On February 18, 2026, the Department of Commerce issued a notice in the Federal Register amending the final results of its 2018-2019 antidumping duty administrative review on circular welded carbon steel pipes and tubes from Thailand. This action stems from a U.S. Court of International Trade decision that found Commerce's original determination not fully compliant with legal requirements. The court sustained Commerce's remand redetermination, resulting in a revised weighted-average dumping margin of zero percent for Saha Thai Steel Pipe Public Company Limited, the key exporter involved. This development highlights ongoing tensions in trade remedy enforcement, where procedural fairness intersects with efforts to address unfair pricing in imports. It affects how antidumping duties are calculated and applied, potentially influencing future reviews in the steel sector.
Background of the Antidumping Review
The antidumping duty order on circular welded carbon steel pipes and tubes from Thailand dates back to 1986, aimed at countering imports sold at less than fair value that injure domestic industries. The administrative review in question covered the period from March 1, 2018, to February 28, 2019. In its original final results, published on January 27, 2021, Commerce determined that Saha Thai had not provided complete information on a substantial portion of its U.S. sales. As a result, Commerce applied facts available with adverse inferences under section 776 of the Tariff Act of 1930, as amended. This approach led to a higher dumping margin, reflecting Commerce's finding that Saha Thai failed to cooperate to the best of its ability.
Key players include Saha Thai Steel Pipe Public Company Limited, a major Thai producer and exporter of the subject merchandise, and domestic interested parties such as U.S. steel manufacturers who benefit from antidumping protections. The review process is governed by the Uruguay Round Agreements Act and related U.S. laws, which require Commerce to assess whether imports are dumped and to calculate margins based on comparisons of export prices to normal values.
Court Challenge and Remand
Saha Thai appealed Commerce's final results to the U.S. Court of International Trade in Saha Thai Steel Pipe Public Company Limited v. United States, Court No. 21-00049. On December 2, 2022, the CIT remanded the case, ruling that Commerce had not provided adequate notice and opportunity for Saha Thai to remedy deficiencies in its submissions, as required under section 782(d) of the Tariff Act. The court also found that Commerce insufficiently explained its decision to apply adverse inferences, deeming the determination unsupported by substantial evidence and not in accordance with law.
This ruling draws on precedents like Timken Co. v. United States (893 F.2d 337, Fed. Cir. 1990), which established protocols for handling court decisions that diverge from agency determinations. The CIT's emphasis on procedural due process aligns with broader judicial oversight in trade cases, ensuring agencies adhere to statutory requirements for fairness. From Saha Thai's perspective, the remand corrected an overly punitive approach. Domestic industries, however, might view it as weakening enforcement against non-cooperative respondents.
Commerce's Remand Redetermination
In response to the remand, Commerce reopened the administrative record in July 2025 and requested a full revised questionnaire response from Saha Thai. The agency recalculated the dumping margin by incorporating all sales of dual-stenciled pipe, which are products certified to multiple standards and potentially subject to the order.
A significant aspect of the redetermination was Commerce's analysis of a particular market situation, or PMS, under section 773(e) of the Tariff Act. Commerce determined that Saha Thai's production costs were outside the ordinary course of trade due to extraordinary circumstances, warranting a PMS adjustment. Despite this finding, which typically increases calculated costs and thus dumping margins, the overall weighted-average dumping margin for Saha Thai was revised to zero percent. The CIT sustained this redetermination in its final judgment on February 4, 2026, as detailed in Slip Op. 26-9.
This outcome reflects Commerce's discretion in applying PMS adjustments, a tool increasingly used in recent years to address distortions in foreign markets, such as subsidies or non-market practices. Quotes from the remand document emphasize that 'the nature of Saha Thai's costs... indicated an extraordinary circumstance,' underscoring the factual basis for the adjustment.
Implications for Trade and Enforcement
The amended results have immediate effects on liquidation and cash deposits. Commerce noted that entries from the review period remain enjoined from liquidation pending any appeals, in line with Timken and Diamond Sawblades Manufacturers Coalition v. United States (626 F.3d 1374, Fed. Cir. 2010). If the ruling stands, U.S. Customs and Border Protection will assess duties based on the zero percent margin, potentially leading to refunds for importers if overpayments occurred.
Short-term implications include reduced duties on Saha Thai's imports, benefiting U.S. buyers of Thai steel pipes while possibly pressuring domestic producers. Long-term, this case could influence how Commerce handles incomplete responses in reviews, encouraging more opportunities for remedy before applying adverse inferences. Different perspectives emerge: exporters like Saha Thai see it as a win for procedural rights, while U.S. industries may argue it complicates swift enforcement against dumping.
The decision also ties into broader political forces, such as U.S. trade policy under the Biden administration, which has maintained robust use of trade remedies amid global supply chain challenges. No direct executive orders are involved here, but the framework aligns with ongoing efforts to protect domestic manufacturing.
Forward-Looking Considerations
This case underscores persistent debates in antidumping law regarding fairness, evidence standards, and market distortions. Potential next steps include appeals to the U.S. Court of Appeals for the Federal Circuit, which could further clarify PMS applications. Ongoing challenges involve balancing procedural protections with effective trade enforcement, while future reviews may see increased scrutiny of dual-stenciled products. Debates will likely continue on whether such adjustments adequately address global trade inequities without overburdening compliant exporters.
