fax: +34 968320033

)g!y!ylgbaggro.e
ATEAC]ONES DE METALES SNTERIZADOS S.A.
AddressCtra Laurea Miro 388 San Feliu De L

Lobregat Spain
sales@ames.es
! /t1vw.ames.es
TRANSGTORY S.A.

AddressC lparraguirre 29 2 Piso 48980 Santurce

Bizkaia Spain 34 944833916 Telex 34

9446t6420
b rce

lo?tt

ra n slll o rv, co

CENTRAT Y ALMACENES

C/ Camino delOlivar, 2 (Esq. Calle Mxco)

28806 Alcal de Henares (Madrid)
Tel.: (+34) 91 887 87 00
Fax: (+34) 91 887 87 33

infoterupocunado,com
www,eruocujado,com

1ofi.
720018787

r-8

KNOWN ITALIAN PRODUCERS OF FLANGES

Metalfar Prodotti lndustriali, S.p.A.

Martin Valmore srl

Via Giuseppe Parini, 28

23861 Cesana Brianza (Lecco)
Tel: +39 03L 655441

V. Bocche Di Sotto 4
3L010 - Orsago (TV)
Tel:0438 990850

Fax: +39 335270322

hlto:ilwww,rna

lml lndustria Meccanica Ligure

UNGEN Steel Engineering

Forged Flanges Fittings

Via Giancarlo Farina, 25, Casarza Ligure
Genoa, 16030

394/396, V. S. Zeno
25124 Brescia (BS)
Italy

Italy

Tel.:030 21,61079

Tel: +39 0185 467661,

Fax: + 39 0L85 466510

http://www.u nieensteel.com/

Italy

lmore.eoml

Fax: 030 2160809

http://www.im lfittinss.it/ind ex.htm

Costruzione Ricambi Machine lndustriali

L4, Yia Cortina D'Ampezzo
20139 Milano (Ml)
Italy
Tel.: 02 569L888
Fax:02 5696392

BifrangiS.p.A.
Via Alessandro Manzoni, 14
36065 Mussolente Vl

Italy
Tel: +39 0424 838L11"
hft

rtin,ra

$:lltvwwlbifransl ;it/

http://www.corima milano.it/

Siderforgerossi Group S.P,A.

Via Cartiera di Mezzo, 38

CAT Carpenteria Metallica srl

Via Brigata Maiella, L4

36011Arsero Vl

48013 FOGNANO Dl BRISIGHELLA (RA)

Italy

Italy
Tel.: +39/04 45/7

Tel: +39 -05468110L

Fax: +39 -{54685699

31"61"L

tax: +39/0445/74I74L
ht-tn://www.siderforse rossi. com/

hltp:/Lw,wwcatc ipe nte iidrneta llicasrl,Eoml

Forgital ltaly S.p.A.

Officine Ambrogio Melesi &

Via Spezzapria 136010 Velo d'Astico

Localita Seghe (Vicenza
Ita ly

Largo De Vecchi, 11- 23813 CORTENOVA (LC)

Tel. +39 0341 9834L
Fax +39 0341 983496 -983497

C. S.R.L.

-nail: info@rnelsi,lt

Tel.:+39 044573I31.3
Fax: +39 0445 731, 49O

Filmag ltalia 5.r.1.

foreita I @forslta l.com

Via Donizetti, 28
26027 - Rivolta D'Adda (CR)

www.forgital.com

Italy
ASFO S.p.A.

+39 0363 310377

FOMAS Group

Via lV Novembre,12
36010 Chiuppano (Vl)
Italy
Tel: +39 0445 805290
Fax: +39 0445 805299
Email : asfo (dfomasgrou p.com

f il m

1of3
?200 I 882 I

{fil

rn

aqita lia,co m

www,filmagitalia.cg
Sales ltaly, Europe, Asia: Federico Fontana

KNOWN ITALIAN PRODUCERS OF FLANGES

FOC Ciscato S.p.A.

M.E.G.A. S.p.A.

Via Pasin L
36010 Seghe diVelo d'Astico
Vicenza - ltalia
+39 0445 7391.L1

24020 Scanzorosciate (BC)

3, v. Dalla Chiesa
ph. +39.035.661280; +39,035.664404

,mg{ittin gi @,leql fd il :it

W\U$r;,n0

lnfAEfg"JI

www.foc.it

Officine di Cortabbio s.r.l.

Via Provinciale 147
238L9 Primaluna (LC)
+ 39 0341 979 977
i nto @pffiineorta b hio;it
http:/LwWwioffcnecr4:itl

FOMAS

via Martiridella Liberazione, L7

23875 Osnago (LC)- ltaly
Phone +39 039 99811 Fax +39 039 587415
ales@foma$rrgun.com
wwW:fomasgroup.com

OFFICINE MECCANICHE CIOCCA S.p.A.

24053 Brignano Gera d'Adda (BG) - ltaly

Forgia Di Bollate S.p.A.

S.P,4, no.9 -46013
Conneto sull'Oglio (M N)

via Treviglio,44

Ita ly

fax 0363 815333

+39 0376 7t4511

lnfo@cioceaspa,,lt
htt p //-www.c occa s pa it/e n/

tel 0363 382345/815504-2 linee r.a.

info@foreiad i bollate.com

www.forsipdibollate.cgm
Officine SANTAFEDE
Forgiatura A. Vienna diAntonio Vienna
Via Ospiate, 46/48

Via Fregera, 1
238L9 Cortabbio di Primaluna (LC), ltaly
+39 034L 979 919

2oot7 Rho (Ml)

Italy
+39 02 9393 0011

sales@forgevienna,it

via lV Novembre 9/L7

25030 - Mairano (BS)- ITALIA

VALVITALIA S.p.A.
Via Tortona, 69
27055 Rivanazzano (PV) ltaly
Phone: +39 0383 945911
Fax: +39 0383 9459962

E-ma il: info@fra nchiniacciai.com

E-mail : info@valvitalia.co!n

Phone: +390309750211
www.fra nchiniacciai.it

www.valvitalia.com

Vyww.fgrqevi.ennq.it

Franchini Acciai S.p.A.

Galperti Forged Products

Via trivio Fuentes 4 | 22OtO - Gera Lario (CO)
Ita ly

Tel. +39.0344.97200 - Fax +39.0344.972IO

E-mail: gelpe.ti@e?lpFrti,com

htlp 11wtvw"s
foreine,php
:

pe rt

i,

corn lE /Ra l oe

rti-

2of3
72001882t

KNOWN ITALIAN PRODUCERS OF FLANGES

Assotherm srl
Registered office and logistcs
Via Broli, L2
24060 Casazza (BG)- ltaly
vAT 033739401.66
Tel. +39 035/813182
Faxl +39 035/816892
Fax2 +39 035/4501280

lnfotassotherinicom
lnox LaghiS.r.l.
Via Molinello
52 - 2!048 Solbiate Arno {VA) ltaly
Tel. +39 0331.76,00,11.
Fax +39 0331".98,57.00

KIASMA SRI.

via Monte Adamello, 31/H

3L059 Zero Branco
Treviso - ITALY
+39 042297 620
+39 0422 4874 47
rna

rtinacrttit

kia s ma sil,

3of3
7200 I 882 I

r-9

lmports of Machined or Tooled lron or Non-Alloy Steel Flanges

Jan.-Mar
2015

2014

2013

2015

2016

60,824,063

55,162,447

66,314,804

19,579,163

9,676,875

Spain

9,765,907

6,887.98!

