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Statement of reasons—Expiry review determination: Aluminum extrusions (AE 2024 ER)

Concerning an expiry review determination under paragraph 76.03(7)(a) of the Special Import Measures Act respecting aluminum extrusions originating in or exported from China.

Decision

Ottawa,

On April 24, 2025, pursuant to paragraph 76.03(7)(a) of the Special Import Measures Act, the Canada Border Services Agency determined that the expiry of the Canadian International Trade Tribunal’s order made on January 13, 2020, in expiry review RR-2018-008:

  • is likely to result in the continuation or resumption of dumping of such goods originating in or exported from China and
  • is likely to result in the continuation or resumption of subsidizing of such goods originating in or exported from China

On this page

Executive summary

[1] On November 25, 2024, the Canadian International Trade Tribunal (CITT), pursuant to subsection 76.03(1) of the Special Import Measures Act (SIMA), initiated an expiry review of its order made on January 13, 2020, in expiry review RR-2018-008, continuing, without amendment, its order made on March 17, 2014, in expiry review RR-2013-003, continuing, without amendment its findings made on March 17, 2009, in inquiry NQ-2008-003, as amended by its determination made on February 10, 2011, in inquiry NQ-2008-003R, concerning the dumping and subsidizing of aluminum extrusions originating in or exported from China (subject goods).

[2] As a result of the CITT’s notice of expiry review, the Canada Border Services Agency (CBSA), on November 26, 2024, initiated an expiry review investigation to determine, pursuant to paragraph 76.03(7)(a) of SIMA, whether the expiry of the order is likely to result in the continuation or resumption of dumping and subsidizing of the subject goods.

[3] The CBSA received ten responses to the Canadian Producer Expiry Review Questionnaire (ERQ) from: Almag Aluminum Inc.(Almag),Footnote 1 APEL Extrusions Limited (APEL),Footnote 2 Apex Aluminum Extrusions Ltd. (Apex),Footnote 3 Can Art Aluminum Extrusion Canada Inc. (Can Art),Footnote 4 Dajcor Aluminum Ltd. (Dajcor),Footnote 5 Extrudex Aluminum Corp. (Extrudex),Footnote 6 Extrudex Aluminium (Québec) Inc. (Extrudex Québec),Footnote 7 Hydro Extrusion Canada, Inc. (Hydro),Footnote 8 Metra Aluminium Inc. (Metra)Footnote 9 and Spectra Aluminum Products Ltd./Spectra Anodizing Inc. (Spectra)Footnote 10 (these ten producers are collectively referred to “the domestic extruders”).

[4] The CBSA received three responses to the Importer ERQ from: Copper Core Limited (Copper Core),Footnote 11 HFI Pyrotechnics Inc. (HFI)Footnote 12 and Marwood Ltd. (Marwood).Footnote 13 These responses did not express an opinion on the likelihood of continued or resumed dumping and subsidizing of the subject goods.

[5] The CBSA received one response to the Exporter/Foreign Producer ERQ from Guangdong Luoxiang Aluminium Co., Ltd. (Guangdong Luoxiang).Footnote 14 The response did not express an opinion on the likelihood of continued or resumed dumping and subsidizing of the subject goods.

[6] The CBSA did not receive a response to the Subsidy ERQ from the Government of China (GOC), nor a case brief or a reply submission.

[7] In addition to responding to the Canadian Producer ERQ, the domestic extruders provided the CBSA with additional information prior to the close of the administrative recordFootnote 15 and a case brief.Footnote 16 The domestic extruders’ case brief included arguments supporting their position that the expiry of the order is likely to result in the continuation or resumption of dumping and/or subsidizing of the subject goods in Canada.

[8] No other case briefs or reply submissions were submitted to the CBSA from any interested parties.

[9] The analysis of information on the administrative record indicates a likelihood of continued or resumed dumping into Canada of aluminum extrusions from China should the CITT’s order expire. This analysis relied upon the following factors:

  • Anti-dumping measures imposed by other authorities on aluminum extrusions from China
  • China’s significant excess capacity
  • China’s export orientation

[10] The analysis of information on the administrative record indicates a likelihood of continued or resumed subsidizing into Canada of aluminum extrusions from China should the CITT’s order expire. This analysis relied upon the following factors:

  • Countervailing measures imposed by other authorities on aluminum extrusions from China
  • Continued availability of subsidy programs for aluminum extrusions exporters/producers in China

[11] For the foregoing factors, the CBSA, having considered the relevant information on the administrative record, determined on April 24, 2025 pursuant to paragraph 76.03(7)(a) of SIMA, that the expiry of the order in respect of aluminum extrusions is likely to result in the continuation or resumption of dumping and subsidizing of the goods from China.

Background

[12] On August 18, 2008, following a complaint filed by Almag Aluminum Inc., Apel Extrusions, Can Art Aluminum Extrusion Inc., Metra Aluminum Inc., Signature Aluminum Canada Inc. (formerly Bon L Canada Inc.), Spectra Aluminum Products Ltd. and Spectra Anodizing Inc., the CBSA initiated investigations pursuant to subsection 31(1) of SIMA, respecting the dumping and subsidizing of aluminum extrusions from China.

