Public Version

PUBLIC VERSION

DOC Investigation Nos. A-570-012 and C-570-013 ITC Investigation Nos. 701-TA-___ and 731-TA-___ Total No. of Pages: 124 Original Investigation AD/CVD Operations Petitioners' Business Proprietary Information for Which Proprietary Treatment Has Been Requested Contained in Volume 1 at Pages 14-15 and 17-20, and Exhibits GEN-1, INJ-2, INJ-3, INJ-4 and INJ-5 PUBLIC VERSION

BEFORE THE INTERNATIONAL TRADE ADMINISTRATION OF THE U.S. DEPARTMENT OF COMMERCE AND THE U.S. INTERNATIONAL TRADE COMMISSION

ANTIDUMPING AND COUNTERVAILING DUTY PETITION VOLUME I GENERAL and INJURY SECTIONS

CARBON AND CERTAIN ALLOY STEEL WIRE ROD FROM THE PEOPLE’S REPUBLIC OF CHINA

PETITIONERS:

ARCELORMITTAL USA LLC, CHARTER STEEL, EVRAZ ROCKY MOUNTAIN STEEL, GERDAU AMERISTEEL US INC., KEYSTONE CONSOLIDATED INDUSTRIES, INC., AND NUCOR CORPORATION

ALAN H. PRICE PAUL C. ROSENTHAL DANIEL B. PICKARD KATHLEEN W. CANNON CHRISTOPHER B. WELD R. ALAN LUBERDA WILEY REIN, LLP BENJAMIN BLASE CARYL 1776 K Street, N.W. KELLEY DRYE & WARREN LLP Washington, DC 20006 3050 K Street, N.W., Suite 400 (202) 719-3375 Washington, D.C. 20007 Counsel to Nucor Corporation (202) 342-8400 Counsel to ArcelorMittal USA LLC, Charter Steel, Evraz Rocky Mountain Steel, Gerdau Ameristeel US Inc., and Keystone Consolidated Industries, Inc. GINA E. BECK, Consultant JULIE H. SANTOBONI, Consultant

January 31, 2014

PUBLIC VERSION

Table of Contents

VOLUME I Page

I. GENERAL INFORMATION ...... 2

A. Petitioners ...... 2

B. Description of the Domestic Industry and Industry Support ...... 3

1. Other U.S. Producers of CASWR ...... 3

2. Industry Support ...... 4

C. Related Proceedings ...... 5

D. Description of the Merchandise and Requested Scope of Investigation ...... 6

1. Product Description ...... 6

2. Technical Characteristics, Production Process, and Uses ...... 6

3. Requested Scope of Investigation ...... 7

4. U.S. Tariff Classification ...... 7

E. Country of Exportation ...... 8

F. Producers and Exporters of the Subject Merchandise ...... 8

G. Volume and Value of Imports ...... 8

H. Names and Addresses of U.S. Importers ...... 8

II. INFORMATION RELATED TO COUNTERVAILABLE SUBSIDIES ...... 9

III. THE U.S. CASWR INDUSTRY HAS BEEN MATERIALLY INJURED BY REASON OF UNFAIRLY TRADED IMPORTS OF CASWR FROM CHINA ...... 9

A. The Domestic Like Product Is Co-Extensive With the Scope of the Petition and Consists of All Carbon and Certain Alloy Steel Wire Rod ...... 9

B. The Domestic Industry Consists of All U.S. Producers of CASWR ...... 12

C. Subject Imports Surpass the Statutory Negligibility Threshold ...... 13

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Table of Contents (continued) Page

D. CASWR Imports from China Are Causing Material Injury to the Domestic Industry ...... 13

1. The Volume of CASWR Imports from China Is Significant and Increasing ...... 14

2. Unfairly Traded CASWR Imports from China Have Had Significant Negative Price Effects on the Domestic Industry ...... 14

a. Subject Imports Have Undersold Domestically- Produced CASWR by Substantial Margins, Causing the Domestic Industry Lost Sales , Lost Revenue, and Price Suppression and Depression...... 15

b. Identification of CASWR Products for Which Petitioners Request Collection of Price Data ...... 16

3. Unfairly Traded CASWR Imports from China Have Had A Significant Negative Impact on the Domestic CASWR Industry ...... 16

a. Decreasing U.S. Shipment and Production Trends and Low Capacity Utilization Rates for CASWR Demonstrate the Material Injury Caused by Subject Imports ...... 17

b. Petitioners' Declining Operating Income Demonstrates the Injurious Impact of the Substantial Volumes of Low-Priced Imports from China ...... 18

C. Petitioners Have Lost Sales and Revenues to Unfair CASWR Imports from China ...... 18

IV. THE DOMESTIC INDUSTRY IS THREATENED WITH FURTHER MATERIAL INJURY BY REASON OF UNFAIR IMPORTS OF CASWR FROM CHINA ...... 19

V. CONCLUSION ...... 21 PUBLIC VERSION

PETITION FOR THE IMPOSITION OF ANTIDUMPING AND COUNTERVAILING DUTIES ON IMPORTS OF CARBON AND CERTAIN ALLOY STEEL WIRE ROD FROM THE PEOPLE'S REPUBLIC OF CHINA

This petition is filed on behalf of the U.S. industry producing carbon and certain alloy

steel wire rod ("CASWR"). The petitioners in this case are ArcelorMittal USA LLC, Charter

Steel, Evraz Rocky Mountain Steel, Gerdau Ameristeel US Inc., Keystone Consolidated

Industries, Inc., and Nucor Corporation (collectively "petitioners"). These companies account

for the majority of CASWR production in the United States and represent the U.S. industry

producing CASWR within the meaning of sections 702(c)(4) and 732(c)(4) of the Tariff Act of

1930, as amended (the "Act"). 19 U.S.C. §§ 167la(c)(4), 1673a(c)(4).

Volume II of this petition presents evidence that CASWR from the People's Republic of

China ("PRC" or "China") is being, or is likely to be, sold in the United States at less than fair value within the meaning of section 731(1) of the Act. 19 U.S.C. § 1673(1). In addition,

Volume III of this petition presents evidence that the Government of China is providing

countervailable subsidies with respect to the manufacture, production, and export of CASWR. within the meaning of section 701(a)(1) of the Act. 19 U.S.C. § 1671(a)(1). This petition demonstrates that the U.S. industry producing CASWR is being materially injured, and is threatened with further material injury, by reason of unfairly traded imports from China within the meaning of sections 701(a)(2) and 731(2) of the Act. 19 U.S.C. §§ 1671(a)(2), 1673(2).

Petitioners, therefore, request that: (1) antidumping duties be imposed on CASWR from China in an amount equal to the amount by which the normal value exceeds the export price or constructed export price of the merchandise; and (2) countervailing duties be imposed on imports of CASWR from China in an amount equal to the net countervailable subsidy. PUBLIC VERSION

This petition sets forth the information reasonably available to petitioners and is filed in conformity with the requirements of section 351.202 of the regulations of the U.S. Department of

Commerce ("Commerce" or "the Department"), 19 C.F.R. § 351.202, and section 207.11 of the regulations of the U.S. International Trade Commission ("ITC" or "Commission"), 19 C.F.R.

§ 207.11.

1. GENERAL INFORMATION

A. Petitioners

This petition is filed on behalf of the U.S. CASWR industry by the following domestic manufacturers:

• ArcelorMittal USA LLC One South Dearborn Street Chicago, IL 60603 Contact: Dan Fuller, Director Wire Rod Sales Tel: (312) 899-3153 Fax: (312) 899-3562 Email: dan.fullergarcelormittal.com Website: http://www.arcelonnittal.com

• Charter Steel Division of Charter Manufacturing Co., Inc. 1658 Cold Springs Road Saukville, WI 53080 Contact: Tom Glaister, President & Chief Operating Officer Tel: (800) 43-8789 Fax: (262) 268-2340 Email: GlaisterTQchartermfg com Website: http://www.chartersteel.com

• Evraz Rocky Mountain Steel 1612 E. Abriendo Ave. Pueblo, CO 81004 Contact: Paige Brodksy, Vice President and General Counsel Tel: (312) 533-3689 Fax: (503) 978-4927 Email: Paijze.Brodsky a,evrazincna.com Website: http://www.evrazna.com

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• Gerdau Ameristeel US Inc. 4221 W. Boy Scout Blvd., Suite 600 Tampa, FL 33607 Contact: Jim Kerkvliet, Vice President of Sales and Marketing Tel: (813) 217-4546 Fax: (800) 628-9931 Email: [email protected] Website: http://www.gerdauameristeel.com

• Keystone Consolidated Industries, Inc. 5430 LBJ Freeway, Suite 1740 Three Lincoln Centre Dallas, TX 75240 Contact: Mark Brachbill, V.P. Finance Tel: (309)-697-7628 Fax: (309)-697-7120 Email: BrachbiMgkeystonesteel.com Website: http://www.keystonesteel.com

• Nucor Corporation 2100 Rexford Road Charlotte, NC 28211 Contact: Douglas Gunson, General Counsel Tel: (704) 366-7000 Fax: (704) 362-4208 Email: d unsongnucor.com Website: http://www.nucor.com

B. Description of the Domestic Industry and Industry Support

This petition is filed on behalf of the domestic industry producing CASWR, as defined in the scope of this petition (section I.D, infra), and meets the statutory support requirement as

described below and as set forth in Exhibit GEN-1.

1. Other U.S. Producers of CASWR

In addition to the named petitioners, other known U.S. producers of CASWR are:

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• Cascade Steel Rolling Mills Inc. 3200 N. Highway 99W P.O. Box 687 Tel: (503) 472-4181 Fax: (503) 434-5739 Email: fwaechtlerQschn.com Website: http://www.cascadesteel.com

• Oklahoma Steel and Wire Highway 70 South Madill, OK 73446 Tel: (800) 654-4164 Fax: (580) 795-7422 Email: [email protected] Website: www.oklahomasteel.com

• Republic Engineered Products 3770 Embassy Parkway Akron, OH 44333-8367 Tel: (440) 996-0740 Fax: (440) 996-0741 Email: lbraungrepublicsteel. com Website: www.republicengineered.com

• Sterling Steel Company LLC/Leggett & Platte P.O. Box 757 Number 1 Leggett Road Carthage, MO 64836 Tel: (417) 358-8131 Fax: (417) 358-4805 Email: joe.downesgleggett.com Website: http://www.legg et t.com

2. Industry Support

Sections 702 and 732 of the Act requires that "the domestic producers or workers who

support the petition account for at least 25 percent of the total production of the like product."

19 U.S.C. §§ 167la(c)(4)(A)(i), 1673a(c)(4)(A)(i). In addition, the statute requires that "the domestic producers or workers who support the petition account for more than 50 percent of the

' Sterling Steel Company, LLC operates as a subsidiary of Leggett & Platt, Incorporated.

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production of the domestic like product produced by the portion of the industry expressing

support for or opposition to the petition." 19 U.S.C. §§ 1671a(c)(4)(A)(ii), 1673a(c)(4)(A)(ii).

As shown in the attached Exhibit GEN-1, the U.S. producers who are known to be in

support of the petition surpass both the 25 percent and 50 percent thresholds for industry support

established in the statute.

C. Related Proceedings

Petitioners have not filed for import relief pursuant to sections 337 or 702 of the Tariff

Act of 1930, as amended, ("the Act") (19 U.S.C. §§ 1337 and 1671a) or section 232 of the Trade

Expansion Act of 1962 (19 U.S.C. § 1862), with respect to the merchandise that is the subject of this petition. A chronology of all prior antidumping and countervailing duty proceedings,

section 201 investigations, and related proceedings covering CASWR is provided in Exhibit

GEN-2 to this volume. Based on petitions filed in 2001, there are currently antidumping duty

orders in place against CASWR from Brazil, Indonesia, Mexico, Moldova, Trinidad & Tobago,

and Ukraine, and a countervailing duty order is in place against CASWR imports from Brazil.

See Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Indonesia, Mexico,

Moldova, Trinidad & Tobago, and Ukraine, Inv. Nos. 701-TA-417 and 731-TA-953, 954, 957-

959, 961 and 962 (Review), USITC Pub. 4014 (June 2008) ("First CASWR Sunset"). A full

sunset review of these orders is currently being conducted. See Carbon and Certain Alloy Steel

Wire Rod From Brazil Indonesia Mexico Moldova, Trinidad and Tobago, and Ukraine: Notice

of Commission Determination To Conduct Full Five-Year Reviews, 78 Fed. Reg. 60,316 (Oct. 1,

2013).

In 2005, the domestic industry filed antidumping duty cases against CASWR from China,

Germany, and Turkey. The Commission reached preliminary negative determinations and those

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investigations were subsequently terminated. See Carbon and Certain Alloy Steel Wire Rod

from China, Germany, and Turkey, Inv. Nos. 731-TA-1099-1101 (Preliminary), USITC Pub.

3546 (Jan. 2006); Carbon and Certain Alloy Steel Wire Rod from China, Germany, and Turkey,

71 Fed. Reg. 132 (Jan. 3, 2006).

Other than the actions described in Exhibit GEN-2, petitioners have not filed, are not

presently filing, and have not otherwise initiated proceedings for import relief with respect to the

merchandise that is the subject of this petition.

D. Description of the Merchandise and Requested Scope of Investigation

1. Product Description

The merchandise covered by these investigations is certain hot-rolled products of carbon

steel and alloy steel, in coils, of approximately round cross section, less than 19.00 mm, in solid

cross-sectional diameter.

2. Technical Characteristics , Production Process, and Uses

The characteristics, production process, and uses of CASWR were fully explained by the

Commission in the most recent sunset reviews it conducted. See First CASWR Sunset, USITC

Pub. 4014 at I-22-I-27. The relevant pages of that publication are attached as Exhibit GEN-3.

