Certain Lithium ION Batteries, Battery Cells, Battery Modules, Battery Packs, Components Thereof, and Processes Therefor, Inv. 337-TA-1159

23 printed pages contain little extracted OCR body text; searchable legal-body completeness has not been established for those pages.

OCR transcription for search; preserved printed pages are authoritative

Tin- and Chromium-Coated Steel Sheet
from Japan

Investigation No. 731-TA-860 (Fourth Review)

Publication 5507 May 2024
U.S. International Trade Commission

Washington, DC 20436

COMMISSIONERS
David S. Johanson, Chairman
Rhonda K. Schmidtlein
Jason E. Kearns
Amy A. Karpel
Catherine DeFilippo
Director of Operations
Staff assigned
Alejandro Orozco, Investigator
Karl Tsuji, Industry Analyst
Ravinder Ubee, Economist
David Boyland, Accountant
Jennifer Catalano, Statistician
Courtney McNamara, Attorney
Douglas Corkran, Supervisory Investigator
U.S. International Trade Commission
Address all communications to
Secretary to the Commission
United States International Trade Commission
Washington, DC 20436

Washington, DC 20436
www.usitc.gov
Tin- and Chromium-Coated Steel Sheet
from Japan
Investigation No. 731-TA-860 (Fourth Review)
U.S. International Trade Commission
Publication 5507 	May 2024

CONTENTS
Page
i
Determination ....................................................................................................................... 1
Views of the Commission....................................................................................................... 3
Part I: Introduction .............................................................................................................. I-1
Background................................................................................................................................ I-1
The original investigation ...................................................................................................... I-2
Subsequent remand proceedings ......................................................................................... I-3
Subsequent five-year reviews ............................................................................................... I-4
Previous and related investigations .......................................................................................... I-5
Summary data ........................................................................................................................... I-7
Statutory criteria ..................................................................................................................... I-12
Organization of report............................................................................................................. I-15
Commerce’s reviews ............................................................................................................... I-15
Administrative reviews ........................................................................................................ I-15
Changed circumstances reviews ......................................................................................... I-16
Scope rulings........................................................................................................................ I-17
Five-year reviews ................................................................................................................. I-18
The subject merchandise ........................................................................................................ I-19
Commerce’s scope .............................................................................................................. I-19
Tariff treatment ................................................................................................................... I-24
The product ............................................................................................................................. I-29
Description and applications ............................................................................................... I-29
Manufacturing processes .................................................................................................... I-34
Domestic like product issues................................................................................................... I-40
U.S. market participants.......................................................................................................... I-41
U.S. producers ..................................................................................................................... I-41
U.S. importers ...................................................................................................................... I-47
U.S. purchasers .................................................................................................................... I-49

CONTENTS
Page
ii
Part I: Introduction--Continued
Apparent U.S. consumption and market shares ..................................................................... I-50
Quantity ............................................................................................................................... I-50
Value .................................................................................................................................... I-52
Part II: Conditions of competition in the U.S. market........................................................... II-1
U.S. market characteristics....................................................................................................... II-1
Impact of section 301 tariffs and section 232 measures ......................................................... II-1
Channels of distribution ........................................................................................................... II-4
Geographic distribution ........................................................................................................... II-5
Supply and demand considerations ......................................................................................... II-5
U.S. supply ............................................................................................................................ II-5
U.S. demand ....................................................................................................................... II-14
Substitutability issues............................................................................................................. II-18
Factors affecting purchasing decisions............................................................................... II-18
Purchase factor comparisons of domestic products, subject imports,
and nonsubject imports ..................................................................................................... II-23
Comparison of U.S.-produced and imported TCCSS .......................................................... II-25
Elasticity estimates ................................................................................................................. II-27
U.S. supply elasticity ........................................................................................................... II-27
U.S. demand elasticity ........................................................................................................ II-27
Substitution elasticity ......................................................................................................... II-28
Part III: Condition of the U.S. industry ................................................................................ III-1
Overview ................................................................................................................................. III-1
Industry events since the last five-year review ................................................................... III-1
Changes experienced by the industry ............................................................................... III-12
Anticipated changes in operations .................................................................................... III-14

CONTENTS
Page
iii
Part III: Condition of the U.S. industry--Continued
U.S. production, capacity, and capacity utilization ............................................................... III-15
Constraints on capacity ..................................................................................................... III-16
Operations data ................................................................................................................. III-17
Alternative products .......................................................................................................... III-19
U.S. producers’ U.S. shipments and exports ......................................................................... III-20
U.S. producers’ inventories ................................................................................................... III-21
U.S. producers’ imports from Japan ..................................................................................... III-22
U.S. employment, wages, and productivity .......................................................................... III-23
Financial experience of U.S. producers ................................................................................. III-24
Background ........................................................................................................................ III-24
Operations on TCCSS ......................................................................................................... III-26
Net sales ............................................................................................................................ III-29
Cost of goods sold and gross profit or loss........................................................................ III-30
SG&A expenses and operating income or loss.................................................................. III-35
All other expenses and net income or loss ....................................................................... III-36
Capital expenditures and research and development expenses ...................................... III-36
Assets and return on assets............................................................................................... III-39
Part IV: U.S. imports and the foreign industries.................................................................. IV-1
U.S. imports ............................................................................................................................. IV-1
Overview .............................................................................................................................. IV-1
Imports from subject and nonsubject countries ................................................................. IV-2
U.S. shipments by coating type and width .......................................................................... IV-5
U.S. inventories of imported merchandise ........................................................................... IV-10
U.S. importers’ imports subsequent to December 31, 2023 ................................................ IV-11
U.S. imports of excluded tin mill products............................................................................ IV-11

CONTENTS
Page
iv
Part IV: U.S. imports and the foreign industries--Continued
The industry in Japan ............................................................................................................ IV-13
Overview ............................................................................................................................ IV-13
Changes in operations ....................................................................................................... IV-20
Operations on TCCSS ......................................................................................................... IV-21
Alternative products .......................................................................................................... IV-28
Foreign producers’ operations on excluded tin mill products .......................................... IV-29
Exports ............................................................................................................................... IV-30
Third-country trade actions .................................................................................................. IV-32
Global market ........................................................................................................................ IV-35
Global exports ................................................................................................................... IV-35
Global imports ................................................................................................................... IV-37
Part V: Pricing data ............................................................................................................. V-1
Factors affecting prices ............................................................................................................ V-1
Raw material costs ............................................................................................................... V-1
Transportation costs to the U.S. market .............................................................................. V-3
U.S. inland transportation costs ........................................................................................... V-3
Pricing practices ....................................................................................................................... V-4
Pricing methods .................................................................................................................... V-4
Sales terms and discounts .................................................................................................... V-6
Price leadership .................................................................................................................... V-6
Price data.................................................................................................................................. V-7
Price trends......................................................................................................................... V-14
Price comparisons .............................................................................................................. V-15

CONTENTS
Page
v
Appendixes
A. Federal Register notices ................................................................................................. A-1
B. List of hearing witnesses ................................................................................................ B-1
C. Summary data ................................................................................................................ C-1
D. Impact of the order and likely effects of revocation ...................................................... D-1
E. Company-specific financial data..................................................................................... E-1
F. Purchaser responses regarding rejection rates.............................................................. F-1
Note: Information that would reveal confidential operations of individual concerns may not be
published. Such information is identified by brackets in confidential reports and is deleted and
replaced with asterisks (***) in public reports.

1
UNITED STATES INTERNATIONAL TRADE COMMISSION
Investigation No. 731-TA-860 (Fourth Review)
Tin- and Chromium-Coated Steel Sheet from Japan
DETERMINATION
On the basis of the record1 developed in the subject five-year review, the United States
International Trade Commission (“Commission”) determines, pursuant to the Tariff Act of 1930
(“the Act”), that revocation of the antidumping duty order on tin- and chromium-coated steel
sheet from Japan would be likely to lead to continuation or recurrence of material injury to an
industry in the United States within a reasonably foreseeable time.
BACKGROUND
The Commission instituted this review on June 1, 2023 (88 FR 35920) and determined
on September 5, 2023 that it would conduct a full review (88 FR 64464, September 19, 2023).
Notice of the scheduling of the Commission’s review and of a public hearing to be held in
connection therewith was given by posting copies of the notice in the Office of the Secretary,
U.S. International Trade Commission, Washington, DC, and by publishing the notice in the
Federal Register on October 30, 2023 (88 FR 74209). The Commission conducted its hearing on
April 9, 2024. All persons who requested the opportunity were permitted to participate.
1 The record is defined in § 207.2(f) of the Commission’s Rules of Practice and Procedure (19 CFR
207.2(f)).

3
Views of the Commission
Based on the record in this five-year review, we determine under section 751(c) of the
Tariff Act of 1930, as amended (“the Tariff Act”), that revocation of the antidumping duty order
on tin- and chromium-coated steel sheet (“TCCSS”) from Japan would be likely to lead to
continuation or recurrence of material injury to an industry in the United States within a
reasonably foreseeable time.
Background
Original Investigation and Remand Proceedings. The original investigation on TCCSS
from Japan resulted from an antidumping duty petition filed on October 28, 1999, by Weirton
Steel Corp., the Independent Steel Workers Union, and the United Steel Workers of America,
AFL-CIO. On August 9, 2000, the Commission determined that an industry in the United States
was materially injured by reason of less than fair value ("LTFV") imports of TCCSS from Japan.1
On August 28, 2000, Commerce issued an antidumping duty order on imports of TCCSS from
Japan.2
1 Tin- and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Final), USITC Pub.
3337 (August 2000) (“Original Determination”). Chairman Koplan and Commissioner Askey dissented.
2 65 Fed. Reg. 52067 (August 28, 2000). The Japanese Respondents appealed the Commission’s
original affirmative determination to the U.S. Court of International Trade (“CIT”). On December 31,
2001, the CIT remanded the case to the Commission. Nippon Steel Corp. v. United States, 182 F. Supp.
2d. 1330 (Ct. Int’l Trade 2001). In the first remand, the Commission made an affirmative determination.
Tin and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860, USITC Pub. 3493 (Remand)
(March 2002) (“First Remand Determination”). On August 9, 2002, the CIT remanded the case to the
Commission for a second time and expressly ordered the Commission to enter a negative determination.
Nippon Steel Corp. v. United States, 223 F. Supp. 2d. 1349, 1372 (Ct. Int’l Trade 2002). The Commission
appealed the CIT’s judgment. On October 3, 2002, the Federal Circuit vacated the CIT’s decision and
ordered a remand to the Commission. Nippon Steel Corp. v. United States, 345 F.3d 1379 (Fed. Cir.
2003).
In its second remand determination, the Commission again made an affirmative injury
determination. Tin- and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860, USITC Pub.
3674 (Second Remand) (Feb. 2004) (“Second Remand Determination”). On October 14, 2004, the CIT
affirmed some aspects of the Commission’s decision, but rejected others, and issued a remand with
instructions to issue a negative material injury determination. Nippon Steel Corp. v. United States, 350 F.
Supp. 2d 1186 (Ct. Int’l Trade 2004).
On December 13, 2004, the Commission issued its third remand determination, making negative
injury and threat determinations, and noting that it would not have made such determinations in the
absence of the CIT’s order. Tin and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860,
USITC Pub. 3751 (Third Remand) (Dec. 2004) (“Third Remand Determination”). On March 25, 2005, the
(Continued…)