11,370,308

2,764,887

2,099,214

Italy

9,484,108

10,276,670

13,859,730

3,584,484

3,429,473

80,074,078

72,327,106
24,467,727

25,928,534
5,266,553

15,205,562

Total

23,896,801
'103,970,879

91,544,842
21,281,963
12,826,805

31,1S5,087

19,012,025

lndia

134,093,946

121,612,341 146,198,943

43,164,614

21,333,832
4.627,969

lndia

Subtotal
Other

96,794,83

85,3981

6,095,525

25,067 ,2Q8

3,806,463

Spain

21,530,114

15,'r

Italy

20,908,854

22,656,1521 30,555;43S

7s02,425

7,560,685

176,532,91t

159,453,7841 201,821,590

57,12,565

33,522,486

Subtotal
Other

52,683,365

Total

229.216.279

53,942,0401 46,918,641
21

3,3e5,S251 248,7 40:231

11,610,748

8,391 ,804

8,773,313

41,914,29',1

lndia

101 ,269,507

82,628.133

96,602,7401, 30,423,768

Spain

25,174,792

Italy

28,221,531

21,034,623
29,772,513

27,550,9551
34,671,e381

Subtotal
Other

158,665,830

133,435,269

12,111,014

6,733,877

4,360,077

e,355,558

7,473,124
23,944,215
9,942,405

158,825,6331 46,513,203
60,676,0391 17,007,314
219.501,6721 63,520,517

77,O44,145

79.030.442,

Total

235,709,975

212,465,711

lndia

95,750,800

76.845,66,

89,133,999

28,140,483

Spain

27,200,462

19,539,513

25,607,347

6,273,336

Italy

25,022,927

26,761,809

3'1,042,060

147,974,189

123,146,986
71,063,907
194,210,893

33,886,62C

Cuslorls Value ($)

Subtotal
Other

69,352,610

Total

217,326,799

145,783,406

8,371,246
42,785,065

11.257

j32

4,028,971
6,659,656

21,945,759

54,002,676

15,301,25e

8,845,800

199,786,082

58,086,324

30,79'1,559

ctF g/tb.
lndia

0.755

0.679

0.661

0.705

Spain

1.355

1.385

1.099

1.105

0.s42

Italy

1.350

1.314

.135

1,184

O.9BB

0.899

0.837

0.787

0.814

0.714

1.462
1.028

1.465

1.293

1.465

0-996

O.BB2

0.924

0.808

0.652
1.029

0.871

Other
Total

0.568

.'l 85

Cusforns Value $/lb.

lndia

0.714

Spain
Italy

1.263
Subtotal

Other
Total

0.632

0.6'10

1.287

LO22

0.528

1.',197

1.181

1.016

1.05S

O.BB1

O.B3B

0.772

0.722

0.748

0.655

1.316

1.317

1.'t51

1.318

1,054

0.948

0.91 0

0.803

0.845

0.735

Source: USITC DataWeb. lmports for HTS ltems 7307.91 .5010 and 7307.91.5050

r-10

LIST OF POSSIBI,E FLANGE IMPORTERS'

ADVANTAGE ADFIESIVES
8345IVHITE OAK AVE
RANCHO CUCAMONGA, CA 91730
info@advantageadhesives. com

ALLIED FITTING, LP
6040 LAGRANGE BLVD
ATLANTA, GA 30336
alliedfi ttings@alliedfi ttings.oom

ALLIED FITTING, LP (separate location frorn above)

72OO MYKAV/A RD
I_IOUSTON,TX77O33
aliedttings@alliedfi ttings.com

ALI.IED FITTING, I-P (separate location from above)

14723 FAIRV/AY PINES DR
MISSOURI CITY, TX 7'I 489
alliedfittings@alliedfi ttings, com

ALGONQUIN GAS TRANSMISSION

54OO WESTHEIMER CT'
HOUSTON, TX77056

+t

713 627 5400

gerncbride@spectraenergy, com
sehel hnan(@spe ctraenergy. c om
gj ohnson@spectraenergy. com
j kdevers@spectraenergy. com
bclonaldson@spectraenergy. com

AMERICAN COMPLETION TOOLS

9223 SOLON RD
HOUSTON, TX17064
sales@americancompletiontools.com

AMERICAN PIPING PROD{JCTS

11403 N HOI]STON ROSSLYN RD
IIOUSTON, TX 77088
sales@amerpipe.com
I ogistics@arrerpipe. com

purchasing@amerpipe.com

lr.rlmed larges inrporrer natnes highlighecl in ltold. Counsel for Petitioners ttnclerlooli ther besl elTorts
'
to olttttin contact infurnrutionfor each tos:;ible importer of the subject nerchanclise. lnde<:cl, over seven Mayer
Brou,n stctl in three d(ferent offces spent nrtt?1ct'ous hout's collectivclt to obtuit email utllrcs.ses/or the identi/ed
possible inttorters. I4/here entuil oddrcs.sc, could simpl, no bc olttuinecl, we trovitle phone nttmbers.

720_5034 8

AMERICAN PIPING PRODUCTS (separate location from above)

825 MARYVILLE CENTRE DRIVE, #310
CHESTERFIELD, MO 63017
sales@arnerpipe.com
logistics@amerpipe. com
purchasing@amerppe. com

AMERIFORGE GROUP
l3TTO INDUSTRIAL RD
HOUSTON, TX 77015
info@afgl

ob al

corp. com

API INTERNATIONAL
6219W STONERDR
GREENIIIELD,IN 46140
info@apiint.com
ARCELORMITTAL AMERICA
1 S DEARBORN
CHICAGO, IL 60603
ami -ameri ca@arcelormittal. com

BALDAUF ENTERPRISES
910 HARRY S TRUMAN PKWY
BAY CITY, MI48706
laurahorney@kerkau.com

BAWDEN WESTER & ASSOCIATES

999,HAYNES ST, STE 340

BIRMINGHAM, MI 48009

+t

248 594 7200

gbawden@bwausa.com

I]BT1'Z USA

r00 QUENTTN BLVD STE s05

GARDEN CITY, NY I I53O
bebitzusa@bebitz.de

BECHTEL INTERNATIONAL
3OOO POST OAK BLVD
IOUS'|ON, ]-X11056
b ec

htel (@contra ctor.

lt

et

nllegasp@bechtel.com

BERENFIELD CONTAINEIS
4555 LAKE FOREST DR
BLUE ASH, OH 45242
jharrel I@berenfleId.com

2
720503411

BORG WARNF,R DRIVETRAIN SYSTEMS

38OO AUTOMATION AVE
ABURN HILLS, MI48150

mediacontact@borgwarner. com
BPS HOUSTON

I4514 LUTFIE RD
HOUSTON, 'l',X71039
dhance@bakersfreldpipe. com
bsrnith@bakersfi eiclpipe.com
rvasquez@bakersfield. com
tberrson@bakersfi ed lpipe.com

CAMERON SURFACE SYSTEMS

OKLATIOMA CITY PLANT
PO BOX 3101
FIOUSTON, TX 77253
belinda.tomlinson@c-a-m.com
j oseph. opitz@c-a-m.com
belinda.tomlinson@c-a-m.com

CERTIFIED POWER INC.