Note that the scope language of these investigations differ from the previous investigations in

two ways. First, the scope language in the previous investigations listed a lower diameter of 5.0

mm, reflecting the known commercial availability of hot-rolled CASWR products in the United

States at the time that those investigations were initiated. Because CASWR with diameters less than 5 mm has become commercially available in the United States since that time, the scope of this petition contains no specified lower diameter. Second, the scope of this petition does not

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contain an exclusion for grade 1080 tire cord quality wire rod or grade 1080 tire bead quality

wire rod.

3. Requested Scope of Investigation

The following language describes the imported merchandise that petitioners intend to

cover in these investigations:

The merchandise covered by this investigation is certain hot-rolled products of carbon steel and alloy steel, in coils, of approximately round cross section, less than 19.00 mm, in solid cross-sectional diameter. Specifically excluded are steel products possessing the above-noted physical characteristics and meeting the Harmonized Tariff Schedule of the United States (HTSUS) definitions for (a) stainless steel; (b) tool steel; (c) high nickel steel; (d) ball bearing steel; or (e) concrete reinforcing bars and rods. Also excluded are free cutting steel (also known as free machining steel) products (i.e., products that contain by weight one or more of the following elements: 0.1 percent or more of lead, 0.05 percent or more of bismuth, 0.08 percent or more of sulfur, more than 0.04 percent of phosphorus, more than 0.05 percent of selenium, or more than 0.01 percent of tellurium). All products meeting the physical description of subject merchandise that are not specifically excluded are included in this scope.

The products under investigation are currently classifiable under subheadings 7213.91.3011, 7213.91.3015, 7213.91.3020, 7213.91.3093; 7213.91.4500, 7213.91 .6000, 7213.99.0030, 7227.20.0030, 7227.20.0080, 7227.90.6010, 7227.90.6020, 7227.90.6030, and 7227.90.6035 of the HTSUS. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of this proceeding is dispositive.

4. U.S. Tariff Classification

CASWR is currently classifiable in the following HTSUS subheadings: 7213.91.3011,

7213.91.3015, 7213.91.3020, 7213.91.3093; 7213.91.4500, 7213.91.6000, 7213.99.0030,

7227.20.0030, 7227.20.0080, 7227.90.6010, 7227.90.6020, 7227.90.6030, and 7227.90.6035.

See Exhibit GEN-4.

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From 2011 through 2013, certain subject alloy wire rod products were classified with

non-subject hot-rolled bar products in HTSUS basket category 7227.90.6085. As of January 1,

2014, HTSUS 7227.90.6085 was replaced with four new breakouts, including 7227.90.6030

(covering circular alloy wire rod with a diameter of less than 14 mm) and 7227.90.6035

(covering circular alloy wire rod with a diameter of 14 mm or more but less than 19 mm). The

remaining two new HTSUS numbers, 7227.90.6040 (circular alloy bars and rods with a diameter

of 19 mm or more) and 7227.90.6090 (shapes other than circular), are considered bar products

outside the scope of this investigation.

E. Country of Exportation

The CASWR that is the subject of this petition is produced in and exported from China.

Petitioners have no knowledge that the subject merchandise is currently being transshipped through any third country to the United States.

F. Producers and Exporters of the Subject Merchandise

Pursuant to the Department's regulations, 19 C.F.R. § 351.202(b)(7)(i)(A), a list of known producers and exporters of CASWR from China is included in Exhibit GEN-5.

G. Volume and Value of Imports

The volume and value of U.S. imports of CASWR from China are presented at Exhibit

GEN-6 for calendar years 2011, 2012, and 2013, as required by the Department's regulations.

See 19 C.F.R. § 351.202(b)(8). These data are taken directly from the Commerce Department

IM-146 import reports.

H. Names and Addresses of U.S. Importers

Based on information reasonably available to petitioners, a list of known and suspected importers of CASWR from China during the 12-month period preceding the filing of this petition

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is included in Exhibit GEN-7, as required by the Department's regulations. See 19 C.F.R.

§ 351.202(b)(9).

II. INFORMATION RELATED TO COUNTERVAILABLE SUBSIDIES

Information related to countervailable subsidies provided by the Government of China

with respect to the manufacture, production, and export of CASWR in China is provided in

Volume III of this petition.

III. THE U.S. CASWR INDUSTRY HAS BEEN MATERIALLY INJURED BY REASON OF UNFAIRLY TRADED IMPORTS OF CASWR FROM CHINA

A. The Domestic Like Product Is Co-Extensive With the Scope of the Petition and Consists of All Carbon and Certain Alloy Steel Wire Rod

The domestic like product in this case mirrors the scope of the petition and consists of all

carbon and certain alloy steel wire rod. This domestic like product definition is consistent with

the statute and supported by the like product definition the Commission adopted in its

investigation and review of imports from Brazil, Indonesia, Mexico, Moldova, Trinidad &

Tobago and Ukraine.' Section 771(10) of the Act defines the domestic like product as "a product

which is like, or in the absence of like, most similar in characteristics and uses with, the article

subject to an investigation." 19 U.S.C. § 1677(10). In defining the like product, the Commission

looks for clear dividing lines among possible like products and disregards minor variations.

Hosiden Corp. v. Advanced Display Mfrs., 85 F.3d 1561 (Fed. Cir. 1996). Applying the

statutory standard in the 2002 determination, the Commission found all wire rod to comprise a single continuum like product with no clear demarcations by type, grade, size or use:

2 See Carbon and Certain Alloy Steel Wire Rod from Brazil, Canada, Germany, Indonesia, Mexico, Moldova, Trinidad & Tobago, Turkey and Ukraine, Inv. Nos . 701-TA-417-421 and 731-TA-953, 954, 956-959, 961 and 962 (Final), USITC Pub. 3546 at 6-12 (Oct. 2002) ("Final Determination in CASWR from Brazil et al."); First CASWR Sunset, USITC Pub. 4014 at 8.

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As a general matter, the record demonstrates no clear demarcation between the various types of wire rod products, but rather indicates a continuum of at least 11 major categories of products ranging from low carbon wire rod such as industrial wire rod used for nails and coat hangers, to medium to high quality wire rod, such as that used for tire bead and prestressed concrete strand, to the highest- end products, including CHQ, CSPBIC, and tire cord wire rod. In cases such as the present one, where the domestically manufactured merchandise consists of a broad spectrum of similar products, the Commission does not consider each item of merchandise to be a separate like product that is only "like" its counterpart in the scope, but considers the continuum itself to constitute the domestic like product.

Final Determination in CASWR from Brazil et al., USITC Pub. 3546 at 7. Based on the

statutory standard and the Commission's prior like product determinations on CASWR, all

carbon and certain alloy steel wire rod comprises a single like product.'

All CASWR have similar of physical characteristics and are "intermediate circular, hot-

rolled products that are sold in irregularly wound coils ." Id. at 9. While wire rods of different

grades, end use categories or sizes are not interchangeable, "there is an overlap of metallurgical

qualities, chemistry, and physical characteristics and a continuum of products with a wide variety

of uses." Id. at 10. All wire rod is sold through similar channels of trade, and all wire rod is

generally produced using the same basic manufacturing process and on the same hot-rolling mills regardless of size or other physical characteristics . Id. at 10-11. Customers and producers perceive all wire rod as comprising a single continuum of products , sharing overlapping characteristics that create a continuum of prices. See id. at 11-12; CASWR from China,

Germany, and Turkey, USITC Pub. 3832 at 11.

' See also First CASWR Sunset, USITC Pub . 4014 at 6-7; Carbon and Certain Alloy Steel Wire Rod from China, Germany, and Turkey, Inv. Nos. 731-TA- 1099-1101 (Prelim .), USITC Pub. 3832 at 9-11 (Jan. 2006)("CASWR from China, Germany , and Turkey").

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As noted in section I.D.2 above, the scope of this case differs from the scope of the

existing CASWR orders in that it does not contain an expressed exclusion of 1080 tire cord

quality and grade 1080 tire bead quality wire rod and does not reference a lower diameter range

for CASWR. These differences in scope do not change the Commission's like product analysis.

In the 2002 investigations, the Commission found "a single like product consisting of all wire

rod, including the certain grade 1080 tire cord and the grade 1080 tire bead wire rod products

that Commerce excluded from the scope of the investigations." Final Determination in CASWR

from Brazil et al., USITC Pub. 3546 at 12. Thus, inclusion of these products within the scope

does not change the Commission's like product analysis.

The removal of the lower diameter limit of 5.0 mm also does not change the like product

analysis. The 5.0 mm lower diameter identified was just beyond the bottom rolling tolerance for

7/32 inch (5.6 mm) wire rod, which was "the lowest cross-sectional diameter that was being hot- rolled in significant commercial quantities." Id. at I-6. As the Commission recognized, "{w)ire rod is a hot-rolled intermediate product of circular or approximately circular cross-section." Id. at 6. Petitioners' intention was to capture all sizes of wire rod within the scope and like product of that case, and there was no domestic or subject foreign production of hot-rolled wire rod in diameters below 5 mm at the time of that case.

After those investigations, Mexican wire rod producer Deacero S.A. de C.V developed the ability to hot-roll CASWR in diameters below 5 mm on the same mill as it produced larger diameter CASWR. Thus, by the time the industry filed antidumping cases against China,

Germany and Turkey in late 2005, the Commission's report noted that hot-rolled CASWR was

"typically produced in nominal fractional diameters from 3/16 inch (4.75 mm) to 47/64 inch

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(18.7 mm)." CASWR from China, Germany, and Turkey, USITC Pub. 3832 at I-6. The

Commission found a single like product in that case. Id. at 11.

Furthermore, on October 1, 2012, Commerce published in the Federal Register an

affirmative circumvention determination with respect to Mexico that "wire rod with an actual

diameter of 4.75 mm to 5.00 mm by Deacero S.A. de C.V (Deacero) constitutes merchandise

altered in form or appearance in such minor respects that it should be included within the scope

of the order. 114 Recognizing that further technical advances may permit CASWR to be

commercially available in even smaller diameters, the scope language of this case removes the

bottom descriptor of diameter to effectuate the same scope and like product as in CASWR from

Brazil et al. and CASWR from China, Germany, and Turkey. Consistent with all of its prior

determinations, the Commission should conclude that the like product in this case is coterminous

with the scope language and covers all hot-rolled products of carbon steel and alloy steel, in

coils, of approximately round cross section, less than 19.00 mm, in solid cross-sectional diameter

not specifically excluded from the scope.

B. The Domestic Industry Consists of All U.S.. Producers of CASWR

Section 771(4)(A) of the Act defines the relevant industry as the "producers as a {w}hole

of a domestic like product, or those producers whose collective output of a domestic like product

constitutes a major proportion of the total domestic production of the product." 19 U.S.C.

§ 1677(4)(A). Based on this definition, the domestic industry consists of all U.S. producers of

4 Carbon and Certain Alloy Steel Wire Rod from Mexico: Affirmative Final Determination of Circumvention of the Antidumping Duty Order on Wire Rod from Mexico, 77 Fed. Reg. 59,892 (Oct. 1, 2012). The U.S. Court of International Trade has remanded the circumvention finding back to Commerce for further analysis and explanation. See Deacero S.A. de C.V. v. United States, Slip Op. 13-126 (Sept. 30, 2013). The Commerce Department's remand redetermination will then be subject to further review by the Court and possible further appeal.

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CASWR. These producers are the six petitioning companies as well as the domestic producers

identified in section I.B.1, supra.

C. Subject Imports Surpass the Statutory Negligibility Threshold

Pursuant to section 771(24) of the statute, imports from any single country that account

for less than 3 percent of the total import volume for subject merchandise in the most recent

12-month period for which data are available that precedes the filing of the petition are

considered negligible. 19 U.S.C. § 1677(24)(A)(i). Exhibit INJ-1 sets forth monthly U.S.

import volumes for CASWR from China for the period December 2012 through November 2013,

the most recent 12-month period for which data are currently available. As those data indicate,

imports of CASWR from China significantly exceed the statutory negligibility threshold.

Specifically, for the 12-month period examined, imports from China accounted for 36.4 percent

of total imports. See Exhibit INJ-1.

D. CASWR Imports from China Are Causing Material Injury to the Domestic Industry

In determining whether the domestic industry has been injured by reason of the imports under investigation, the statute directs the Commission to consider:

(1) the volume of imports of the subject merchandise;

(2) the effect of imports of that merchandise on prices in the United States for the

domestic like product; and

(3) the impact of imports of such merchandise on domestic producers in the context

of production operations within the United States.

19 U.S.C. § 1677(7)(B). Information reasonably available to petitioners indicates that increasing volumes of dumped and subsidized imports from China have been, and continue to be, a cause of material injury to the domestic CASWR industry. -13- PUBLIC VERSION RANGED DATA

1. The Volume of CASWR Imports from China Is Significant and Increasing

The volume of unfairly priced CASWR imports from China has rapidly increased over the past three years. The total volume of subject imports rose from 144 tons in 2011 to 614,402 tons in 2013, representing an increase of 426,568 percent in absolute terms from 2011-13. See

Exhibit INJ-2. As a share of the U.S. market, subject imports rose from [ ] percent in

2011 to [ 12.5] percent in 2013. Id. While subject imports' market share increased, the domestic industry's share of the market declined from [ ] percent to [ ] percent over the

2011-13 period. Subject import market share grew by substantially more that the estimated

[ ] percent growth in domestic consumption over the same period.