4
Prior Reviews. In the first, second, and third full reviews (all full reviews), the
Commission found that revocation of the antidumping duty order on TCCSS from Japan would
be likely to lead to continuation or recurrence of material injury to an industry in the United
States within a reasonably foreseeable time.3 Commerce published a notice of continuation of
the antidumping duty orders on TCCSS from Japan following each of the prior five-year
reviews.4
Related Proceedings. On January 18, 2023, Cleveland-Cliffs Inc. (“Cleveland-Cliffs”), a
domestic producer of TCCSS, and the United Steel, Paper and Forestry, Rubber, Manufacturing,
Energy, Allied Industrial and Service Workers International Union, AFL-CIO, CLC, a union
representing workers at domestic tin mill products production facilities, filed antidumping and
countervailing duty petitions on tin mill products from Canada, China, Germany, Netherlands,
South Korea, Taiwan, Turkey, and the United Kingdom.5 Commerce subsequently issued final
negative antidumping duty determinations with respect to tin mill products from the
Netherlands, Taiwan, Turkey, and the United Kingdom.6 Consequently, the Commission
terminated the antidumping duty investigations concerning tin mill products from the
CIT affirmed the negative determinations. Nippon Steel Corp. v. United States, Slip Op. 2005-038 (Ct.
Int’l Trade 2005).
The Commission appealed the CIT’s judgment to the Federal Circuit. On August 10, 2006, the
Federal Circuit reversed the CIT’s decision, instructed the CIT to vacate the Commission’s negative injury
and threat determinations, and directed the CIT to reinstate the Commission’s affirmative material
injury determination. Nippon Steel Corp. v. United States, 458 F.3d 1345 (Fed. Cir. 2006). On November
16, 2006, in accordance with the Federal Circuit’s mandate, the CIT ordered the Commission’s second
remand determination sustained and its affirmative material injury determination reinstated. Nippon
Steel Corp. v. United States, 433 F. Supp. 2d 1336 (Ct. Int’l Trade 2006).
3 Tin- and Chromium-Coated Steel Sheet From Japan, Inv. No. 731-TA-860 (Review), USITC Pub.
3860 (June 2006) (“First Review”); Tin- and Chromium-Coated Steel Sheet From Japan, Inv. No. 731-TA-
860 (Second Review), USITC Pub. 4325 (May 2012) (“Second Review”); Tin- and Chromium-Coated Steel
Sheet From Japan, Inv. No. 731-TA-860 (Third Review), USITC Pub. 4795 (June 2018) (“Third Review”).
4 71 Fed. Reg. 41422 (July 21, 2006); 77 Fed. Reg. 34938 (June 12, 2012); 83 Fed. Reg. 32074
(July 11, 2018).
5 See Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-685
and 731-TA-1599-1601, 1603 (Final), USITC Pub. 5492 (Feb. 2024) at 3-4 & n.1. As discussed below in
Section II.A., the scope of this review is substantively identical to the scope of those investigations. See
id. 6 Tin Mill Products From the Netherlands: Final Negative Determination of Sales at LTFV, 89 Fed.
Reg. 1524 (Jan. 10, 2024); Tin Mill Products From Taiwan: Final Negative Determination of Sales at LTFV
and Final Negative Determination of Critical Circumstances, 89 Fed. Reg. 1526 (Jan. 10, 2024); Tin Mill
Products From Turkey: Final Negative Determination of Sales at LTFV, 89 Fed. Reg. 1520 (Jan. 10, 2024);
Tin Mill Products From the United Kingdom: Final Negative Determination of Sales at LTFV, 89 Fed. Reg.
1535 (Jan. 10, 2024).

5
Netherlands, Taiwan, Turkey, and the United Kingdom.7 In the remaining investigations, the
Commission determined that an industry in the United States was not materially injured or
threatened with material injury by reason of imports of tin mill products from Canada, China,
and Germany found by Commerce to be sold in the United States at LTFV and to be subsidized
by the government of China. The Commission further found imports of tin mill products from
South Korea found by Commerce to be sold in the United States at LTFV to be negligible and
therefore terminated that investigation.8
Current Review. On June 1, 2023, the Commission instituted the current fourth review
of the antidumping duty order on TCCSS from Japan.9 The Commission received two responses
to the notice of institution from domestic interested parties United States Steel Corporation
(“U.S. Steel”) and Cleveland-Cliffs (collectively, “Domestic Producers”). The Commission also
received three responses from respondent interested parties: JFE Steel (“JFE”), Nippon Steel
Corporation (“Nippon Steel”), and Toyo Kohan, Japanese producers and exporters of TCCSS
(collectively, “Japanese Respondents”). On September 5, 2023, the Commission found that the
domestic interested party group response and the respondent interested party group response
were adequate.10 Accordingly, the Commission determined to conduct a full review of the
order.11
Parties to the Reviews. Domestic Producers filed prehearing and posthearing briefs and
appeared at the Commission’s hearing represented by counsel.12 Japanese Respondents JFE,
Nippon Steel, and Toyo Kohan, filed joint prehearing and posthearing briefs and were
represented by counsel at the hearing.13 U.S. Steel and Japanese Respondents also filed final
comments.14
7 Tin Mill Products from the Netherlands, Taiwan, Turkey, and the United Kingdom: Termination
of Investigations, 89 Fed. Reg. 3694 (Jan. 19, 2024).
8 Tin Mill Products from Canada, China, Germany, and South Korea, USITC Pub. 5492 at 1; Tin
Mill Products From Canada, China, Germany, and South Korea; Determinations, 89 Fed. Reg. 14902 (Feb.
29, 2024).
9 88 Fed. Reg. 35920 (June 1, 2023).
10 See Explanation of Commission Determination on Adequacy, EDIS Doc. No. 804249.
11 88 Fed. Reg. 64464 (Sept. 19, 2023); see also Explanation of Commission Determination on
Adequacy, EDIS Doc. No. 804249.
12 U.S. Steel Prehearing Br., EDIS Doc. No. 817078; U.S. Steel Posthearing Br., EDIS Doc. 818654;
Cleveland-Cliffs Prehearing Br., EDIS Doc. No. 817503; Cleveland-Cliffs Posthearing Br., EDIS Doc. No.
818651.13 Japanese Respondents Prehearing Br., EDIS Doc. No. 817080; Japanese Respondents
Posthearing Br., EDIS Doc. No. 818704.
14 U.S. Steel Final Comments, EDIS Doc. No. 820826; Japanese Respondents Final Comments,
EDIS Doc. 820819.

6
Data/Response Coverage. U.S. industry data for this review is based on the
questionnaire responses of three U.S. producers of TCCSS that accounted for all known
domestic production of TCCSS in 2023, and information from the original investigation and the
prior five-year reviews.15
U.S. import data and related information are based on the questionnaire responses of
21 U.S. importers of TCCSS that are believed to have accounted for the vast majority of U.S.
imports during 2023, including *** percent of subject imports from Japan that year, as well as
Commerce’s official import statistics for certain broader data, and information from the original
investigation and the prior five-year reviews.16
Foreign industry data and related information are based on the questionnaire responses
of three subject producers of TCCSS that are believed to have accounted for all TCCSS
production in Japan in 2023, as well as all exports of TCCSS from Japan to the United States that
year, and information from the original investigation and prior five-year reviews.17
Domestic Like Product and Industry
A. 	Domestic Like Product
In making its determination under section 751(c) of the Tariff Act, the Commission
defines the “domestic like product” and the “industry.”18 The Tariff Act defines “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 under this subtitle.”19 The Commission’s
practice in five-year reviews is to examine the domestic like product definition from the original
15 Confidential Staff Report, Memorandum INV-WW-034, (“CR”), Tin-and Chromium-Coated Steel
Sheet from Japan, Inv. No. 731-TA-860 (Fourth Review), USITC Pub. 5507 (May 2024), (“PR”), at III-1.
16 CR/PR at IV-1 & n.3. The Commission received 21 questionnaire responses from firms that
imported TCCSS into the United States, as well as five questionnaire responses from firms that import
excluded tin mill products into the United States. Id. at IV-1.
17 CR/PR at IV-13.
18 19 U.S.C. § 1677(4)(A).
19 19 U.S.C. § 1677(10); see, e.g., Cleo Inc. v. United States, 501 F.3d 1291, 1299 (Fed. Cir. 2007);
NEC Corp. v. Department of Commerce, 36 F. Supp. 2d 380, 383 (Ct. Int’l Trade 1998); Nippon Steel Corp.
v. United States, 19 CIT 450, 455 (1995); Timken Co. v. United States, 913 F. Supp. 580, 584 (Ct. Int’l
Trade 1996); Torrington Co. v. United States, 747 F. Supp. 744, 748-49 (Ct. Int’l Trade 1990), aff’d, 938
F.2d 1278 (Fed. Cir. 1991); see also S. Rep. No. 249, 96th Cong., 1st Sess. 90-91 (1979).