390 KOOPMAN LANE

ELKHORN,

WI

53121

powertrain@certi fi edpower, com

CHART ENERGY AND CHEMICALS

3415 EARL B RD
WILSON, WA
wanda. Schol lian@chartindustries. com
chart, sales@chartindustri es.com

ken.webster@chartindu stries. com

CONSARC

INDEL AVE
RANCOCAS, NJ 08073
lOO

om
sales@consarceng.com
sa I es (r.!c orr sa rc. c

CONTECH INTERNA'TIONAI1046

ANNUNCIATION ST

NEW ORLEANS, LA 70130

in 1'o@con -'l-ech

nternation al. com

DI- F-ANGI1
.]185

LTTTLE YORK RI)

HOI,ISTON, TX17OI6
gperki ns@)dl fl ange.con,
dj

ohnson@dllan ge.com

3
72050:i48

DNOW I- P
7402 N ELDRIDGE PKV/Y
HOUSTON, TX
ap@dnow.com

DNOW L P (separate location from above)

359 A OLD IjNDEIIWOOD RD STE B

LA PORTE, TX7757I
ap@dnow.com

DODSON GLOBAL
175 SOUTHBELT INDUSTRIAL DR
FIOUS'I'ON,TX71O41
sales@dodsonglobal.com

DSTI DYNAMIC SEALING TECHNOLOGIES

13829 JAY ST NW
ANDOVER, MN 55304
info@dsti.com

DYNAMIC INDUSTRIES
6005 PORT RD

NEW IBERIA, LA 70560

contacti ntl @dynami cind. com
contactgeneral @dynamicind. com
contactdcs@dynamicind, com

DYNO NOBEL
660 HOPMEADOW ST
SIMSBURY, CT 06070
boisbriand.reception@am. dynonobel.com
francois. lambert(@arn. clynonobel.com

DWYEI{ INDUSTRII]S
600 N SHEPHERD DR STE 420
FIOUSTON,'[X77001
sdwyer(@dwyerin dustri

e s. c

onr

skoch@dwyerindustries.com
kpatterson@dwyerindustries. com

IIDGEN MURRAY
83OO BREEN DR

FtousToN,'t'x

11064

j oe.hammonds(@edgenmurray. com

EDGEN MURRAY (separate location fiorn above)

I141 KRAEMER BLVD
BATON ROUGI], I,A 70884
j oe. harrrrnorrds(!edgenrnLr'ray.cor.rl

4
7205014t

EP CLEVELAND

1621IIUR PKWY
VALLEY VIEW, OI144125
hBp ;i/pp I eveland..Cq m

f1 866 8623816
FAIRCHILD INDUSTRIES
475 CAPITAL DR

LAKE ZURICH,IL 60047

info@fa irchi ldi n d.c om

FERGUSON ENTERPRISES

9IOA COBB PKWYN

MARIETTA, GA 30062
frank.roach@ferguson. com

FEDERAL FLANGE AND FITTING

4014 PINEMONT DR
FIOUSTON, TX 77018
nfo@federal fl ange. com

FILTER TECFIS
FAIRGROLINDS DR
MANLIUS, NY I3IO4
info@filtertech,com
FLEXSTEEL CONNECTIONS
12450 CUl"r'EN ROAD
HOUSTON, TX 77066

+t

832

53i

8555

IILUID EQUIPMENT DEVELOPMENT

8OO

TERNES DR

MONROE, MI48162
sales@fedco-usa.com

IOI{GED COMPONENI'S
14527 SMITH RD
HUMtsI,E, 'TX1'/396
ahrabowiecky@forgedcomponeltts. com

FORGED FLANGES AND FITTINGS

(part of the Global Group)
B9OO

IAIT,WOOD DR, ST'E B

IlotJSl'ON,

+t

'I',X 11078

113 695 5400

steve. lee@globalgroupl, com

5
72050348

GALPER'I'I
I60 SOUTFIBELT INDUSTRIAL DR

I.IOUSTON,TXl7O47
galprnail@galperti-am. com

GENERAL FLANGE AND FORGE

2381 PHILMONT AVE STE 125

FIUNTINGDON VY, PA I9006

jpaskus@general fl ange. com

GLOBAL STAINLESS SUPPLY

4111 CAROLINA AVE BLDG A
RICFIMOND,V A23222

+t

113 9B0 5089

administrator@global stnls.com

GLOBAL STAINLESS SITPPLY (separate location from above)

9O4O RAILWOOD DR STE I5O
HOUSTON,TXTTOlB
+1 713 980 5089
administrator@global stnl

s.

com

HOERBIGER COPORATION OF AMERICA

3350 GATEWAY DR
POMPANO BEACH, FL 33069
info-americas@hoerbiger. com

HYDRIL USA DISTRIBUTION

33OO N SAM I-IOUSTON PKWY E
TIOUSTON,TX77O32
+l 281 449 2000
lester.bmno@ge.com

INDIMET
50 MAIN ST STE 1260
V/TIITE PLAINS, NY 10606
info@indimet.com

INDUSTRIAL VACCUM EQUIPMENT

N7959 BIRCH RD

IXONIA, WI53036
i

nfo@industrialvaccum, com

INDUSTRIAI, VALCO
635 GELLHORN DR
HOUS'TON,TX ]1029
webrnaster@industria lvalco.conl

6
720-50348

INDUSTRIAL VALCO RANCHO DOMINGUEZ

3I35 EASTANA STREET
RANCHO DOMINGUEZ, CA 90221
wakeharn@industrialva

co.

corlr

ITEX PIPING PRODUCTS

12945 MARKET ST
HOUSTON, TX 770I5
sales@itexpp.com

ITEX CO TEAM ALLOYS (separte location from above)

8786 WALLISVILLE RI)
HOUSTON,TX''I']029
sales@itexpp.com

ITEX PIPING PRODUCTS (separate location from above)

I34l1WESTROAD
HOUSTON,TX77O4l
sales@itexpp.com

I(ERI(AU MANUFA CTURIN G

9I O HARRY S TRUMAN PKWY
BAY CITY, MI48706
patrickbarckholtz@kerkau. com
joehader@kerl<au,com
laurabaldauf@kerkau. com

KERKAU MAMJFACTURING (separate location from above)

13215 VALLEY CENTER DR
BAY CITY, MI48706
patri ckbarckholtz@kerkau. com

joehader@kerkau.com
I

aurabaldauf@kerkau. com

KONGESBERG AUTOMOTIVE USA

3OOE OI,MOS

HIDAI-GO, TX 78557
fredri k.tan geraas@ka-group. com

I,INDE ENGINEERING NORTH AMI]RICA

5 SENTRY PKY E
BLUE BELL, PA 19422
al.zdzi

er

a@l i nde -l e. com

r-rQUrD coNTROr.S
105 ALBRECHT DR

LAKE BLTJFF, lL 60044

I

c-i nf-o. lcrneter(c-r)i

excorp. com

1
7205014t

LOBLAW COMPANIES
2755 1g0r'r ST
SUITIIEY T]C V353W6 CANADA
investor@loblaw.ca

LYNVO FLANGI]
5114 STEADMONTH DR
HOUSTON,TXTTO4O
sales@lyncoflange,com

MACLEAN POWER
78OI PARK PLACE ROAD
PO BOX 949
YORK, SC 29745
+1 803 276 4462 ext. 15
lblackmon@macleanpower. com
atoby@)mac l eanpower.

otl

MATCO-NORCA
t944P.OUTE22
PO BOX 27
BREWSTER, NEW YORK 10509
partsandservice@matco-norca. com