2. Unfairly Traded CASWR Imports from China Have Had Significant Negative Price Effects on the Domestic Industry

In its 2002 investigations of CASWR from multiple countries, the Commission found that price was one of the most important factors in CASWR sales in the U.S. market. Final

Determination in CASWR from Brazil et al. USITC Pub. 3546 at 28 and 29. Similarly, the

Commission found in the first CASWR sunset review that "price plays an important role in the purchasing decision for wire rod." First CASWR Sunset, USITC Pub. 4014 at 33. CASWR remains a price-sensitive product. The low-priced, dumped and subsidized subject imports in these investigations have had significant negative price effects on the domestic CASWR industry. Price underselling by unfairly-traded imports of CASWR from China has significantly depressed the prices at which domestic producers have sold CASWR during the past three years. PUBLIC VERSION

a. Subject Imports Have Undersold Domestically-Produced CASWR by Substantial Margins, Causing the Domestic Industry Lost Sales , Lost Revenue, and Price Suppression and Depression

Based on the domestic industry's examples of lost sales provided at Exhibit INJ-3, import prices from China show consistent, significant, and widespread underselling of U.S. producer's prices. See Exhibit INJ-3 (Lost Sales and Lost Revenue Data). In 2013, the underselling margins by imports from China were generally in the [ ] percent range. Id.

The average unit values ("AUVs") of imports from China fell significantly over the 2011-2013 period, dropping from $994 per ton in 2011 to the extremely low level of $507 per ton in 2013.

See Exhibit GEN-6 (Volume and Value of U.S. Imports). Chinese import AUVs were well below the AUVs of other countries, with the average import AUV of all other countries standing at $762 per ton in 2013. Id.

The underselling and declining prices of imports from China resulted in the depression of

U.S. producer prices during the 2011-2013 period. See Exhibits INJ-3 (Lost Sales and Lost

Revenue Data) and INJ-4 (U.S. Producers' Trade and Financial Data). As U.S. producers were forced to reduce their prices to compete with low-priced subject imports, domestic producers' prices fell over the past three years. Notably, the AUV of domestic producers' U.S. shipments declined from [ ] per ton in 2011 to [ ] in 2013. See Exhibit INJ-4 (U.S.

Producers' Trade and Financial Data).

The lost sales and lost revenue examples provided in Exhibit INJ-3 demonstrate that subject imports caused U.S. producers to lose sales volume and revenue, negatively affecting their bottom line. See Exhibits INJ-3 and INJ-4.

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b. Identification of CASWR Products for Which Petitioners Request Collection of Price Data

Pursuant to Section 207.11(b)(2)(iv) of the Commission' s regulations, 19 C.F.R.

§ 207.11(b)(2)(iv), petitioners recommend that the Commission collect pricing data on the

following CASWR products:

PRODUCT l: Industrial quality wire rod, grade C1006, 5.5 mm (7/32 inch) through 12 mm (15/32 inch ) in diameter, for hangers, chain link fencing, collated nails and staples, grates, and other formed products (in green condition, e.g., NOT cleaned, coated, etc.).

PRODUCT 2: Industrial quality wire rod, grades C 1008 through C 1010, 5.5 mm (7/32 inch) through 12 mm (15/32 inch ) in diameter, for hangers, chain link fencing, collated nails and staples, grates, and other formed products (in green condition, e.g., NOT cleaned, coated, etc.).

PRODUCT 3: Mesh quality wire rod, grades C1006 through C1015, 5.5 mm (7/32 inch) through 14 mm (9/16 inch) in diameter, for manufacturing of concrete reinforcement products such as wire for A-82 applications (in green condition, e.g., NOT cleaned, coated, etc.).

PRODUCT 4: Grades C1050 through C1070, 5.5 mm (7/32 inch) through 6.5 mm (1/4 inch) in diameter, for spring applications excluding valve spring (in green condition, e.g. not cleaned, coated, etc.).

PRODUCT 5: Industrial quality wire, Grades C1060 through 1065, 5.5mm (7/32 inch) through 17.5 mm (11/16 inch) in diameter, for spring wire rod used in upholstery and mechanical applications, as well as oil- tempered spring applications.

These price descriptors accounted for a significant percentage of sales made in the United States of CASWR during the past three years and, accordingly, are the appropriate products for the

Commission's analysis and comparison of U.S. producer and import prices.

3. Unfairly Traded CASWR Imports from China Have Had A Significant Negative Impact on the Domestic CASWR Industry

In assessing whether the domestic industry is materially injured by reason of unfairly-traded imports, the Commission considers relevant statutory factors reflecting the state -16- PUBLIC VERSION

of the domestic industry. See 19 U.S.C. § 1677(7)(c)(iii). The domestic CASWR industry has

suffered material injury by reason of subject imports, as manifested in the market share lost to

the unfairly-traded imports, suppressed and depressed U.S. prices, and resultant weakness and

deterioration of key U.S. industry trade and financial indicators. The significant volume of

subject imports that has undersold domestically-produced CASWR has caused U.S. production

and shipment cutbacks. The reduction in domestic sales volume, as well as suppression and

depression of U.S. prices by imports, has resulted in lost sales, decreased employment and

financial deterioration. These data, described in more detail below, provide evidence of a causal

link between rising imports of dumped and subsidized CASWR from China and the material

injury being suffered by the U.S. industry producing CASWR.

a. Decreasing U.S. Shipment and Production Trends and Low Capacity Utilization Rates for CASWR Demonstrate the Material Iniury Caused by Subiect Imports

The substantial increase in subject imports' share of the CASWR market has resulted in the domestic industry's loss of sales volume and substantial production declines. Domestic production and shipments both decreased during the 2011-13 period.' See Exhibit INJ-4 (U.S.

Producers' Trade and Financial Data). The displacement of U.S. producer sales by unfairly- traded subject imports led to anemic capacity utilization in the domestic industry. By 2013, the

U.S. industry was utilizing only [ ] percent of its capacity. Id. Petitioners have ample capacity to supply CASWR customers' requirements but have been unable to supply more

CASWR to the market due to lost sales and market share to the high volume of lower-priced, dumped, and subsidized subject imports.

' The data in Exhibit INJ-4 (U.S. Producers' Trade and Financial Data) represent actual performance information reported by the five petitioning companies during the past three years.

-17- PUBLIC VERSION RANGED DATA

In addition, the loss of U.S. market share and decrease in CASWR shipments over the

past three years has had a negative effect on domestic industry employment. Specifically,

petitioners' employment and related workers ("PRWs") declined from [ f S00] workers in 2011

to [ 1,45b] workers in 2013. See Exhibit INJ-4 (U.S. Producers' Trade and Financial Data).

The growth in volume and unfair pricing of subject imports are directly affecting the livelihood

of workers in the United States.

b. Petitioners ' Declining Operating Income Demonstrates the Injurious Impact of the Substantial Volumes of Low-Priced Imports from China

The financial performance of the domestic CASWR industry also displayed deterioration

as a result of unfairly traded imports from China. The domestic industry's net sales value

declined significantly over the past three years, falling from [ ] in 2011 to [

] in 2013. Id. This decline reflects both the decline in net sales quantity and the price

depression and suppression experienced by the domestic industry. See Exhibit INJ-4 (U.S.

Producers' Trade and Financial Data).

The increasing volumes of low-priced imports that continually undercut U.S. producer prices resulted in declining operating profits for the U.S. industry. Id. From 2011-13, the domestic producers' operating profits declined by [ ] percent. Id. The financial deterioration of the domestic CASWR industry is directly related to declining sales and revenue resulting from increased volumes of unfairly-priced imports.

C. Petitioners Have Lost Sales and Revenues to Unfair CASWR Imports from China

The existence of a causal link between rising import volume and market share and U.S. producers' declining profits and market share is corroborated by the anecdotal lost sales and lost revenue information collected and attached as Exhibit INJ-3. This exhibit identifies instances in -18- PUBLIC VERSION which petitioners lost sales to unfairly traded CASWR imports from China, as well as transactions in which petitioners lost revenues due to being forced to lower their prices in response to competing bids from unfairly-traded CASWR imports from China. Id. This evidence of lost sales and revenues ties the financial performance of the domestic industry to the injurious price and volume of dumped and subsidized subject imports.

IV. THE DOMESTIC INDUSTRY IS THREATENED WITH FURTHER MATERIAL INJURY BY REASON OF UNFAIR IMPORTS OF CASWR FROM CHINA

In addition to analyzing present material injury, the statute requires the Commission to determine whether the domestic industry is threatened with material injury by reason of the unfair imports. 19 U.S.C. § 1677(7)(F). In making this determination, the Commission is directed to examine a number of factors specified in the statute, including, inter alia, an increase in foreign producers' productive capacity or existing unused capacity; a significant rate of increase of the volume or market penetration of the subject imports; and the likelihood that imports of the subject merchandise are entering at prices that will have a significant depressing or suppressing effect on domestic prices. 19 U.S.C. § 1677(7)(F)(i).

As indicated below, there is ample evidence that imports of CASWR from China also present a massive and imminent threat of further material injury to the domestic industry.

• Chinese CASWR productive capacity is massive. Petitioners have identified at least 33 major producers of carbon steel wire rod in China, many of which have annual CASWR productive capacities of [ ] metric tons. See Exhibit INJ-5. Total production of CASWR in China was over [ ] in the first eleven months of 2013. Id. at [ ]. This massive capacity dwarfs the [ ] of annual apparent U.S. consumption of CASWR in 2013. See Exhibit INJ-2.

• Despite massive inventories and millions of tons of unused Chinese CASWR productive capacity, Chinese producers are still building additional capacity. See Exhibit INJ-5.

-19- PUBLIC VERSION RANGED DATA

• The subject producers are highly export-oriented, with the United States being one of their primary export markets. Id. and Exhibit INJ-2.

• There has been a significant rate of increase in subject import volume and U.S. market share during the 2011-2013 period. From a volume of 144 tons and a market share of [ ] percent in 2011, subject imports increased in volume to 614,402 tons and to a market share of [ )a,^ ] percent in 2013. See section III.D.1 and Exhibit INJ-2.

• It is likely that subject imports will enter the United States at pricing levels that will depress and suppress U.S. prices in the imminent future, as they have during the past three years. See section III.D.2. In the face of recent price aggression, the threat of continued suppressing and depressing effects of subject imports on domestic prices is real and imminent. See id. PUBLIC VERSION

V. CONCLUSION

For the reasons stated in this petition, petitioners request that the Commerce Department

and the International Trade Commission initiate antidumping and countervailing duty

investigations of CASWR from China.

Respectfully submitted,

1.^'j B yawk - ALAN H. PRICE PAUL C. ROSENTHAL DANIEL B . PICKARD KATHLEEN W. CANNON CHRISTOPHER B. WELD R. ALAN LUBERDA WILEY REIN, LLP BENJAMIN BLASE CARYL 1776 K Street, N.W. KELLEY DRYE & WARREN LLP Washington, DC 20006 3050 K Street, N.W., Suite 400 (202) 719-3375 Washington, D.C. 20007 (202) 342-8400 Counsel to Nucor Corporation Counsel to 4rcelorMittal USA LLC, Charter Steel, Evraz Rocky Mountain Steel, Gerdau Ameristeel US Inc., and Keystone Consolidated Industries, Inc.

ECONOMIC CONSULTANTS:

GINA E. BECK JULIE H. SANTOBONI GEORGETOWN ECONOMIC SERVICES, LLC 3050 K Street, N.W., Suite 400 Washington, DC 20007 (202) 945-6660

Dated: January 31, 2014 PUBLIC VERSION

VOLUME I EXHIBITS : TABLE OF CONTENTS

Exhibit GEN-1 Industry Support Data

Exhibit GEN-2 History of Prior Actions

Exhibit GEN-3 Description of Merchandise, USITC Pub. 4014, pp. I-22 - I-27

Exhibit GEN-4 Excerpts from HTSUS Chapter 72, 2013-2014

Exhibit GEN-5 Chinese CASWR Producers and Exporters

Exhibit GEN-6 Volume and Value of U.S. Imports

Exhibit GEN-7 List of U.S. Importers

Exhibit INJ-1 Negligibility Chart: U.S. Imports Dec. 2012 -Nov. 2013

Exhibit INJ-2 Import Volume and Market Share

Exhibit INJ-3 Lost Sales and Lost Revenue Data

Exhibit INJ-4 U.S. CASWR Producers' Trade and Financial Data

Exhibit INJ-5 Articles Concerning Chinese CASWR Industry Exhibit GEN-1 PUBLIC VERSION

RANGED DATA

Carbon and Certain Alloy Steel Wire Rod ("CASWR")

STANDING CALCULATIONS

U.S. PRODUCTION IN 2013 (in short tons):

ArcelorMittal USA LLC Charter Evraz Rocky Mountain Stee Gerdau Ameristeel US Inc. Keystone Consolidated Industries, Inc. Nucor Corporation Petitioners' Subtotal

I I

TOTAL U .S. PRODUCTION I

THOSE IN SUPPORT OF THE PETITION AS A SHARE OF TOTAL U.S. PRODUCTION

THOSE IN SUPPORT OF THE PETITION AS A SHARE OF THOSE EXPRESSING SUPPORT OR OPPOSITION I

Source: Production figures represent actual data reported by [ r,pvv, g0Lr%e,$ $ AN1-N If

0((X6+ ] and [ orbnwS I

Prepared by Georgebwn Economic Services PUBLIC VERSION

DECLARATION OF [ f)CLYhe-, 1

I, [ r-so. f_ ] do hereby declare and state that:

1. [ De d ay-avyt \ s ex pert ^+n ce and pos f+10 ".