7
investigation and consider whether the record indicates any reason to revisit the prior
findings.20
Commerce has defined the imported merchandise within the scope of the order under
review as follows:
The products covered by the order are tin mill flat-rolled products that
are coated or plated with tin, chromium or chromium oxides. Flat-rolled
steel products coated with tin are known as tin plate. Flat-rolled steel
products coated with chromium or chromium oxides are known as tin-
free steel or electrolytic chromium-coated steel. The scope includes all
the noted tin mill products regardless of thickness, width, form (in coils or
cut sheets), coating type (electrolytic or otherwise), edge (trimmed,
untrimmed or further processed, such and scroll cut), coating thickness,
surface finish, temper, coating metal (tin, chromium, chromium oxide),
reduction (single- or double-reduced), and whether or not coated with a
plastic material.
All products that meet the written physical description are within the
scope of the Order unless specifically excluded. The following products,
by way of example, are outside and/or specifically excluded from the
scope of the order:
• 	Single reduced electrolytically chromium coated steel with a thickness
0.238 mm (85 pound base box) (± 10%) or 0.251 mm (90 pound base
box) (± 10%) or 0.255 mm (±10%) with 770 mm (minimum width) (±
1.588 mm) by 900 mm (maximum length if sheared) sheet size or
30.6875 inches (minimum width) (± 1/16 inch) and 35.4 inches
(maximum length if sheared) sheet size; with type MR or higher (per
ASTM) A623 steel chemistry; batch annealed at T2 1/2 anneal
temper, with a yield strength of 31 to 42 kpsi (214 to 290 Mpa); with
a tensile strength of 43 to 58 kpsi (296 to 400 Mpa); with a chrome
coating restricted to 32 to 150 mg/m²; with a chrome oxide coating
restricted to 6 to 25 mg/m² with a modified 7B ground roll finish or
blasted roll finish; with roughness average (Ra) 0.10 to 0.35
micrometers, measured with a stylus instrument with a stylus radius
of 2 to 5 microns, a trace length of 5.6 mm, and a cut-off of 0.8 mm,
and the measurement traces shall be made perpendicular to the
rolling direction; with an oil level of 0.17 to 0.37 grams/base box as
type BSO, or 2.5 to 5.5 mg/m² as type DOS, or 3.5 to 6.5 mg/m² as
20 See, e.g., Internal Combustion Industrial Forklift Trucks from Japan, Inv. No. 731-TA-377
(Second Review), USITC Pub. 3831 at 8-9 (Dec. 2005); Crawfish Tail Meat from China, Inv. No. 731-TA-
752 (Review), USITC Pub. 3614 at 4 (July 2003); Steel Concrete Reinforcing Bar from Turkey, Inv. No. 731-
TA-745 (Review), USITC Pub. 3577 at 4 (Feb. 2003).

8
type ATBC; with electrical conductivity of static probe voltage drop of
0.46 volts drop maximum, and with electrical conductivity
degradation to 0.70 volts drop maximum after stoving (heating to 400
degrees F for 100 minutes followed by a cool to room temperature).
• 	Single reduced electrolytically chromium-or tin-coated steel in the
gauges of 0.0040 inch nominal, 0.0045 inch nominal, 0.0050 inch
nominal, 0.0061 inch nominal (55 pound base box weight), 0.0066
inch nominal (60 pound base box weight), and 0.0072 inch nominal
(65 pound base box weight), regardless of width, temper, finish,
coating or other properties.
• 	Single reduced electrolytically chromium coated steel in the gauge of
0.024 inch, with widths of 27.0 inches or 31.5 inches, and with T-1
temper properties.
• 	Single reduced electrolytically chromium coated steel, with a
chemical composition of 0.005% max carbon, 0.030% max silicon,
0.25% max manganese, 0.025% max phosphorous, 0.025% max sulfur,
0.070% max aluminum, and the balance iron, with a metallic
chromium layer of 70-130 mg/m², with a chromium oxide layer of 5-
30 mg/m² , with a tensile strength of 260-440 N/mm², with an
elongation of 28-48%, with a hardness (HR-30T) of 40-58, with a
surface roughness of 0.5-1.5 microns Ra, with magnetic properties of
Bm (KG)10.0 minimum, Br (KG) 8.0 minimum, Hc (Oe) 2.5-3.8, and
MU 1400 minimum, as measured with a Riken Denshi DC magnetic
characteristic measuring machine, Model BHU-60.
• 	Bright finish tin-coated sheet with a thickness equal to or exceeding
0.0299 inch, coated to thickness of 3/4 pound (0.000045 inch) and 1
pound (0.00006 inch).
• 	Electrolytically chromium coated steel having ultra flat shape defined
as oil can maximum depth of 5/64 inch (2.0 mm) and edge wave
maximum of 5/64 inch (2.0 mm) and no wave to penetrate more than
2.0 inches (51.0 mm) from the strip edge and coilset or curling
requirements of average maximum of 5/64 inch (2.0 mm) (based on
six readings, three across each cut edge of a 24 inches (61 cm) long
sample with no single reading exceeding 4/32 inch (3.2 mm) and no
more than two readings at 4/32 inch (3.2 mm)) and (for 85 pound
base box item only: crossbuckle maximums of 0.001 inch (0.0025 mm)
average having no reading above 0.005 inch (0.127 mm)), with a
camber maximum of 1/4 inch (6.3 mm) per 20 feet (6.1 meters),
capable of being bent 120 degrees on a 0.002 inch radius without
cracking, with a chromium coating weight of metallic chromium at
100 mg/m² and chromium oxide of 10 mg/m², with a chemistry of

9
0.13% maximum carbon, 0.60% maximum manganese, 0.15%
maximum silicon, 0.20% maximum copper, 0.04% maximum
phosphorous, 0.05% maximum sulfur, and 0.20% maximum
aluminum, with a surface finish of Stone Finish 7C, with a DOS-A oil at
an aim level of 2 mg/square meter, with not more than 15
inclusions/foreign matter in 15 feet (4.6 meters) (with inclusions not
to exceed 1/32 inch (0.8 mm) in width and 3/64 inch (1.2 mm) in
length), with thickness/temper combinations of either 60 pound base
box (0.0066 inch) double reduced CADR8 temper in widths of 25.00
inches, 27.00 inches, 27.50 inches, 28.00 inches, 28.25 inches, 28.50
inches, 29.50 inches, 29.75 inches, 30.25 inches, 31.00 inches, 32.75
inches, 33.75 inches, 35.75 inches, 36.25 inches, 39.00 inches, or
43.00 inches, or 85 pound base box (0.0094 inch) single reduced CAT4
temper in widths of 25.00 inches, 27.00 inches, 28.00 inches, 30.00
inches, 33.00 inches, 33.75 inches, 35.75 inches, 36.25 inches, or
43.00 inches, with width tolerance of 1/8 inch, with a thickness
tolerance of 0.0005 inch, with a maximum coil weight of 20,000
pounds (9071.0 kg), with a minimum coil weight of 18,000 pounds
(8164.8 kg) with a coil inside diameter of 16 inches (40.64 cm) with a
steel core, with a coil maximum outside diameter of 59.5 inches
(151.13 cm), with a maximum of one weld (identified with a paper
flag) per coil, with a surface free of scratches, holes, and rust.
• 	Electrolytically tin coated steel having differential coating with 1.00
pound/base box equivalent on the heavy side, with varied coating
equivalents in the lighter side (detailed below), with a continuous cast
steel chemistry of type MR, with a surface finish of type 7B or 7C,
with a surface passivation of 0.7 mg/square foot of chromium applied
as a cathodic dichromate treatment, with coil form having restricted
oil film weights of 0.3- 0.4 grams/base box of type DOS-A oil, coil
inside diameter ranging from 15.5 to 17 inches, coil outside diameter
of a maximum 64 inches, with a maximum coil weight of 25,000
pounds, and with temper/coating/dimension combinations of: (1)
CAT 4 temper, 1.00/.050 pound/base box coating, 70 pound/base box
(0.0077 inch) thickness, and 33.1875 inch ordered width; or (2) CAT5
temper, 1.00/0.50 pound/base box coating, 75 pound/base box
(0.0082 inch) thickness, and 34.9375 inch or 34.1875 inch ordered
width; or (3) CAT5 temper, 1.00/0.50 pound/base box coating, 107
pound/base box (0.0118 inch) thickness, and 30.5625 inch or 35.5625
inch ordered width; or (4) CADR8 temper, 1.00/0.50 pound/base box
coating, 85 pound/base box (0.0093 inch) thickness, and 35.5625 inch
ordered width; or (5) CADR8 temper, 1.00/0.25 pound/base box
coating, 60 pound/base box (0.0066 inch) thickness, and 35.9375 inch
ordered width; or (6) CADR8 temper, 1.00/0.25 pound/base box

10
coating, 70 pound/base box (0.0077 inch) thickness, and 32.9375
inch, 33.125 inch, or 35.1875 inch ordered width.
• 	Electrolytically tin coated steel having differential coating with 1.00
pound/base box equivalent on the heavy side, with varied coating
equivalents on the lighter side (detailed below), with a continuous
cast steel chemistry of type MR, with a surface finish of type 7B or 7C,
with a surface passivation of 0.5 mg/square foot of chromium applied
as a cathodic dichromate treatment, with ultra flat scroll cut sheet
form, with CAT 5 temper with 1.00/0.10 pound/base box coating,
with alithograph logo printed in a uniform pattern on the 0.10 pound
coating side with a clear protective coat, with both sides waxed to a
level of 15-20 mg/216 sq. in., with ordered dimension combinations
of (1) 75 pound/base box (0.0082 inch) thickness and 34.9375 inch x
31.748 inch scroll cut dimensions; or (2) 75 pound/base box (0.0082
inch) thickness and 34.1875 inch x 29.076 inch scroll cut dimensions;
or (3) 107 pound/base box (0.0118 inch) thickness and 30.5625 inch x
34.125 inch scroll cut dimension.
• 	Tin-free steel coated with a metallic chromium layer between 100-
200 mg/m² and a chromium oxide layer between 5-30 mg/m²;
chemical composition of 0.05% maximum carbon, 0.03% maximum
silicon, 0.60% maximum manganese, 0.02% maximum phosphorous,
and 0.02% maximum sulfur; magnetic flux density (“Br”) of 10 kg
minimum and a coercive force (“Hc”) of 3.8 Oe minimum.
• 	Tin-free steel laminated on one or both sides of the surface with a
polyester film, consisting of two layers (an amorphous layer and an
outer crystal layer), that contains no more than the indicated
amounts of the following environmental hormones: 1 mg/kg BADGE
(BisPhenol – A Di-glycidyl Ether), 1 mg/kg BFDGE (BisPhenol – F Di-
glycidyl Ether), and 3 mg/kg BPA (BisPhenol – A).
Merchandise subject to the Order is typically classified under
subheadings in the 7210.11.0000, 7210.12.0000, 7210.50.0000,
7212.10.0000, and 7212.50.0000 if of non-alloy steel and under HTSUS
subheadings 7225.99.0090, and 7226.99.0180 if of alloy steel of the
Harmonized Tariff Schedule of the United States (HTSUS). While HTSUS
subheadings and ASTM specifications are provided for convenience and
customs purposes, the written description of the scope if dispositive.21
21 Certain Tin Mill Products From Japan: Final Results of the Expedited Fourth Sunset Review of
the Antidumping Duty Order, 88 Fed. Reg. 69133 (Oct. 5, 2023) & accompanying Issues and Decisions
Memorandum, EDIS Doc. No. 805435. HTSUS 7210.50.0000 has been subsequently annotated by
statistical reporting numbers 7210.50.0020 and 7210.50.0090. CR/PR at I-23 n.46.