MCJUNKIN RED MAN

835 HILLCREST DRIVE E
CHARLESTON, WV 25322

bill.dobbins@mrcglobal.com

MC JUNKIN RED MAN BR (separate location fiom above)

4732 DARIEN ST
HOUSTON, TX71O2B
bill.dobbins@mrcglobal. com

M S NORCA INDI.]STRIAL COMPANY

I85 GREATNECK IIOAD
NEW YORK, NY i IO22
garibaldi@norcaind.com
yevonne@norcaind.com

MERFISH PIPE AND SUPPLY

12I

KRESS ST

HOUSTON, TX']1020
rsetzekorn@merfi sh.com

gmerfish@merlish.com

MlrIlT Ill{ASS
ONE MERIT DRIVE

CLEVELAND, OH 4414I
ie(!fi nepvfsa es. c on-l

arn

l
72050341( I

MERIT I]RASS COMPANY

2BOD OXMOOR CT

BIRMINGHAM, AL 35209
mbsal esal@meritbrass. com

MIDLAND MANUFACTUI{ING
7733 GROSS POINT RD
SKOKIE, IT,6A1
seosrni th @mi dlan dmfg.

co

M]SSISSIPPI FORGE PVF

4OO W MAIN ST

ACKEI{MAN, MS 39735
info@mspforge.com

MISSOURI PIPE FITTINGS CO

4OO WITHERS AVENUE
ST LOUIS, MO 63147
sales@mopipe.us

MITSUI
2OO I] RANDOLPH ST, STE 5210
CHICAGO, IL 6060I
+t 2t2 878 4000
a.blum@rnitsui.com
k.bateman@mitsui.com
t.golub@mitsui,com

NATIONAI, OILWELL DHT L P

7909 PARKTVOOD CIRCLE DR
HOUSTON, TX17036
+1 713 346 7500
mike.hart@nov.com
loren.singletary@nov.com

OIL STATES INDUST'RII]S

5819 ALMEDA GENOA RD
HOUSTON, TX7'7048
info@oi lstatesintl,com

ORASCOMI]&CUSA
3546 tgO'r'STREET

V/EVER,IA 52658
contactus@orascom. corn

PART;AB INDUSTRIES
r56r5 E 590 RD

INOLA, OK74036
contactus@orascom.0oul

9
72050348

PERIORMANCE CONCEP'TS
16898 PARADISE LANE, SUITE 9
SCOTTSDALE, AZ 85260
amoore@prfabfs.com

PM INTERNATIONAL SUPPLIERS
4305 HIGHLAND PARK BLVD
LAKELAND, FL 33813
info@pmfirst.com
POTS WEI.,DING
I9O1 OGLETOWN RD
NEWARK, DE 19711

dmccoy@pottswelding. com
tbuni s@pottswel ding.com

PRIME STAINLESS PRODUCTS

4848 N. RIVER RD
SCHILLER PARK, IL 60176
michael@primestainlessproducts,

com

PRO FLANGES
I3O VONDRAU DR

CAMBRIDGE, CA N3E 188

tonyt@proflange.com
P S SUPPLY

3352 WALNUT BEND LN

HOUSTON,TXT]042
sales@pssupply.net.

QUARTER TURN RESOURCES

114W I3TI.I ST
DEER PARK, TX'1'1536
sales@qtrinc.biz.
R AND S OILFIELD
14202 PARABLE LN

CYPRESS, T){17429
sales@rsoilfield,com.
R I] FI'I''I'TNGS AND I,LANGES
65IO MADRID ST

HOUSTON,TX7lj2l
sales@rbfittings.com.

RED V/OI,}.COMPANY
I826 BOONE TRAIL RD
SANFORD, NC 27330
i

rrfo(@redwol fl I c. com.

10
72050348

REGAL BELOIT AMERICA

I2O8 OLD NORRIS RD

LIBERTY,5C29657
i

nvestor@regalbeloit. com.

SASOL CHEMICALS NORTH AMERICA

9OO'I'IIREADNEEDLE
HOUSTON, TX770''9
ric.sweeney@us. sasol.com.

SERVICE METAL PRODUCTS

12630 W AIRPORT BLVD
SUGAR LAND, TX774'78
j fears@servicemetal.net

SERVICE METALS
N KINGSHIGHV/AY BLVD
SAINT LOUIS, MO 63115

4OO1

+l
+l
j

800 325 7820

314 421 t44I

braden@servicemetalcompany. com

SHAV/ ALLOY PIPING PRODUCTS

740 N MARKET ST

SHREVEPORT, LA 7T101
app,sales@shawgrp.com

SILVO INDUSTRIES
50 CIIESTNUT RIDGE RD

MONTVALE, NJ 07645
+1 2At 307 0900
info@silboind.com
SOUTHWEST STAINLESS
D BA SFIALE INLAND PVF
4355 DRANE FIET,D RD
LAKELAND,IL 338I1
+1 863 646 1493
scott.batten@shaleinland.com

SPECIAL'|Y MANUFACTURTNG SOI,UTIONS

66 JANNEY RD
DAYTON, OI.I
ass i gn @)spec i al

tygroup i nc. com

INTERNATIONAI, INC.
PAIK DIIVE
HOUS'I'ON, 1'X11041
STA'I. S

10950 BR]TTMOORE

usa@statsgrtlup.com

l1
?2050348

TA CI.IEN INTERNATIONAI,
9525 WALLISVILLE RD
WALLISVNLE, TX 17413

jeny

leneck@tachen.com

TEAM ALLOYS
7350 ROUND}IOUSE LANE
HOUSTON, TXl7O'18
bill.bootz@teamalloys.com

TEAM INDUSTRIAL SERVICES CORPORATE

13131 DAIRY ASHFORD RD
SUGAR LAND, TEXAS 77478
contact@teaminc.com
"I'EVEX GLOBAL BUSINESS SERVICES
10612TI] STREET SE

WAVERLY,TA 50677
inf'o@terex.com

TEXAS EASTERN TRANSMISSION

54OO WESTHEIMER CT
HOUSTON, 'f'X17056
bdonaldson@spectraenergy. com

TEXAS PIPE AND SUPPLY COMPANY

2330 HOLMES RD
I'IOUSTON, TX77O5I
customerservice@texaspipe.corn

TIOGA PIPE SUPPLY

2450 WHEATS}IEAF LANE
P}IILADELPHIA, PA 1 9 137
joeg@tiogapipe.com
sales@tiogapipe.com

TRIANGLE MEI'ALS
17845 S HWY 75
GLENPOOL, AK14A33
brobbins@trianglemetal susa.com

TRI I,AD FLANGE

I4623 FAIRWAY P]NE DR
MISSOUII CI'I'Y, TX
lpappas@tri-lad.com
hdej ong(rltri -l ad. com

TURNER INDUSTRIES GROUP

1200 sv/ I8l sT
PARtS,',tX15460

whi I l@turner-industries.com

12
720.5014

f I

ULMA PIPING USA CORP

REGUS GROUP WILOWBROOK

83OO

1960 WEST ROAD, STE 450

HO{JSTON,

TX

+34 943't8 05

17070

522

US METALS
19102 GUNDLE RD
HOUSTON, TX77073
sales@usmetals.com

VAL II'I'
I57B LITTON DR
STONE MTN, GA

3OOB3

salesatl@valft.com

VAL FIT (separate location from above)

