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Earlier this week, Arcosa Wind Towers and Broadwind Towers, Inc (Petitioners) petitioned for an investigation on utility scale wind towers from Canada, Indonesia, Korea and Vietnam. The merchandise covered in this scope consists of certain wind towers, whether or not tapered, and sections thereof. Certain wind towers are designed to support the nacelle and rotor blades in a wind turbine with a minimum rated electrical power generation capacity in excess of 100 kilowatts and with a minimum height of 50 meters measured from the base of the tower to the bottom of the nacelle (i.e., where the top of the tower and nacelle are joined) when fully assembled.
A wind tower section consists of, at a minimum, multiple steel plates rolled into cylindrical or conical shapes and welded together (or otherwise attached) to form a steel shell, regardless of coating, end-finish, painting, treatment, or method of manufacture, and with or without flanges, doors, or internal or external components (e.g., flooring/decking, ladders, lifts, electrical buss boxes, electrical cabling, conduit, cable harness for nacelle generator, interior lighting, tool and storage lockers) attached to the wind tower section. Several wind tower sections are normally required to form a completed wind tower.
Wind towers and sections thereof are included within the scope whether or not they are joined with nonsubject merchandise, such as nacelles or rotor blades, and whether or not they have internal or external components attached to the subject merchandise.
Specifically excluded from the scope are nacelles and rotor blades, regardless of whether they are attached to the wind tower. Also excluded are any internal or external components which are not attached to the wind towers or sections thereof, unless those components are shipped with the tower sections.
Merchandise covered by this investigation is currently classified in the HTSUS under subheading 7308.20.0020 or 8502.31.0000. While the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of the investigation is dispositive.
The listed producers are CS Wind, Enercon Canada, Fabrication Delta, Marmen, Kenertec, Korindo Wind, Dongkuk S&C, Speco, Win&P, Ltd., CS WIND Vietnam Co., Ltd, Vina Halla Industrial Company, UBI Tower Sole Member Co. LTD.
If you are a manufacturer or importer of utility scale wind towers and want to know your options, contact David Hsu at 832-896-6288 or by email at dh@gjatradelaw.com. Time is of the essence in antidumping investigations so you need to act soon.