I 2. I Z D 13 ? rod u c-+t ova x v\4)r ma+-t d vN eKp lainai--^ 0 N . I [name I

[ name. I

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January 27, 2014 PUBLIC VERSION

DECLARATION OF f, AaYy\e--

1 do hereby declare and state that; I' 1 ►n0.Ylfle Cynplocjer and po%t+lovn I

3. I do.A%x. I

s igna^vre,

January 27.20:14 Exhibit GEN-2 EXHIBIT G E N-2

CHRONOLOGY OF ANTIDUMPING AND COUNTERVAILING DUTY INVESTIGATIONS, SECTION 201 INVESTIGATIONS, AND OTHER RELATED PROCEEDINGS INVOLVING CASWR

Antidumping and Countervailing Duty Investigations

Filing Date of, I Initiation Type of Country Disposition Petition Date Investigation j Feb. 8. 1982 Mar. 4, 1982 I Section 701 of Brazil I Brazil: I the Trade Act Belgium Investigation ("Inv.) suspended on Sept. 27, 1982 (47 of 1930 (the France FR 42399) "Act'' (^C.)VD i ^ Inv. terminated on Oct. 21, 1985 (50 FR 33809)

Belgium & France: 1 Inv. terminated (petition withdrawn) on Nov. 9, 1982 (47 j FR 50732)

Feb. 8. 1982 j Mar. 4. 1982 11 Section 303 of Argentina Argentina: the Act South Africa ( Inv. suspended on Sept_ 27: 1982 (47 FR 42393); (CVD) i Order revoked (ITC negative sunset) (Pub. 3270. Jan. 2000) i I South Africa: ` e Order issued on Sept. 27. 1982 (47 FR 42396); Order revoked on Oct. 7, 1985 in DOC changed j ' circumstances review (50 FR 40885)

Feb. 8. 1982 Mar. 4, 1982 ' Section 731 of Venezuela Negative Injury (Pub. 1338, Feb. 1983) the Act (AD) I Sept. 30, 1982 I Oct. 26, 1982 Section 731 of ; Brazil I Brazil: I I the Act (AD) 1 Trinidad & Affirmative injury (Pub. 1444, Oct. 1983) 1 Tobago . Order revoked on Sept. 20, 1985 and replaced with f Voluntary Restraint Agreement ("VRA") (50 FR 38150)

Trinidad & Tobago: j • Affirmative injury (Pub. 1444, Oct. 1983) • Order revoked on Dec. 3, 1987 and replaced with VRA (52 FR 45982)

May 16.1983 June 15, 1983 Section 303 of Trinidad & Affirmative injury (Pub. 1444, Oct. 1983) the Act Tobago Order revoked on Dec. 14, 1987 and replaced with VRA I (CVD) (52 FR 47440)

Nov. 23, 1983 Dec. 21. 1983 Section 701 of Spain Affirmative injury (Pub. 1544, June 1984) the Act Order revoked on Sept. 11, 1985 and replaced with VRA { (CVD) ! (50 FR 37018) I Nov. 23.. 1983 Dec. 21, 1983 Section 303 Czechoslovakia i Czechoslovakia: of the Act Poland Inv. terminated (DOC negative) on Feb. 16. 1984 (49 FR (CVD) 6773)

Poland: • Inv. terminated (DOC negative) on May 7, 1984 (49 FR 19374)

i i i I I i I

I I

{

2 Nov. 23, 1983 1 Dec. 30, 1983 Section 731 of i Argentina ( Argentina: the Act (AD) i Mexico Affinnative injury (Pub. 1598. Nov. 1984) i i Poland e Order revoked (ITC negative sunset) (Pub. 3270, Jan. i Spain 2000 I ) I r 1 Mexico: j Inv. terminated (petition withdrawn) on July 6, 1984 due i { to VRA (49 FR 27806) i Poland: ITC negative (Pub. 1574, Sept. 1984) l1 Spain: i ® Affirmative injury (Pub. 1598, Nov. 1984) i Order revoked on Sept. 16, 1985 and replaced with VRA ! (50 FR 37560) Ii Sept. 26, 1984 Oct. 24, 1984 Section 731 of 11 German a Inv. tenninated (petition withdrawn) on Aug. 1, 1985 j i the Act (AD) Democratic and. replaced with VRA (50 FR 31213) 1 I i Republic i i Apr. 8, 1985 May 3, 1985 ':. Section 731 of Poland , Poland: j i the Act (AD) ! Portugal Inv. terminated (petition withdrawn) on Sept. I0. 1985 Venezuela { and replaced with VRA (50 FR 36909) j i Portugal: Inv. terminated (petition xithdrawn) on Dec. 10, 1985 and replaced with VRA (50 FR 50335) I I I Venezuela: I Inv. terminated (petition withdrawn) on Aug. 12, 1985 j i and replaced with VRA (50 FR 32465) Apr. 8, 1985 May 6, 1985 Section 701 Portugal Inv. terminated (petition withdrawn) on Dec. 1.0, 1985 of the Act I Venezuela and replaced with VRA (50 FR 50335) ! (CVD) June 12, 1985 July 11, 1985 ; Section 303 of Saudi Arabia Order issued on Feb. 3, 1986 (51 FR 4206) the Act • Order revoked on Nov. 15, 1994 (59 FR 58814) (CVD) I Aug. 8, 1985 Sept. 5, 1985 ! Section 303 Singapore . Inv. terminated (Negative at DOC) on Tan. 27, 1986 (51 j I of the Act FR 3357) (CVD) Sept. 23; 1985 Oct. 18, 1.985 Section 303 New Zealand • Order issued on Mar. 7, 1986 (51 FR 7971) of the Act . Order revoked on May 26, 1995 due to enactment of the (CVD) Uruguay Round Agreements Act of 1994 (URAA) (See j 60 FR 27693) I I I I Mar. 4, 1986 Mar. 31, 1986 Section 303 Malaysia Malaysia: I of the Act Zimbabwe Inv. terminated (petition withdrawn) on Aug. 14, 1986 (CVD) (51 FR 29145) I Zimbabwe: Order issued on Aug. 15, 1986 (53 FR 13303) Order revoked on Sept. 29, 1995 due to URAA (60 FR I 50503)

Sept- 3, 1987 i Sept. 307 1987 Section 303 of 1 Malaysia i • Order issued on Apr. 22, 1988 (53 FR 13303) ! the Act Order revoked on May 26.1995 due to URAA (See 60 (CVD) I FR 27693)

Oct. 22, 1987 Section 303 of Singapore i • Inv. terminated (DOC negative) on May 6,. 1988 (53 FR the Act I 16304) (CVD)

I ^ i!

4 Apr. 23, 1. 993 Apr. 30, 1993 Section 731 of Brazil i Canada: the Act (AD) Canada Inv. terminated (petition withdrawn) on May 4, 1994(59 Japan FR 23053) Trinidad & j ! Tobago Brazil & Japan: ITC final negative (Pub. 2761, Mar. 1994) I ! Trinidad & Tobago: ` Inv. terminated (negative prelim. injury) (Pub. 2647, June 1993) i Feb. 14, 1994 Mar. 14, 1994 Section 731 of Belgium { Belgium: the Act Germany i Inv. terminated (petition withdrawn) on Aug. 2, 1994 j i (CVD) (59 FR 39324)

Germany: ' e Inv. terminated (ITC prelim. negative) (Pub. 2760. Mar. ! 1994) ! Feb. 14, 1994 i Mar. 14, 1994 I Section 701 of I Germany j Inv. terminated (ITC prelim. negative) (Pub. 2760, Mar. ? the Act (AD) I 1994) j

Feb. 26. 1997 Mar. 24; 1997 i Section 731 of Canada ITC final negative (Pub. 3087, Mar. 1998) ! ! the Act (AD) Germany j Trinidad & Tobago Venezuela j

! ! i j

^ i j i Feb. 26; 1997 Mar. 24. 1997 Section 701 of Canada Germany: the Act i Germany Inv_ terminated (negligible imports) (Pub. 3075; Nov. I (CVD) i "Trinidad & 1997) Tobago i Venezuela Canada, Trinidad & Tobago, Venezuela: ITC final negative (Pub. 3075; Nov. 1997)

I i

Aug. 31, 2001 Oct. 2. 2001 ' Section 731 of Brazil Egypt, South Africa, and Venezuela: the Act (AD) Canada Inv. terminated (ITC prelim. negative) (Pub. 3987, Mar. Egypt 2008, 3r`^ Remand) j Germany Indonesia Germany: Mexico • Inv. terminated (negligible imports) (Pub_ 3546, Oct. I ; { Moldova 2002) South Africa Trinidad & Canada: Tobago Affirmative injury (Pub. 3730. Oct. 2004, Remand) I ! Ukraine ® Order revoked (ITC negative in 1tit^ sunset) (Pub. 4014, i Venezuela Jun. 2008) ' i

Brazil, Indonesia, Mexico, Moldova, and Ukraine: i • Affirmative injury (Pub. 3546, Oct. 2002) • Affinnative 1" sunset (Pub. 4014, Jun. 2008) i • Currently in 2"d Full Sunset Review (78 FR 60316, Oct. i 1, 2013) i i Trinidad & Tobago: • Affirmative injury (Pub. 4170, June 2010, 2"'1 Remand) j o Affinnative I" sunset (Pub. 4014; Jun. 2008) I) • Currently in 2nd Full Sunset Review (78 FR 60316, Oct. 1.2013) I

6 Aug. 17 2001 Oct. 1, 2001 Section 701 of ! Brazil Trinidad & Tobago and Turkey: j y the Act Canada i e Inv. terminated (DOC negative) on Aug. 30, 2002 (67 (CVD) Germanv FR 55810) Trinidad & Tobago Germanv: i Turkey Inv. tenninated (negligible imports) (Pub. 3546, Oct. i 2002) j Canada: Affirmative injury (Pub. 3730, Oct. 2004, Remand) j Order revoked in DOC changed circumstances review i ' on Jan. 23, 2004 (69 FR 333 0)

Brazil: e Affirmative injury (Pub. 3546, Oct. 2002) e Affirmative I" sunset (Pub. 4014, Jun. 2008) . Currently in 2"d Full Sunset Review (78 FR 60316, Oct. 1, 2013)

Nov. 10, 2005 Dec. 7, 2005 i Section 731 of China ^ China, Germany and Turkey: 1 the Act (AD) Germany ; Inv. terminated (ITC prelim. negative) (Pub. 3832, Jan. Turkey 2006)

7 SafejZuard Investigations

Filing Date of Petition Type of Investigation Disposition

Jan. 24, 1984 Section 201 of the Act (TA- . Negative with respect to carbon steel wire rod (Pub. 1553, 201-51) July 1984)

Jan. 12, 1999 Section 201 of the Act e Affirmative, 3-3 vote; except for Canada and Mexico (Pub. (TA-201-69) 3207; July 1999) • President announced relief to the industry on Feb. 16; 2000; in the form of tariff rate quota (`' FRQ") for 3 years and 1 day (Pres. Proclamation 7273) • On Nov. 21, 2001; the President modified the TRQ to be allocated among four supplier country groupings (Pres. Proclamation 7505) • Relief expired on March 1, 2003.

July 24, 2001 Section 312(c) of NAFTA . ITC made an affirmative determination that Canada and Implementation Act (NAFTA- Mexico were undermining the section 201 relief to the 312-1) i domestic wire rod industry (66 FR 45692, Aug. 29, 2001) • President declined to extend the import relief to imports ! from Canada and Mexico

Apr. H. ; 2003 Section 204(d) of the Act e On Apr_ 11, 2003, ITC instituted an investigation to (TA-204-6) evaluate effectiveness of the relief (68 FR 19578) On August 28; 2003; the ITC transmitted its report to the President and Con<_7ress (Pub. 3629, Aug. 2003)

8 Exhibit GEN-3 Carbon and Certain Alloy Steel Wire Rod from Brazil , Canada, Indonesia , Mexico, Moldova , Trinidad and Tobago, and Ukraine

I nvestigation Nos. 701-TA-417 and 731-TA-953, 954, 957-959, 961, and 962 (Review)

Publication 4014 June 2008

Washington, DC 20436 Tariff "Treatment

Wire rod is imported under the following statistical reporting numbers ofthe Harmonized Tariff Schedule ofthe United States ("HTS"): 7213.91.301 1, 7213.91.3015, 7213.91.3092, 7213,91,4500, 7213,91,6000, 7213.99.0030, 7213.99.0090, 7227.20.0000, 7227. 90.6010, and 7227,90,6080," At the time of the original investigations general U,S. tariffs on wire rod, applicable to U,S. imports that are products of the subject countries and classified under these headings , ranged from 0.8 to 0.9 percent ad valorem for nonalloy steel and were 1 , 8 percent ad valorem for alloy steel . By January 1, 2004, these tariffs had been eliminated , resulting in a general duty rate of"Free,"

THE DOMESTIC LIKE PRODUCT

Description and Uses

Wire rod is a hot-rolled intermediate steel product of circular or approximately circular cross section that typically is produced in nominal fi•actional diameters from 7/32 inch (5.6 nun) to 47/64 inch (18.7 mm) and sold in irregularly wound coils, primarily for subsequent drawing and finishing by wire drawers. " s Wire rod sold in the United States is categorized by "quality" according to end use. End-use categories are broad descriptions with overlapping metallurgical qualities, chemistries, and physical characteristics." 'I'able 1-12 presents quality and commodity descriptions for 1 I major types of wire rod, as indicated by the Iron and Steel Society. Industrial quality wire rod currently accounts for the majority of wire rod consumed in the United States. It is primarily intended for drawing into industrial (or standard) quality wire that, in turn, is used to manufacture such products as nails, reinforcing wire mesh and chain lint: fence. Most of the industrial quality wire rod is produced and sold in the smallest cross-sectional diameter that is hot rolled in substantial commercial quantities (7/32 inch or 5,6 mm). Industrial quality wire rod generally is manufactured From low- or medium-low-carbon steel.'"