95OI SPIKEWOOD DR
HOUSTON, TX77O78
saleshou@valfit.com

VAL FIT LOS ANGELES (separate location from above)

8360 WILCOX AVE
BELL GARDENS, CA 90201
salesla@valfit.com

VALVTECHNOLOGIES
6600 DI]IHL RD
IIOUS'|ON, 'I-X17092
info@valv,com
VAN LEEUWEN MRO AND SERVICES
9OO SBUSINTJSS PARK DR
POIT AIITI_IUR,'TX 77 640
usa@vanleeuwen.com

VIRAJ USA
I 00 QUENTTN ROOSEVELI' BI-VD
GARDEN CITY, NY 1 I53O

wwuerthner@hvcbiz.rr. com

WELDFIT ENRRCY

4]33 SOUI'IIEIILANI)
HOUSTON, TXTA92
email@weldfit.com

-fexas
Secretary of State records, Bloonrberg,
cked Accurint public records, l-exis for
OneSource company database, Dun & Braclstreet and even called Houston irf'ornration. No cnrail or U.S. phone
numbel for this conlpany could be localed.

'

Moyer Brorvn

che

13
72050i48

WILO CANADA
9550 WIIIGGINS RD, STE 3OO
ROSEMONT, IL 60018
info@wilo-canada.com

14
7?0-5014 ri

r-11

PETITTONruRS' MARKET
SHARE DATA

Market Shares for Carbon Steel Flanges

Jan.-Mar,

2013

2oL4l 2o15lr 2o15l

20161

2013

2oL4l 2o15l

Jan.-Mar.

z0t6

2Ot5

U.S. Producers' U.S. Shipments

lmports:
134,094

lnd ia

Subtotal
AllOther

11,611

8,392

25,067

6,096

30,555

7,902

176,533

!59,454

52,683

Consumption

57,=163

15,185

22,656

Total lmports
U.S. Apparent

zot,822 :

21,334
4,629
7,561
33,522

43,165

L46,L99

20,909

Spain
Ita ly

727,672

53,942
213,396

46,9L9

68,772

4L,9t4

0,66

0.70

0.57

0.94
0.77

248,740

tot,27(
29,775
28,222

82,628l e5,6o3l 30,424l L2,rL7

21,035|t 27,55t1 6,4lit 4,36C

2s,7l 34,6721 s,3s6l

,+O,SrS

L58'6''.'
77,O44

L33,4g5li . .158,8261

235,71(

2t2,4661' zLg,s,Ol 63,52i1

60,6761 t7,Oo7l'

7,473
23,944

9,942

33,887

U.5. Producers' Shipments

lm po rts:

lndia
Spain

Ita ly

I
Subtotal t

AllOther

Total lmports I

U.S. Producers' Shipments

lmports:
0.76

lndia
Spain

Italy

Subtotal

AllOther
Total lmports

0.68

1.36
1.35

1.39
1.31

1.10
1.13

1.10
1.18

0.90

o.84

o.79

0.81

r.46

1.47

1.29
0.88

1_.46

1.18

0.92

0.81

1.03

1.00

0.99

Source: U.S. producers: Boltex and Weldbend and Bureau of Census import statistics from USITC dataweb.

PUBLIC VERSION

P'ffiffTTTONERS' TRADE

DATA

CONTAINS BUSINESS PROPRI ETARY

FORMATION

Trade Data for Finished Carbon Steel Flanges

T-E-li

Jan.-Mar.

2ot4l'

2015

2016

Capacity (1-,000 lbs)

Production {1,000 lbs)
Capacity Utilization
U.S. Commercial Shipments (1,00O lbs)
U.S. Commercial Shipments (51,000)

Ending lnventories (1,00O lbs)

Employment Data for Steel Flanges

Jan.-Mar

2Ol

2AL4

2015

2o1sl

2Ot6

Avg. PRWs (number):

Hours Worked:
Wages Paid (51,000)

Source: U.S. producers: Boltex and Weldbend.

PUBLIC VERSION

FETTTIONERS'

FTI{AI{CIAL DATA

CONTAINS BUSNESS PROPRIETARY INFORMATION

Financial bata for Fnlshed Carbon Steel Flanges

2,li,

zAtA

2015 ,

Jan.-Mar
2015

2016

7,000|bs.
Net Sales (volume)
Net Sales (value)
Cost of Goods Sold:
Raw Materials

ti

Direct Labor

Other Factory Costs

Total COGS
Gross Profit
SGA:

Selling Expenses
G&A Expenses

Ii

l
I

TotalSG&A

Operating Profit
Other Expenses
Other lncome
Net lncome
Depreciation/Amortization

I
J

I
ratio

Colculotions
COGs/Sales

Gross Profit Margin

t
I

Operating Profit Margin

Source: U.S. producers: Boltex and Weldbend,

PUBLIC VERSION

I,-I2

WELDBEI{I)

FL.{AT I9N

p ;nM ES J.

Q,U!,AS;

J8'.9',*FI,DEND CORPORATI oN

I, James J. Coulas, Jr, owner and president of Weldbend Corporation (a Petitoner in this
action), hereby certiff and affirm as follows:
Whereas,

1,"
2.

I have been with Weldbend since 1967, and as such, have over 49 years of
experience in the carbon steel flanges business; and
Since the year 1980, I have been involved in selling carbon steel flanges produced
by Weldbend to ou U.S. customers, and thus am intimately familiar with the U.S.
marketplace for carbon steel flanges.

As a result of the above,

3

4.

5.

Over the last three years or so, our sales ofcabon steel flanges have been under
increasing volume and pricing pressure from imported product - in great part
from India, Spain and/or ltaly, who ae the Iargest sources of imports of this
product based on Census data. Flowever, customers rarely divulge to us the
specific source from whom they purchased when we lose sales volume.
Indeed, it is my belief that V/eldbend is increasingly losing sales to unfairlypriced imported carbon steel flanges - based on price, and price alone. In
addition, Weldbend has had to reduce is prices to retain sales as competition from
these imports has increased.
on April 14,2016,we were contacted
By way of
ll

a that was offered at

our forging cost for

I declare that all statements made above are true and correct.

June 22, 2016

Date

72065517.

PUBLIC VERSION

BOLTEX

I, Frank Bernobich, of Boltex Mfg, Co., L.P. ("Boltex") (a Petitioner in this action), hereby
certify and affirm as follows:
'Whereas,

1.
2.

As

as such, have over 39 years of experience in the

business;
carbon steel flanges
and
Since the year 1988, I have been involved in selling carbon steel flanges produced by
Boltex to our U.S. customers, and thus am intimately familiar with the U.S. marketplace
for carbon steel flanges.

I have been with Boltex since 1988 and

a result of the above,

J

4
5

Over the last three years or so, our sales offinished carbon steel flanges have been under
increasing volume and pricing pressure from imported product - in great part frorr India,
Spain and/or Italy, who are the largest soulces of imports of this product based on Census
data. However, customers rarely divulge to us the specific source from whom they
purchased when we lose sales volume.
Indeed, it is my belief that Boltex is increasingly losing sales to unfairly-priced imported
carbon steel flanges - based on price, and price alone.
In great part due to pricing pressure from impofed flnished carbon steel flanges from
India, Spain and ltaly, Boltex has had to offer price reductions on its finished carbon steel
flanges. In the carbon steel flanges industry, this is generally done through applying a

"multiplier" to list prices

A.

