On September 28, 2023, Eastman Kodak Company (the “Petitioner”) filed a petition for the imposition of antidumping duties on Aluminum Lithographic Printing Plates from China and Japan, as well as the imposition of countervailing duties on Aluminum Lithographic Printing Plates from China.
SCOPE OF THE INVESTIGATION
The following language describes the imported merchandise that Petitioner intends to be included in the scope of these investigations:
The merchandise covered by these investigations is aluminum lithographic printing plates. Aluminum lithographic printing plates consist of a flat substrate containing at least 90 percent aluminum. The aluminum-containing substrate is generally treated using a mechanical, electrochemical, or chemical graining process, which is followed by one or more anodizing treatments that form a hydrophilic layer on the aluminum-containing substrate. An imagerecording,
oleophilic layer that is sensitive to light, including but not limited to ultra-violet,
visible, or infrared, is dispersed in a polymeric binder material that is applied on top of the hydrophilic layer, generally on one side of the aluminum lithographic printing plate. The oleophilic light-sensitive layer is capable of capturing an image that is transferred onto the plate by either light or heat. The image applied to an aluminum lithographic printing plate facilitates the plate’s use in offset printing processes to produce materials such as newspapers, magazines, books,
yearbooks, coupons, packaging, and other printed materials. Aluminum lithographic printing plates within the scope of these investigations include all aluminum lithographic printing plates, irrespective of the dimensions or thickness of the underlying aluminum substrate, whether the plate requires processing after an image is applied to the plate, whether the plate is ready to be mounted to
a press and used in printing operations immediately after an image is applied to the plate, or whether the plate has been exposed to light or heat to create an image on the plate or remains unexposed and is free of any image.
Subject merchandise also includes aluminum lithographic printing plates produced from an aluminum sheet coil that has been coated with a light-sensitive image-recording layer in a subject country and that is subsequently unwound and cut to the final dimensions to produce a finished plate
in a third country (including the United States), or exposed to light or heat to create an image on the plate in a third country (including the United States).
Excluded from the scope of these investigations are lithographic printing plates manufactured using a substrate produced from a material other than aluminum, such as rubber or plastic.
Aluminum lithographic printing plates are currently classifiable under HTSUS subheadings 3701.30.0000 and 3701.99.6060. Further, merchandise that falls within the scope of these investigations may also be entered into the United States under HTSUS subheadings 3701.99.3000 and 8442.50.1000. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of these investigations is dispositive.
PETITIONERS
Eastman Kodak Company
343 State Street
Rochester, NY 14650
Phone: (800) 356-3259
Fax: (585) 724-1089
Contact: Paul Smith, Corporate Compliance Manager
Email: paul.h.smith@kodak.com
Website: www.kodak.com
COUNSEL FOR PETITIONERS
KELLEY DRYE & WARREN LLP
3050 K Street, N.W., Suite 400
Washington, D.C. 20007
(202) 342-8400
NAMED PRODUCERS/EXPORTERS
For a list of foreign producers/exporters alleged by Petitioner, please see Attachment I.
NAMED IMPORTERS
For a list of importers alleged by the Petitioner, please see Attachment II.
ESTIMATED SCHEDULE
| Event | Earliest Date |
| Petition Filed | September 28, 2023 |
| DOC Initiation | October 18, 2023 |
| ITC Preliminary Investigation: | |
| Questionnaires Due | October 12, 2023 |
| Request to appear at hearing | October 17, 2023 |
| Hearing | October 19, 2023 |
| Briefs | October 24, 2023 |
| ITC Vote | November 12, 2023 |
| DOC Investigation Schedule: | |
| DOC Preliminary Antidumping Determination | March 6, 2024 |
| DOC Final Antidumping Determination | May 20, 2024 |
| DOC Preliminary Countervailing Determination | December 22, 2023 |
| DOC Final Countervailing Determination | March 6, 2024 |
| ITC Final Investigation: | |
| ITC Final AD Determination | July 4, 2024 |
| ITC Final CVD Determination | April 20, 2024 |
ALLEGED DUMPING MARGINS
China: 107.64%
Japan: 23.52 %
ALLEGED COUNTERVAILING DUTY MARGINS
Above de minimis
ALLEGED SUBSIDIES
For a list of subsidies alleged by the Petitioner, please see Attachment III.
IMPORTS OF SUBJECT MERCHANDISE
| 2020 | 2021 | 2022 | Jan-Jun-2022 | Jan-June- 2023 | |
| China | |||||
| Quantity(Square Meters) | 82,234 | 697,424 | 5,249,631 | 1,678,902 | 4,071,640 |
| Value ($) | 408,846 | 2,605,157 | 17,471,668 | 5,075,476 | 13,449,995 |
| AUV ($/M2) | 4.97 | 3.74 | 3.33 | 3.02 | 3.30 |
| Japan | |||||
| Quantity(Square Meters) | 5,054,546 | 5,451,299 | 14,721,850 | 6,328,029 | 7,935,304 |
| Value ($) | 27,268,544 | 47,140,860 | 87,932,578 | 39,729,043 | 38,678,354 |
| AUV ($/M2) | 5.39 | 8.65 | 5.97 | 6.28 | 4.87 |
CONTACT US
For more information concerning this petition and how it may affect your business, please contact Jeffrey Neeley, Nithya Nagarajan, Stephen Brophy or Dan Wilson.