Chinese Chassis Under Investigation

On July 30, 2020 the Coalition of American Chassis Manufacturers filed antidumping (AD) and countervailing duty (CVD) petitions on certain chassis and subassemblies thereof from China. The Coalition includes Cheetah Chassis Corporation, Hercules Enterprises, LLC, Pitts Enterprises, Inc., Pratt Industries, Inc., and Stoughton Trailers, LLC. The alleged dumping margin in the filing was 211.49%

The chassis and subassemblies thereof are further defined to include finished and unfinished, assembled or unassembled, coated or uncoated regardless of the number of axles. The subassemblies description includes reference to;

• Chassis frames, or sections of chassis frames, including kingpins or kingpin assemblies, bolsters consisting of transverse beams with locking or support mechanisms, goosenecks, drop assemblies, extension mechanisms, and/or rear impact guards
  
  
• Running gear assemblies or axle assemblies for connection to the chassis frame, whether fixed in nature or capable of sliding fore and aft or lifting up and lowering down, which may or may not include suspension(s) (mechanical or pneumatic), wheel end components, slack adjusters, axles, brake chambers, locking pins, and tires and wheels
  
  
• Landing gear (legs) or landing gear assemblies, for connection to the chassis frame, capable of supporting the chassis when it is not engaged to a tractor
  
  
• Assemblies and/or components that connect to the chassis frame or a section of the chassis frame, such as, but not limited to, pintle hooks or B-trains (which include a fifth wheel), which are capable of connecting a chassis to a converter dolly or another chassis
  
  
• Importation of any of these subassemblies, whether assembled or unassembled, constitutes an unfinished chassis for purposes of this investigation.

NATM convened its Special Projects Subcommittee to evaluate the case, its scope, and potential impact to the industry. The Association also reached out to contacts in peer groups as well as some petitioners for additional insights.

Importantly, this language would include materials brought in to be further assembled as well as fully assembled products. In discussions with certain members of the coalition, it was clear the intention was to include potential workarounds to the chassis and subassemblies, thus identifying unassembled products as well. Essentially, this includes kits that could be sold as components needing further assembly upon receipt.

On September 11, the International Trade Commission (ITC) made an affirmative preliminary injury determination. Investigations will now be undertaken for the Department of Commerce (DOC) to gather information from respondents and the Chinese government. DOC is to make its preliminary decision by October 23, 2020 of the CVD case and January 6, 2021 on the AD case.

For a complete outline of the case schedule, click here.

NATM member companies may receive requests for information and should respond accordingly. NATM will continue to monitor the situation and the impact on its members, though at this time any direct participation by the Association in the case has not yet been deemed appropriate.