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On January 15, 2020, Petitioner Coalition of American Vertical Engine Producers filed a petition for the imposition of antidumping and countervailing duties on imports of vertical shaft engines between 225cc and 999cc, and parts thereof from the People’s Republic of China.


The physical characteristics of the covered products, which define the scope, are as follows:

The merchandise covered by this investigation consist of spark-ignited, non-road, vertical shaft engines, whether finished or unfinished, whether assembled or unassembled, designed primarily for use in riding lawn mowers and zero-turn radius lawn mowers. Engines meeting this physical description may also be designed for use in other non-hand-held outdoor power equipment. The subject engines are spark ignition, single or multiple cylinder, air cooled, internal combustion engines with vertical power take off shafts with a minimum displacement of 225 cubic centimeters (“cc”) and a maximum displacement of 999cc. Typically, engines with displacements of this size generate gross power of between 6.7 kilowatts (“kw”) to 42 kw.


Engines covered by this scope normally must comply with and be certified under Environmental Protection Agency (EPA) air pollution controls title 40, chapter I, subchapter U, part 1054 of the Code of Federal Regulations standards for small non-road spark-ignition engines and equipment. Engines that otherwise meet the physical description of the scope but are not certified under 40 CFR part 1054 and are not certified under other parts of subchapter U of the EPA air pollution controls are not excluded from the scope of this proceeding. Engines that may be certified under both 40 CFR part 1054 as well as other parts of subchapter U remain subject to the scope of this proceeding.

For purposes of this investigation, an unfinished engine covers at a minimum a sub-assembly comprised of, but not limited to, the following components: crankcase, crankshaft, camshaft, pistons( s), connecting rode s), and oil pan. Importation of these components together, whether assembled or unassembled, and whether or not accompanied by additional components such as a manifold, cylinder head(s), valve train, or valve cover(s), constitutes an unfinished engine for purposes of this investigation. The inclusion of other products such as spark plugs fitted into the cylinder head or electrical devices (e.g., ignition modules, ignition coils) for synchronizing with the motor to supply tension current does not remove the product from the scope. The inclusion of any other components not identified as comprising the unfinished engine subassembly in a third-country does not remove the engine from the scope.

The engines subject to this investigation are typically classified in the Harmonized Tariff Schedule of the United States (HTSUS) at subheadings: 8407.90.1020, 8407.90.1060, and 8407.90.1080. Engines subject to this investigation may also enter under HTSUS 8407.90.9060 and 8407.90.9080. The engine subassemblies that are subject to this investigation enter under HTSUS 8409.91.5085, and 8409.91.9990. The HTSUS subheadings are provided for convenience and customs purposes only, and the written description of the merchandise under investigation is dispositive.



Kohler Co.

444 Highland Dr,

Kohler, WI 53044



Briggs & Stratton Corporation

3300 N 124th St.,

Wauwatosa, WI, 53222

(414) 259-5333



Daniel B. Pickard Esq.

Wiley Rein LLP

1776 K Street, NW

Washington, DC 20006




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 January 15, 2020
DOC Initiation February 4, 2020
ITC Preliminary Investigation:
Questionnaires Due January 29, 2020
Request to appear at hearing February 3, 2020
Hearing February 5, 2020
Briefs February 10, 2020
ITC Vote March 2, 2020
DOC Preliminary Antidumping Determination June 23, 2020
DOC Preliminary Countervailing Determination April 9, 2020
DOC Final Antidumping Determination September 7, 2020
DOC Final Countervailing Determination June 23, 2020
ITC Final AD Determination October 21, 2020
ITC Final CVD Determination August 7, 2020



People’s Republic of China: 320.41% – 633.64%%



For a list of alleged countervailing duty programs, please see Attachment III.




2016 2017 2018 2018 Jan-Sept. 2019 Jan-Sept.
Quantity(Units) 139,693 144,262 247,770 186,253 132,944
Value ($) 23,828,398 23,998,787 52,629,338 38,392,465 30,347,410
AUV ($/Quantity) 170.58 166.36 212.41 206.13 228.27




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