17 "I,here have been several changes to the FITS classifications for reporting IJ,S. imports of wire rod. The following are the relevant statistical reporting numbers Rn- subject wire rod during previous periods: 2002: 7213.91.3010, 7213.91.3090, 7213.91.4510, 7213.91.4590. 7213.91.6010, 72 13,91.6090, 7213.99.0031, 7213.99.0038, 7213.99,0090, 7227,20.0010, 7227.20,0020, 7227,20.0095, 7227.90.6051, 7227.90.6053, and 7227.90.6059. 2003: 7213.91.301(1, 7213.91.3090, 7213.91.4510, 7213.91.4590, 7213.91.6010. 7213.91,6090. 72- 13,99.0031, 7213,99.0038, 7213.99.0090, 7227.20.0010, 7227.20.0020, 7227.20.0095, 7227,90,605 1, 7227.90.6053, and 7227.90.6059. 2004: 7213.91,301 I, 7213,91.3091, 7213.91.4500, 7213.91.6000, 7213.99.0030. 7213.99.0090, 7227.20.0000, and 7227.90.6050. 2005: 7213.91.3011, 7213.91,3015, 7213.91.3092, 7213.91.4500, 7213.91.6000, 7213.99.0030, 7213.99.0090. 7227.20.0000, and 72227.90.6050. 2006-08: 7213.91.301 1, 7213.91.3015, 7213.91.3092, 72 13.91.4 5001 7213.91.6000, 7213.99.0030, 7213,99,0090, 7227.20.0000, 7227.90.6010, and 7227.90.6080. 31 Wire drawers (also referred to as redi'mvers) manulitcture wire and wwire products and may be independent of" the wire rod manufacturers or may be affiliated parties. Steel ductility, hardness, and tensile strength are positively correlated with carbon content. Alloying elements can be added dining the melt stage of the steelmaking process to convey various characteristics to 1110 wire rod. 10 Iron and Steel Society, Steel Products kfonuul: Carbon Steel IVire and Rocls, August 1993.. p. 36.

1-22 Table 1-12 Wire rod : Quality, end uses , and im portant characteristics Quality End uses Important characteristics

Chain quality Electric welded chain Butt-welding properties and uniform internal soundness

Cold-finishing quality Cold-drawn bars Surface quality

Cold-heading quality Cold-heading, cold-forging, cold- Internal soundness, good surface extrusion products quality, may require thermal treatments

Concrete reinforcement Nondeformed rods for reinforcing Chemical composition important concrete (plain round or smooth surface only insofar as it affects mechanical rounds) property

Fine wire Insect screen, weaving wire, florist wire Rods must be suitable for drawing into wire sizes as small as 0.035 inch (0.889 mm) without intermediate annealing; internal quality important

High carbon and medium-high Strand and rope, tire bead, upholstery Requires thermal treatment prior to carbon spring, mechanical spring, screens, drawing; however, it is not intended aluminum conductors steel reinforced to be used for music wire or valve core, prestressed concrete strand; pipe spring wire wrap wire is a subset

Industrial (standard) quality Nails, coat hangers, mesh for concrete Can only be drawn a limited number reinforcement, fencing of times before requiring thermal treatment

Music spring wire Springs subject to high stress; valve Restrictive requirements for springs are a subset chemistry, cleanliness, segregation, decarburization, surface imperfections

Scrapless nut Fasteners produced by cold heading, Internal soundness, good surface cold expanding, cold punching, thread quality tapping

Tire cord Tread reinforcement in pneumatic tires Restrictive requirements for cleanliness, segregation, decarburization, chemistry, surface imperfections

Welding quality Wire for gas welding, electric arc Restrictive requirements for uniform welding, submerged arc welding, metal chemistry inert gas welding

Source: Iron and Steel Society, Steel Products Manual: Carbon Slee/ Wire and Rods, August 1993, pp. 35-37.

I-23 Other relatively large-volume qualities of wire rod consumed in the United States include high- and medium-high carbon and cold-heading quality. 1-ligh- and medlun-high carbon wire rod are intended for drawing, into wire for such products as strand, upholstery Spring, mechanical Sprint),, rope, screens, and pre-stressed concrete wire." Cold-heading quality wire rod meeting ASTM F2282, a quality standard, generally is used in the production of industrial fasteners and other products that must be cold headed, cold forged, or cold-extruded."'

Manufacturing Process

The manufacturing process for wire rod consists of several stages: (1) steelmaking, where the steel's chemistry is fixed; (2) casting the steel into a semifinished shape (billet); (3) hol-rolling the billet into rod on a multistand, high-speed rolling mill; and (4) coiling and controlled cooling of the wire rod as it passes along a Stelmor deck (a specialized conveyor Unique to the wire rod industry).'' U.S. and foreign wire rod Inal1ufactUITI-S have made capital investments in their production Iacilities to improve processing efficiencies and product quality. Standards ol'product quality (e.g., tighter dimensional tolerances, control over residuals, and coil weight) have become higher across the entire range of wire rod products largely in response to customer demands for improved performance on the customer's equipment. These improvements have tended to blur the distinctions among quality terms over time." Most US. wire rod producers use minimill technology to melt scrap in an electric arc furnace. The exceptions to this are (1) Republic Technologies (formerly USS/Kobe), which employs the integrated route to steelmaking (i.e., a basic oxygen furnace using pig iron, which is produced from iron ore), and (2) those rod producers who are not steelmakers and, therefore, purchase billets. Both *** purchase billets for their specialty products."

11,1'he end uses of very high quality wire rod are those where nlanul'acturing process involve huge amounts of cold deformation ol'the steel such as in recessed quality colic heading; those that are safety critical, such as automotive wheel bolts and tire reinforcing wire; those that have very demanding consistency requirements or unusual steel chenlisty requirements, such as certain welding grades: and other applications that put unusual and dcnlanding rcquircntcnts on the steel. Posthcaring brieful'k aeu. Ans\\ers to Commissioners' Questions p. 15. ASfM F2282 establishes quality assur,ulcc requirements 1101111C physical, nlechtill iCa1. and metallurgical requirements 101- carbon and alloy steel wire, rods, and bars in coils intended for the manufacture of inechanical fasteners (bolts, nuts, rivets, screws, washers, and special parts mallUNCtured cold). The steel industry uses the term "quality" to designate material having characteristics particularly well suited to a specific labricanon and/or application and does not imply "quality" in the usual sense. While wire rod meeting ASTM F2282 generally is termed cold-heading quality, other rod, not meeting the standard, also may be classified as cold-heading quality. ASTM F2282, however, is the standard identified in the I H'S for classifying imports of cold-heading quality wire rod. a' The Stelmor deck allows for the controlled cooling of wire rod. This cooling speed imparts certain physical characteristics, enabling producers to produce a wider range ofwirc rod qualities. Must. iinot all. U.S. Wire rod producers have installed controlled cooling capacities. 1 Carbon arnlCerleiii?AllnpSteel Wire KoditomC'hina. Germane. anell'urkev. /revs. ;Vos. 73/-1:4-1099-//U/ (Preliminary), USITC Publication 3832, January 2006. p. 1-8. -IS . S producer questionnaire, I1-6.

1-24 Wire rod producers that purchase billets, such as ***," may purchase virgin steel billets for their higher quality production." Wire rod manufacturers, such as Republic, that have steelmaking capabilities, can produce their own billets for the desired end product by using more virgin iron ore to limit residues or by using more scrap for more industrial grade products, One non-U.S. producer further claims the use of virgin iron ore enables it to produce its highest quality wire rod.'" Minimills use scrap as their primary raw material and may add direct reduced iron (DRI) or hot- briquetted iron and/or pig iron to the mix, depending on the specifications for the end product and the relative costs of the rave materials. Minimills that produce high quality rod products, such as high carbon, cold heading quality, fire cord quality, and/or other special quality wire rod may use less scrap and more DR I than other steelmakers, however the production process in general does not change.

Melt Stage

There are two primary process routes by which steel for rod is made in the United States and the seven subject countries: the integrated process, which employs blast furnaces and basic oxygen furnaces (BOFs), and the nonintegrated production processes which utilizes an electric are furnace (EW') to produce raw steel, in both processes, pig iron, steel scrap, and/or DR I" is charged into 1301-'s or FAY"s. Most of the steel produced in the United States Im rod production is melted !font scrap it) Ill ["Al", although pig iron may be used as part of the [?Al' charge. Alloy agents are added to the liquid steel to impart specific properties to finished steel products. The molten steel is poured or tapped from the furnace to a ladle, which is an open-topped, refractory-lined vessel that has an olT center opening in its bottom and is equipped with a nozzle. Meanwhile, the primary steelmaking vessel (I-AP or 1301") may be charged with new materials to begin another relining cycle. Molten steel typically is treated in a ladle metallurgy station, where its chemistry is refined to give the steel those properties required for specific applications, At the ladle metallurgy, or secondary steel making, station the chemical content (particularly that of carbon and sulfur) is adjusted, and alloying agents may be added. The steel may be degassed (eliminating oxygen and hydrogen) at low pressures.' Ladle metallurgy stations are equipped with electric are power to adjust the temperature ofthe molten steel for optimum casting and to allow it to serve as a holding reservoir for tile lundish.

10 ***. [-mail from *** March 19, 2008. '" * * * questionnaire responses. Virgin here refers to billets from iron ore that is mined and refined. Sled producers nlay choose to use higher portions of virgin ore, commonly in the form of'pig iron, direct reduced iron, or taconite pellets, in their production mix to limit residual elements found in recycled scrap. 's ***,s questionnaire, II- l. " The advantage of using DR) or pig iron (1301' steel) is the low levels ofresidual elements (copper, chromium, nickel, molybdenum, and tin) and reduced gaseous content (parliculttt'ly nitrogen) that tlley impart to the steel. Compared to i3Of steel, FAP scrap-based steel contains higher levels of certain residuals. which adversely al'Icct yields and drawing efficiencies.. and limit such scrap-based steel use in certain critical applications. }0 Liquid steel absorbs gasses from the aunosphere and from the materials used in the steehnaking process. These gasses, chielly oxygen and hydrogen, cause embrittlenlent, voids, and nonmetallic inclusions. Low pressures. such US in a vacuum, aid the release. of oxygen in gas form without the need For additions of "deoxidizeas" such as silicon, altnninunl, or titanium, Which form nonmetallic inclusions. Additionally, carbon content may be reduced more easily at low pressure (because it combines with oxygen to form carbon monoxide and is released in gas Form), resulting in a more ductile steel, Moreover, hydrogen gas causes embrittlcment, low ductility, and blow holes in steel; vacuum treatment more easily removes hydrogen from the steel. I-lence the use ofdcoxidizing processes results in more efficient process and cleaner steel

1-25 Casting Stage

Once molten steel with the requisite properties has been produced, it is cast into a Rn•m that can enter the rolling process. Continuous (strand) casting is the method primarily used in the United States. In strand casting, the ladle containing molten steel is transferred from the ladle metallurgy station to the caster and the molten steel is poured at a controlled rate into a tundish, which in turn controls the rate of flow of the molten steel in to the caster's molds. The tundish may have a special design or employ electromagnetic stirring to ensure homogeneity of the steel. The strand caster is designed to produce billets in the desired cross-sectional dimensions, based on the dimensions of the rod and the design of the rolling mill. Billets may be charged directly into the rolling mill ("hot-charged") or, depending upon the rolling mill's schedule, sent to a storage yard. While in storage, they may be inspected and subjected to one or more conditioning operations (grinding, or turning for example) to ready them for hot rolling. This preparation is more common with cold-heading quality rods intended to be made into fasteners."

Rolling Stage

The wire rod rolling process determines the rod's size (diameter) and dimensional precision, depth ol'decarbtn'IZation, surface defects and seams, amount of mill scale, structural grain size, and within limits set by the chemistry, tensile strength and other physical properties. ']'here is little or no difference among the wire rod rolling mills in the United States, or between U.S. mills and their foreign competitors.' A larger billet will produce a heavier coil. Also, usable coil size may be limited by the capabilities of the wire drawer's equipment and machinery. Modern rod rolling mills consist of five parts: a roughing mill, an intermediate mill, a pre-finishing mill, a no-twist finishing mill, and a coiler combined with a conveyor cooling bed along which the coiled rod travels prior to being collected, tied, compacted, and readied for shipment. Wire rod mills typically consist of22 to 29 rolling stands and the specialized Stelmor conveyor deck.-,'-' the need for uniform metallurgical properties requires close temperature control accomplished by accelerating or retarding the rod's cooling as it is rolled and conveyed along the Stelmor deck. This is accomplished by water quench, forced air drafts, or by lowering removable hoods overtop the deck. Metallurgical quality, temperature, and dimensional tolerance usually are inspected in-line, Exiting the reheat furnace, the billet is initially reduced on the roughing mill (which usually consists of approximately five stands). It then is passed through and successively reduced in size on several more stands, termed intermediate rolling. After the last intermediate rolling stand, the rolling mill usually splits into dual lines and the product is passed along to a pre-finishing mill which reduces it further in diameter. Rod mills often employ a "twist" mill for primary and intermediate rolling, but the final rolling is nearly always on a no-twist Morgan vee mill (the rolls in each of approximately five stands are set a 90-degree angles to allow the rod to be rolled without twisting). This produces a nearly uniform non-oriented grain structure in the steel. Alter exiting the last Imishing stand, the rod is coiled into concentric loops and placed on a conveyor which moves the hot wire rod along while it cools.

" The purpose of these surface treatments is to make the steel billet softer and more ductile (annealing): in the case ol'surface grinding, scam and folds are removed. "The rolling process, however, can be optimized for various quality levels. The rolling process fur higher quality steel, such as for cold heading quality and other surface sensitive products, must be designed to maximize surface integrity. This is managed by the number ol'rolling stands used to get to a specilic end diumeter, the design of the reductions taken at each step, and the design ol'the guiding equipment used to keep the steel moving on the proper path through the mill. Nosthearing brief of Ivaco, Answers to Commissioners' Questions. p. 17. "The Stelmor deck may be optimized for specilir end products. ***. f'osthcaring hriel•ol'l\aco. Ans\vers to COmmissiOnel's' Questions, p. 17.

