On June 3, 2014 the U.S. Department of Commerce (DOC) and U.S. International Trade Commission (ITC) received an antidumping and countervailing duty (CVD) petition alleging certain passenger vehicle and light truck tires produced in China were unfairly competing with domestically produced tires. In response, an investigation was opened by the DOC and ITC and several parties submitted comments particularly regarding the scope of the pending investigation.  

The trailer industry was instantly concerned with the scope issue for several reasons. Since specialty trailer (ST) tires are not vastly produced in the U.S., as opposed to the massive number of passenger ‘P’ and light truck ‘LT’ tires produced in the U.S., Chinese ST tires are not competing with domestic products. Further, the scope expansion request submitted by the petitioner could possibly have captured certain types of ST tires that would have otherwise been excluded from any ensuing antidumping or countervailing duties which are assessed by U.S. Customs and Border Protection.

Comments submitted by NATM and RVIA, as well as other interested parties, included requests to exclude ST tires given that certain sidewall markings were present to clearly identify the tires as ST tires and to prevent confusion with P and LT tires. The petitioner responded, agreeing with NATM that such tires should be excluded, and outlined five characteristics that must be present in order for such an exclusion to occur. As of November 24, 2014, the DOC has preliminarily agreed with the petitioners’ response. The five scope exclusion characteristics for ST tires are as follows;

1. The size designation molded on the tire’s sidewall is listed in the ST sections of the Tire and Rim Association Year Book;

2. The designation “ST” is molded into the tire’s sidewall as part of the size designation;

3. The tire incorporates a warning, prominently molded on the sidewall, that the tire is “For Trailer Service Only” or “For Trailer Use Only;”

4. The load index molded on the tire’s sidewall meets or exceeds those load indexes listed in the Tire and Rim Association Year Book for the relevant ST tire size; and

5. The tire’s speed rating is molded on the sidewall, indicating the rated speed in MPH or a letter rating as listed by TRA, and the rated speed does not exceed 81 MPH or an “M” rating.

The DOC has yet to issue a preliminary antidumping duty determination. Currently the DOC is set to make a final determination on the antidumping and countervailing duty on April 6, 2015.

For more information on this topic, please contact NATMHQ@natm.com