8,y'way pf'gxrnple as,of Jauary 3I,2076, in an slTrt to try and stay - --.
oompetitve against s'bject'itrnpos, Boltex was ofrihg a multiplier of(
J
For example'

LIST PRICE DISCOUNT SALES PRICE B

Hovr'ever, because subject imports continued their increased presence in the U.S
market with even lower prices, on February'2,2016, Boltex generally had to
redrce its pricc an additional25o/o (which was done by applying a multiplier of
For example:

LISI'PRICE DISCOUNT SALES PRICE C.

Due to continued import penetration and decreased prices being offered by

subject imporls, as of this month, Boltex is cnrrently offering a

72N55362.3

PUBLIC VERSION

t pricesJmulttplier from the list price. We may even have to further reduce
beyond this.

I recently spoke by phone with three of our largest customers about boltex's
finishcd carbon steel flange prices vis-a-vis those from India, Spain and ltaly. To

6.

summarize those conversations

A.

B,

C.

I declare that all statements made above are true and conect.

-1. ?-o /l
Date

Bernobich
President

Attachment

(l)

720655362.2

PUBLIC VERSION

t
I

A,-TTAC'HIVTEI\T

t
l
I

i
I

ir
i

I
I

'

Lsnnu Nefi
I

F;iltil
sltriry

[t:r**

i
I

I
t,

r
!,

t,

t
I

T:

lI
I

I
I

f
I
I

1,.

I
I

t
t.

i
I
T

t
.

PUBLIC VERSION

\ryELDBEI{I} LOST SALB,S TEMPLATE

CONFIDENTIAL BUSINESS NFORMATION

.goqh,4 infoF.na$on-ptease identiff the individual that Commission stafi may contact regarding the Lost Sales
and Lost Revenue allegations.
Nerne

Jr

Tlle
Firm
Er,nail

Telephone

CONFI DENTIAL BUSINESS I NFORMATION

PUBUC VERSION

.-n
E

g
o

o-

CONFIDENTIAL BUSINESS INIORlATION

Allegatn type (secl "lol sales", lost

fevenu", of "bol lol sales and lost
fevenues'-use drop (lm, see intrc Pge
for definitions)

Generl time Period (Years

Unit for the rePoned qunlity

Aqgregte quantity of any los-t losl sales (e.9., short tons,

pounds, etc.)
seles allegations

both lost sales and lost revenues

both lost sates and lost revenues

Note

lost sales and lost revenues

fevenues

Note

lost sales and lost revenues

Note

bth loSt.Sts and lost e\ienues

fet,

were lrst and/or pri(s were

reduced

Gneral desiption of method

of sle (e 9., indvidual sale,
confad negotiatons, RFO bd,
tnteme{ saes, etc.)

tethod(s) Of Sale

Tmng

unt

(of lost sles)

TyPe

of d/or months) whi$ eles

both lost

bth lst seles and lost revenues

lndia/ltaly/Spain
ndie/lly/Span

lndividual sale/RFQ bid

lndividual saler/RFQ bd

Flges
Flanges

lndia/ltaly/Spain

POt

POt

lndividuat sale/RFQ bid

Flanges

lnda/ltaly/Spen

Flanges

lndialltialy/Spain

Flanges

lndia/ltaly/Spain

lbs
lbs

POr

lbs

POr

lndividual sale/RFQ bid

1-

bid

lb's

Note

Note

both lost seles ard lost revenues

revenues
los sles

Sutect

Flenqes
anges

POI

revenues
and lost

Product

Country('res) of or!in of the

competing irported Produd

lndividual sale/RFQ bid

lbs
lbs

both

General descsription of
product(s) nvolved

lbs
lbs

both lost sales and lost revenues

Note

both lost sales nd lost revenues

Note

POI

lndividual sale/RFQ bid

POt

ndividual sate/RFQ bid

POt

slelRFQ bid
bttl

sale/RFQ bid
lndvdual sale/RFQ bid
POr

both lost sales nd lost revenues

both lost sles end lost revenues

lbs

lndividual sale/RFQ bid

lndvdual sale/RFQ bid

both lo6t sales and lost revenues

revenues

Note

lbs

POr

lndivdul sle/RFQ bid

Flanges

lndia/ltaly/Spain

Note

lbs

POI

lndividual sle/RFQ bd

Flanges

lndi/ltlv/Soan

both lost sales and lost revenues

both lost sales and lost revenues
and lost revenues
revenues
both
and lost revenues
both lost sales and lost revenues
both lost sales and lost revenues

Note

lbs

POr

lndividual sale/RFQ bid

Flanges

lnda/ltialy/Spain

lbs

POr

llndividual saler'RFQ bid

Flanges

lndia/ltaty/Spain

lbs

POt

sale/RFQ brd

lbs

POt

lndividual sale/RFQ bid

lbs

both lost sales and lost revenues

both lost sales and lost revenues

Note

.bolh lost seles and lost revenues

revenues

Note

Nofe

lbs

POt
POt

lndvidual sale/RFQ bd
lndvidual sele/RFQ bd

Flenges

iHote t

lbs

POI

lndividuat sale/RFQ bid

Flanqes

both lost sles end tost

revenues

CONFIDENTIAL BUSINESS INFORMATION

lndia/ltalylSpain

CONFIDNTIAL EUSINESS INFORMATION

General tim period (years Generl

Allegion lype (seled "lost sas:, "lol
sale'
Unit for the reported quantity c and/or monts) in which sales of sl (e.9., odividuel
venues", or'hh losi sles ard S
pri:es were conFeci negolations' RFQ bid'
fevenues'-use droP down, se no page Aggregate quantity cfany losl lost sles (e.9., sorllons, feet, were losl and/or
lntemet seles, etc.)
rduced
pounds, etc.)
sales allegatns
for defnitbns)
Method(s) Of Sale
Tmrg
Unt
Quantty (of os{ sas)
Allegation Type
lndividual sale/RFQ bd
POr
lbs
Note 1
both lost sales and lost revenues
descriPtion of metlod

General desriplion of
product(s) nvolved

Product Type(s)

Couny(es) of origin of the

competng imported produci

Subiec{ Country(ies)
lndia/ltaly/Spain

both lost sales and lost revenues

Note

lbs

POt

lndividual sale/RFQ bid

Flanges

lndiaf taly/Span

both lost sales and lost revenues

Note

lbs

POt

lndividual sale/RFO bd

Flanges

lndia/ltaly/Spain

both lost sales and lost revenues

Note

l,o"