11
The scope in this review defines TCCSS as comprising both tin-coated steel sheet, known
as tinplate, and chromium-coated steel sheet, known as tin-free steel (“TFS”).22 Both tinplate
and TFS are produced from black plate, an uncoated flat-rolled steel product. To produce
tinplate, black plate is coated on both sides with commercially pure tin. To produce TFS, black
plate is coated on both sides with chromium metal and chromium oxide.23
Tinplate is commonly manufactured to several ASTM standard specifications, including
A599, A623, A624, and A626.24 It is primarily used to make two- or three-piece metal cans –
e.g., food, aerosol, and paint cans.25 A specific type of tinplate – drawn and walled ironed
(“D&I”) tinplate – is used to make two-piece cans.26 Tinplate is sometimes sold in wider widths
for two-piece cans than tinplate used in other applications.27
TFS is manufactured to ASTM Standard Specification A657. It is primarily used to make
certain two-piece metal cans and ends for food cans. It is also used to make caps and closures
for glass containers.28
In its original determination and prior five-year reviews, the Commission defined a
single domestic like product consisting of all TCCSS corresponding with Commerce’s scope.29
There is no new information on the record of this review indicating that the pertinent
characteristics and uses of TCCSS have changed since the prior review so as to warrant the
Commission's reconsideration of the domestic like product definition.30 No party has argued
for a different definition.31 Accordingly, we again define a single domestic like product
consisting of all TCCSS coextensive with the scope of the review.
22 As noted earlier, the scope of this review is substantively identical to the scope of the recent
antidumping duty investigations of tin mill products from Canada, China, Germany, and South Korea.
See Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-685 and 731-TA-
1599-1601, 1603 (Final), USITC Pub. 5492 (Feb. 2024).
23 CR/PR at I-29 – I-32.
24 CR/PR at I-29.
25 CR/PR at I-33 – I-34.
26 CR/PR at I-33 – I-34. A two-piece can is manufactured by taking a flat piece of tinplate and
pushing it through progressively smaller rings (drawing and ironing) to form the base and body of the
can out of one piece of steel. CR/PR at I-33. D&I tinplate is also referred to as “DWI” tinplate. Id.
27 CR/PR at I-34.
28 CR/PR at I-31 – I-32.
29 Original Determination, USITC Pub. 3337 at 5; First Review, USITC Pub. 3860 at 5-6; Second
Review, USITC Pub. 4325 at 5-6; Third Review, USITC Pub. 4795 at 5-6.
30 See generally CR/PR at I-29 – I-39.
31 Domestic Producers argue that there is a single domestic like product consisting of TCCSS
coextensive with the scope. U.S. Steel Prehearing Br. at 4-6; Cleveland-Cliffs Prehearing Br. at 13-15;
(Continued…)

12
B. 	Domestic Industry
Section 771(4)(A) of the Tariff Act defines the relevant industry as the domestic
“producers as a whole 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.”32 In defining the domestic industry, the Commission’s general practice has been
to include in the industry producers of all domestic production of the like product, whether toll-
produced, captively consumed, or sold in the domestic merchant market.
1. 	Related Parties
We must determine whether any producer of the domestic like product should be
excluded from the domestic industry pursuant to section 771(4)(B) of the Tariff Act. This
provision allows the Commission, if appropriate circumstances exist, to exclude from the
domestic industry producers that are related to an exporter or importer of subject merchandise
or which are themselves importers.33 Exclusion of such a producer is within the Commission’s
discretion based upon the facts presented in each investigation.34
CR/PR at I-40. Japanese Respondents did not address the domestic like product definition. See
generally, Japanese Respondents Prehearing Br.; Japanese Respondents Posthearing Br.
32 19 U.S.C. § 1677(4)(A). The definitions in 19 U.S.C. § 1677 are applicable to the entire subtitle
containing the antidumping and countervailing duty laws, including 19 U.S.C. §§ 1675 and 1675a. See 19
U.S.C. § 1677.
33 See Torrington Co v. United States, 790 F. Supp. 1161, 1168 (Ct. Int’l Trade 1992), aff’d without
opinion, 991 F.2d 809 (Fed. Cir. 1993); Sandvik AB v. United States, 721 F. Supp. 1322, 1331-32 (Ct. Int’l
Trade 1989), aff’d mem., 904 F.2d 46 (Fed. Cir. 1990); Empire Plow Co. v. United States, 675 F. Supp.
1348, 1352 (Ct. Int’l Trade 1987).
34 The primary factors the Commission has examined in deciding whether appropriate
circumstances exist to exclude a related party include the following:
(1) the percentage of domestic production attributable to the importing producer;
(2) the reason the U.S. producer has decided to import the product subject to investigation
(whether the firm benefits from the LTFV sales or subsidies or whether the firm must import in order to
enable it to continue production and compete in the U.S. market);
(3) whether inclusion or exclusion of the related party will skew the data for the rest of the
industry;
(4) the ratio of import shipments to U.S. production for the imported product; and
(5) whether the primary interest of the importing producer lies in domestic production or
importation. Changzhou Trina Solar Energy Co. v. USITC, 100 F. Supp.3d 1314, 1326-31(Ct. Int’l. Trade
2015); see also Torrington Co. v. United States, 790 F. Supp. at 1168.

13
In the original investigation and prior five-year reviews, the Commission defined a single
domestic industry comprised of all domestic producers of TCCSS.35 In this review, no party has
argued for a different definition of the domestic industry.36
In this review, one domestic producer, ***, may be subject to possible exclusion
pursuant to the related parties provision because ***.37 The record, however, indicates that
*** does not exercise sufficient direct or indirect control over *** for *** to qualify as a related
party.38 In particular, *** and ***.39 Accordingly, based on the record in this review, and in the
absence of contrary party argument, we find that *** is not eligible for exclusion from the
domestic industry pursuant to the related parties provision.
Therefore, consistent with our definition of the domestic like product, we again define
the domestic industry as all domestic producers of TCCSS.
Revocation of the Antidumping Duty Order Would Likely Lead to
Continuation or Recurrence of Material Injury Within a Reasonably
Foreseeable Time
A. 	Legal Standards
In a five-year review conducted under section 751(c) of the Tariff Act, Commerce will
revoke an antidumping or countervailing duty order unless: (1) it makes a determination that
dumping or subsidization is likely to continue or recur and (2) the Commission makes a
determination that revocation of the antidumping or countervailing duty order “would be likely
to lead to continuation or recurrence of material injury within a reasonably foreseeable time.”40
The SAA states that “under the likelihood standard, the Commission will engage in a
counterfactual analysis; it must decide the likely impact in the reasonably foreseeable future of
an important change in the status quo – the revocation or termination of a proceeding and the
35 Original Determination, USITC Pub. 3337 at 6; First Review, USITC Pub. 3860 at 6; Second
Review, USITC Pub. 4325 at 6; Third Review, USITC Pub. 4795 at 6.
36 U.S. Steel Prehearing Br. at 6-7; Cleveland-Cliffs at 15; see generally Japanese Respondents
Prehearing Br.; Japanese Respondents Posthearing Br.
37 CR/PR at III-22. U.S. Steel indicates that, although Japanese producer Nippon recently
proposed to acquire U.S. Steel, that transaction remains under regulatory review; therefore, U.S. Steel
does not qualify as a related party. U.S. Steel Prehearing Br. at 7 n.27.
38 See 19 U.S.C. § 1677(4)(B)(ii).
39 CR/PR at III-22 n.10, Table I-9. ***. CR/PR at III-22 n.10.
40 19 U.S.C. § 1675a(a).

14
elimination of its restraining effects on volumes and prices of imports.”41 Thus, the likelihood
standard is prospective in nature.42 The U.S. Court of International Trade has found that
“likely,” as used in the five-year review provisions of the Act, means “probable,” and the
Commission applies that standard in five-year reviews.43
The statute states that “the Commission shall consider that the effects of revocation or
termination may not be imminent, but may manifest themselves only over a longer period of
time.”44 According to the SAA, a “‘reasonably foreseeable time’ will vary from case-to-case, but
normally will exceed the ‘imminent’ timeframe applicable in a threat of injury analysis in
original investigations.”45
Although the standard in a five-year review is not the same as the standard applied in an
original investigation, it contains some of the same fundamental elements. The statute
provides that the Commission is to “consider the likely volume, price effect, and impact of
imports of the subject merchandise on the industry if the orders are revoked or the suspended
investigation is terminated.”46 It directs the Commission to take into account its prior injury
41 SAA at 883-84. The SAA states that “{t}he likelihood of injury standard applies regardless of
the nature of the Commission’s original determination (material injury, threat of material injury, or
material retardation of an industry). Likewise, the standard applies to suspended investigations that
were never completed.” Id. at 883.
42 While the SAA states that “a separate determination regarding current material injury is not
necessary,” it indicates that “the Commission may consider relevant factors such as current and likely
continued depressed shipment levels and current and likely continued {sic} prices for the domestic like
product in the U.S. market in making its determination of the likelihood of continuation or recurrence of
material injury if the order is revoked.” SAA at 884.
43 See NMB Singapore Ltd. v. United States, 288 F. Supp. 2d 1306, 1352 (Ct. Int’l Trade 2003)
(“‘likely’ means probable within the context of 19 U.S.C. § 1675(c) and 19 U.S.C. § 1675a(a)”), aff’d
mem., 140 Fed. Appx. 268 (Fed. Cir. 2005); Nippon Steel Corp. v. United States, 26 CIT 1416, 1419 (2002)
(same); Usinor Industeel, S.A. v. United States, 26 CIT 1402, 1404 nn.3, 6 (2002) (“more likely than not”
standard is “consistent with the court’s opinion;” “the court has not interpreted ‘likely’ to imply any
particular degree of ‘certainty’”); Indorama Chemicals (Thailand) Ltd. v. United States, 26 CIT 1059, 1070
(2002) (“standard is based on a likelihood of continuation or recurrence of injury, not a certainty”);
Usinor v. United States, 26 CIT 767, 794 (2002) (“‘likely’ is tantamount to ‘probable,’ not merely
‘possible’”).
44 19 U.S.C. § 1675a(a)(5).
45 SAA at 887. Among the factors that the Commission should consider in this regard are “the
fungibility or differentiation within the product in question, the level of substitutability between the
imported and domestic products, the channels of distribution used, the methods of contracting (such as
spot sales or long-term contracts), and lead times for delivery of goods, as well as other factors that may
only manifest themselves in the longer term, such as planned investment and the shifting of production
facilities.” Id.
46 19 U.S.C. § 1675a(a)(1).