[13] On February 16, 2009, pursuant to paragraph 41(1)(a) of SIMA, the CBSA made final determinations of dumping and subsidizing with respect to aluminum extrusions from China.

[14] On March 17, 2009, pursuant to subsection 43(1) of SIMA, the CITT found in inquiry NQ-2008-003 that the dumping and subsidizing of aluminum extrusions from China had caused injury to the domestic industry.

[15] On February 10, 2011, in inquiry NQ-2008-003R, the CITT determined that MAAX Bath Inc. was entitled to the product exclusions that it had requested, at the time of the original inquiry, for certain aluminum extrusions used in the assembly of shower enclosures.

[16] On February 20, 2012, the CBSA concluded a re-investigation to update the normal values, export prices and amounts of subsidy of aluminum extrusions from China.

[17] On October 3, 2013, following the initiation of an expiry review of the CITT’s findings of injury, the CBSA determined that the expiry of the findings was likely to result in the continuation or resumption of dumping and subsidizing of aluminum extrusions from China. On March 17, 2014, in expiry review RR-2013-003, the CITT continued its findings on aluminum extrusions from China.

[18] On August 2, 2019, following the initiation of an expiry review of the CITT’s order, the CBSA determined that the expiry of the order was likely to result in the continuation or resumption of dumping and subsidizing of aluminum extrusions from China. On January 13, 2020, in expiry review RR-2018-008, the CITT continued its order on aluminum extrusions from China.

[19] On March 3, 2022, the CBSA concluded a normal value review and the cooperative exporter was issued normal values and an amount of subsidy.

[20] On November 25, 2024, pursuant to subsection 76.03(1) of SIMA, the CITT initiated an expiry review of its order made in expiry review RR-2018-008.

[21] On November 26, 2024, pursuant to paragraph 76.03(7)(a) of SIMA, the CBSA initiated an expiry review investigation to determine whether the expiry of the order is likely to result in continued or resumed dumping and/or subsidizing of the subject goods.

Product definition

[22] The goods subject to this expiry review investigation are defined as:

Aluminum extrusions produced via an extrusion process, of alloys having metallic elements falling within the alloy designations published by The Aluminum Association commencing with 1, 2, 3, 5, 6 or 7 (or proprietary or other certifying body equivalents), with the finish being as extruded (mill), mechanical, anodized or painted or otherwise coated, whether or not worked, having a wall thickness greater than 0.5 mm, with a maximum weight per meter of 22 kilograms and a profile or cross-section which fits within a circle having a diameter of 254 mm, originating in or exported from the People's Republic of China.

Exclusions

[23] The CITT excluded the following aluminum extrusions from its findings:Footnote 17

  • aluminum extrusions produced from either a 6063 or a 6005 alloy type with a T6 temper designation, in various lengths, with a powder coat finish on both the interior and the exterior surfaces of the extrusion, which finish is certified to meet the American Architectural Manufacturers Association AAMA 2603 standard, "Voluntary Specification, Performance Requirements and Test Procedures for Pigmented Organic Coatings on Aluminum Extrusions and Panels", for use in exterior railing systems
  • aluminum extrusions produced from a 6063 alloy type with a T5 temper designation, having a length of 3.66 m, with a powder coat finish, which finish is certified to meet the American Architectural Manufacturers Association AAMA 2603 standard, "Voluntary Specification, Performance Requirements and Test Procedures for Pigmented Organic Coatings on Aluminum Extrusions and Panels", for use as head rails and bottom rails in fabric window shades and blinds where the fabric has a cross-sectional honeycomb or "cellular" construction
  • aluminum extrusions produced from a 6063 alloy type with a T5 temper designation and forming part of the Vario System[trademark] 20, 30, 40, 45 and 60 series line of profiles, or equivalent, having a length of either 4.5 or 5.8 m and a straightness tolerance of +/- 1.5 mm or less per 6.0 m of length, for use in those parts of mechanical systems and automated machinery, such as gantry systems and conveyors, where precise linear movement is required
  • aluminum extrusions produced from either a 6063 or a 6463 alloy type, having a length of 3 m, with a hand-applied gold and silver leaf finish, for use as picture frame mouldings
  • aluminum extrusions produced from a 6063 alloy type with either a T5 or a T6 temper designation, having a length of between 20 and 33 ft. (between 6.10 and 10.06 m), with a powder coat finish, which finish is certified to meet the American Architectural Manufacturers Association AAMA 2603 standard ("Voluntary Specification, Performance Requirements and Test Procedures for Pigmented Organic Coatings on Aluminum Extrusions and Panels"), for use in window frames
  • heat sinks imported under tariff item No. 8473.30.90 and weighing 700 g or less and
  • aluminum extrusions produced by China Square Industrial Ltd. from either a 6063 or a 6463 alloy type with a T5 temper designation, with a profile or cross-section which fits within a circle having a diameter of 100 mm, for use by MAAX Bath Inc. in the assembly of its shower enclosures, specifically identified in the Appendix of the Determination and reasons issued by the Canadian International Trade Tribunal on February 10, 2011, in Inquiry No. NQ-2008-003R. The list of these excluded products can be found at the following link: https://decisions.citt-tcce.gc.ca/citt-tcce/a/en/item/353483/index.do.