Por

lndividual ste/RFO bid

Flnges

lndia/ltaly/Spain

both lost sales and lost revenues

Note

lbs

POt

lndividual sale/RFQ bid

Flanqes

lndia/ltaly/Spain

Nt

lndividual sale/RFQ bid

Flanges

lndiatlY/SDin

Note

lndividual sale/RFQ bd

Flanqes

lndiantaly/Spain

both lst ss and iost revnijs'

lost sds nd lost re\nues

'-'

both lost sales and lost revenues

lbs

POr

lndividual sale/RFQ bid

Flanges

lnda/ltelv/Soan

Flanqes

lndia/ltaly/Spain

both lo'st seles nd lost revenues

Note

lbs

POt

lndividual sale/RFQ bid

both los{ sales and lost revenues

Note

lbs

POr

sale/RFQ bid

both lost sales and lost revenues

Note l

lbs

POt

lndividual sale/RFQ bd

Flanges

lndiantalv/Soain

both lost sales and lost revenues

both lost sales and lost revenues

Note
Note

POr
POt

lndividual saleiRFQ bid

lndividual sele/RFQ bid

Flanges
Flanqes

lndialltaly/Spain

lbs
lbs

both lost sales end lost revenues

Note

lbs

POt

lndlvrdual sale/RFQ bd

Flanqes

lndialltaly/Spn

both lost sales and lost revenues

Note

lbs

POt

lndvidual sale/RFQ bid

Flanqes

lndia/ltaly/Spain

dh

lost sales and lost revenues

Note

lbs

POt

Note
Note
Note

lbs

Por

lbs
lbs
lbs
lbs
lbs
bs

POr

POt

lndividual sle/RFQ
lndividual sale/RFQ
lndvidual sale/RFQ
lndvdual sale/RFQ

bid

both lost sales and lost revenues

both lo6t sales and losi revenues
both lost sales and lost evenues

bid
bid

Flanqes
Flanges
Flanges
Flanqes

POI
POt

lndividual sale/RFQ bd
lndividual sle/RFQ bd
lndvdual sale/RFO bd

Flanqes
Flanges
Flanges

sales and lost

both tost sales ard losl
6or lost sates an lost
bolh loot sales and lost

revenues
revenues

Note't

relenues

Note'l
Note l

revenues

Note

bd

lndialtaly/Spin

lndia/ltalY/Soain
ndia/ltalyrsoain

CONFIDNTIAL BUSINESS INFORMATON

CONFIDNTIAI BUSIN E55 INFORMATION

CONFDNTAL B{JSINE55 INFORMATON

BOLTEX L,OST SALES TENIPLATE

CONFIDENTI/II SUSINESS lN FOMATION

Gontact information.-please identif, the ndMdualthat Commission staffmay contact garding the Lost Sales
and Lost Revenue allegations.
Name

Tifle
Frm
Eml

Telephone

coN FlDEl,tTlAt BUSINESS INFORMATION

Ldn{nGCrton&d

pom|intcF!@
ft moettrif

PFd

salsrloaa

l3t

wllh

lr

rra

loct

safta{ffi

A.

@ca<laoftfrprcflg
coda

Blb:( iiCo.. LP

PUB['C YER$ON

Gl dMiplto dmod
Gnl lim Pcriod (Y6rs
lod
of slo (o.9.. indivrrC sle,
Unit fd ttro Epodd q6w cl nd/d mf,3) in hlc sls
rda5od
rafr oS alrd 9ri re ntad neesttm4 RFQ bid, Gomrdsriptsol
!P olrtl, so niD pr$ Agqrgquadnyofanybl lod sls (c.g. sho b,
produc{s) nnld
lnt6md sal6s, rtcl
rdu6d
fad. ponds. stc.)
selos lgslixs
6rdftifru)

Alogstoni} (ld'1061 6s',

!d: d'o

rtfirf.

lo{n

lndMdual Sales, RFO Bids

lol

2011.

sales ard lol r\renus

15 and 2016 to{at and Neoolatms

RF.9 Bids

L8

2014.2015

'ld

16lodat

Produ

S.b

Unlt

AleodlmTyp.

County(s) of qigin d

npdino impord

ndvitual Sales, RFQ 8'rfs

rnd Naliatons

:ARBON STEEL FTAI'GES

INDI SPAN E |TALY
30TH 4105 & 4694

GARBON SEFL Fl4r-.GS

BOH A105 & A69{

INDIA SPAIN &

ITALT ,.

CARBON STEEL FL,ANGES

INDIA SPAIN & ITALY
BOTH A105 6e4

its sales

eadr

ofrse

lhe years 20f

and 2016 (to date.)
Cormssm wil note,
qnant'tes sold to all
n

haE
dedhed os l
Eoltex b certah ttat
dedne h pllrdtass

thes key
iporl
Fomtt sb.:ct

is die 1o

and ws Boltx
prices d to

redEd

rporl mpltion, the

ha droppd prices
resrtn0 in bol
sas and
loYr,

PUBLIC VERSION

I-13

Subject Finished Carbon Steel Flange lmports by Port (2015-2016.Q1)

lbs.

Port

Spain

tal

5,509

lndia

Italv

5,509

337,225

337,225

428,4r5

390

428,B05

32,I04

32,1.04

4,43r,081

4,431.,O81.

1,629,667

198

5,898,659
L6,396,533

4,180

1,628,866
5,go2,g3g

28,7:99

490,892

16,91.5,723

629,LO6

629,1,06

101,902

101,902

25,243

18,I82

14,834
27,240,697

373,090
5,620,518

t34,912,236

Laredo, TX

347,847
5,59L,503
73,226,958
1,526

8,579

Los Angeles, CA

Anchorage, AK
Baltimore, MD
Boston, MA
Buffalo, NY
Charleston, SC
Charlotte, NC

Chicago, lL
Clevela n

'

Clumbia-Snake, OR
Dallas-Fort Worth, TX

Detroit, Ml
Great Falls, MT
Houston-Galveston, TX

r.3,253,909

34,504,580
7,053
L,453,35g

1,300,331

L6,007,598

FL

507,007

9,764

t,1_42

5r7,91,4

Minneapolis, MN
New Orleans, LA
New York, NY
Norfolk, VA
Ogdensburg, NY

1,819

L,81"9

,284

73r;1,41"

2,81,4,625

9,479,672
4,013,286

182,556

9,662,228
4,0L3,290

Miami,

Pembina,.ND

125,335
0

Philadelphia, PA
San Juan, PR

Savannah, GA

Seattl, WA

44,350
258,031
136

338,603
85,760
20,824,792

San Francisco, CA

48,438..
0
0

440,948

594,884

7,96L

FL

Total
Ports Where all 3 Presen

3,544,526
335,290
767,532,775
!29,926,O37

2!,860,624

38,L16,t23

29,695,!78

36,713,L62

29t687,2t7

196,326,4L5

Share of Total lmpo

Source: USTIC dataweb.

44,35O

'_ 431,803
363,136
338,603
85,760
3,926,966
3,552,487
335,290
235,344,076

3,g2O,O7O

St. Louis, MO

Iampa,

83.4%

r-14

CONTAINS BUSIN ESS PROP RIETARY INFORMATION

Volume and Value of Shipments for Selected Garbon SteelFlange ltem

2013

Pices
1Q

2Q
3Q

2014

1Q

I
t
I
t
t
t
t

2Q
3Q

I
t

4Q
1Q

2Q
3Q

2015

2016

4Q

40
1Q

Price

t
t

I
I

Source:Weldbend and Boltex for:

Standard 4-inch flange, weld-neck, raised face, 150-pound pressure grade

PUBLIC VERSION

r-15

PETTTTONERS ACC9IJNT,FOR MORE THAN s0% OF,TOTAL U.S. PRODUCTION

As set forth in the affictavits at Exhibit I-2 of these petitions, there are no published data
on finished carbon steel flange production in the Unitecl States. However, the presidents of both

Petitioners submit that, cornbinecl, they constitute well over 50% of total U.S, production of
finished carbon steel flanges (including in 2015). $es alss, Exhibit I-2. To demonstrate that

'

fact, at Exhibit I-15-4, we provide an affidavit ftom the president of Boltex, where he calculates

total 2015 U.S. flange forging production plus imports, Because all finished flanges come from
flange forgings, and because all flange forgings are used to make finished flanges, total U.S.

production plus total U.S. imports of flange forgings is a reasonable substitute for finished
carbon steel flanges, As detailed in that affidavit, total 2015 flange forgings produced, as well as
importecl, in the United States was

] pounds. As set forth in the Boltex affidavit at

Exhibit I-15-4, Boltex's 2015 finishecl carbon steel flange production quantity was [
poun<ls. As set forth in the Weldbend affidavit at

calbon steel flange production quantity was

Exhibit I-L5-8, Weldbend's 2015 finished

] pounds, As such, combined,

Weldbend and Boltex's 2015 production of finishecl flanges was

] pouncls'

Therefore, using flange forgings production and imports as the denominator in calculating total
U.S. production, Weldbqnd and Boltex accounted fbr
steel flange production in 2015

([

] percent of total U.S. finished carbon

]).

