MESSAGE NO: 9224111 DATE: 08 12 1999
CATEGORY: CVD TYPE: ORD
REFERENCE: REFERENCE DATE:
CASES: C - 427 - 815 C - 475 - 825
C - 580 - 835 - -
- - - -

PERIOD COVERED: 08 06 1999 TO

LIQ SUSPENSION DATE:

TO: DIRECTORS OF FIELD OPERATIONS
PORT DIRECTORS

FROM: DIRECTOR, TRADE ENFORCEMENT & CONTROL

RE: COUNTERVAILING DUTY ORDERS IN THE INVESTIGATIONS OF
STAINLESS STEEL SHEET & STRIP IN COILS FROM FRANCE (C-427-
815) ITALY (C-475-835) & KOREA (C-580-835)

1. ON AUGUST 6, 1999, THE DEPARTMENT OF COMMERCE PUBLISHED IN
THE FEDERAL REGISTER ITS AMENDED FINAL DETERMINATION IN THE
INVESTIGATION OF STAINLESS STEEL SHEET AND STRIP IN COIL
FROM THE REPUBLIC OF KOREA ("KOREA") AND THE COUNTERVAILING
DUTY ORDERS IN THE INVESTIGATIONS OF STAINLESS STEEL SHEET
AND STRIP IN COILS FROM FRANCE, ITALY, AND KOREA.

2. FOR PURPOSES OF THESE INVESTIGATIONS, THE PRODUCTS COVERED
BY THESE ORDERS 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.

THE MERCHANDISE SUBJECT TO THESE ORDERS IS CLASSIFIED IN THE
HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES ("HTSUS") AT
THE FOLLOWING SUBHEADINGS:

7219.13.00.30, 7219.13.00.50, 7219.13.00.70, 7219.13.00.80,
7219.14.00.30, 7219.14.00.65, 7219.14.00.90, 7219.32.00.05,
7219.32.00.20, 7219.32.00.25, 7219.32.00.35, 7219.32.00.36,
7219.32.00.38, 7219.32.00.42, 7219.32.00.44, 7219.33.00.05,
7219.33.00.20, 7219.33.00.25, 7219.33.00.35, 7219.33.00.36,
7219.33.00.38, 7219.33.00.42, 7219.33.00.44, 7219.34.00.05,
7219.34.00.20, 7219.34.00.25, 7219.34.00.30, 7219.34.00.35,
7219.35.00.05, 7219.35.00.15, 7219.35.00.30, 7219.35.00.35,
7219.90.00.10, 7219.90.00.20, 7219.90.00.25, 7219.90.00.60,
7219.90.00.80, 7220.12.10.00, 7220.12.50.00, 7220.20.10.10,
7220.20.10.15, 7220.20.10.60, 7220.20.10.80, 7220.20.60.05,
7220.20.60.10, 7220.20.60.15, 7220.20.60.60, 7220.20.60.80,
7220.20.70.05, 7220.20.70.10, 7220.20.70.15, 7220.20.70.60,
7220.20.70.80, 7220.20.80.00, 7220.20.90.30, 7220.20.90.60,
7220.90.00.10, 7220.90.00.15, 7220.90.00.60, AND
7220.90.00.80.

ALTHOUGH THE HTSUS SUBHEADINGS ARE PROVIDED FOR CONVENIENCE
AND CUSTOMS PURPOSES, COMMERCE'S WRITTEN DESCRIPTION OF THE
MERCHANDISE COVERED BY THESE ORDERS IS DISPOSITIVE.

EXCLUDED FROM THE SCOPE OF THESE ORDERS 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, COMMERCE
DETERMINED THAT CERTAIN SPECIALTY STAINLESS STEEL PRODUCTS
ARE ALSO EXCLUDED FROM THE SCOPE OF THESE ORDERS. 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 THESE ORDERS.
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
LESS THAN 0.002 OR GREATER THAN 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 THESE ORDERS. 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 THESE ORDERS. 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 THESE ORDERS. 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 THESE
ORDERS. 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 AISI
GRADE 420 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 100 SQUARE MICRONS. 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 THESE CASES HAVE BEEN
ASSIGNED INVESTIGATION NUMBERS C-427-815 (FRANCE), C-475-825
(ITALY), AND C-580-835 (KOREA).

4. FOR IMPORTS OF STAINLESS STEEL SHEET AND STRIP IN COILS FROM
FRANCE, ITALY, AND KOREA, THE CUSTOMS SERVICE SHALL SUSPEND
LIQUIDATION OF SUCH SHIPMENTS ENTERED OR WITHDRAWN FROM
WAREHOUSE, FOR CONSUMPTION ON OR AFTER AUGUST 6, 1999.
EFFECTIVE AUGUST 6, 1999, CUSTOMS SHALL REQUIRE CASH
DEPOSITS EQUAL TO THE SUBSIDY RATES SHOWN BELOW:

MFR/PRODUCER CUSTOMS ID AD VALOREM RATE

FRANCE:
USINOR C-427-815-001 5.38 PERCENT
ALL OTHERS C-427-815-000 5.38 PERCENT

ITALY:
ACCIAI SPECIALI TERNI C-475-825-001 12.22 PERCENT
ARINOX C-475-825-002 1.03 PERCENT
ALL OTHERS C-475-825-000 12.09 PERCENT

KOREA:
INCHON C-580-835-002 2.65 PERCENT
DAI YANG C-580-835-003 1.58 PERCENT
TAIHAN C-580-835-004 7.00 PERCENT
SAMMI C-580-835-005 59.30 PERCENT
ALL OTHERS C-580-835-000 1.68 PERCENT
POSCO C-580-835-001 EXCLUDED

COMMERCE HAS DETERMINED THAT THE NET COUNTERVAILABLE SUBSIDY
RATE FOR POSCO (C-580-835-001)IN THE KOREAN INVESTIGATION IS
0.65 PERCENT AD VALOREM, WHICH IS DE MINIMIS. THEREFORE,
POSCO IS EXCLUDED FROM THE ORDER ON SUBJECT MERCHANDISE FROM
KOREA. CUSTOMS SHOULD NOT SUSPEND LIQUIDATION ON ENTRIES OF
MERCHANDISE FROM POSCO.

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 MARIAN WELLS (FRANCE),
CYNTHIA THIRUMALAI (ITALY), AND EVA TEMKIN (KOREA), OFFICE
OF AD/CVD ENFORCEMENT, IMPORT ADMINISTRATION, INTERNATIONAL
TRADE ADMINISTRATION, U.S. DEPARTMENT OF COMMERCE, AT (202)
482-6309, (202) 482-4087, AND (202) 482-1167, RESPECTIVELY.

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


PAUL SCHWARTZ