For the excluded products listed above that require a finish which is "certified to meet the American Architectural Manufacturers Association AAMA 2603 standard", the importer must be able to provide evidence that their goods meet that standard.

Classification of imports

[24] The subject goods are normally imported into Canada under the following tariff classification numbers:

  1. 7604.10.00.30
  2. 7604.10.00.40
  3. 7604.21.00.10
  4. 7604.21.00.90
  5. 7604.29.00.11
  6. 7604.29.00.19
  7. 7604.29.00.21
  8. 7604.29.00.29
  9. 7604.29.00.30
  10. 7608.10.00.10
  11. 7608.10.00.90
  12. 7608.20.00.00
  13. 7610.10.00.10
  14. 7610.10.00.20
  15. 7610.10.00.30
  16. 7610.90.10.00
  17. 7610.90.90.10
  18. 7610.90.90.20
  19. 7610.90.90.30
  20. 7610.90.90.90

[25] These tariff classification numbers may also include non-subject goods, and subject goods may also fall under additional tariff classification numbers.

Classes of goods

[26] In its findings,Footnote 18 the CITT had separated the aluminum extrusions into two classes of goods: standard-shaped aluminum extrusions and custom-shaped aluminum extrusions.

[27] The information gathered by the CBSA in terms of statistical data and other research did not reveal any differentiation within the industry regarding the two classes of goods, with news articles and analyses consistently referring to aluminum extrusions as a whole.

[28] Therefore, unless stated otherwise, the analysis respecting the likelihood of continued or resumed dumping and subsidizing applies to both classes of goods as defined by the CITT.

Period of review

[29] The period of review (POR) for the CBSA’s expiry review investigation is from January 1, 2021 to September 30, 2024.

Canadian industry

[30] The Canadian industry for aluminum extrusions is comprised of the producers listed in Table 1.

Table 1: Canadian producers
Name Location
Almag Aluminum Inc.1 Brampton, Ontario
APEL Extrusions Limited1 Calgary, Alberta
Apex Aluminum Extrusions Ltd.1 Langley, British Columbia
Can Art Aluminum Extrusion Canada Inc.1Footnote 19 Brampton, Ontario
Dajcor Aluminum Ltd.1 Chatham, Ontario
Extrudex Aluminum Corp.1 Woodbridge, Ontario
Extrudex Aluminium (Québec) Inc.1 Saint-Nicholas, Québec
Hydro Extrusion Canada, Inc.1 Mississauga, Ontario and Pointe Claire, Québec
Kaiser Aluminum Corporation London, Ontario
Kawneer Co. Canada Ltd. Lethbridge, Alberta
Kromet International Inc. Cambridge, Ontario
Metra Aluminium Inc.1Footnote 20 Laval, Québec
Signature Aluminum Canada Inc. Pickering, Ontario
Spectra Aluminum Products Ltd. / Spectra Anodizing Inc.1 Bradford, Ontario
1These producers are collectively referred as to the domestic extruders.

[31] Each producer who forms part of the domestic extruders provided a response to the ERQ. The vast majority of the domestic extruders produce both standard-shaped aluminum extrusions and custom-shaped aluminum extrusions, and account for over 90% of the domestic production of like goods.Footnote 21

[32] The other producers, namely, Kaiser Aluminum Corporation, Kawneer Co. Canada Ltd., Kromet International Inc. and Signature Aluminum Canada Inc. did not participate in this expiry review investigation. As such, no information on their production and sales was available to the CBSA.

Canadian market

[33] The apparent Canadian market for aluminum extrusions over the PORFootnote 22 is presented in volume and share in Table 2 and in volume and unit value in Table 3. Although the sales of the other producers are not contained in the tables, the CBSA is the opinion that the domestic extruders’ data is representative when analyzing the trends in terms of sales, share and unit prices of the Canadian producers.

Table 2: Apparent Canadian market
(Volume and share)
Source 2021 2022 2023 Jan 1 – Sept 30, 2024
Volume (kg) Share (%) Volume (kg) Share (%) Volume (kg) Share (%) Volume (kg) Share (%)
Domestic extruders 154,038,272 65.5 153,339,104 64.4 135,822,676 68.7 106,347,068 64.6
China 5,263,448 2.2 8,397,406 3.5 5,798,114 2.9 8,396,126 5.1
United States 33,740,852 14.3 31,603,181 13.3 24,255,294 12.3 21,619,358 13.1
All other countries 42,219,961 17.9 44,743,238 18.8 31,692,077 16.0 28,234,095 17.2
Total market 235,262,534 100.0 238,082,928 100.0 197,568,160 100.0 164,596,647 100.0
Note Data for volumes and shares are rounded and may not add up to totals.
Table 3: Apparent Canadian market
(Volume and unit value)
Source 2021 2022 2023 Jan 1 – Sept 30, 2024
Volume (kg) Unit value ($/kg) Volume (kg) Unit value ($/kg) Volume (kg) Unit value ($/kg) Volume (kg) Unit value ($/kg)
Domestic extruders 154,038,272 6.39 153,339,104 8.07 135,822,676 7.62 106,347,068 7.54
China 5,263,448 4.79 8,397,406 5.78 5,798,114 5.38 8,396,126 5.41
United States 33,740,852 6.28 31,603,181 7.06 24,255,294 7.02 21,619,358 7.08
All other countries 42,219,961 4.58 44,743,238 5.88 31,692,077 5.40 28,234,095 5.19
Total market 235,262,534 6.01 238,082,928 7.44 197,568,160 7.12 164,596,647 6.97
Note Data for volumes are rounded and may not add up to totals.

