U.S. Finds Circumvention of Antidumping Orders on Oil Country Tubular Goods from China via Thailand
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On August 19, 2025, the U.S. Department of Commerce (Commerce) issued a preliminary affirmative determination that imports of seamless oil country tubular goods (OCTG) from Thailand, made with steel billets from China, are circumventing existing antidumping (AD) and countervailing duty (CVD) orders on OCTG from China.
Background
Antidumping and countervailing duty orders have been in place against OCTG from China since 2010. These orders are meant to protect U.S. businesses from goods sold at less than fair value and from unfair subsidies. Commerce began a country-wide circumvention inquiry on December 18, 2024. The question: Are OCTG finished in Thailand from Chinese steel billets avoiding the original orders?
Three companies in Thailand were selected for review: Boly Pipe Co., Ltd., Nanobest Limited, and Petroleum Equipment (Thailand) Co., Ltd.
On April 23, 2025, Commerce extended the deadline for its preliminary determination. This notice, along with the full explanation, can be found online through the Antidumping and Countervailing Duty Centralized Electronic Service System (ACCESS).
Scope of Orders
The original orders apply to hollow, round steel products, such as oil well casing and tubing. These items can be made of iron or steel, made by seamless or welded methods. They may have different finishes and may meet various specifications. Both finished and unfinished goods are covered.
Merchandise Subject to Inquiry
This inquiry focuses on seamless OCTG finished in Thailand using steel billets made in China and then exported to the U.S.
Methodology
Commerce conducted the inquiry using U.S. law (section 781(b) of the Tariff Act of 1930) and relevant regulations. The full details are included in the Preliminary Decision Memorandum.
Preliminary Determination
Commerce found that seamless OCTG finished in Thailand using Chinese steel billets and then shipped to the U.S. are circumventing the original orders from China on a country-wide basis. As a result, this merchandise should be included in the scope of the existing orders.
Suspension of Liquidation and Cash Deposit Requirements
Commerce will instruct U.S. Customs and Border Protection (CBP) to suspend liquidation and require cash deposits on entries made on or after December 18, 2024. This is only for OCTG from Thailand made with Chinese steel billets. If the merchandise is made with billets from countries other than China, the cash deposit requirements do not apply.
Specific case numbers have been created for these products: A-549-991 and C-549-992.
Certification Requirements
Importers and exporters can submit certifications showing that the merchandise does not use Chinese-origin steel billets. These certifications must be completed and submitted with supporting documents, such as steel mill certificates, at the time of entry. Steel mill certificates must show the country where the steel was melted and poured.
If these certifications are not provided, Commerce may require cash deposits at rates established for the AD and CVD orders on China (99.14% for AD, 13.41% for CVD). For companies with specific rates, those rates apply.
Both importers and exporters must keep these records for five years after the last covered entry or three years after any related court cases.
Certification Process and Timing
For entries made between December 18, 2024, and September 3, 2025, importers and exporters must complete and upload certifications no later than October 3, 2025. Blanket certifications can be used for multiple entries.
If non-AD or non-CVD entries were made during this period and cannot be certified, importers must submit a Post Summary Correction and pay any required duties.
Public Comments
Parties may comment on this finding and on certification procedures. Case briefs are due within fourteen days of this notice, with rebuttals due seven days later. Executive summaries are required for each issue and are limited to 450 words per issue.
Requests for a hearing must be filed within 30 days of this notice. Hearings, if requested, will be scheduled later.
International Trade Commission Notification
Commerce will inform the U.S. International Trade Commission of this preliminary determination. The ITC may seek consultations if it believes there is an injury issue within 60 days of notification.
Certification Templates Provided
The notice includes detailed importer and exporter certification templates. These templates must be filled out with names, addresses, invoice numbers, and documentation showing that the OCTG does not use Chinese-origin steel billets.
Conclusion
The Department of Commerce is taking steps to ensure that seamless OCTG from Thailand using Chinese steel billets is covered by existing orders against China. Suspension of liquidation and cash deposits are required unless proper certifications are provided.
For more details, refer to the Federal Register notice and the Preliminary Decision Memorandum by the U.S. Department of Commerce.
Legal Disclaimer
This article includes content collected from the Federal Register (federalregister.gov). The content is not an official government publication. This article is for informational purposes only and does not constitute legal advice. For case-specific consultation, please contact us. Read our full Legal Disclaimer, which also includes information on translation accuracy.
