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On September 20, 2018, Petitioner American Keg Company LLC filed a petition for the imposition of antidumping duties on imports of Refillable Stainless Steel Kegs from Germany, Mexico, and the People’s Republic of China.


The merchandise covered by this investigation are cylindrical kegs, vessels, or containers capable of being pressurized made from stainless steel (i. e. , steel containing at least 10.5 percent chromium by weight and less than 1.2 percent carbon by weight, with or without other elements) (“refillable stainless steel kegs”) with a nominal liquid volume capacity of 10 liters or more, regardless of the type of finish, gauge, thickness, or grade of stainless steel, regardless of finish, and whether or not covered by or encased in other materials. Refillable stainless steel kegs may be imported assembled or unassembled, with or without all components (including spears, couplers or taps, necks, collars, and valves), and filled or unfilled. Assembled refillable stainless steel kegs must be capable of being pressurized to 60 pounds per square inch (“PSI”) and must be tested to 90 PSI.

“Unassembled” or “unfinished” refillable stainless steel kegs include drawn stainless steel cylinders that have been welded to form the body of the keg and welded to an upper (top) chime and/or lower (bottom) chime. Unassembled refillable stainless steel kegs may or may not be welded to a neck, may or may not have a valve assembly attached, and may be otherwise complete except for testing, certification and/or marking.

Subject merchandise also includes refillable stainless steel kegs that have been further processed in a third country, including but not limited to, attachment of necks, collars, spears or valves, heat treatment, pickling, passivation, painting, testing, certification or any other processing that would not otherwise remove the merchandise from the scope of the investigation if performed in the country of manufacture of the in-scope refillable stainless steel keg.

Specifically excluded are the following:

(1) vessels or containers that are not cylindrical in nature;

(2) stainless steel kegs, vessels, or Containers that have either a “ball lock” valve system or a “pin lock” valve system (commonly known as a “Cornelius,” “corny” or “ball lock” kegs);

(3) any fully assembled or finished stainless steel keg, vessel, or container that is incompatible with a “D Sankey” extractor (commonly known as a “D Coupler” or “Sankey”); and

(4) necks, spears, couplers or taps, collars, and valves that are not imported with the subject merchandise.

(5) stainless steel kegs that are filled with beer, wine, or other liquid and that are designated by the Commissioner of Customs as Instruments of International Traffic within the meaning of section 332(a) of the Tariff Act of 1930, as amended.

The merchandise covered by this investigation are currently classified in the Harmonized Tariff Schedule of the United States (“HTSUS”) under subheading 7310.10.0010, 7310.10.0050, 7310.29.0025, and 7310.29.0050.

These HTSUS subheadings are provided for convenience and customs purposes; the written description of the scope of this investigation is dispositive.


American Keg Company, LLC

31 Robinson Street

Pottstown, PA 19464


Andrew W. Kentz

Picard Kentz & Rowe LLP

1750 K Street, N.W.

Suite 800

Washington, D.C. 20006


China: 196.55%

Mexico: 25.39%

Germany: 76.36%


For a list of foreign products/exporters alleged by Petitioner, please see Attachment I.


For a list of importers alleged by Petitioner, please see Attachment II.


Event Earliest Date
Petition Filed September 20, 2018
DOC Initiation October 10, 2018
ITC Preliminary Investigation:
Questionnaires Due October 4, 2018
Request to appear at hearing October 9, 2018
Hearing October 11, 2018
Briefs October 16, 2018
ITC Vote November 5, 2018
DOC Preliminary CVD Determination December 14, 2018
DOC Preliminary Antidumping Determination February 27, 2019
DOC Final CVD Determination February 27, 2019
DOC Final Antidumping Determination May 13, 2019
ITC Final Determination April 13, 2019



2015 2016 2017 2017 Jan-Jun 2018 Jan-Jun
Volume (Units) 258,895 209,207 294,155 172,431 121,131
Value ($) 18,141,682 14,098,140 18,064,433 10,511,628 6,972,286
AUV ($/unit) $70.07 $67.39 $61.41 $60.96 $57.56
Volume (Units) 193,804 176,122 144,633 94,871 16,758
Value ($) 19,210,405 15,400,057 11,834,898 7,935,215 1,727,692
AUV ($/unit) $99.12 $88.95 $81.83 $83.64 $103.10
Volume (Units) 130,844 108,602 84,663 56,294 64,603
Value ($) 9,332,721 7,189,847 5,672,357 3,963,534 4,822,139
AUV ($/unit) $71.33 $66.20 $67.00 $70.41 $74.64



For more information concerning this petition and how it may affect your business, please contact Nithya Nagarajan, Jeffrey Neeley, or Stephen Brophy.