15
determination, whether any improvement in the state of the industry is related to the order or
the suspension agreement under review, whether the industry is vulnerable to material injury if
an order is revoked or a suspension agreement is terminated, and any findings by Commerce
regarding duty absorption pursuant to 19 U.S.C. § 1675(a)(4).47 The statute further provides
that the presence or absence of any factor that the Commission is required to consider shall not
necessarily give decisive guidance with respect to the Commission’s determination.48
In evaluating the likely volume of imports of subject merchandise if an order under
review is revoked and/or a suspended investigation is terminated, the Commission is directed
to consider whether the likely volume of imports would be significant either in absolute terms
or relative to production or consumption in the United States.49 In doing so, the Commission
must consider “all relevant economic factors,” including four enumerated factors: (1) any likely
increase in production capacity or existing unused production capacity in the exporting country;
(2) existing inventories of the subject merchandise, or likely increases in inventories; (3) the
existence of barriers to the importation of the subject merchandise into countries other than
the United States; and (4) the potential for product shifting if production facilities in the foreign
country, which can be used to produce the subject merchandise, are currently being used to
produce other products.50
In evaluating the likely price effects of subject imports if an order under review is
revoked and/or a suspended investigation is terminated, the Commission is directed to
consider whether there is likely to be significant underselling by the subject imports as
compared to the domestic like product and whether the subject imports are likely to enter the
United States at prices that otherwise would have a significant depressing or suppressing effect
on the price of the domestic like product.51
47 19 U.S.C. § 1675a(a)(1). Commerce has not issued duty absorption findings since the issuance
of the order. Certain Tin Mill Products From Japan: Final Results of the Expedited Fourth Sunset Review
of the Antidumping Duty Order, 88 Fed. Reg. 69133 (Oct. 5, 2023) & accompanying Issues and Decisions
Memorandum, EDIS Doc. No. 805435; CR/PR at I-15 n.34.
48 19 U.S.C. § 1675a(a)(5). Although the Commission must consider all factors, no one factor is
necessarily dispositive. SAA at 886.
49 19 U.S.C. § 1675a(a)(2).
50 19 U.S.C. § 1675a(a)(2)(A-D).
51 See 19 U.S.C. § 1675a(a)(3). The SAA states that “{c}onsistent with its practice in
investigations, in considering the likely price effects of imports in the event of revocation and
termination, the Commission may rely on circumstantial, as well as direct, evidence of the adverse
effects of unfairly traded imports on domestic prices.” SAA at 886.

16
In evaluating the likely impact of imports of subject merchandise if an order under
review is revoked and/or a suspended investigation is terminated, the Commission is directed
to consider all relevant economic factors that are likely to have a bearing on the state of the
industry in the United States, including but not limited to the following: (1) likely declines in
output, sales, market share, profits, productivity, return on investments, and utilization of
capacity; (2) likely negative effects on cash flow, inventories, employment, wages, growth,
ability to raise capital, and investment; and (3) likely negative effects on the existing
development and production efforts of the industry, including efforts to develop a derivative or
more advanced version of the domestic like product.52 All relevant economic factors are to be
considered within the context of the business cycle and the conditions of competition that are
distinctive to the industry. As instructed by the statute, we have considered the extent to
which any improvement in the state of the domestic industry is related to the orders under
review and whether the industry is vulnerable to material injury upon revocation.53
B. 	Conditions of Competition and the Business Cycle
In evaluating the likely impact of the subject imports on the domestic industry if an
order is revoked, the statute directs the Commission to consider all relevant economic factors
“within the context of the business cycle and conditions of competition that are distinctive to
the affected industry.”54 The following conditions of competition inform our determination.
1. 	Demand Conditions
Original Investigation and Prior Reviews. In the original investigation and prior reviews,
the Commission found that U.S. demand for TCCSS depends primarily on the demand for
downstream products in which it is used, including cans for food and beverage products, and
aerosol, paint, and varnish cans.55 In the original investigation, the Commission also found that
52 19 U.S.C. § 1675a(a)(4).
53 The SAA states that in assessing whether the domestic industry is vulnerable to injury if the
order is revoked, the Commission “considers, in addition to imports, other factors that may be
contributing to overall injury. While these factors, in some cases, may account for the injury to the
domestic industry, they may also demonstrate that an industry is facing difficulties from a variety of
sources and is vulnerable to dumped or subsidized imports.” SAA at 885.
54 19 U.S.C. § 1675a(a)(4).
55 Original Determination, USITC Pub. 3337 at 7; First Review, USITC Pub. 3860 at 10; Second
Review, USITC Pub. 4325 at 15, Third Review, USITC Pub. 4795 at 9-10.

17
demand for TCCSS had been relatively stable for many years.56 In the first review, the
Commission concluded that demand for TCCSS in the U.S. market would likely be flat or
decreasing in the reasonably foreseeable future given the downward trend in apparent U.S.
consumption since 2000 and the projections of lower future demand by many market
participants.57 In the second review, the Commission concluded that demand in the reasonably
foreseeable future would likely be flat, decreasing, or at best only marginally improved over the
current low levels, especially given demand trends between 2006 and 2011 and projections by
most firms.58 In the third review, the Commission observed that most market participants
reported that demand decreased between 2012 and 2016 and that they expected the decline
to continue in the near future, citing available substitute products and the use of can designs
that required less steel.59 The Commission further found that apparent U.S. consumption
declined from 2014 to 2016, continuing a long-term downward trend.60
Current Review. We find that demand for TCCSS continues to be derived from demand
for the products in which it is used, including food, aerosol spray, and paint cans.61 Most
responding U.S. producers and purchasers reported that U.S. demand for TCCSS fluctuated
upward or steadily increased between January 1, 2017, and December 31, 2020, citing the
COVID-19 pandemic, while responding importers' responses were mixed but generally indicated
that demand fluctuated during the period.62 Most market participants reported that U.S.
demand fluctuated downward or steadily decreased between January 1, 2021, and December
31, 2023.63 Most market participants report that they expect demand for TCCSS in the U.S.
market to remain stable or decline over the next two years.64 Domestic Producers and
Japanese Respondents agree that, although demand for TCCSS in the United States temporarily
increased due to the COVID-19 pandemic, it subsequently declined and has declined overall
since the original investigation.65
56 Original Determination, USITC Pub. 3337 at 7.
57 First Review, USITC Pub. 3860 at 12.
58 Second Review, USITC Pub. 4325 at 11-12.
59 Third Review, USITC Pub. 4795 at 10.
60 Third Review, USITC Pub. 4795 at 10.
61 CR/PR at II-1.
62 CR/PR at II-15 & Tables II-5, II-6.
63 CR/PR at II-15 & Tables II-5, II-6.
64 CR/PR at II-17 & Tables II-7.
65 U.S. Steel Prehearing Br. at 8-9; Cleveland-Cliffs Prehearing Br. at 19-20; Japanese
Respondents Prehearing Br. at 5, 17-19.

18
Substitutes for TCCSS used in food packaging or aerosol cans include aluminum, plastic,
glass, foil pouches, flexible packaging, and PET.66 Most firms reported no change in the types of
substitutes since January 1, 2017; however, seven importers and seven purchasers reported
changes, citing increases in the use of pouches, cardboard, and plastic due to the cost of steel,
as well as increases in the use of light gauge cold rolled steel for painted end uses such as oil
filters.67
During the January 2021 through December 2023 period of review,68 apparent U.S.
consumption declined from 2.5 million short tons in 2021 to 2.3 million short tons in 2022 and
1.9 million short tons in 2023, for an overall decrease of 24.2 percent.69
2. 	Supply Conditions
Original Investigation and Prior Reviews. In the original investigation, the Commission
found that the U.S. market for TCCSS was national in scope and that subject imports competed
throughout the United States.70 Subject imports’ total market share increased at a substantially
greater rate than did that of nonsubject imports, and subject imports’ market share had
surpassed that of all other imports combined by the end of the period of investigation.71
Although nonsubject imports did not compete throughout the United States, nonsubject
imports were a significant competitive factor in the U.S. market and accounted for a somewhat
greater proportion of the market than subject imports during most of the period of
investigation.72
In the first review, the Commission found that there had been virtually no subject
imports from Japan since 2000 and therefore the U.S. market was supplied during the period of
review only by domestically produced TCCSS and nonsubject imports.73 Domestic producers’
market share decreased during the period of review, while nonsubject imports’ market share
66 CR/PR at II-17.
67 CR/PR at II-17.
68 Although in this review the Commission collected some information covering the period from
January 2017 through December 2023, the data that was collected generally covered only January 2021
through December 2023. See, e.g., CR/PR at Table C-1. Accordingly, when we refer to the period of
review, we mean the January 2021 through December 2023 period.
69 CR/PR at Tables I-12, C-1.
70 Original Determination, USITC Pub. 3337 at 9.
71 Original Determination, USITC Pub. 3337 at 9.
72 Original Determination, USITC Pub. 3337 at 9.
73 First Review, USITC Pub. 3860 at 12.