[34] As shown in Table 2, the domestic extruders’ share of the apparent Canadian market, as a percentage of total volume of sales, fluctuated over the POR accounting for approximately two thirds of the apparent Canadian market for aluminum extrusions. In the period of January to September 2024, as compared to the year 2023, imports from China, United States and All Other Countries have increasingly captured a greater share of the total apparent Canadian market to the detriment of the domestic extruders.

[35] As shown in Table 3, the domestic extruders’ unit selling price peaked in 2022 and has subsequently continued to decrease in 2023 and in the period of January to September 2024. During the POR, the average unit prices from China and All Other Countries have remained significantly lower than the average unit prices of the domestic extruders.

Enforcement data

[36] In the enforcement of the CITT’s order during the POR, as detailed in Table 4, the total amount of anti-dumping and countervailing duties assessed on subject goods from China was $15,791,047.Footnote 23

Table 4: SIMA duties assessed during the POR from China
  2021 2022 2023 Jan 1 - Sept 30 2024
Volume (kg) 5,263,448 8,397,406 5,798,114 8,396,126
Value for duty ($) 25,203,985 48,504,559 31,180,286 45,452,894
SIMA duties ($)1 3,722,170 3,449,647 5,229,788 3,379,442
1Includes both anti-dumping and countervailing duties.

Parties to the proceedings

[37] On November 26, 2024, the CBSA sent a notice of initiation of the expiry review investigation and ERQs to the known Canadian producers, importers and exporters/foreign producers. The CBSA also sent a Subsidy ERQ to the GOC.

[38] The ERQs requested information relevant to the CBSA’s consideration of the expiry review factors, as listed in subsection 37.2(1) of the Special Import Measures Regulations (SIMR).

[39] The CBSA received responses to the Canadian Producer ERQ from Almag, APEL, Apex, Can Art, Dajcor, Extrudex, Extrudex Québec, Hydro, Metra and Spectra. Additional documents were also filed on behalf of the domestic extruders prior to the closing of the administrative record.

[40] The CBSA received responses to the Importer ERQ from Copper Core, HFI and Marwood as well as a response to the Exporter/Foreign Producer ERQ from Guangdong Luoxiang.

[41] The GOC did not respond to the Subsidy ERQ.

[42] Counsel, on behalf of the domestic extruders, filed a case brief and argued that the expiry of the order is likely to result in the continuation or resumption of dumping and/or subsidizing of the subject goods in Canada.

[43] No other interested party, including the GOC, provided a case brief or reply submission.

Information considered by the CBSA

Administrative Record

[44] The information considered by the CBSA for purposes of this expiry review investigation is contained in the administrative record. The administrative record includes the information on the CBSA’s exhibit listing, which is comprised of the CBSA exhibits and information submitted by interested parties, including information which the interested parties feel is relevant to the decision as to whether dumping and subsidizing are likely to continue or resume absent the CITT order. This information may consist of expert analysts’ reports, excerpts from trade magazines and newspapers, orders and findings issued by authorities of Canada or of a country other than Canada, documents from international trade organizations such as the World Trade Organization (WTO) and responses to the ERQs submitted by Canadian producers, importers, exporters and governments.

[45] For purposes of an expiry review investigation, the CBSA sets a date after which no new information submitted by interested parties will be placed on the administrative record or considered as part of the CBSA’s expiry review investigation. This is referred to as the “closing of the record date” and is set to allow participants time to prepare their case briefs and reply submissions based on the information that is on the administrative record as of the closing of the record date. For this expiry review investigation, the administrative record closed on January 15, 2025.

Position of the parties: Dumping

Parties contending that continued or resumed dumping is likely

[46] The domestic extruders made representations in their ERQ responses and in their case brief,Footnote 24 in support of the position that the expiry of the order is likely to result in the continuation or resumption of dumping of the subject goods from China.

[47] The main factors identified by the domestic extruders can be summarized as follows:

  • Extensive production and capacity
  • Weakening demand in China
  • Export orientation of China’s aluminum extrusions industry and
  • Restrictive trade measures

Extensive production and capacity

[48] The domestic extruders cited information on the administrative record pertaining to the production of aluminum extrusions in China as reported by the China Business Industry Research InstituteFootnote 25 and highlighted that in 2023, China’s production of aluminum extrusions was 117 times greater than the Canadian market of 198,000 metric tonnes (MT).Footnote 26

[49] In terms of capacity, from its own research, the domestic extruders prepared a list of the individual capacity of Chinese extrudersFootnote 27 and noted that the data underrepresented the total capacity given that there are many other extruders in China, and many Chinese extruders do not report their capacity. The domestic extruders emphasized that the combined capacity of only the top 10 Chinese extruders, was over 40 times the size of the Canadian market in 2023 of 198,000 MT.Footnote 28

[50] The domestic extruders contended that despite the tremendous volume of aluminum extrusions production in China, all indications are that there remains significant excess capacity.

