On July 17, 2026, the U.S. Court of International Trade delivered a definitive judgment in Saha Thai Steel Pipe Public Company Limited v. United States. This ruling concludes a prolonged legal challenge against the Department of Commerce's antidumping duty determination involving circular welded carbon steel pipes and tubes imported from Thailand. The court's decision affirms Commerce's third redetermination, resulting in an amended dumping margin of 14.74 percent for Saha Thai Steel Pipe Public Co., Ltd. and Thai Premium Pipe Co., Ltd. This judgment significantly revises the initial findings and clarifies the duty assessment for goods imported between March 1, 2019, and February 29, 2020. It underscores the intricate legal framework governing international trade disputes and the critical role of judicial review in ensuring administrative agencies adhere to statutory requirements.
Background of the Administrative Review
The dispute originated from an administrative review conducted by the Department of Commerce covering the period from March 1, 2019, to February 29, 2020. In December 2021, Commerce issued its initial final results. These results assigned a weighted-average dumping margin of 36.97 percent to Saha Thai and Thai Premium. Dumping occurs when a foreign company sells a product in the U.S. at a price lower than its domestic market price or production cost. Antidumping duties are then imposed to offset this price difference.
Saha Thai, supported by plaintiff-intervenor Thai Premium, promptly challenged Commerce's findings before the Court of International Trade. This initiated a multi-year process of judicial scrutiny and administrative adjustments.
The Judicial Remand Process and Commerce's Adjustments
First Remand
The first significant development occurred in October 2022. The CIT instructed Commerce to re-evaluate its cost-based particular market situation adjustment. This directive followed new Federal Circuit precedent impacting how such adjustments should be applied. In response, Commerce filed its first remand redetermination in November 2022, recalculating the dumping margin without this specific cost adjustment.
Second Remand
A year later, in November 2023, the CIT issued a second remand. This time, the court focused on two distinct issues. First, it questioned the inclusion of sales of "dual-stenciled pipe" in the margin calculation. This issue was tied to ongoing litigation regarding the scope of the antidumping order itself. Second, the court challenged Commerce's application of "partial adverse facts available" to determine an affiliation between Saha Thai and one of its home market customers. The term "adverse facts available" refers to Commerce's ability to use adverse information if a party fails to provide requested information or significantly impedes an investigation.
In October 2024, Commerce responded to this second remand. It maintained the inclusion of dual-stenciled pipe sales, citing the resolution of the separate scope litigation. Crucially, Commerce reversed its previous finding on affiliation. It concluded that the sharing of a single human resources manager was insufficient evidence to establish affiliation between Saha Thai and BNK. Consequently, Commerce treated them as unaffiliated entities, leading to another recalculation of Saha Thai's dumping margin.
Third Remand
The legal back-and-forth continued. In June 2025, the CIT remanded the case for a third time. The court found that Commerce had changed its position regarding the affiliation without adequately explaining its shifting rationale. It specifically required Commerce to identify the precise question to Saha Thai that formed the basis for applying partial adverse facts available. During this third remand, the CIT did sustain Commerce's inclusion of dual-stenciled pipe sales.
Commerce's Third Redetermination
Commerce filed its third and final redetermination in August 2025. It revisited the affiliation issue, this time concluding that Saha Thai and BNK were affiliated. Commerce acknowledged an inadvertent citation error in its earlier determination and corrected its supporting documentation. This time, it reapplied an adverse inference, leading to the revised dumping margin of 14.74 percent for both Saha Thai and Thai Premium.
The Court's Final Judgment and Its Impact
On July 17, 2026, the CIT issued its final judgment. The court sustained Commerce's third redetermination. It found that Commerce's determination that Saha Thai failed to report necessary information and did not act to the best of its ability was supported by substantial evidence. The court also affirmed that Commerce complied with its statutory obligations when applying partial adverse facts available.
This judgment is significant under the Timken notice requirement. The Timken decision, clarified by Diamond Sawblades, mandates that Commerce publish a notice when a court decision is not "in harmony" with a Commerce determination. It also requires the suspension of liquidation of entries pending a "conclusive" court decision. The current CIT judgment is deemed "not in harmony" with Commerce's initial final results from December 2021.
Consequently, Commerce is amending its final results. The dumping margin for Saha Thai Steel Pipe Public Co., Ltd. and Thai Premium Pipe Co., Ltd. is now officially set at 14.74 percent.
Regarding cash deposit requirements, the notice states that Commerce will not issue revised instructions to U.S. Customs and Border Protection. This is because superseding cash deposit rates have been established in a more recent administrative review for 2023-2024. Therefore, the current cash deposit rate will not be affected by this specific ruling.
The liquidation of suspended entries remains enjoined by CIT order for affected entries from the 2019-2020 period. These entries will continue under injunction throughout any potential appeals process. Should the CIT's ruling stand without appeal or be upheld by a conclusive court decision, Commerce will instruct Customs and Border Protection to assess antidumping duties on unliquidated entries based on the 14.74 percent margin. Entries with a zero or de minimis assessment rate will be liquidated without antidumping duties.
