MESSAGE NO: 9021116 DATE: 01 21 1999
CATEGORY: ADA TYPE: PRE
REFERENCE: REFERENCE DATE:
CASES: A - 428 - 825 - -
- - - -
- - - -

PERIOD COVERED: 01 04 1999 TO

LIQ SUSPENSION DATE:

TO: CMC DIRECTORS,
PORT DIRECTORS

FROM: DIRECTOR, IMPORT OPERATIONS

RE: NOTICE OF PRELIMINARY DETERMINATION IN AN ANTIDUMPING DUTY
INVESTIGATION OF STAINLESS STEEL SHEET & STRIP IN COILS
FROM GERMANY (A-428-825)

1. ON 01/04/1999, THE DEPARTMENT OF COMMERCE PUBLISHED IN THE
FEDERAL REGISTER (64 FR 92) ITS PRELIMINARY DETERMINATION OF
SALES AT LESS THAN FAIR VALUE AND THE POSTPONEMENT OF THE
FINAL DETERMINATION IN THE ANTIDUMPING DUTY INVESTIGATION OF
STAINLESS STEEL SHEET AND STRIP IN COILS FROM GERMANY.

2.
FOR PURPOSES OF THIS INVESTIGATION, THE PRODUCTS COVERED ARE
CERTAIN STAINLESS STEEL SHEET AND STRIP IN COILS. STAINLESS
STEEL IS AN ALLOY STEEL CONTAINING, BY WEIGHT, 1.2 PERCENT
OR LESS OF CARBON AND 10.5 PERCENT OR MORE OF CHROMIUM, WITH
OR WITHOUT OTHER ELEMENTS. THE SUBJECT SHEET AND STRIP IS A
FLAT-ROLLED PRODUCT IN COILS THAT IS GREATER THAN 9.5 MM IN
WIDTH AND LESS THAN 4.75 MM IN THICKNESS, AND THAT IS
ANNEALED OR OTHERWISE HEAT TREATED AND PICKLED OR OTHERWISE
DESCALED. THE SUBJECT SHEET AND STRIP MAY ALSO BE FURTHER
PROCESSED (E.G., COLD-ROLLED, POLISHED, ALUMINIZED, COATED,
ETC.) PROVIDED THAT IT MAINTAINS THE SPECIFIC DIMENSIONS OF
SHEET AND STRIP FOLLOWING SUCH PROCESSING.

EXCLUDED FROM THE SCOPE OF THIS INVESTIGATION ARE THE
FOLLOWING: (1) SHEET AND STRIP THAT IS NOT ANNEALED OR
OTHERWISE HEAT TREATED AND PICKLED OR OTHERWISE DESCALED,
(2) SHEET AND STRIP THAT IS CUT TO LENGTH, (3) PLATE (I.E.,
FLAT-ROLLED STAINLESS STEEL PRODUCTS OF A THICKNESS OF 4.75
MM OR MORE), (4) FLAT WIRE (I.E., COLD-ROLLED SECTIONS,
WITH A PREPARED EDGE, RECTANGULAR IN SHAPE, OF A WIDTH OF
NOT MORE THAN 9.5 MM), AND (5) RAZOR BLADE STEEL. RAZOR
BLADE STEEL IS A FLAT-ROLLED PRODUCT OF STAINLESS STEEL, NOT
FURTHER WORKED THAN COLD-ROLLED (COLD-REDUCED), IN COILS, OF
A WIDTH OF NOT MORE THAN 23 MM AND A THICKNESS OF 0.266 MM
OR LESS, CONTAINING, BY WEIGHT, 12.5 TO 14.5 PERCENT
CHROMIUM, AND CERTIFIED AT THE TIME OF ENTRY TO BE USED IN
THE MANUFACTURE OF RAZOR BLADES. SEE CHAPTER 72 OF THE
HTSUS, "ADDITIONAL U.S. NOTE" 1(D).