1-26 During ro ll ing, the rod is w ate r-cooled as it travels along the Slel mor deck ; cooling practices are varied depending o i l the designated end use of the rod and th e Cu Stol1l e f'S pl•elCrellCCS. The speed at whi ch the rod is cooled a ffects the consistency and formatio n of Its mCtaIIt11•LjCaI Stl•IICIUI•e (gralll StRICtllre and physical properties such as tensile strength). It also affects scale buildup, which determines yield losses at the wire drawer. The cooling rate may be varied through the use of renlovable covers (insulating hoods which may be independently raised or lowered) over the deck or blown-air cooling, or a combination of the two, or through varying the speed of the roller table. The end user often specifies the cooling practice of tile rod purchased. At the end of the cooling deck, workers crop the ends of each rod to remove the part of the rod which may be of lower quality due to uneven temperature control; the cropped ends are also used for testing and inspection. The rod is then collected onto a carrier, transferred to a "c" hook, com patted, tied, and readied for shipment, or for further finishing or in-house fabrication. Figure 1-1 illustrates the reheat through cooling stages of the wire rod production process.

Figure 1-1 Wire rod : Reheat and rolling process

Reheat furnace

Roughing stand

Finishing stands

Stelmor cooling deck

Source: POSCO Web site, h/iwvwv.steel-n.comlesales/gen4ral/uslcaotal /wire rod/. accessed March 10, 2008

Domestic producers manufacture various types of wire rod on essentially the same equipment, in the same facilities, and with the same production personnel. While changes to production processes are limited, changes in chemical composition, alloying elements and other raw materials, stand fittings, and cooling speed determine the quality of the wire rod produced. The basic equipment, machinery, facilities, and production personnel, however, remain, the same for the production of industrial quality, tire cord quality, welding quality, and cold heading quality wire rod. Company-specific inl'ormation compiled in response to Commission questionnaires concerning several types 01'\A/ire rod products produced in the United States are presented in section 111.

1-27 Exhibit GEN-4 Harmonized Tariff Schedule of the United States (2014) Annotated for Statistical Reporting Purposes XV 72-18 Heading/ Slat Unit Rates of Duly Subheading Suf- Article Description of fix Quantity General Special 7213 Bars an rods, hot-rolled, in irregularly wound coils, o iron or nonalloy steel: 7213.10.00 00 Concrete reinforcing bars and rods ...... kg...... Free 20%

7213.20.00 Other, of free-cutting steel ...... Free 5.5% 10 Containing by weight 0.1% or more of lead...... kg 80 Other ...... kg

Other: 7213.91 Of circular cross section measuring less than 14 mm in diameter: 7213.91.30 Not tempered, not treated and not partly manufactured ...... Free 5.5% 11 Tire cord-quality steel wire rod as defined in statistical note 4 of this chapter.. kg

15 Of Cold Heading Quality (CHQ) steel, as defined in statistical note 5 to this chapter.. kg

20 Of welding quality wire rods as defined in statistical note 6 to this chapter . , ..... , .. kg

93 Other ...... kg

Other: 7213.91.45 00 Containing by weight 0.6 percent or more of carbon ...... kg...... Free 5.5%

7213.91.60 00 Other ...... kg...... Free 6%

7213.99.00 Other ...... Free 5.5% Of circular cross section: 30 With a diameter of 14 mm or rnore but loss than 19 mm...... kg 60 With a diameter of 19 rnm or rnore...... kg 90 Other ...... kg Harmonized Tariff Schedule of the United States (2014) Annotated for Statistical Reporting Purposes XV 72.36 beading/ Stat Unit Rates of Duty Subheading Suf- Article Description of fix Quantity General Spodal 7227 Bars and rods, hot rolled, in irregularly wound coils, of other alloy steel: 7227.10.00 00 Of high-speed steel ...... kg...... Free 14%

7227.20.00 Of silico-manganese steel ...... Free 10%

30 Of welding quality wire rods as defined in statistical note 6 to this chapter ...... kg

80 Other ...... kg

7227.90 Other: Of tool steel (other than high-speed steel): 7227.90.10 Not tempered, not treated, and not partly manufactured ...... Free 12% 30 Of ball-bearing steel ...... kg 60 Other ...... kg 7227.90.20 Other ...... Froe 11% 30 Of ball-bearing steel ...... kg 60 Other ...... kg 7227.90.60 Other ...... Free 10%

05 Of high-nickel alloy steel ...... kg

10 Of Cold Heading Quality (CHQ) steel, as defined in statistical note 5 to this chapter..... kg

20 Of welding quality wire rods as defined in statistical note 6 to this chapter ...... kg

Of a circular cross section: 30 With a diameter of less than 14 mm...... kg 35 With a diametor of 14 mm or more but less than 19 rnrn ...... kg 40 With a diameter of 19 mm or more...... kg

90 Other...... kg

7228 Other bars and rods of other alloy steel; angles, shapes and sections, of other alloy steel; hollow drill bars and rods, of alloy or non-alloy steel: 7228.10.00 Bars and rods, of high-speed steel ...... Free 32% 10 Not cold-formed ...... kg Cold-formed: 30 With a maximum cross-sectional dimension of less than 18 mm ...... kg

60 With a maximum cross-sectional dimension of 18 mm or more ...... kg 7228.20 Bars and rods, of silico-manganose steel: 7228.20.10 00 Not cold-formed ...... kg...... Free 28%

7228.20.50 00 Cold-formed...... kg...... Free 28% Harmonized Tariff Schedule of the United States (2013) Annotated for Statistical Reporting Purposes XV 72-18 Heading/ Stal Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 7213 Bars and rods, hot-rolled, in irregularly wound coils, of iron or nonalloy steel: 7213.10.00 00 Concrete reinforcing bars and rods ...... kg...... Free 20%

721120.00 Other, of free-cutting steel ...... Free 5.5% 10 Containing by weight 0.1 % or more of lead...... kg 80 Other ...... kg

15 Of Cold Heading Quality (CHQ) steel, as defined in statistical note 5 to this chapter.. kg

20 Of welding quality wire rods as defined in statistical note 6 to this chapter ...... kg 93 Other ...... kg

Other: 7213.91.45 00 Containing by weight 0.6 percent or more of carbon...... kg...... Free 5.5% 7213.91.60 00 Other ...... kg...... Free 6%

7213.99.00 Other ...... Free 5.5% Of circular cross section: 30 With a diameter of 14 mm or more but less than 19 mm ...... kg 60 With a diameter of 19 mm or more...... kg 90 Other ...... kg Harmonized Tariff Schedule of the United States (2013) Annotated for Statistical Reporting Purposes XV 72-36 Heading/ Stat Unit Rates of Duty Subheading Suf- Article Description of 1 2 fix Quantity General Special 7227 Bars and rods, hot-rolled, in irregularly wound coils, of other alloy steel: 7227.10.00 00 Of high-speed steel ...... kg...... Free 14%

7227.20.00 Of silico- manganese steel ...... Free 10% 30 Of welding quality wire rods as defined in statistical note 6 to this chapter ...... kg

80 Other ...... kg

7227.90 Other: Of tool steel (other than high-speed steel): 7227.90.10 Not tempered, not treated, and not partly manufactured ...... Free 12% 30 Of ball-bearing steel ...... kg 60 Other ...... kg 7227.90.20 Other ...... Free 11% 30 Of ball-bearing steel ...... kg 60 Other...... kg 7227.90.60 Other ...... Free 10%

05 Of high-nickel alloy steel ...... kg

10 Of Cold Heading Quality (CHQ) steel, as defined in statistical note 5 to this chapter..... kg

20 Of welding quality wire rods as defined in statistical note 6 to this chapter ...... kg

85 Other ...... kg

60 With a maximum cross-sectional dimension of 18 mm or more ...... kg 7228.20 Bars and rods, of silico-manganese steel: 7228.20.10 00 Not cold-formed ...... kg...... Free 28%

7228.20.50 00 Cold-formed ...... kg...... Free 28% Exhibit GEN-5 EXHIBIT GEN-5

LIST OF FOREIGN PRODUCERSIEXPORTERS OF CASWR FROM CHINA

FOREIGN 2WIM :SS ^ _ PROD UC:ER/[?\PORI'ElZ Anshan Iron & Steel Group Corp. 1 Huangang Road Tiexi District Anshan, Liaoning Province, 114021 China Email: [email protected] Tel: +86 412 672 3090 Fax: +86 412 672 3080 Website: http://www.ansteelgroup.com Anyang Iron & Steel Group Co., Ltd Meiyuan Village (AISCO) (Angang Group Yindu District International) Anyang, Henan, 455004 China Email: [email protected] Tel: +86 372 312 0114 Fax: +86 372 393 1892 Website: http://www.angang.com.cn Baoshan Iron & Steel Co., Ltd Baosteel Administrative Center (Baosteel Group Corp.) (includes No. 885 Fujin Road Guangdong Shaoguan Iron & Steel Baoshan District, Shanghai, 201900 Co., Ltd.) China Email: customer rx,baosteel.com Tel: +86 21 26647000 Fax: +86 21 26648888 Website: http://www.baosteel.com/plc e/index.asp Baotou Iron and Steel (Group) Co., Hexi Industrial Park Ltd Kun District Baotou City, Inner Mongolia, 14010 China Email: infogbtsteel.com Tel: +86 472 218 9000 Fax: +86 472 218 3708 Website: http://www.btsteel.com

I Beijing Jianlong Heavy Industry Building 50, Block 12, Advanced Business Park, No. 188 Group Co., Ltd. West Road,South Ring 4, Fengtai District,Bejing, 100070 China Tel: +86 010 83627444 Fax: +86 010 83607005 Website: http://en.eiianlong.com/ilWeb/index.do?actionf^en^lish Beitai Iron & Steel Group Co., Ltd No. 36 Huanshan Road (a.k.a Beigang Group) (includes Mingshan District Benxi-Beiying Iron & Steel Group Benxi, Liaoning, 117022 Co.) China Email: beitaigchinabeitai.com Tel: +86 41 4486 8855 Fax: +86 41 4484 3613 Website: http://www.bxsteel.com/btsteel/index.htm Chongqing Iron and Steel (Group) Chengdu Babao Street No. 88 Co., Ltd. Guoxin Plaza, 16 floor E block Sichuan China Tel: +86 028 86277458, +86 028-86277468, +86 028 86277478 Fax: +86 028 86267458 http://www.cqgtjt.com Fugang Group Pan Jia Zhuang Industrial Zone, Jiu Guan Town, Huzhou City, Zhejiang, 313011 China Email: infogf isteels.com Tel: +86 572 3511711 Fax: +86 572 3511715 Website: www.fusteels.com Guangxi Liuzhou Iron and Steel North Bird Road 117 (Group) Company Liuzhou, Guangxi, 545002 China Wesbite: http://www.liuzhousteel.com/ Guofeng Iron and Steel Wesbite: http://ww-w.gfgt.com/defaultl.g.^px Handan Iron & Steel Group Co., Ltd. Fuxing Road 232 Handan, Hebei China Email: [email protected] Tel: +86 310 6072141 Wesbite: http://www.hgit.com.cn/en/index.aspx Hangzhou Iron & Steel Group Wesbite: http://en.hzsteel.com/web/index.asp Company

2 Hebei Iron & Steel Group Co., Ltd No.40 Yuhua West Road (includes Jin Ding Heavy Industry Shijiazhuang, Hebei, 050000 Co., Ltd.) China Email: infoghebgtit.com, hbgtjdzg_(iD163.com Tel: +86 311 6677 8886 Fax: +86 311 66778662 Website: http://www.hebgft.com Hebei Xinjin Iron and Steel Co., Ltd Tongan North Road (includes Xuanhua Iron & Steel Wu'an City, Hebei Province, 56300 Group and Tang Steel) China Email: [email protected] Tel: +86 310 5630685, +86 310 5688556, +86 310 5630686 Fax: +86 310 5630661 Website: http://www.xiniinsteel.com Henan Jiyuan Iron & Steel Group Tiantan District Co., Ltd Jiyuan, Henan, 454650 China Email: [email protected] Tel: +86 391 6688 172, +86 391 6695 008 Fax: +86 3916695008 Website: http://www.haig.com Hunan Valin Xiangtan Iron & Steel Gangcheng Road Co., Ltd (XISC) (subsidiary of Yuetang District Hunan Valin Iron & Steel Group Xiangtan City, Hunan Province, 411101 Co., Ltd.) China Tel: +86 731 5865 2516, +86 731 58659077 Fax: +86 731 58659075, + 86 731 58663053 Website: http://www.hnxg.com.cn Jiangsu Shagang Group Co., Ltd Jin feng Zhangjiagang City, Jiangsu Province, 215625 China Tel: +86 512 5856 8872, +86 512 58568873 Fax: +86 512 5855 1627 Website: http://www.sha-steel.coM/sg Jiangsu Yonggang Iron & Steel YongLian Industrial park Group Co., Ltd Nanfeng Town Zhangjiagang City, Jiangsu Province, 215628 China Email: [email protected] Tel: +86 512 58612888 Fax: +86 512 58612528 Website: http://www.yong-gang.com Jiangxi PXSteel Industrial Co., Ltd. Email: wlzx(a)pxsteel.com Website: http://www.pxsteel.com/

