UNITED STATES COURT OF INTERNATIONAL TRADE

Slip Op. 25-20

Before the Court in Precision Components, Inc., v. United States, Court No.23-00218 Slip Op. 25-20 (February 25, 2025) was a challenge to the final scope ruling of the United States Department of Commerce regarding certain low-carbon steel blanks imported from the People’s Republic of China by plaintiff. The final scope ruling found that the merchandise, low-carbon steel blanks, was covered by the antidumping duty order on tapered roller bearings, including finished and unfinished parts thereof, from China. Commerce’s final scope decision was based on its consideration of interpretive sources specified by 19 C.F.R. 351.225(k)(1), including a 2020 scope ruling regarding steel blanks imported by Precision.

The issue turned on Commerce’s alleged failure to reach a decision regarding the merchandise that is supported by substantial evidence and otherwise in accordance with law. The plaintiff moved for judgment on the agency record and asked the court to remand proceedings to Commerce. The question in the case was whether Commerce’s determination in the 2023 Scope Ruling that Precision Inc.’s low-carbon steel blanks fell within the written description of the scope: “tapered roller bearings and parts thereof, finished and unfinished,” and whether this ruling was supported by substantial evidence and otherwise in accordance with law. The plain meaning of an antidumping order is a question of law, while the question of whether certain merchandise falls within the scope of such an order is a question of fact reviewed for substantial evidence. The Court of International Trade disagreed with plaintiff’s argument and upheld Commerce’s final ruling.

The Court agreed with the government that the final scope ruling was supported by substantial evidence given it was reasonable for the agency to conclude that the merchandise in question was within the scope of the Order based on a plain-language reading of the Order. Because steel composition is absent from the written description of the Order, the Court held that it was correct for Commerce to decline to consider Precision’s comments relating to steel grade when evaluating the language of the Order. The Court agreed with the agency’s reasoning that to find the merchandise within the scope the decisive interpretive question was whether “low-carbon steel blanks” were “unfinished TRB parts.” The Court found that Commerce correctly used the interpretative sources under 19 C.F.R. 351.225(k)(1), relying upon the plain language of the Order and the 2020 Scope Ruling, which under the regulation was considered a valid dispositive (k)(1) source. The Court also agreed that Commerce reached the initial interpretation that the merchandise was an unfinished TRB part in a reasonable way. In the Court’s view, the agency recognized implicitly that it could not fairly characterize the merchandise as a “finished”

TRB part. In considering whether the merchandise was an “unfinished” part, Commerce observed that Precision had identified bearing manufacturers as the only consumers of the merchandise, described as a process by which the merchandise would be used “to make a finished bearing”. The Court reasoned this was a fair reading of the Order and plaintiff’s own statements. Thus, the Court held that Commerce did not err in its interpretation that the merchandise in question was an “unfinished” TRB part, within the language of the Order. Moreover, given the 2020 Scope Ruling was not timely challenged, and that the merchandise in question was deemed the same as the merchandise at issue in the 2020 ruling, the Court found it reasonable for Commerce to have used this fact to reach its finding. The Court sustained Commerce’s determination according to its jurisdictional powers pursuant to 28 U.S.C. §1581(c).