IN RESPONSE TO COMMENTS BY INTERESTED PARTIES THE DEPARTMENT
HAS DETERMINED THAT CERTAIN SPECIALTY STAINLESS STEEL
PRODUCTS ARE ALSO EXCLUDED FROM THE SCOPE OF THIS
INVESTIGATION. THESE EXCLUDED PRODUCTS ARE DESCRIBED BELOW:
FLAPPER VALVE STEEL IS DEFINED AS STAINLESS STEEL STRIP IN
COILS CONTAINING, BY WEIGHT, BETWEEN 0.37 AND 0.43 PERCENT
CARBON, BETWEEN 1.15 AND 1.35 PERCENT MOLYBDENUM, AND
BETWEEN 0.20 AND 0.80 PERCENT MANGANESE. THIS STEEL ALSO
CONTAINS, BY WEIGHT, PHOSPHORUS OF 0.025 PERCENT OR LESS,
SILICON OF BETWEEN 0.20 AND 0.50 PERCENT, AND SULFUR OF
0.020 PERCENT OR LESS. THE PRODUCT IS MANUFACTURED BY MEANS
OF VACUUM ARC REMELTING, WITH INCLUSION CONTROLS FOR
SULPHIDE OF NO MORE THAN 0.04 PERCENT AND FOR OXIDE OF NO
MORE THAN 0.05 PERCENT. FLAPPER VALVE STEEL HAS A TENSILE
STRENGTH OF BETWEEN 210 AND 300 KSI, YIELD STRENGTH OF
BETWEEN 170 AND 270 KSI, PLUS OR MINUS 8 KSI, AND A HARDNESS
(HV) OF BETWEEN 460 AND 590. FLAPPER VALVE STEEL IS MOST
COMMONLY USED TO PRODUCE SPECIALTY FLAPPER VALVES IN
COMPRESSORS.

ALSO EXCLUDED IS A PRODUCT REFERRED TO AS SUSPENSION FOIL, A
SPECIALTY STEEL PRODUCT USED IN THE MANUFACTURE OF
SUSPENSION ASSEMBLIES FOR COMPUTER DISK DRIVES. SUSPENSION
FOIL IS DESCRIBED AS 302/304 GRADE OR 202 GRADE STAINLESS
STEEL OF A THICKNESS BETWEEN 14 AND 127 MICRONS, WITH A
THICKNESS TOLERANCE OF PLUS-OR-MINUS 2.01 MICRONS, AND
SURFACE GLOSSINESS OF 200 TO 700 PERCENT GS. SUSPENSION
FOIL MUST BE SUPPLIED IN COIL WIDTHS OF NOT MORE THAN 407
MM, AND WITH A MASS OF 225 KG OR LESS. ROLL MARKS MAY ONLY
BE VISIBLE ON ONE SIDE, WITH NO SCRATCHES OF MEASURABLE
DEPTH. THE MATERIAL MUST EXHIBIT RESIDUAL STRESSES OF 2 MM
MAXIMUM DEFLECTION, AND FLATNESS OF 1.6 MM OVER 685 MM
LENGTH.

CERTAIN STAINLESS STEEL FOIL FOR AUTOMOTIVE CATALYTIC
CONVERTERS IS ALSO EXCLUDED FROM THE SCOPE OF THIS
INVESTIGATION. THIS STAINLESS STEEL STRIP IN COILS IS A
SPECIALTY FOIL WITH A THICKNESS OF BETWEEN 20 AND 110
MICRONS USED TO PRODUCE A METALLIC SUBSTRATE WITH A
HONEYCOMB STRUCTURE FOR USE IN AUTOMOTIVE CATALYTIC
CONVERTERS. THE STEEL CONTAINS, BY WEIGHT, CARBON OF NO
MORE THAN 0.030 PERCENT, SILICON OF NO MORE THAN 1.0
PERCENT, MANGANESE OF NO MORE THAN 1.0 PERCENT, CHROMIUM OF
BETWEEN 19 AND 22 PERCENT, ALUMINUM OF NO LESS THAN 5.0
PERCENT, PHOSPHORUS OF NO MORE THAN 0.045 PERCENT, SULFUR OF
NO MORE THAN 0.03 PERCENT, LANTHANUM OF BETWEEN 0.002 AND
0.05 PERCENT, AND TOTAL RARE EARTH ELEMENTS OF MORE THAN
0.06 PERCENT, WITH THE BALANCE IRON.

PERMANENT MAGNET IRON-CHROMIUM-COBALT ALLOY STAINLESS STRIP
IS ALSO EXCLUDED FROM THE SCOPE OF THIS INVESTIGATION. THIS
DUCTILE STAINLESS STEEL STRIP CONTAINS, BY WEIGHT, 26 TO 30
PERCENT CHROMIUM, AND 7 TO 10 PERCENT COBALT, WITH THE
REMAINDER OF IRON, IN WIDTHS 228.6 MM OR LESS, AND A
THICKNESS BETWEEN 0.127 AND 1.270 MM. IT EXHIBITS MAGNETIC
REMANENCE BETWEEN 9,000 AND 12,000 GAUSS, AND A COERCIVITY
OF BETWEEN 50 AND 300 OERSTEDS. THIS PRODUCT IS MOST
COMMONLY USED IN ELECTRONIC SENSORS AND IS CURRENTLY
AVAILABLE UNDER PROPRIETARY TRADE NAMES SUCH AS "ARNOKROME
III" (ARNOKROME III IS A TRADEMARK OF THE ARNOLD ENGINEERING
COMPANY).