3 Jinxi Group East Third Ring Road No. 9, Building 2901, Room 3 Chaoyang District, Beijing China Wesbite: http://hbjx.com.cn Jiuquan Iron & Steel (Group) Co., No. 12 Xiongguan East Road Ltd (JISCO) (includes Yugang East Xiongguan (Yuzhong Iron & Steel)) Jiayuguan City, Gansu, 735100 China Email: hon aigiiugan .com Tel: +86 937 671 141 1 Fax: +86 937 671 141 1 Website: http://www.jiggang.com Kuming Iron & Steel Holding Co., Anning City, Yunnan Province, 650302 Ltd. (KISC) China Email: lzy7245gynk .com Tel: 86-871-68607457 Fax: 86-871-68606802 Website: http://Ynkg.com/web/guest/home Laiwu Iron and Steel Group. Co., House before Gangcheng Avenue 99 Ltd. Laiwu City, Shandong Province, 271104 China Website: http://www.laigang.com/index.asp Ling Yuan Iron and Steel Group Co., Steel Road, No. 3 Ltd. Lingyuan City, Liaoning Province China Wesbite: http://lgit.com.cn/LoginDispAction.do Maanshan Iron & Steel Co., Ltd No. 8 Jiuhuahuaxi Road Maanshan City, Anhui Province, 243003 China Tel: +86 555 288 3492 Fax: +86 555 288 4350 Website: http://www.masteel.com.cn Nanjing Iron and Steel United Co., Wesbite: Ltd. http://www.nisteel.com.cn/portal/welcome/index.*sp Pingxiang Iron & Steel Co., Ltd Room 1219 No. 669 Lvyin Road Honggutan New Area Nanchang City, Jiangxi Province, 330022 China Email: wlzxgpxsteel.com Tel: +86 791 675 3021 Website: http://www.,oxsteel.com

4 Qingdao Iron & Steel Group Co. 5 Zunyi Road (Qinggang) Qingdao, Shandong Province, 266043 China Email: steelgpublic.gd.sd.cn Tel: +86 532 8481 6761 Fax: +86 532 8481 6057 Website: http://www.qdsteel.com Rizhao Steel Group (owned by No. 600 Yanhai Road Shandong, and owns/operates Rizhao, Shandong, 276806 Minmetals Yingkou Medium Plate China Co.) Email: service(,rizhaosteel.com Tel: +86 633 6188 060 Fax: +86 633 6180000 Website: http://www.rizhaosteel.com Shaanxi Longmen Iron & Steel Longmen Town (Group) Co., Ltd (includes Hancheng City, Shaanxi Province, 715405 Hangzhong Iron and Steel) China Tel: +86 913 518 2222, +86 913 518 2333, +86 913 518 2300 Fax: +86 913 5182345 Website: http://www.lm-steel.com Shandong Iron and Steel Group Co., 21 Gongyebeilu Road Ltd. Jinan, Shandong, 31200 China Tel: +86 531889 82126 Email: [email protected] Websites: http://www.iigang.com.cn, htt-p://www.sdsteel.cc Shanxi Zhongyang Iron and Steel Zhongyang, Beijiaoqu Co., Ltd. Shanxi Province China Tel: +86 358 5033489 Fax: +86 358 5033489 Website: http://www.sxagc.com.cn Shougang Changzhi Iron & Steel Ltd Changzhi, Shanxi, 47100 (includes Shougang Qian'an) China Email: cgwebechanggang com Tel: +86 355 508 6633 Website: http://www.changgang.com Shougang Group Shinjingshan Road Shingjingshan District, Beijing, 100041 China Email: bbtgmail.shougang.com.cn Tel: +86 88291114 Website: http://www.shougang.com.cn

5 Shougang Tonggang Group Tonghua Iron and Steel International Building, No. 3218 Yatai Avenue B Changchun, Jilin Province, 130022 China Wesbite: http://www.jllg.com.cn/ Tangshan Iron and Steel Group No. 9 Riverside Road Company Limited Tangshan City, Hebei Province, 063016 China Website: http://www.tangsteel.com.cn/indexl.isp Tempo International Industry Co., Shenzhen Road, Laoshan District, Ltd. Qingdao Shandong China Tel: +86 0532 8887 6338 Website: www.temposteel.com Tianjin Iron & Steel Group Co., Ltd 398 Jingtang Road Dongli District, Tianjin, 300301 China Tel: +86 22 2470 6800 Fax: +86 22 2470 6820 Website: http://www.tgsteel.com Tianjin Rockcheck Steel Group Co., Metallurgical Industry Area Ltd. Gegu Town Jiannan District, Tianjin China Email: newsgrockcheck.com Tel: +8122-58663680 Website: http://www.rockcheck.com Tianjin Tiantie Metallurgical Group Shexian Hebei Province, 056404 China Email: [email protected] Tel: +86 310 397 0114 Website: http://www.tiantie.com Tianjin Tiantie Zhaer Steel Yangdi Opposite, North of Yinhe Bridge Production Co., Ltd. Beichen District, Tianjin China Email: zhaowg962g126.com, zhaowg962gyahoo.com Tel: +86 135 02183107 Fax: +86 222 6418488 Wesbite: http://titiantiesteel.com/main.aspx

6 Tonghua Steel Group Block B No. 3218 Yatai Street Tong Gang International Building Changchun, Jilin Province, 130022 China Email: iltg_gjltg.com.cn Tel: +86 431 88623000 Fax: +86 431 88623888 Website: http://www.iltg.com.cn Weifang Special Steel Group Co., East of Weifang Road Ltd Steel Industrial Zone Weifeng City, 261201 China Email: [email protected] Tel: +86 536 767 1810 Fax: +86 536 767 1810 Website: http://www.weifangsteel.com Wuhan Iron & Steel Co., Ltd. No. 3 Yangang Road (Wuhan Iron & Steel (Group) Corp.) Qingshan District (WISCO) Wuhan City, Hubei Province, 430083 China Tel: +86 27 8680 7870, +86 8680 7873 Fax: +86 27 8680 7875 Website: http://www.wisco.com.en Wuanshi Yuhua Steel Co., Ltd North Chongyisi Street Wuanshi, Hebei Province, 56300 China Tel: +86 310 575 2581 Fax: +86 310 573 9689 Website: http://www.vuhuasteel.com Xilin Iron & Steel Group Xilin District Yichun City, Heilongjiang Province, 153025 China Email: xlgtitgl26.com Tel: +86 458 378 8334 Fax: +86 458 3716007 Website: http://www.xlsteel.com.cn Xingtai Iron & Steel Co., Ltd 262 Gangtie Nan Street Xingtai City, Hebei, 54027 China Email: [email protected] Tel: +86 3 19 204 2022, +86 319 204 2183 Fax: +86 319 262 4517 Website: http://www.xtsteel.com

7 Xinyu Iron & Steel Co., Ltd Yanjin Road Xinyu City, Jiangxi Province, 338001 China Email: xgxxygxinsteel.com.cn Tel: +86 790 629 0782 Website: http://www.xinsteel.com.cn

8 Exhibit GEN-6 U.S. Imports of Carbon and Alloy Steel Wire Rod Annual 2011-2013" Quantity in Short Tons , Value in U.S. Dollars, AUV in $/ton

Quantity 2011 2012 2013 China 144 241,938 614,402 All Others 1,253,534 1,276,956 1,100,260 Total 1 , 253,678 1 ,518,894 1,714,662

Value 2011 2012 2013 China 143,155 137,591,869 311,399,286 All Others 1,076,369,396 1,044,946,658 838,367,731 Total 1,076,512,551 1 , 182,538,527 1,149,767,017

AUV

China 994.13 568.71 506.83 All Others 858.67 818.31 761.97 Total 858.68 778.55 670.55

Source : U.S. Department of Commerce *2013 represents annualized January-November 2013 actual data.

Prepared by Georgetown Economic Services Exhibit GIN-7 EXHIBIT GEN-7

U.S. IMPORTERS OF CASWR FROM CHINA

1. C&F International 6. Macsteel International USA Corp. 16510 Northchase Dr. 801 Twelve Oaks Center Drive, Houston, TX 77060 Suite 806 Tel: 281-999-9995 Wayzata, MN 55391 Fax: 281-999-4143 Tel: 952-249-1542 Email: no email address found Fax: 952-249-0837 Website: www.ferrostaal.com Email: tkgmit r.com Website: 2. Commercial Metals Company http://macsteelintemational.com (Cometals) 6565 N. MacArthur Blvd., Suite 800 7. Stemcor USA Inc. Irving, TX 75039 350 Fifth Avenue, Suite 1526 Tel: 214-689-4300 New York, NY 10118 Fax: 214-689-5886 Tel: 212-563-0262 Email: no email address found Fax: 212-563-0403 Website: www.commercialmetals.com Email: newyork&stemcor.com Website: www.stemeor.co.uk 3. G3 Steel Group, LLC 1633 Kirkton Drive 8. Tata Steel International Americas Troy, MI 48083 475 North Martingdale Road, Suite 400 Tel: 248-524-0192 Schaumburg, IL 60173 Fax: 248-524-0406 Tel: 847-619-0400 or 800-542-6244 Email: no email address found Fax: 847-619-0468 or 207-975-8499 Website: no website found Email: TSIA(cr^,tatasteel.come Website: 4. King Steel Corporation hftp://www.tatasteelamericas.com/en/ 5225 E. Crook Road Grand Blanc, MI 48439 9. Insteel Wire Products Company Tel: 810-953-7637 1373 Boggs Drive Fax: 810-953-1718 Mount Airy, NC 27030 Email: [email protected], Tel: 336-786-2141 dscribnerkkingsteelcorp.com Fax: 336-786-2144 Website: www.kingsteelcop2.com Email: hwoltzginsteel.com Website: www.insteel.com 5. Kurt Orban Partners LLC 111 Anza Blvd., Suite 350 Burlingame, CA 94010 Tel: 650-579-3959 Fax: 650-579-3965 Email: markna,kurtorbanpartners.com Website: www.kurtorbanpartners.com

1 EXHIBIT GEN-7

U.S. IMPORTERS OF CASWR FROM CHINA

10. Duferco Steel Inc. 15. Baosteel America Inc. 101 Matawan Road, Suite 400 85 Chestnutridge Road Matawan, NJ 07747 Montvale, NJ 07645 Tel: 732-566-3130 Tel: 201-307-3555 Fax: 732-583-9406 Fax: 201-307-3358 Email: duferco(,duferconj.com, Email: [email protected] duferco@dufercosteel. com Website: www.baosteelusa.com Website: www.duferco.com 16. Bekaert Corp. 11. Hanwa American Corp. 1395 South Marietta Parkway, 18100 Von Karman, Suite 320 Building 700, Suite 708, Irvine, CA 92612 Marietta, Georgia 30067 Tel: 949-955-2780 Tel: 770-421-8520 Fax: 949-955-2785 Fax: 770-421-8521 Email: no email address found Email: no email address found Website: www.hanwa.co.ip Website: www.bekaert.com/en.aspx

12. Metals Solutions LLC 17. Alliance Wire and Steel, Inc. 31105 Bainbridge Road, Building 4 9500 West Commerce Street Solon, OH 44139 San Antonio, TX Tel: 440-349-9304 Tel: 210-892-0472 Fax: 440-349-9305 Fax: 210-892-0477 Email: purchasing@metals- Email: no email address found solutions.com Website: www.alliance-wire.com Website: www.metals-solutions.com 18. Metal One America, Inc. 13. Precision Metal Services, Inc. 6250 N. River Road, Suite 20155 418 Stump Road Rosemont, IL 60018 Montgomeryville, PA 18936 Tel: 847-685-5446 Tel: 215-661-0225 Fax : 847-685-5430/5440 Fax: 215-661-0366 Email: darek.kusnierewiczgmtlo.com Email: Website: www.metaloneamerica.com pms ,precisionmetalservices.com Website: 19. United Springs, Inc. www.precisiomnetalservices.com 6455 Canning Street Commerce, CA 90040 14. Uniwire International Ltd. Tel: 323-728-8188 509 Madison Ave., Suite 902 Fax: 323-728-8777 New York, NY 10022 Email: [email protected] Tel: 212-688-1565 Website: http://unitedspringsinc.com Fax: 212-688-2311 Email: [email protected] Website: www.uniwireintemational.com

2 EXHIBIT GEN-7

U.S. IMPORTERS OF CASWR FROM CHINA

20. M&H Metal International Packard Place, Suite 100 222 South Church Street Charlotte, NC 28202 Tel: 864-230-4114 Fax: 864-653-5598 Email: sales&mandhllc.com Website: http://haltman.wix.com/mandhllc

21. Stena Metal Inc. 1 Landmark Square, Suite 720 Stamford, CT 06901 Tel: 203-357-0111 Fax: 203-964-8443 Email: matt.sieg elkstenametal.com Website: htti):Hstenametaline.com/

22. ThyssenKrupp Steel Services 22355 West Eleven Mile Road Southfield, MI 48034 Tel: 248-233-5600 Fax: 248-233-5699 Email: no email address found Website: www.tkmna.com

3 Exhibit INJ-1 A

Monthly U.S. Imports of CASWR from China (quantity in short tons)

Quantity Dec-12 Jan-13 Feb-13 Mar-13 Apr-13 May-13 China 53,401 54,185 19,457 36,572 23,446 69,413 All Others 69,307 81,797 84,660 83,808 103,454 137,654 Total 122,708 135,981 104,117 120,379 126,900 207,068

Jun-13 Jul-13 Aug-13 Sep-13 Oct-13 Nov-13 12 Month Total China 66,145 81,892 25,502 81,839 62,226 42,524 616,603 All Others 77,219 109,575 85,778 82,570 84,870 77,189 1,077,879 Total 143,364 191,467 111,280 164,409 147,096 119,713 1,694,482

Source: U.S. Department of Commerce, IM146 Report

Prepared by Georgetown Economic Services Exhibit INJ-2 RANGED DATA CASWR VOLUMES AND MARKET SHARES PUBLIC VERSION Annual 2011 - 2013

2011 2012 2013*

Import Volume (in short tons) China 144 241,938 614,402 All Others 1,253,534 1,276,956 1,092,673 Total 1,253,678 1,518,894 1,714,662

U.S. Shipments [ Apparent Domestic Consumption [ 4,gOt^,000^

Market Share of: Imports from China [ 0 Imports from All Others [ U.S. producers [

Source: U.S. Department of Commerce and actual shipment data by [ S0%XCe,

* Import data are actual import statistics from Department of Commerce, Census Bureau, IM146, for 2011, 2012 and January-November 2013 (annualized to estimate full year 2013 imports).