19
increased.74 The domestic industry’s capacity and production decreased over the period of
review as a result of consolidation due to mergers and bankruptcies.75
In the second review, the Commission found that the U.S. market was supplied during
the period of review almost exclusively by domestically produced TCCSS and nonsubject
imports.76 It noted that the domestic industry consisted of the same seven facilities that were
operating in the first five-year review notwithstanding changes in ownership among firms.77 It
observed that there were virtually no subject imports from Japan during the period of review,
although some Japanese producers supplied tin mill products to the U.S. market that were
excluded from the antidumping duty order.78
In the third review, the Commission found that the U.S. market was supplied exclusively
by domestically produced TCCSS and nonsubject imports during the period of review.79 It
noted that the domestic industry consisted of four domestic producers of TCCSS operating six
production facilities.80 It observed that there were no subject imports from Japan during the
period of review, although some Japanese producers supplied tin mill products to the U.S.
market that were excluded from the antidumping duty order.81 The Commission noted that,
although the domestic industry’s capacity exceeded apparent U.S. consumption throughout the
period of review, several purchasers reported supply constraints from domestic producers,
including limited supplies and late shipments.82
Current Review. The domestic industry, comprising of U.S. Steel, Cleveland-Cliffs, and
Ohio Coatings, was the largest supplier of TCCSS to the U.S. market at the beginning of the
period of review but had become the second largest supplier of TCCSS by the end of the period,
having been overtaken by nonsubject imports in 2022.83 Subject imports were the smallest
source of supply throughout the period of review.84
The domestic industry has undergone several changes since the last review. U.S. Steel
was the largest domestic supplier of TCCSS to the U.S. market during the period of review,
74 First Review, USITC Pub. 3860 at 12.
75 First Review, USITC Pub. 3860 at 12-14.
76 Second Review, USITC Pub. 4325 at 12.
77 Second Review, USITC Pub. 4325 at 12.
78 Second Review, USITC Pub. 4325 at 12.
79 Third Review, USITC Pub. 4795 at 11-13.
80 Third Review, USITC Pub. 4795 at 11-13.
81 Third Review, USITC Pub. 4795 at 11-13.
82 Third Review, USITC Pub. 4795 at 12-13.
83 CR/PR at Tables I-12, C-1.
84 CR/PR at Tables I-12, C-1.

20
accounting for *** percent of U.S. production of TCCSS in 2023.85 During the period of review,
U.S. Steel produced TCCSS at four facilities: East Chicago Tin (East Chicago, Indiana), Gary
Works (Gary, Indiana), Midwest (Portage, Indiana), and USS-UPI (Pittsburg, California).86 U.S.
Steel’s East Chicago plant was idled in 2019 and permanently closed in 2022.87 U.S. Steel’s Gary
Works and USS-UPI plants were indefinitely idled in late 2022 and late 2023, respectively.88 As
a result, U.S. Steel currently operates only two TCCSS production lines at its Midwest facility.89
However, according to U.S. Steel, its Gary Works facility could be restarted quickly if warranted
by market conditions.90
Cleveland-Cliffs was the second largest domestic supplier of TCCSS to the U.S. market
during the period of review, accounting for *** percent of U.S. TCCSS production in 2023.91
Cleveland-Cliffs produced TCCSS at its facility in Weirton, West Virginia, which it acquired from
ArcelorMittal USA LLC in December 2020.92 On April 20, 2024, Cleveland-Cliffs indefinitely idled
its TCCSS plant in Weirton, West Virginia.93 According to Cleveland-Cliffs, the idled Weirton
facility is being maintained so that it could be restarted quickly if warranted by market
conditions.94
Ohio Coatings was the smallest domestic supplier of TCCSS to the U.S. market during the
period of review, accounting for *** percent of U.S. TCCSS production in 2023.95 As the only
non-integrated domestic producer, Ohio Coatings produces TCCSS using black plate acquired
from outside suppliers.96
The domestic industry’s practical TCCSS capacity declined from *** short tons in 2021 to
*** short tons in 2022 and *** short tons in 2023.97
85 CR/PR at Table I-8.
86 CR/PR at III-1 – III-14 & Tables III-1, III-2. U.S. Steel’s USS-UPI facility is so named because U.S.
Steel acquired USS-POSCO Industries (“UPI”) in February 2020. CR/PR at Table III-1.
87 CR/PR at III-1 – III-14 & Tables III-1, III-2.
88 CR/PR at III-1 – III-14 & Tables III-1, III-2.
89 CR/PR at III-1.
90 CR/PR at III-1 n.3; Hearing Tr. 19, 42 (Kopf); U.S. Steel Prehearing Br. at 29; U.S. Steel
Posthearing Br. at 5-6.
91 CR/PR at Table I-8.
92 CR/PR at III-1 – III-14 & Tables III-1, III-2.
93 CR/PR at III-1 – III-14 & Tables III-1, III-2.
94 Cleveland-Cliffs Posthearing Br., Exhibit 1 at paras. 10-12.
95 CR/PR at Table I-8.
96 CR/PR at III-1.
97 CR/PR at Table III-3.

21
During the period of review, *** domestic producers reported that they had
experienced supply constraints since January 1, 2017.98 U.S. producer *** reported that it
largely met its contractual commitments for TCCSS during the period of review and did not
decline or refuse to continue supplying any existing or new customers, although it reported
transitioning to supplying certain existing customers via spot sales rather than annual
contracts.99 U.S. Steel specifically reported supply constraints in ***.100 U.S. producer ***
reported that there was a temporary tightness of supply in 2021 as the economy began to
recover from the COVID-19 pandemic, but that it had ample supply available for at least the last
20 months as of the date it responded to the questionnaire.101 ***, reported that it was forced
to put customers on allocation in January 2022, after its largest supplier of black plate, ***,
refused to continue supplying it with black plate and the imposition of Section 232 measures
made it difficult to source black plate from foreign suppliers.102
Purchasers103 reported delays, refusals, and allocation limits from domestic TCCSS
producers, primarily in 2020, 2021, and 2022.104 Specifically, nine of 22 responding purchasers
reported that domestic producers had frequently experienced supply constraints and five
reported occasional instances of being unable to obtain domestically produced TCCSS.
Purchasers reported being put on allocation (***), refusal by domestic producers to accept
orders or provide quotes (***), or an inability by domestic producers to meet contractual
obligations for volume (***). *** reported an inability of U.S. Steel and Cleveland-Cliffs to
supply volumes in excess of their contracted amounts.105
The domestic industry’s share of apparent U.S. consumption declined from *** percent
in 2021 to *** percent in 2022 and *** percent in 2023.106
Subject imports were *** from the U.S. market in 2021 and were the smallest source of
supply to the U.S. market in 2022 and 2023, accounting for less than *** percent of apparent
U.S. consumption in both years.107
98 CR/PR at II-9.
99 CR/PR at II-9 – II-10.
100 CR/PR at II-9 – II-10. Specifically, U.S. Steel reported that *** Id.
101 CR/PR at II-9.
102 CR/PR at II-9.
103 The Commission received 22 usable purchaser questionnaire responses. CR/PR at I-49. The
largest responding purchasers were ***, in descending order of 2023 purchase quantity. Id.
104 CR/PR at II-11.
105 CR/PR at II-11.
106 CR/PR at Table C-1.
107 CR/PR at Table C-1.

22
Nonsubject imports were the second-largest source of TCCSS supply to the U.S. market
in 2021 but the largest source of supply in 2022 and 2023. Nonsubject imports increased as a
share of apparent U.S. consumption from *** percent in 2021 to *** percent in 2022 and ***
percent in 2023.108 The largest sources of nonsubject imports were ***.109 As discussed above
in Section I, during the period of review, Commerce and the Commission conducted
antidumping duty and countervailing duty investigations concerning imports of tin mill products
from several nonsubject countries. These investigations, however, did not result in any new
antidumping or countervailing duty orders being imposed on imports of tin mill products from
nonsubject sources.110
Eleven of 21 responding importers reported that they had experienced supply
constraints since January 1, 2017, with several citing import restrictions as a reason.111 With
respect to subject imports, no responding purchasers reported frequent or occasional supply
constraints, and four purchasers reported rarely or never experiencing supply constraints.112
Most responding purchasers (11) reported rarely or never experiencing supply constraints from
nonsubject sources.113
3. 	Substitutability and Other Conditions
Original Investigation and Prior Reviews. In the original investigation and first and
second reviews, the Commission found that the domestic like product and subject imports were
generally substitutable.114 In each of these prior proceedings, the Commission found that the
U.S. market for TCCSS was price sensitive notwithstanding that both price and non-price factors
108 CR/PR at Table C-1.
109 CR/PR at IV-2 n.6.
110 Commerce issued final negative antidumping duty determinations with respect to tin mill
products from the Netherlands, Taiwan, Turkey, and the United Kingdom and, as a result, the
Commission terminated the antidumping duty investigations concerning tin mill products from those
countries. The Commission also terminated its investigation of imports from South Korea that were
found by Commerce to be sold at LTFV after determining such imports were negligible. The Commission
further determined that an industry in the United States was not materially injured or threatened with
material injury by reason of imports of tin mill products from Canada, China, and Germany found by
Commerce to be sold in the United States at LTFV and to be subsidized by the government of China.
111 CR/PR at II-10 – II-11.
112 During the period of review, *** importer of subject merchandise, ***, and one purchaser of
subject merchandise, ***. CR/PR at I-49 n.109, IV-1 n.3.
113 CR/PR at II-11.
114 Original Determination, USITC Pub. 3337 at 8, 12; First Review, USITC Pub. 3860 at 14-15;
Second Review, USITC Pub. 4325 at 13.

23
(including quality and delivery) were important factors in purchasing decisions.115 In the third
review, the Commission found that there was at least a moderate degree of substitutability
between the domestic like product and subject imports and that both price and non-price
factors, including quality, delivery/availability, product consistency, and reliability of supply,
were important purchasing factors.116
In the original investigation, the Commission found that the U.S. market for TCCSS was
concentrated with relatively few purchasers.117 In the first and second reviews, the
Commission found that the U.S. market remained concentrated with fewer purchasers than in
the original investigation.118
In the original investigation and first two reviews, the Commission observed that most
TCCSS was sold in the U.S. market through contract sales establishing both price and target
quantities.119 It found that most TCCSS supply contracts were annual contracts that were
negotiated in the fourth quarter of each year for shipments in the following year, although
multi-year contracts with meet-or-release or most-favored-nations provisions also were
sometimes used.120 In the second review, the Commission also found that there was significant
overlap in the timing of domestic and foreign contract negotiations, and that Japanese prices
had been used in contract negotiations with domestic suppliers to leverage lower domestic
prices for TCCSS.121
In the third review, the Commission noted that during the period of review, nearly all
U.S. producers’ sales of TCCSS were on an annual or longer-term contract basis with very few
spot sales, while importers reported using spot sales and contracts, including short-term and
annual contracts.122
In terms of other conditions of competition that the Commission identified in prior
proceedings, the Commission observed in the second and third reviews that raw material costs
accounted for a substantial share of the cost of goods sold (“COGS”) for TCCSS, and that the
115 Original Determination, USITC Pub. 3337 at 8; Second Remand Determination, USITC Pub.
3674 at 29-33; First Review, USITC Pub. 3860 at 14, 23; Second Review, USITC Pub. 4325 at 24, 28.
116 Third Review, USITC Pub. 4795 at 14.
117 Original Determination, USITC Pub. 3337 at 8.
118 First Review, USITC Pub. 3860 at 15; Second Review, USITC Pub. 4325 at 14.
119 Original Determination, USITC Pub. 3337 at 8; First Review, USITC Pub. 3860 at 15-16; Second
Review, USITC Pub. 4325 at 14-15.
120 Original Determination, USITC Pub. 3337 at 8; First Review, USITC Pub. 3860 at 15-16; Second
Review, USITC Pub. 4325 at 14-15.
121 Second Remand Determination, USITC Pub. 3674 at 33-36.
122 Third Review, USITC Pub. 4795 at 15.