[51] In support of its claim, the domestic extruders cited various articlesFootnote 29 and referenced a recent Reuters article which reported that “China's mid-stream aluminium processing sector is plagued by overcapacity with utilisation rates typically below 65% and as low as 40% in some sectors”. “Mid-stream aluminium processing” is understood to include aluminum extrusions and other semis.Footnote 30

[52] The domestic extruders concluded that with excess capacity, Chinese extruders will have an incentive to dump aluminum extrusions in export markets, including Canada if the order is rescinded.

Weakening demand in China

[53] The domestic extruders underlined that there had been a slowdown in China’s economy in recent years and the International Monetary Fund forecasted that such trend would continue in 2024 and 2025 with an annual growth rate of 4.8% and 4.5%,Footnote 31 respectively.

[54] The domestic extruders contended that the downturn in the Chinese demand for aluminum extrusions is directly related to the challenges facing key downstream industries which include construction, industrial and consumer applications, auto parts, solar panels and other products,Footnote 32 who are large consumers of aluminum extrusions.

[55] In terms of trends and forecasts in China, the domestic extruders provided evidence to support that the real estate and property sector is in the midst of a significant, multi-year downturnFootnote 33 and the manufacturing sector has experienced a general downward trend throughout 2024 and by the end of June 2024, approximately 30% of industrial and manufacturing firms were making losses at levels higher than during the Asian financial crisis in 1998.Footnote 34

[56] The domestic extruders also cited information on the administrative record regarding the challenges facing the automotive sector in ChinaFootnote 35 and the photovoltaic and solar industry in China.Footnote 36

[57] The domestic extruders concluded that the grim demand conditions in China for aluminum extrusions increases the likelihood that the expiry of the order will result in the continued and resumed dumping of subject goods in Canada as the lack of domestic consumption in China will push Chinese extruders to offload production in export markets by selling at discounted prices.

Export orientation of China’s aluminum extrusions industry

[58] The domestic extruders stated that China’s exports of aluminum extrusions are very significant and enough to satisfy the whole Canadian market. In support of its assertion, the domestic extruders summarized the GOC, General Administration of Customs, Export Statistics data on HS Codes 76042100, 76042910, 76042990, 76081000, 76082010, 76082091 and 76082099. On an yearly basis and for the period of January to October 2024, the export volumes of aluminum extrusions were greater than 1 million MT.Footnote 37

[59] To emphasize the export orientation of producers of aluminum extrusions in China, the domestic extruders cited information on the administrative record to demonstrate how exportation is required as part of the business model of Changshu Changfa Changsheng Aluminum Products, Shandong Huajian Aluminum and JMA Aluminum.Footnote 38 Furthermore, the domestic extruders highlighted that in its response to the Exporter/Foreign Producer ERQ, Guangdong Luoxiang stated that it plans to increase annual export sales of aluminum extrusions by 3% to 5% for 2025 to 2029.Footnote 39

[60] The domestic extruders concluded that with such extensive reliance on export markets, producers of aluminum extrusions in China will export to any market without a trade measure.

Restrictive trade measures

[61] The domestic extruders argued that the numerous anti-dumping and other restrictive trade measures currently in place on aluminum extrusions from China demonstrates China’s propensity to dump and increases the likelihood that Chinese extruders will resume or continue exporting subject goods to Canada at dumped prices if the order is rescinded.

[62] In support of its claim, the domestic extruders provided a list of jurisdictions, other than Canada, that have imposed anti-dumping measures on aluminum extrusionsFootnote 40 and on other semi-finished aluminum products, such as foil and sheet from China.Footnote 41

[63] Additionally, the domestic extruders cited information on the administrative record pertaining to other trade restrictive measures, in the form of tariffs levied on aluminum extrusions from China.Footnote 42

Parties contending that continued or resumed dumping is unlikely

[64] No other parties contended that the continuation or resumption of dumping of the subject goods from China is unlikely if the order expires.

Consideration and analysis: Dumping

[65] In making a determination under paragraph 76.03(7)(a) of SIMA as to whether the expiry of the order is likely to result in the continuation or resumption of dumping of the goods from China, the CBSA may consider factors identified in subsection 37.2(1) of the SIMR, as well as any other factors relevant in the circumstances.

[66] Prior to addressing the likely of continued or resumed dumping, the CBSA underlines that it is conducting this expiry review investigation on the basis that the conditions of section 20 of SIMA continue to exist in the aluminum extrusions sector in China. Section 20 inquiries are conducted in investigations and re-investigations.

