Notice of conclusion of administrative review: Carbon Steel Fasteners (FAS 2025 UP1)

Period of investigations

For this review, for dumping, the period of investigation (POI) and the profitability analysis period were from July 1, 2024 to February 28, 2025. For subsidizing, the POI was from March 1, 2024 to February 28, 2025.

Administrative review process

At the initiation of the administrative review, the CBSA sent requests for information (RFI) to Robertson Jiaxing, the Government of China and their known importer in order to solicit information on the costs, selling prices of subject goods and like goods, and subsidy programs. The information was requested for purposes of determining normal values, export prices, and an amount of subsidy applicable to subject goods exported to Canada.

As part of the administrative review, case briefs and reply submissions were provided by counsel representing the Canadian industry, the exporter and the importer. Details of the representations are provided in Appendix 1.

Details pertaining to the information submitted by the exporter in response to the RFIs as well as the results of the CBSA’s administrative review are provided below.

Normal values, export prices and amounts of subsidy

Robertson Jiaxing is a manufacturer and exporter of subject goods located in China. During the POI, Robertson Jiaxing exported subject goods to Canada. Robertson Jiaxing provided a response to the CBSA’s dumping RFI as well as three supplemental requests for information. Robertson Jiaxing also provided a response to the CBSA’s subsidy RFI.

Normal values

Robertson Jiaxing did not have any domestic sales of like goods during the POI/PAP, and therefore normal values could not be determined in accordance with section 15 of SIMA.

Robertson Jiaxing provided sufficient cost of production and administrative, selling and all other costs to determine normal values pursuant to paragraph 19(b) of SIMA. However, the CBSA was unable to determine an amount for profits pursuant to paragraph 11(1)(b) of the Special Import Measures Regulations (SIMR). As such, normal values were determined pursuant to section 29 of SIMA using a method similar to that of paragraph 19(b) of SIMA, based on the aggregate of cost of production of the goods, a reasonable amount for administrative, selling and all other costs plus a reasonable amount for profits.

Export price

During the POI, subject goods exported by Robertson Jiaxing were sold to Robertson Inc, a related importer. Due to the relationship between the parties, a reliability test was performed to determine whether the section 24 export prices were reliable as envisaged by SIMA. This test was conducted by comparing the section 24 export prices with the section 25 export prices. The test revealed that the export prices determined in accordance with section 24 of SIMA were unreliable. Therefore, export prices for sales to Robertson Inc will be determined in accordance with section 25 of SIMA.

Amount of subsidy

The CBSA received a timely response to the subsidy RFI from Robertson Jiaxing. However, the Government of China and the exporter/producer were notified at the initiation of the review that in cases where either the Government of China or exporter/producer in China do not provide complete and accurate submissions enabling the determination of specific amounts of subsidy, countervailing duties will be determined in accordance with a ministerial specification, pursuant to subsection 30.4(2) of SIMA. As the Government of China did not provide a response to the RFI, subject goods produced or exported by Robertson Jiaxing will be assessed countervailing duties at the rate of 1.25 Chinese Renminbi per kilogram.

These normal values, export price and amount of subsidy are effective as of today, August 28, 2025.

The normal values and amount of subsidy determined as a result of this administrative review may be applied to any requests for re-determination of importations of subject goods that have not been processed prior to the conclusion of the review, regardless of the date that the requests were received.

Exporter responsibility

All parties are cautioned that, where there are increases in domestic prices and/or costs, the export price should be increased accordingly to ensure that any sale made to Canada is not only above the normal value but at or above selling prices and full costs and profit of the goods in the exporter’s domestic market. If exporter do not adjust export prices accordingly, retroactive assessments of anti-dumping duties may be warranted. Please refer to the Memorandum D14-1-8: Administrative Review Policy – Special Import Measures Act (SIMA) for details.

Importer responsibility

Importers are reminded that it is their responsibility to declare their anti-dumping and countervailing duties liabilities. If importers are using the services of a customs broker to clear importations, the brokerage firm should be advised that the goods are subject to SIMA measures and be provided with sufficient information necessary to clear the shipments. To determine their anti-dumping and countervailing liabilities, importers should contact the exporter(s) to obtain the applicable normal values and amount of subsidy. For further information on this matter, refer to Memorandum D14-1-2: Disclosure of Normal Values, Export Prices, and Amounts of Subsidy Established under the Special Import Measures Act.

The Customs Act (Act) applies, with any modifications that the circumstances require, with respect to the accounting and payment of anti-dumping and countervailing duties. As such, failure to pay the SIMA duties within the prescribed time will result in the application of the interest provisions of the Act.

Should the importer disagree with the determination made on any importation of goods, a request for re-determination may be filed. For more information on how to file a request for redetermination, please refer to the Guide for appealing a duty assessment.

Contact us

Email: simaregistry-depotlmsi@cbsa-asfc.gc.ca

Appendix 1: Representations

Representations

During the course of the administrative review, counsel for the Canadian industry^{Footnote 1}, discussed various concerns pertaining to the responses to the RFIs and SRFIs. Issues raised included:amount of subsidy, cost reporting methodologies, export price and other various alleged inconsistencies and deficiencies within the responses.

There were a number of exporter and importer specific issues that were raised. In order to respect the confidentiality designations made by interested parties, the CBSA is limited in the information that can be divulged in response to arguments made concerning certain topics.

CBSA response

Due consideration has been given to submissions on the topics raised in case briefs on a case-bycase basis and appropriate adjustments were made, as applicable, in accordance with SIMA and SIMR. Additional information on the calculation of normal values and export price is provided to the exporter and the importer in the confidential respective conclusion letters.