24
cost of steel, rather than tin or chromium, was the largest raw material cost in producing
TCCSS.123
Finally, in the third review, the Commission observed that on March 8, 2018, the
President issued Presidential Proclamation 9705, entitled “Adjusting Imports of Steel into the
United States,” exercising his authority under Section 232 of the Trade Expansion Act of 1962
(“Section 232”), as amended (19 U.S.C. § 1862), to impose 25 percent ad valorem duties on all
steel mill products (including TCCSS) from all countries except Canada and Mexico effective
March 23, 2018.124
Current Review. We find that there is at least a moderate degree of substitutability
between the domestic like product and TCCSS from Japan, although substitutability is higher for
products of the same type.125 As discussed in Section II.A. above, TCCSS is commonly produced
to ASTM standards. Additionally, the record indicates that the domestic like product and TCCSS
produced in Japan consist of substantially overlapping TCCSS product types in terms of coating
type and width.126 All responding domestic producers reported that TCCSS from domestic and
imported sources are always interchangeable, while a majority of responding U.S. importers
and purchasers reported that the domestic like product and subject imports are frequently
interchangeable.127 When asked about the comparability of the domestic like product with
123 Second Review, USITC Pub. 4325 at 15; Third Review, USITC Pub. 4795 at 15.
124 Third Review, USITC Pub. 4795 at 15-16.
125 CR/PR at II-18.
126 CR/PR at Tables IV-3, IV-4. In 2023, U.S. producers reported that their U.S. shipments were
comprised of *** short tons of D&I tin plate (*** percent of their total shipments), *** short tons of
other tin plate (*** percent of the total), and *** short tons of tin-free plate (*** percent of the total).
CR/PR at Table IV-3. In 2023, Japanese producers reported that their total shipments were comprised of
*** short tons of D&I tin plate (*** percent of their total shipments), *** short tons of other tin plate
(*** percent of the total), and *** short tons of tin-free plate (*** percent of the total). CR/PR at Table
IV-3. U.S. importers’ minimal U.S. shipments of subject imports were *** short tons of D&I tin plate and
*** short tons of other tin plate. CR/PR at Table IV-3.
In 2023, U.S. producers reported that their U.S. shipments were comprised of *** short tons of
TCCSS less than 41 inches (*** percent of the total) and *** short tons of TCCSS equal to or greater than
41 inches (*** percent of the total). CR/PR at Table IV-4. In 2023, Japanese producers reported that
their total shipments included *** short tons of TCCSS less than 41 inches (*** percent of the total) and
*** short tons of TCCSS equal to or greater than 41 inches (*** percent of the total). CR/PR at Table IV-
4. U.S. importers reported that all TCCSS imported from Japan that year was less than 41 inches. CR/PR
at Table IV-4.
127 CR/PR at II-25, Table II-14. Four importers reported that domestic product was frequently
interchangeable with subject imports, two reported that domestic product was sometimes
interchangeable with subject imports, and one importer reported that domestic product was never
(Continued…)

25
subject imports, responding purchasers’ responses were mixed. Most purchasers reported that
the domestic like product was comparable or superior to subject imports across most factors,
although most purchasers reported the domestic like product to be inferior to subject imports
in terms of availability, availability of TCCSS equal to or greater than 41 inches wide, and
product range.128
The record also shows that price is an important factor in TCCSS purchasing decisions,
although other factors, such as quality, availability, and reliability of supply, were reportedly
more important. Responding purchasers ranked quality as their top purchasing factor and as
among their top three purchasing factors more than any other factor.129 Availability was the
next most frequently reported top purchasing factor and the third most frequently ranked as
among the top three purchasing factors.130 Price was the second most frequently identified
factor among purchasers’ top three purchasing factors and it was most frequently reported as
their third most important factor.131 Purchasers also most frequently identified reliability of
supply as among the very important factors in their purchasing decisions, followed by
availability, quality meets industry standards, product consistency, delivery time, availability of
product less than 41 inches wide, price, and other factors.132 As noted above, most purchasers
reported that the domestic like product was comparable or superior to subject imports across
most factors except availability, availability of TCCSS equal to or greater than 41 inches wide,
and product range.133 In reporting the significance of differences other than price in comparing
domestically produced TCCSS with subject imports, responding U.S. producers reported that
such differences were only sometimes or never significant.134 However, most responding
importers reported that differences other than price were frequently significant and most
purchasers reported that differences other than price were always or frequently significant.135
interchangeable with subject imports. CR/PR at Table II-14. Three purchasers reported that domestic
product was frequently interchangeable with subject imports and one purchaser each reported that
domestic product was sometimes and never interchangeable. Id.
128 CR/PR at II-24 & Table II-13.
129 CR/PR at Table II-9.
130 CR/PR at Table II-9.
131 CR/PR at Table II-9.
132 CR/PR at Table II-10.
133 CR/PR at II-24 & Table II-13.
134 CR/PR at Table II-15.
135 CR/PR at Table II-15.

26
Most responding purchasers (18 of 22) reported that they require their suppliers to
become certified or qualified to sell TCCSS to their firm.136 Sixteen purchasers reported the
time to qualify a new supplier ranging from 30 to 540 days.137 Seven out of 12 purchasers
reported that U.S. Steel or Cleveland-Cliffs failed to qualify for certain specifications or at
certain times since January 1, 2017.138 Currently, there are no qualified suppliers in Japan to
provide any specification of TCCSS to U.S. purchasers and there were no reports of suppliers in
Japan having failed qualification to supply TCCSS to U.S. purchasers.139 Silgan, however, is
currently undergoing the process of qualifying a subject supplier, ***, to provide TCCSS.140
U.S. producers predominantly sold TCCSS through annual contracts, with a smaller
portion of sales being sold through long-term contracts and the smallest portion of sales being
made on the spot market. In 2023, U.S. producers reported that *** percent of their
commercial U.S. shipments were sold pursuant to annual contracts, while *** percent were
sold pursuant to long-term contracts and *** percent were sold as spot sales.141 All three U.S.
producers reported that their annual contracts fix prices, specify a range for quantities, and are
not indexed to raw material prices, and that prices are not re-negotiable during the contract
period; however, U.S. producer *** reported that prices are subject to renegotiation during the
course of the contract “whe{nev}er foreign offers are aggressively low.”142 Contracts for
supplying TCCSS in a given year are generally negotiated in the fall of the preceding year.143 The
small volume of subject imports was *** sold on the spot market.144 Responding Japanese
producers reported that most of their TCCSS sales were on a spot or short-term contract basis.
Spot sales comprised *** percent of their sales to the U.S. market in 2023; for sales to other
export markets, *** percent were on a short-term contract basis and *** percent were spot
sales, with the remainder annual contracts.145
136 CR/PR at II-21.
137 CR/PR at II-21. Five of the 16 firms reported 90 days or fewer and the remaining 11 firms
reported 180 days to 540 days. Id.
138 CR/PR at II-22.
139 CR/PR at II-21 – II-22. We recognize that a *** importer ***. CR/PR at II-21 n.24. It clarified
that ***. EDIS Doc. No. 818778.
140 Hearing Tr. at 133, 136 (Arena); Japanese Respondents Prehearing Br. at 43-44; Japanese
Respondents Posthearing Br. at 4-6. The small volume of subject imports during the period of review
related to that qualification process.
141 CR/PR at Table V-3.
142 CR/PR at V-4 – V-5.
143 CR/PR at V-4 – V-5 n.5.
144 CR/PR at Table V-3.
145 CR/PR at V-5.

27
Most purchasers contact between one and five suppliers before making a purchase,
although four purchasers reported contacting ten or more suppliers.146
TCCSS is primarily produced to order. U.S. producers reported that *** percent of their
U.S. shipments were produced to order in 2023, with lead times averaging *** days for
deferred shipment and *** days for shipment upon completion. The sole importer of Japanese
TCCSS reported that *** percent of its U.S. shipments were produced to order, with lead times
averaging *** days.147
The U.S. TCCSS market is relatively concentrated in terms of purchasers. The *** largest
purchasers in descending order based on their respective 2023 purchase quantity were ***,
which combined accounted for *** percent of all reported purchases of TCCSS, from all
sources, in 2023.148
Steel coil is the main raw material input for TCCSS.149 Prices for cold-rolled steel coil
(“CRC”), which includes black plate, as well as hot-rolled steel coil (“HRC”), which is used by
integrated TCCSS producers to make black plate, increased rapidly from January 2021 through
September 2021, declined irregularly through the end of 2022, then fluctuated and partially
recovered over the course of 2023. HRC prices were modestly lower in December 2023 than in
January 2021, and CRC prices were modestly higher.150 All three U.S. producers and most
responding importers reported that raw material prices increased from 2017 to 2020. Most
importers and one U.S. producer reported that raw material prices increased from 2021 to
2023 but the other two U.S. producers reported that raw material prices decreased over the
period.151
TCCSS imported from Japan was subject to an additional 25 percent ad valorem duty
pursuant to Section 232, effective March 23, 2018, but became subject to an annual tariff-rate
quota (“TRQ”), effective April 1, 2022, with the in-quota volume exempt from additional duties
and any over-quota volume subject to the 25 percent duty.152 For 2023, the TRQ applicable to
TCCSS imported from Japan was 56,119 short tons.153 Under Section 232, as amended,
Commerce is authorized, after consulting with other appropriate federal agency heads, to
146 CR/PR at V-5.
147 CR/PR at II-21.
148 CR/PR at I-49 & calculated from Importer Questionnaires at question II-1.
149 CR/PR at V-1.
150 CR/PR at V-1 – V-2, Figure V-1, Table V-1.
151 CR/PR at V-3.
152 CR/PR at I-25. The TRQ categories for tinplate and tin-free steel originating in Japan covers
both TCCSS and out-of-scope products. Id.
153 CR/PR at Table I-6.