Prepared by Georgetown Economic Services Exhibit INJ-3 PUBLIC VERSION NOT OTHERWISE SUSCEPTIBLE TO SUMMARY

CASWR LOST SALES

Quantity Import Detailed Product Price) Country Customer name and contact information Address Date of Quote (short price Description $ per ton of Origin ($ tons) ($ P per ton)

Page 1 Exhibit INJ-4 RANGED DATA PUBLIC VERSION

U.S. CASWR Producers' Trade and Financial Data Annual 2011-2013 (Quantity in short tons, Value in $1,000 , Average Unit Values ("AUV") in $/short tons)

% Change Trade Data: 2011 2012 2013 2011-2013 Capacity [ S,o^,DOo Production Capacity Utilization U.S. Shipments (Q) U.S. Shipments (V) [ U.S. Shipments (AUV) 14CO Production and Related Workers [ t Soo t soo

Financial Data: Net Sales M Operating Income Operating Income to Net Sales Ratio

Source: Capacity, production, shipments, employment, net sales, and operating income data represent actual data reported by AMUSA, Charter, Evraz, Gerdau, Keystone, and Nucor to Georgetown Economic Services. These data were compiled and aggregated by Georgetown Economic Services. DECLARATION OF GINA BECK

I, Gina Beck, do hereby declare and state that:

1. I am Senior Economist with Georgetown Economic Services ("GES"). I have worked for GES for 18 years.

2. I received actual capacity, production, shipment, employment, net sales, and operating income data from petitioners, AMUSA, Charter, Evraz, Gerdau, Keystone, and Nucor.

I reviewed the data, and they are accurate to the best of my knowledge . I compiled and aggregated these data for purposes of this petition.

January 29, 2014 Exhibit INJ-5 China Wire Rod price, China Wire Rod Daily prices provided by SunSirs, China Commo... Page 1 of 2

SunSirs--China Commodity Data Group

Horne Bulk Commodity Index Spot Pricey Futures Pricey Industrial Sectors. Pr

Global Language: UK DE 6 JP e, KR RU ES I FR SA Ti

China Wire Rod Price Product C Energy Fuel Oil I Dic Wire Rod Methanol gae 2013 -10-16 - 2014-01-14 :3464 Chemical 3450 Propane I Fli Benzene I- 3431 lene I Styren hloroforn-i I P :341:1 bide I Bromir 3398 Rubber & plc a3r;4 t-DPE I HDP

Textile 3J5iJ flaw silk I Dr 3345 Non--ferrous Lead ingot 10116 10/25 11/03 11/12 11/21 11/30 12/09 12/18 12/27 01'05 Steel

Cold rolled sl Commodity Sectors Price Date olled roil C< Wire Rod Steel 3343.00 2014-01-13 n 1 Sialnless Wire Rod Steel 3345.00 2014-01-12 Wire Rod Steel 3345.00 2014-01-11 Building mai Glass I WOO( Wire Rod Steel 3345.00 2014-01-10 Wire Rod Steel 3352.00 2014-01-09 Agri.cultura: Wire Rod Steel 3361.00 2014-01-08 Soybean I Pi I

Links Bloomberg - Reuters - Xinhua News Agency - China News Service(CNS) - CCTV-2- 21 cbh- cnsb

Vertical Websites China Exporters - ChinaChemical - Chemindex - PharmNet- China Medical Device.. TexNet- Chil Market Place Toocle Global- 1'oocle China-'Toocle Japan- 1"oocle Korea- Toocle Russia- ToorlC Vietnam

littp://www.suiisirs.com/ul(/pi-odetail-740.html 1/13/2014 Chinese wire rod export price moves down (30/09/2013) Page 1 of 2

Monday 0111312,014

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MARKET NEWS HC,mepatl0 ° Ne'.vx & Evei'ls' kiatW:f Nev:3 PRODUCT CATEGORIES Chinese wire rod export price moves down (30/09/2013) steel

Cormint BEIJING, 30 Sep 13 - The export price of wire rod in China is on a downward trend at present with that of SABI008 06.5-1 Onus (boron Materials for cement production added) at USD525-545/t FOB main ports in North China. Observers Indonesia slealn Coal 'redict that the price will go down slightly in coming days of this week, Interior finished products

I xpurtod products A wire rod exporter in Tangshan, Heibei Province said that the last offer for SAE1008 06.5-10ntm (boron added) last Friday was USD525A FOB Tianjin Port, down by USDIOA compared with that of SUPPORT ONLINE wo weeks ago, and he thought the price is likely to go down further phis week,

Kinh Doanh ov An • 0908 879 333 "The domestic market gets worse and the price keeps going down, so exporters have to lower offers," said the source. The price of wire rod HPB235 06.5-iOntni from ^,^N^I" C7ngha n t Boo- Aujiang Steel in Tangshan has decreased by RMB180/t since early September, and the current. price is Marketing - 0933 999 727 RMB3,240-3,260/t (VAT included). Therefore, exporters have nothing to do but reduce offers. Considering the dim domestic market and the downward price trend, the source deemed that the export price will move down again this week. mio,wrLIGHTED NEWS Another wire rod exporter in Tangshan said the current quotation for SAE1008 06.5-1 Onun (boron added) front Tangshan Steel is USD528A FOB Tianjin Port, down by USD17/t compared with that of early September. M4subis4li Corporaton to build 1,200 MW thermal The source mainly deals with products from Tangshan Steel, and the milt kept its export offer as high as power plant in Viownin USD545/t FOB Tianjin Port last month, but domestic market price went down greatly recently, so the still cut (26/12/20131 the price to a normal level. Meanwhile, seeing the downward price trend, more overseas buyers prefer to watch the market and wait for a further price decline, and few of them place orders now. The source said he only took small orders of no more than 1,000t this month, white the regular monthly sales volume is 2,000-3,000t.

Asian Metal

y jPnnl --Zama to trend QlFceul;ock .`Hooitmar Other hews HRC prices to rise In Vietnam in January (13/01/2014) - Chinese flats suppliers forecast market rebound in January'"` (1310112014) Vietnam's PVN signs contract to construct power plant (0210112014) Vietnam successful at controlling inflation, increasing exports in 2013 (25!12/2013) South Korean stainless scrap import price increases (2511212013) Mitsubishi Corporation to build 1,200 MW thermal power plant in Vietnam (25/1212013) Vietnam users ask PM to scrap plan for anti-dumping lax on sto[el (2411212013) Border trade needs nurturing' officials (24/12J2013) USA's Peabody Energy to eslablish jout venture with Chine's Shenhua Group (2411212013) China's Benxi Iron & Steel maintains offers of January-produced flats (24/12/2013)

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S ouga.ncg. Qian'an to star1 up 5 000 nitly stir€re rod milli (23'1012013)

Shougang Qian'an Iron & Steel (Qiangang), a subsidiary of Shougang Group in northern China's Hebei province, plans to bring on stream a. wire rod mill at the end of November. The mill is the relocated No. i wire rod mill from Shougang's old site in Beijing's Changping district.

The mill, with a capacity of about 500,000 metric tons` /vear, had been sourcing billets from Qiangang after Shougang closed its major steel making operation in Beijing s SiiPFCRT 0NLINF Shijingshan district at end-2010, according to a source with tot niir{e Qiangang. This line, Shougang's last longs product mill in n^ht 2 - arch J-, n _56 Beijing, was shut down in March of this year for relocating to , ^ 33s iangang in order to save billet transport and re-heating costs. ^^.. :Not CJnI1nE ) _ L' ri^hrt nov - A company source with Shougang said the mill previously produced mainly low carbon wire rod for 0,233 9S-9 '27 construction uses, medium carbon wire rod for processing and welding rod, and wire rod for tyre cord. After the relocation, the product mix Avould be essentially the same as before, he added.

'GH-1 ED NEWS It will be the first rod mill installed at Qiangang, which predominantly produces hot rolled coils and silicon sheets. The plant currently boasts a crude steel making capacity of about 8 million mt/y.

Li Fu Source: steelbb.com

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HRC prces to rise in Vietnam in January "° "13i"01 12014) Chinese "Pats suppliers forecast rnarket rebound ir, January - (13101/2014) Vietnam's PVN signs contract tc construct po er Nlant (0210112014) Vietnam successful at controll:rg inflation, mcreas ng exports in 2013 (25/12,2013) South Korean stainless scrap i:npor price P-reases (25!12/2013) http:i'^a,^\N.iicot.radin`.com.viVen-us/zone/175/news/1810-shouQano-gianan-to-start-up-500000-mty-wire-rod-mill-2S102013.aspx 1/14/2014 KOBELE a

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Kobe feel's wire rod Iires U ca i China starts c

March 14, 2013

TOKYO: March 14, 2013 - Kobe Steel , Ltd. announces that its joint venture , Kobelco Spring Wire ( Foshan ) Co.: Ltd. ( or KSIAO, has started operations in China. KSW began production of steel wire for high-quality springs in February . After obtaining product approval from its customers. KSW will go into commercial production.

KS'Af was established in January 2012 in Foshan , Guangdong Province to produce and sell steel wi!e for high-quality springs. Capitalized at 1.3 billion yen , the company has a production capacity of 600 metric tons per month . KSW is 50% owned by Kobe Steel through subsidiary Kobelco Holding (China) Co.; Ltd.; Kobe Steel 's China headquarters . Shinko Wire Company: Ltd. and Suncall Corporation each have a 25% equity share . The president is Hidenori Sakai.

China. the world ' s largest auto market , produced about 19 million cars in 2012 . Production is forecast to expand considerably over the medium- to long-term future, reaching 28 million cars in 2020.

http_/:`N\»^\N.kohelco. cojp!en lislL'releases/2013;1188212 13522_html 1/13/2014 Consequently, world automakers have been expanding their production bases in China , raising the need for the local sourcing of parts . To meet this demand , the world's major spring manufacturers have been actively adding new production lines and increasing their capacity to make engine valve springs and other high-quality springs . This, in turn , has increased demand for high-quality steel wire, the material from which the springs are made.

Kobe Steel has a roughly 50 % share of the world market for steel wire rod. the base material for steel wire . It has earned high marks from automakers in Japan, the United States and Europe for its wire rod . Booming demand in China le8 Kobe Steel to form KSW, its first overseas company to process wire rod into wire for use in engine valve springs and other high quality spring products.

Kobe Steel already has two companies in Thailand , one in the United States , and three in China that process steel wire rod for suspension springs and CHQ (cold heading quality) wire rod for fasteners . Through KSW, Kobe Steel , along with the equity participation and cooperation of wire rod processors . is strengthening its wire processing base and building a global supply network to supply high-quality special steel products.

Background Information

Profile of Shinko Wire Company; Ltd.

Location: Amagasaki , Hyogo Prefecture, Japan Established : march 1954 President : Takanori Kominami Capital: 8,062 million yen Shareholding : Kobe Steel, Ltd. 30. 71%, treasury shares 11.24%. Shinko Wire client stock ownership 3.77%, Metal One Corporation 3.35%, Mizuho Bank, Ltd. 2.57%, other 48.36`/0 Employees : About 800 (consolidated) Business : Manufacture and sale of steel wire, wire rope and other products

Profile of Suncall Corporation

L ocation: Kyoto, Japan Established : June 1943 http:'/^,\ \N-\v,kobelco.co.jp/en-elishh-eleases!?013/118b212_13522.html I /13/2014 President & C.E.O.: Shigetsugu Yoshida Capital 4;808 million yen Shareholding: Itochu Corporation 24.98%, The Master Trust of Japan; Ltd. (Kobe Steel, Ltd.) 14.88%; treasury shares 7.08%, The Sumitomo Trust and Banking, Co., Ltd. 2.94%: Bank of Kyoto, Ltd. 2.26%, other 47.86%0 Employees: About 2,070 (consolidated) Business: Manufacture and sale of automotive parts, electronic and information- related products, and optical communication devices

Kobelco (China] Holding Co.; Ltd.

Location: Shanghai, China Established: January 2011 President: Hiroshi Umeda Capital: USS59.44 million Shareholding: Kobe Steel, Ltd. 100% Employees: 22 Business: China headquarters

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Turkish Metal Producers' Sales Prices up 2 1% in Nov Over Oct Shanxi Province based Chinese steelmaker Changzhi Iron and Steel Co a subsidiary of Shougang Group, has started to carry out trial tests at its new high speed wire rod project, as announced by Shougang Group on Ferrous Metal Shipments by Russian December 20. Radways Down 5.1 % in Jan-Nov A Decade of Progress Since World's First Construction work on the project started in April of the current year, while production operations are expected to Rigless Platform Well Abandonment commence in January 2013 . The designed annual output of high speed wire rod is 1.1 million tonne, with an estimated annual output value of CNY 7. 5 billion (LSD 1. 2 billion). The wire rod products will be in a diameter Hot Searches range of 5 .5 to 25 mm , and will include medium carbon steel, high carbon steel and cold forging steel. Iron Co 4)xtluswri Line Co Gas Alarm