CERTAIN ELECTRICAL RESISTANCE ALLOY STEEL IS ALSO EXCLUDED
FROM THE SCOPE OF THIS INVESTIGATION. THIS PRODUCT IS
DEFINED AS A NON-MAGNETIC STAINLESS STEEL MANUFACTURED TO
AMERICAN SOCIETY OF TESTING AND MATERIALS (ASTM)
SPECIFICATION B344 AND CONTAINING, BY WEIGHT, 36 PERCENT
NICKEL, 18 PERCENT CHROMIUM, AND 46 PERCENT IRON, AND IS
MOST NOTABLE FOR ITS RESISTANCE TO HIGH TEMPERATURE
CORROSION. IT HAS A MELTING POINT OF 1390 DEGREES CELSIUS
AND DISPLAYS A CREEP RUPTURE LIMIT OF 4 KILOGRAMS PER SQUARE
MILLIMETER AT 1000 DEGREES CELSIUS. THIS STEEL IS MOST
COMMONLY USED IN THE PRODUCTION OF HEATING RIBBONS FOR
CIRCUIT BREAKERS AND INDUSTRIAL FURNACES, AND IN RHEOSTATS
FOR RAILWAY LOCOMOTIVES. THE PRODUCT IS CURRENTLY AVAILABLE
UNDER PROPRIETARY TRADE NAMES SUCH AS "GILPHY 36" ("GILPHY
36" IS A TRADEMARK OF IMPHY, S.A.).

CERTAIN MARTENSITIC PRECIPITATION-HARDENABLE STAINLESS STEEL
IS ALSO EXCLUDED FROM THE SCOPE OF THIS INVESTIGATION. THIS
HIGH-STRENGTH, DUCTILE STAINLESS STEEL PRODUCT IS DESIGNATED
UNDER THE UNIFIED NUMBERING SYSTEM (UNS) AS S45500-GRADE
STEEL, AND CONTAINS, BY WEIGHT, 11 TO 13 PERCENT CHROMIUM,
AND 7 TO 10 PERCENT NICKEL. CARBON, MANGANESE, SILICON AND
MOLYBDENUM EACH COMPRISE, BY WEIGHT, 0.05 PERCENT OR LESS,
WITH PHOSPHORUS AND SULFUR EACH COMPRISING, BY WEIGHT, 0.03
PERCENT OR LESS. THIS STEEL HAS COPPER, NIOBIUM, AND
TITANIUM ADDED TO ACHIEVE AGING, AND WILL EXHIBIT YIELD
STRENGTHS AS HIGH AS 1700 MPA AND ULTIMATE TENSILE STRENGTHS
AS HIGH AS 1750 MPA AFTER AGING, WITH ELONGATION PERCENTAGES
OF 3 PERCENT OR LESS IN 50 MM. IT IS GENERALLY PROVIDED IN
THICKNESSES BETWEEN 0.635 AND 0.787 MM, AND IN WIDTHS OF
25.4 MM. THIS PRODUCT IS MOST COMMONLY USED IN THE
MANUFACTURE OF TELEVISION TUBES AND IS CURRENTLY AVAILABLE
UNDER PROPRIETARY TRADE NAMES SUCH AS "DURPHYNOX 17" ("
DURPHYNOX 17" IS A TRADEMARK OF IMPHY, S.A.).