Conditions of section 20 of SIMA in the aluminum extrusions sector in China

[67] In its last proceedingFootnote 43 on aluminum extrusions from China, with respect to the dumping portion of the re-investigation, the CBSA was of the opinion that the domestic prices of aluminum extrusions in China were still being substantially determined by the GOC and the aluminum extrusions sector in China was still operating under conditions where the prices were not substantially the same as they would be if they were determined in a competitive market. As the conditions of section 20 of SIMA were found to exist, the normal values for the exporters that provided a complete and reliable submission were determined using an alternate methodology under a ministerial specification, pursuant to subsection 29(1) of SIMA.

[68] The normal values determined for these cooperative exporters were based on the monthly average settlement price of aluminum as reported on the London Metal Exchange (LME), plus added to these LME prices were amounts for the i) conversion costs of the aluminum into a finished aluminum extrusion product, ii) administrative, selling and all other costs and iii) profit (the LME methodology).

[69] There are presently fourteen cooperative exporters who have been issued normal values as per the LME methodology.Footnote 44

[70] Guided by these aforementioned factors, and having considered the information on the administrative record, the following is a summary of the CBSA’s analysis conducted in this expiry review investigation with respect to dumping:

  • Anti-dumping measures imposed by other authorities on aluminum extrusions from China
  • China’s significant excess capacity and
  • China’s export orientation

Anti-dumping measures imposed by other authorities on aluminum extrusions from China

[71] The information on the administrative record indicates the presence of anti-dumping measures in other jurisdictions against aluminum extrusions from China, namely in Australia,Footnote 45 in the United States,Footnote 46 in the European UnionFootnote 47 and in the United Kingdom.Footnote 48

[72] Since 2010, Australia has conducted two sunset reviews and made affirmative final dumping rulings on aluminum extrusions from China. In August 2024, the Australian Anti-dumping Commission announced that the anti-dumping measures on aluminum extrusions from China will expire on October 28, 2025 and applications for a sunset review by stakeholders is to be submitted by October 15, 2024.Footnote 49

[73] Since 2011, the United States has conducted two sunset reviews on the anti-dumping duty order on aluminum extrusions from China. In both instances, the US Department of Commerce (DOC) determined that revoking the order would likely to lead to continuation or recurrence of dumping.Footnote 50

[74] These anti-dumping measures in jurisdictions other than Canada against China demonstrate a historical pattern by Chinese exporters in continuing to export aluminum extrusions at dumped prices. Furthermore, these anti-dumping measures also demonstrate a propensity by Chinese exporters to dump aluminum extrusions into markets.

[75] While on the subject of anti-dumping measures, the CBSA notes that in July 2024, the Department of Foreign Trade of Thailand initiated an anti-dumping investigation into aluminum extrusions from China.Footnote 51 Furthermore, the CBSA underlines that although the US International Trade Commission determined in October 2024 that the US industry had not been materially injured or threatened with material injury by aluminum extrusions,Footnote 52 the US DOC had nevertheless made affirmative final determinations of dumping against the multiple countries which included China.Footnote 53

China’s significant excess capacity

[76] As indicated earlier, the CBSA received only one response to its Exporter/Foreign Producer ERQ. As a result, the CBSA relied on its own research and on other information on the administrative record to obtain a snapshot of the capacity, production and utilization rates of aluminum extrusions in China.

[77] While the data pertaining to these three variables may be limited, the CBSA is nevertheless able to draw inferences from the available data.

[78] In terms of total capacity for aluminum extrusions in China, information on the administrative record estimates that it is greater than 30 million MT, with one source indicating 34.32 million MT in 2021Footnote 54 and another, indicating 31.07 million MT in 2023.Footnote 55

[79] Furthermore, the CBSA notes that the individual capacity alone of over 30 aluminum extruders in ChinaFootnote 56 is greater that the total volume of the Canadian market in 2023, which was 197,568 MT.

[80] In terms of production, information on the administrative record indicates that the output in China for aluminium extrusions in 2022 was 21.5 million MT and estimated at 22.47 million MT in 2023Footnote 57 and 23.5 million MT in 2024.Footnote 58

[81] As to the utilization rates, AZ Global, a research house, indicated that China's mid-stream aluminium processing sector, which includes aluminum extruders, operate at rates typically below 65% and as low as 40%.Footnote 59 Another research house, Shanghai Metals Market (SMM), indicated that the average operating rate of aluminum extruders in December 2021 was at 50.5% and at 36.5% in December 2022, with large enterprises operating at 37.8%, mid-sized companies at 35.8% and small firms at 20.5%.Footnote 60 In the last week of March 2024 and in the first week of April 2024, the SMM reported that the operating rate of aluminium extrusions was at 62.3%.Footnote 61

[82] Based on the data above, in 2023, with a capacity of 31.07 million MT and an estimated production of 22.47 million MT or of 23.15 million MT,Footnote 62 depending on the source, it can be seen that the available excess capacity for aluminium extrusions is either 8.6 million MT or 7.92 million MT, which could easily fulfill the needs of the entire volume of the Canadian market of 197,568 MT in 2023.

[83] The CBSA underlines that even if only a small amount of the excess capacity would be directed to Canada, it would dwarf the domestic extruders in regard to their sales in the Canadian market.