As noted in Exhibt I-15-4, the total 2015 production of flange forgings figure of

pounds was alculated using Ameri-Forge's estimated actual rocluotiqli, If one

were to use its estimatcd, theoretical production capacily, the 2015 flange forging number
increases to

I pounds. If that number is used, Weldbend and Boltex accounted for

I percent of total U,S. prod,uction in 2015

([

])'

"t20871402

PUBLIC VERSION

In shofi, clearly, Weldbend and Boltex account for well over

production offinished carbon steel flanges.

72087 1402

500%

of total 2015

I-L5-A

DECLARA1'IqN OF trIlANK BEINOIICH OF |OLTIIX MFG. CO.. L.P,

I, Frank Bernobich, president and chairman of tlie board of Boltex Mfg. Co., I,,P'
("Boltex") (a Petitioner in ths action), heleby csrtify and affirm as follows:
I

.l

Boltex began as a flange rnachining opelation ih 1989, and started forging its own
line of flanges in 1996.
I have been with lloltex since its inception, ancl includillg my time at Boltex,I
have over 3,9 years of experieuce irl the carbon steel flanges business'
During my iaknost four decacles in the carbon stecl flangcs business, I have visitecl
the facilities of severai otlrer domesic producers of finished carbon steel flanges,
ancl have,visited foreign producels of the product in ltaly, India, Germany and

France.
4,
5

o.
,1

8.

r0.

The uumbcr of Il,S. companies proclucing finished carbon steel flanges is quitc
surall, and these companies ale well-known to those in the industry.
To my knowledge, there is no public information on U.S. production capacity or
output offinished carbon steel flanges.
l:fowever, in 201 5, Boltex produced
I pound of finishecl,
A finished flange first stas with a flange forgig, As such, all finished flanges
produced in the tjnited States start out as a flattge fbrging. Accordingly, the
number of flange forgings produced/imported into the {Jnited States in a given
year is a r:eliable and reasonable substitute lbr domestic fnished flange

procluction.
In the Unitecl States, there are only three meaningful sources of suppiy for flange
forgings consumed in the lJnited States: imported flange forgings (under HTSUS
7307 .91.10,00), flange forgings producecl by Boltex, and flange forgings
produccd'by a ompany called Ameri-Forge Corporatiotr ("Amer-lorge"), which
is locatd al13770Idustrial Rd, Flouston,TX77015, I am not aware of any
other clomestic producels of flange forgings that sell in any meaningful quanities,
In 201 5, Roltex produced
1 pounds of fanges forgings.
At Attaclrrnent A hereto are 2015 U.S. irnport stalistics for HTSUS
7307 .91,l0;00. 'l'he total kilograrns of flange forgings imported into the United
Statcs wus 16,47V,956 kilograms (which equals 36,316,652 pounds)' As such,
between Boltcx and irnports, the total pounds of flange forgings
prodr.ree<i/importecl into the United States in 2015 was
l. The missing
quantity is that from Amei-f olge.
An:eri-Forge does not publish its production, sales ol capacity data. I'lowever, it
is also located in Flouston, "l'exas (where Bollex is located), and their production
lacility is conliguous to that of 3oltex's production facility.
As his is:a ,smali industty, I am very familiar lVith Amcri-Forge, their operations,

ll.
12.

l3

and their ecluiprr:ent.

With my decades-long experience in tlte flange industry, being located in
Houston, my first-hand observatious of Anleri-l;'orge's opertions over the yeals,
and my understanding of tlreir procluction equipment, I reasonably eslimate that
Araeri-rorge's 2015 theoretical flange f'orging production capacity rvould have
been approximately 7,000,000 pounds. I'lowevcr, this capacity figure assunles

72086091.t

PUBLIC VERSION

t4,

full operational production (20 hours a day/6 days a week), Considering the
current domestic nTarketplace in terms of impor-ted finished carbon steel fanges
and demand, I eslimate lhat, at most, Ameri-Forge could have produced
approximately I ;400,000 pounds of forgings in the United States in 20 I 5,
In short, my best and rnost reasonable calculation of the quantity of flange
,] pounds (Boltex's
forgings consumed n the United States in 2015 is
aclual procluctiorr + actual imports + estimated Anreri-Forge ctual production).
Because flange forgings can only be used to produce fnishcd flanges, I believe
that tcltal lU:.S. prociLrction of finished carbon steel flanges in 2015 was, at ntost,

15.

] pounds.

I declare that all statenents made above are true and corect.

la

3c -

Zo/

Date

7208l09r,r

PUBLC VERSION

ATTACHMEI{T A

7307911000: tirst Unit of Quantity BY Quantity Description AND BY Frst Unit of Quantity Annual Data

2015

country KG

Short Tons

Italy

gro77,L7g

9,903

China

4:r!g!,89L

4,621

Spain

L:,269,924

1.,400

lndia
Germany

t,1v2,388

7,292
763

Korea

'691,783
529,793

Canaba

199,753

2t9

Mexico

'tt4,2gg

126

Turkey
lsrael
Taiwan

54,720

56

, 47,359

584

52

4r,087

45

Japan

35,74L

39

Argentina

33,597

37

United Kin
Thailand
Malaysia

7,506
2,2L9

I
2

1,986

Czech Rept

1,965

Denmark
Unted Ara

1,813

854

Romania
France

s72

t
0

Belarus
Sweden

297

Netherla nd

108

59

s0

Uruguay
Austria
Poland

Total

26

L6,472,956

18,158

'I

r-1-5-B

DECLARATION
In

0r

JAMES J. COULAS JR. OJ:WELDBEND CORPORATION

rr)/eldbend Corporation (a Petitioner in this

James J. Coulas, Jr, owner and president of

action), hereby certi$ and affirm as follows:

Whereas,

l.
2.
3.
4,

My parents:stafed r/eldbend Corporation ("Weldbend") back in the late 1940's,

and the cornpany has grown to become one of the largest, if not the largest,
manufacturer of finished carbon steel flanges in the United States.
I began woking for the family business in 1967, and lave thus been in the carbon
steel flanges business for over 49 years.
Weldbend purchases flange forgings that it manufactures into finished flanges. In
the United States, there are realistically only three sources of supply for llange
forgings * those produced by Boltex Mfg, Co., L.P., those produced by AmeriForge Coporation, and flange forgings that were imported from overseas.
In 2015, Weldbend produced
lpounds of fitished flanges'

I declare that all statements made above are true and correct.

June 29, 201,6

Date

720812 L

las,

PUBLIC VERSION