FINALLY, THREE SPECIALTY STAINLESS STEELS TYPICALLY USED IN
CERTAIN INDUSTRIAL BLADES AND SURGICAL AND MEDICAL
INSTRUMENTS ARE ALSO EXCLUDED FROM THE SCOPE OF THIS
INVESTIGATION. THESE INCLUDE STAINLESS STEEL STRIP IN COILS
USED IN THE PRODUCTION OF TEXTILE CUTTING TOOLS (E.G.,
CARPET KNIVES). THIS LIST OF USES IS ILLUSTRATIVE AND
PROVIDED FOR DESCRIPTIVE PURPOSES ONLY. THIS STEEL IS
SIMILAR TO ASTM GRADE 440F, BUT CONTAINING, BY WEIGHT, 0.5
TO 0.7 PERCENT OF MOLYBDENUM. THE STEEL ALSO CONTAINS, BY
WEIGHT, CARBON OF BETWEEN 1.0 AND 1.1 PERCENT, SULFUR OF
0.020 PERCENT OR LESS, AND INCLUDES BETWEEN 0.20 AND 0.30
PERCENT COPPER AND BETWEEN 0.20 AND 0.50 PERCENT COBALT.
THIS STEEL IS SOLD UNDER PROPRIETARY NAMES SUCH AS "GIN4 MO."
THE SECOND EXCLUDED STAINLESS STEEL STRIP IN COILS IS
SIMILAR TO AISI 420-J2 AND CONTAINS, BY WEIGHT, CARBON OF
BETWEEN 0.62 AND 0.70 PERCENT, SILICON OF BETWEEN 0.20 AND
0.50 PERCENT, MANGANESE OF BETWEEN 0.45 AND 0.80 PERCENT,
PHOSPHORUS OF NO MORE THAN 0.025 PERCENT AND SULFUR OF NO
MORE THAN 0.020 PERCENT. THIS STEEL HAS A CARBIDE DENSITY
ON AVERAGE OF 100 CARBIDE PARTICLES PER SQUARE MICRON. AN
EXAMPLE OF THIS PRODUCT IS "GIN5" STEEL. THE THIRD
SPECIALTY STEEL HAS A CHEMICAL COMPOSITION SIMILAR TO AISI
420 F, WITH CARBON OF BETWEEN 0.37 AND 0.43 PERCENT,
MOLYBDENUM OF BETWEEN 1.15 AND 1.35 PERCENT, BUT LOWER
MANGANESE OF BETWEEN 0.20 AND 0.80 PERCENT, PHOSPHORUS OF NO
MORE THAN 0.025 PERCENT, SILICON OF BETWEEN 0.20 AND 0.50
PERCENT, AND SULFUR OF NO MORE THAN 0.020 PERCENT.
THIS PRODUCT IS SUPPLIED WITH A HARDNESS OF MORE THAN HV 500
GUARANTEED AFTER CUSTOMER PROCESSING, AND IS SUPPLIED AS,
FOR EXAMPLE, "GIN6" ("GIN4 MO," "GIN5" AND "GIN6" ARE THE
PROPRIETARY GRADES OF HITACHI METALS AMERICA, LTD.).

3. FOR FURTHER REPORTING PURPOSES THIS CASE HAS BEEN ASSIGNED
INVESTIGATION NUMBER A-428-825.

4. BECAUSE CRITICAL CIRCUMSTANCES EXIST FOR IMPORTS OF
STAINLESS STEEL SHEET AND STRIP IN COILS FROM GERMANY FROM
KRUPP THYSSEN NIROSTA GMBH (AND FROM ALL OTHER MFRS
/EXPORTERS/PRODUCERS), THE CUSTOMS SERVICE SHALL SUSPEND
LIQUIDATION OF SUCH SHIPMENTS ENTERED OR WITHDRAWN FROM
WAREHOUSE, FOR CONSUMPTION ON OR AFTER 10/06/1998, WHICH IS
90 DAYS PRIOR TO THE DATE OF PUBLICATION OF THE PRELIMINARY
DETERMINATION IN THE FEDERAL REGISTER. EFFECTIVE 10/06/1998
, FOR SUCH ENTRIES, CUSTOMS SHALL REQUIRE A CASH DEPOSIT OR
THE POSTING OF A BOND EQUAL TO THE MARGINS SHOWN BELOW:

MFR/PRODUCER CUSTOMS ID MARGIN PERCENTAGE
EXPORTER NUMBER

KRUPP THYSSEN NIROSTA
GMBH A-428-825-001 21.34
ALL OTHERS A-428-825-000 21.34


5. IF THERE ARE ANY QUESTIONS REGARDING THIS MATTER BY CUSTOMS
OFFICERS, PLEASE CONTACT, VIA E-MAIL, THROUGH THE
APPROPRIATE SUPERVISORY CHANNELS, OTHER GOVERNMENT AGENCY
LIAISON, USING THE ATTRIBUTE "HQ OAB." THE IMPORTING PUBLIC
AND OTHER INTERESTED PARTIES SHOULD CONTACT STEPHANIE ARTHUR
OR CHARLES RANADO, OFFICE OF AD/CVD ENFORCEMENT, IMPORT
ADMINISTRATION, INTERNATIONAL TRADE ADMINISTRATION, U.S.
DEPARTMENT OF COMMERCE, AT (202) 482-6312 OR 3518,
RESPECTIVELY.

6. THERE ARE NO RESTRICTIONS ON THE RELEASE OF THIS
INFORMATION.



PAUL SCHWARTZ