China’s export orientation

[84] In taking a closer look at producers and exporters in China, information on the administrative record corroborates their export orientation, which includes as destinations the United States and Canada.Footnote 63

[85] In 2023, China’s exports of aluminum extrusions totalled 990,800 MT, an increase of 42,800 MT year-on-year.Footnote 64 The CBSA notes that from January to June 2024, exports of aluminum extrusions totalled 520,100 MT, an increase of 11.61% year-on-year.Footnote 65

[86] In response to the Exporter/Foreign Producer ERQ, Guangdong Luoxiang indicated that it expected an increase in export sales by 3-5% on average from 2025 to 2029.Footnote 66

[87] This increasing export trend for aluminum extrusions was also witnessed in Canada. In 2013, imports into Canada from China totalled 5,798 MT, and reached 8,396 MT in the period of January to September 2024.Footnote 67

[88] While there may be strong incentives to seek additional export sales of aluminum extrusions, the imposition of anti-dumping measures by other jurisdictions demonstrate the restricted access to other export markets that Chinese exporters will continue to face in the near future, which would make the Canadian market very attractive if the CITT order expires.

Determination regarding likelihood of continued or resumed dumping

[89] Based on the information on the administrative record in respect of: anti-dumping measures imposed by other authorities on aluminum extrusions from China, China’s significant excess capacity and China’s export orientation, the CBSA has determined that the expiry of the order is likely to result in the continuation or resumption of dumping of aluminum extrusions from China.

Position of the parties: Subsidizing

Parties contending that continued or resumed subsidizing is likely

[90] The domestic extruders made representations in their ERQ responses and in their case brief,Footnote 68 in support of the position that the expiry of the order is likely to result in the continuation or resumption of subsidizing of the subject goods from China.

[91] The main factors identified by the domestic extruders can be summarized as follows:

  • Availability of subsidy programs for aluminum extrusions
  • Countervailing measures against China and
  • Pass-through subsidies from aluminum extrusions

Availability of subsidy programs for aluminum extrusions

[92] The domestic extruders indicated that Chinese exporters/producers of aluminum extrusions continue to benefit from subsidy programs. In support of its claim, the domestic extruders argued that there is no information on the administrative record in this expiry review investigation that demonstrates that any of the subsidy programs previously identified have ceased to exist. As a result, the domestic extruders noted that in the CBSA’s 2009 final determination, 56 potential subsidy programs were investigated, 15 of which were determined to have conferred a benefit to the cooperative exporters.Footnote 69

[93] The domestic extruders further alleged that Chinese exporters/producers of aluminum extrusions likely benefit from additional subsidy programs that were not included in the CBSA’s final determination on aluminum extrusions. In support of its claim, the domestic extruders cited information on the administrative record regarding subsidy programs reported by the GOC in its 2023 subsidy notification to the WTO,Footnote 70 by a producer in its annual reportsFootnote 71 and by the CBSA.Footnote 72

[94] The domestic extruders concluded that aluminum extrusions from China continue to benefit from subsidy programs which will result in the resumed export of subsidized aluminum extrusions to Canada if the order expires.

Countervailing measures against China

[95] The domestic extruders noted that the CBSA currently has countervailing measures in force against 17 other products from China. Furthermore, in the past two years, the CBSA determinations in its expiry review investigations found continued subsidization from China. The domestic extruders submitted that these determinations show that the GOC has a propensity for continuing countervailable subsidies in manufacturing industries and to subsidize Chinese producers of aluminum extrusions.Footnote 73

[96] The domestic extruders also cited the countervailing measures imposed by other jurisdictions, including AustraliaFootnote 74 and the United StatesFootnote 75 on Chinese aluminum extrusions.

[97] The domestic extruders concluded that considering the GOC’s pattern of subsidizing industrial products, it is highly likely that the GOC will continue countervailing subsidies for aluminum extrusions producers if the order is permitted to expire.

Pass-through subsidies from aluminum extrusions

[98] The domestic extruders cited articles and reports indicating that Chinese primary aluminum producers, which is comprised of state-owned enterprises who account for more than 50% of the total output, continue to be subsidized through energy, financial and tax benefits. As a result, the downstream producers, which includes Chinese extruders, benefit from below-market costs for their inputs.Footnote 76

[99] As Chinese producers of aluminum extrusions continue to receive pass-through subsidies, the domestic extruders concluded that the likelihood of Chinese aluminum extrusions being exported to Canada at subsidized prices is high.

Parties contending that continued or resumed subsidizing is unlikely

[100] No other parties contended that the continuation or resumption of subsidizing of the subject goods from China is unlikely if the order expires.

Consideration and analysis: Subsidizing

[101] In making a determination under paragraph 76.03(7)(a) of SIMA as to whether the expiry of the order is likely to result in the continuation or resumption of subsidizing of the goods from China, the CBSA may consider factors identified in subsection 37.2(1) of the SIMR, as well as any other factors relevant in the circumstances.

