WASHINGTON—The government of Taiwan, based on its analysis of the U.S. tire market, is planning to urge the International Trade Commission at a hearing May 25 to "render a negative final jury determination" in the U.S. government's pending investigation of passenger and light truck (P/LT) tires from Taiwan and three other Asian nations.
In a 13-page written submission to the ITC ahead of the May 25 hearing, the Taipei Economic and Cultural Representative Office in the U.S. argues that: "… we respectfully urge the ITC to conclude that the domestic U.S. P/LT tire industry is not suffering material injury nor threatened with future material injury by reason of P/LT tire imports from Taiwan."
In its submission, the Taiwan representative office presents evidence that the U.S. domestic tire industry has not suffered due to imports of P/LT tires from Taiwan, which it notes represent no more than 5 percent of the U.S. replacement market for such products by volume and less than 4 percent by value.
Furthermore, the office argues that, according to the information disclosed in the U.S. Commerce Dept.'s prehearing report, a "very large proportion" of U.S. purchasers of Taiwan-sourced tires did not think Taiwanese products enjoyed any price advantages vis-a-vis U.S. competitive products—which it interprets to mean that Taiwanese products have "not deliberately manipulated prices or exerted a depressing effect on the prices of the U.S. market"—and some U.S. buyers increased purchases of Taiwanese products because similar products were not available from U.S. producers.
The Commerce Department's preliminary determination on the case—which also is looking at imports from South Korea, Thailand and Vietnam at the request of the United Steelworkers union—resulted in anti-dumping import duties on passenger and light truck tires shipped from the four Asian lands, ranging from 13.25 percent (Sumitomo Rubber (Thailand) Co. Ltd.) to as high as 98.44 percent (Nankang Rubber Tire Corp. Ltd., Taiwan).
Taiwan's tire makers were given some of the higher duties in the Commerce Department's determination: Cheng Shin Rubber Ind. Co. Ltd. (Maxxis)—33.3 percent; Nankang Rubber Tire Corp. Ltd.— 98.44 percent; all others (i.e, Federal Corp., Hwa Fong Rubber Ind. Co. Ltd, and Kenda Rubber Industrial Co. Ltd.)—84.33 percent.
At last report, the rates were:
- South Korea: Hankook Tire & Technology Co. Ltd.—38.07 percent; Nexen Tire Corp.—14.14 percent; all others (including Kumho Tire Co. Inc.)—27.81 percent;
- Thailand: LLIT Thailand Co. Ltd.—22.21 percent; Sumitomo Rubber (Thailand) Co. Ltd.—13.25 percent; all others—16.66 percent; and
- Vietnam: countrywide entity—22.30 percent. Excluded are: Sailun Vietnam Co. Ltd.; Kenda Rubber (Vietnam) Co. Ltd.; Bridgestone Tire Manufacturing Vietnam L.L.C.; Kumho Tire (Vietnam) Co. Ltd.; and Yokohama Tyre Vietnam Co. Ltd.
Tire makers in Vietnam also have to contend with countervailing duties of between 6.23 percent and 10.08 percent.
In its submission to the ITC, the Taiwan office also urged the agency to restrict its investigation to the original 2017-19 time period and to not include any data from 2020, arguing that it would be "distortive and unfair" to include data for the full-year considering the extraordinary nature of the world economy during the COVID-19 pandemic and the extreme impact on U.S. production.
The office also urged the ITC to restrict its investigation to the replacement market, since the original equipment and replacement market are vastly different.
In a separate filing, Nankang Rubber Tire Corp. Ltd. pointed out to the ITC that "subject imports from Taiwan are typically of Tier 3 tires, while the U.S. industry is focused on satisfying demand for Tier 1 and Tier 2 tires.
"This attenuated competition supports a finding that there is no price effect from imports from Taiwan on the price of the domestic like product," Nancy Noona, attorney for Arent Fox, said. "Inventory levels in Taiwan have been stable and do not show a volume that could injure the U.S. industry."