[102] Guided by these aforementioned factors, and having considered the information on the administrative record, the following is a summary of the CBSA’s analysis conducted in this expiry review investigation with respect to subsidizing:

  • Countervailing measures imposed by other authorities on aluminum extrusions from China and
  • Continued availability of subsidy programs for aluminum extrusions exporters/producers in China

Countervailing measures imposed by other authorities on aluminum extrusions from China

[103] The information on the administrative record indicates the presence of countervailing measures in other jurisdictions against aluminum extrusions from China, namely in AustraliaFootnote 77 and in the United States.Footnote 78

[104] Since 2010, Australia has conducted two sunset reviews and made affirmative final subsidizing rulings on aluminum extrusions from China. In August 2024, the Australian Anti-dumping Commission announced that the countervailing measures on aluminum extrusions from China will expire on October 28, 2025 and applications for a sunset review by stakeholders is to be submitted by October 15, 2024.Footnote 79

[105] Since 2011, the United States has conducted two sunset reviews on the countervailing duty order on aluminum extrusions from China. In both instances, the US DOC determined that revoking the order would likely to lead to continuation or recurrence of subsidizing.Footnote 80

[106] These countervailing measures in jurisdictions other than Canada against China demonstrate a historical pattern by Chinese exporters in continuing to export aluminum extrusions at subsidized prices into markets. Furthermore, these countervailing measures also demonstrate China’s propensity to export subsidized aluminum extrusions into markets.

[107] While on the subject of countervailing measures, the CBSA underlines that although the US International Trade Commission determined in October 2024 that the US industry had not been materially injured or threatened with material injury by aluminum extrusions,Footnote 81 the US DOC had nevertheless made affirmative final determinations of subsidizing against the multiple countries which included China.

Continued availability of subsidy programs for aluminum extrusions exporters/producers in China

[108] As indicated earlier, the GOC did not respond to the Subsidy ERQ. As a result, the CBSA relied on information on the administrative record and from the original investigation, the re-investigation and a normal value review on aluminum extrusions.

[109] As per China’s latest subsidy notification to the WTO, the domestic extruders identified 13 subsidies at the central government level and 40 additional subsidies from sub-central government levels which likely apply to Chinese producers of aluminum extrusions. Although China’s subsidy notification is presumed to be incomplete,Footnote 82 it nevertheless indicates that support programs are available or benefit the producers in China of aluminum extrusions.

[110] In its original investigation, the CBSA’s final determinations indicated that 56 subsidy programs were investigated, 15 of which were determined to have conferred benefits to the cooperative exporters.Footnote 83

[111] At the conclusion of the re-investigation on February 20, 2012, the CBSA determined amounts of subsidy for the cooperative exporters.Footnote 84 The listing of the subsidy programs which conferred benefits were contained in the protected ruling letters issued to the cooperative exporters.

[112] On March 3, 2022, at the conclusion of the normal value review, the CBSA determined an amount of subsidy for the cooperative exporter.Footnote 85 The listing of the subsidy programs which conferred benefits were contained in the protected ruling letter issued to the cooperative exporter.Footnote 86

[113] The results for the cooperative exporters in these proceedings demonstrate that subsidy programs continue to be available to Chinese exporters of aluminum extrusions.

Determination regarding likelihood of continued or resumed subsidizing

[114] Based on the information on the administrative record in respect of: countervailing measures imposed by other authorities on aluminum extrusions from China and continued availability of subsidy programs for aluminum extrusions exporters/producers in China, the CBSA has determined that the expiry of the order is likely to result in the continuation or resumption of subsidizing of aluminum extrusions from China.

Conclusion

[115] For the purpose of making determinations in this expiry review investigation, the CBSA conducted its analysis within the scope of the factors found under subsection 37.2(1) of the SIMR and considered any other factors relevant in the circumstances. Based on the foregoing analysis of pertinent factors and consideration of information on the administrative record, on April 24, 2025, the CBSA made a determination pursuant to paragraph 76.03(7)(a) of SIMA that the expiry of the order made by the CITT on January 13, 2020, in expiry review RR-2018-008 in respect of aluminum extrusions originating in or exported from China:

  1. is likely to result in the continuation or resumption of dumping of the goods from China and
  2. is likely to result in the continuation or resumption of subsidizing of the goods from China

Future action

[116] The CITT has now initiated its expiry review to determine whether the continued or resumed dumping and subsidizing are likely to result in injury. The CITT’s expiry review schedule indicates that it will make its decision by October 1, 2025.

[117] If the CITT determines that the expiry of the order with respect to the goods is likely to result in injury, the order will be continued in respect of those goods, with or without amendment. If this is the case, the CBSA will continue to levy anti-dumping and/or countervailing duties on dumped and/or subsidized importations of the subject goods.

[118] If the CITT determines that the expiry of the order with respect to the goods is not likely to result in injury, the order will expire in respect of those goods. Anti-dumping and/or countervailing duties would then no longer be levied on importations of the subject goods, and any anti-dumping and/or countervailing duties paid in respect of goods that were released after the date that the order was scheduled to expire will be returned to the importer.

Contact us

[119] For further information, please contact the SIMA Registry listed below:

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

Sean Borg
A/Executive Director
Trade and anti-dumping programs directorate

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