28
provide relief from the additional duties for any steel articles determined “not to be produced
in the United States in a sufficient and reasonably available amount or of a satisfactory quality
and is also authorized to provide such relief based upon specific national security
considerations. Such relief (exclusions) shall be provided for any article only after a request for
exclusion is made by a directly affected party located in the United States.”154 Excluded steel
articles, including any TCCSS, count toward filling the TRQs for Japan.155 The fill rate in 2023 for
the TRQ, including tin-free steel for which exclusions were granted, was 100 percent. Not
including products for which exclusions were granted, 26,271 short tons of the TRQ was filled in
2023, for a fill rate of 46.8 percent.156
C. 	Likely Volume of Subject Imports
1. 	The Original Investigation and Prior Five-Year Reviews
In the original investigation and related remand proceedings, the Commission found
that the volume of subject imports increased in absolute terms by 85.9 percent between 1997
and 1999, and continued to increase rapidly through the first quarter of 2000.157 It found that
the market share of subject imports increased significantly during the period of investigation.158
Accordingly, the Commission found that the volume of subject imports, as well as the increase
in such volume, was significant, both in absolute terms and relative to production and
consumption.159
In the first and second reviews, the Commission found that the likely volume of subject
imports would be significant within the reasonably foreseeable future if the order were
154 CR/PR at I-26.
155 CR/PR at I-26. Imports of excluded products (“quota exclusion entries”) are counted against
the quarterly TRQ in place at the time of entry and count toward the annual TRQ. However, as the
excluded products are exempt from both the quarterly and annual TRQs, they may exceed the TRQs
without becoming subject to the 25 percent duty. Id.
156 CR/PR at Table I-6. The fill rate as calculated in Table I-6 refers to tin-free steel, for which an
exclusion was not granted. However, as reflected in Table I-6 and noted by Japanese Respondents, tin-
free steel imports, for which exclusions were granted, were greater than the quota limit; therefore, the
fill rate for the TRQ including tin-free steel for which exclusions were granted would be 100 percent. See
CR/PR at Table I-6; Japanese Respondents Final Comments at 3-4.
157 Original Determination, USITC Pub. 3337 at 10; Second Remand Determination, USITC Pub.
3674 at 61.
158 Original Determination, USITC Pub. 3337 at 10; Second Remand Determination, USITC Pub.
3674 at 61.
159 Original Determination, USITC Pub. 3337 at 9-10; Second Remand Determination, USITC Pub.
3674 at 61-62.

29
revoked.160 In finding likely significant volumes, the Commission emphasized the Japanese
TCCSS producers’ large production capacity, excess production capacity, export orientation,
declining home market shipments, the inability of the global tin market to absorb Japan’s
excess capacity, the fact that Japanese producers have well established relationships with U.S.
purchasers of excluded tin mill products that are also the main purchasers of TCCSS, the
attractiveness of the U.S. market for TCCSS in terms of both its size and relative prices, and the
volume behavior of subject imports prior to imposition of the order during the original
investigation.161
In the third review, the Commission again found that, if the order was revoked, the
likely volume of subject imports from Japan would be significant.162 As support, the
Commission emphasized the Japanese TCCSS producers’ excess production capacity, declining
home market shipments, increasing export orientation, the fact that Mexico was a leading
export market for Japanese TCCSS, the fact that Japanese producers had well established
relationships with U.S. purchasers of excluded tin mill products that were also the main
purchasers of TCCSS, the attractiveness of the U.S. market for TCCSS, and the increasing volume
of subject imports during the original investigation, prior to imposition of the order.163 The
Commission was not persuaded by purchasers’ affidavits claiming that they would not purchase
significant quantities of subject imports if the order was revoked. Rather, the Commission
found that the record indicated that purchasers had a strong interest in purchasing more
subject imports, citing their purchases of out-of-scope products and their applications for
Section 232 exclusions. The Commission was also not persuaded that purchasers prefer
domestically produced TCCSS, citing the increased volume of nonsubject imports. The
Commission also found that there was information in the record from other purchasers and
importers indicating their interest in purchasing more Japanese TCCSS or having subject imports
from Japan as an alternative supply source upon revocation.164
2. 	The Current Review
In this review, we find that if the order were revoked, the likely volume of subject
imports from Japan would be significant. The volume of subject imports declined dramatically
160 First Review, USITC Pub. 3860 at 18-22; Second Review, USITC Pub. 4325 at 17-22.
161 First Review, USITC Pub. 3860 at 18-22; Second Review, USITC Pub. 4325 at 17-22.
162 Third Review, USITC Pub. 4795 at 17-22.
163 Third Review, USITC Pub. 4795 at 17-21.
164 Third Review, USITC Pub. 4795 at 21-22.

30
after the order was imposed and remained minimal during the period of review.165 There were
*** subject imports in 2021, *** short tons in 2022, and *** short tons in 2023.166 Subject
imports accounted for less than *** percent of apparent U.S. consumption in 2022 and 2023.167
The record in this review indicates that Japanese producers have the ability to export
significant volumes of subject merchandise to the United States in the event of revocation of
the order, however. Although their TCCSS capacity has declined since the original
investigation,168 subject producers maintained significant practical TCCSS capacity throughout
the period of review.169 Subject producers reported practical TCCSS capacity of *** short tons
in 2021 and *** short tons in 2022 and 2023 and production of TCCSS of *** short tons in 2021,
*** short tons in 2022, and *** short tons in 2023.170 Thus, the Japanese industry’s capacity
utilization rate was *** percent in 2021, *** percent in 2022, and *** percent in 2023, leaving
them with available capacity that could be used to increase exports of TCCSS to the United
165 Subject imports have been largely absent from the U.S. market from 2001 onward. CR/PR at
C-7 – C-13.
166 CR/PR at Table IV-1.
167 CR/PR at Table C-1.
168 In 1999, Japanese producers’ reported TCCSS capacity was 3.2 million short tons, which may
have been overstated because it included out-of-scope products. CR/PR at Table IV-10. Subject
producers reported 1.9 million short tons of TCCSS capacity in 2005, 1.8 million short tons in 2011, and
1.7 million short tons in 2016. Id.
169 CR/PR at Table IV-13.
170 CR/PR at Table IV-13.

31
States.171 Subject producers’ excess capacity was *** in 2023, equivalent to *** percent of
apparent U.S. consumption that year.172 173
Additionally, Japanese producers have the ability to increase production of TCCSS by
shifting production from excluded tin mill products and/or other out-of-scope products that are
produced on the same equipment. *** reported producing out-of-scope products on the same
equipment and machinery used to produce TCCSS, although TCCSS accounted for the largest
portion of subject producers’ overall production on the same equipment and machinery
throughout the period of review.174
171 CR/PR at Table IV-13. We are not persuaded by Japanese Respondents’ arguments that
subject producers could not produce additional TCCSS because the “’excess’ capacity reported by
Japanese producers does not represent capacity that the producers could easily bring online.” Japanese
Respondents Prehearing Br. at 32-33. Subject producers reported their practical TCCSS capacity, which
was defined in the questionnaires as “{t}he level of production of TCCSS that your establishment(s)
could reasonably have expected to attain.” See Foreign Producers Questionnaire at II-3a. We likewise
are not persuaded by Japanese Respondents’ arguments that we should limit our assessment of the
Japanese TCCSS industry’s available capacity to only the capacity as reported by *** or by ***, as the
only subject producers to have exported TCCSS to the United States. Japanese Respondents Prehearing
Br. at 33; Japanese Respondents Posthearing Br. at 3-4. All three subject producers exported substantial
volumes of TCCSS, and are therefore capable of exporting TCCSS to the U.S. market. See Foreign
Producer Questionnaires at II-13. Even if we were to focus on the available capacity of *** in Japan, we
would still find that the TCCSS industry in Japan had the ability to increase its exports of subject
merchandise to the United States to significant levels if the order were revoked. *** alone possessed
excess capacity equivalent to *** percent of apparent U.S. consumption in 2023. Calculated from ***
Foreign Producer Questionnaire at II-3a. In the same vein, Japanese Respondents acknowledge that ***
possessed excess capacity that was equivalent to *** percent of apparent U.S. consumption in 2023.
Japanese Respondents Prehearing Br. at 33.
172 CR/PR at Tables IV-13, C-1.
173 We have also considered subject producers’ inventories. Subject producers’ end-of-period
inventories initially decreased from *** short tons in 2021 to *** short tons in 2022 before increasing to
*** in 2023, which was equivalent to *** percent of apparent U.S. consumption that year. CR/PR at
Tables IV-15, C-1. We acknowledge, however, that TCCSS in the U.S. market primarily is produced to
order. CR/PR at II-21.
174 CR/PR at IV-28. TCCSS accounted for *** percent of overall production in 2021, *** percent
in 2022, and *** percent in 2023. CR/PR at Table IV-17. Thus, TCCSS accounted for a *** of overall
production and was relatively stable at these levels throughout the period of review, contrary to
Japanese Respondents’ assertions that subject producers are increasingly focused on out-of-scope
products. Japanese Respondents Prehearing Br. at 29-30; Japanese Respondents Posthearing Br. at 3.
Similarly, TCCSS as a share of overall production increased somewhat overall during the period of
review, while out-of-scope products as a share of overall production decreased, undercutting Japanese
Respondents’ arguments that they would not shift production to TCCSS. Japanese Respondents
Prehearing Br. at 36-40.

32
Subject producers are also export oriented. Although Japanese producers’ export
shipments and home market shipments declined irregularly during the period of review, export
shipments accounted for *** of their total shipments throughout the period.175 Subject
producers' exports were *** short tons in 2021, *** short tons in 2022, and *** short tons in
2023.176 Exports as a share of subject producers’ total shipments were *** percent in 2021, ***
percent in 2022, and *** percent in 2023.177 According to Global Trade Atlas ("GTA") data
concerning TCCSS, which include subject TCCSS as well as out-of-scope products, Japan is the
third largest global exporter of TCCSS.178 The responding subject producers' exports of TCCSS
were largely to markets other than Asia during the period of review, and their TCCSS exports to
non-Asian markets accounted for an increasing share of their total exports.179 Indeed, North
America was a top TCCSS export market for subject producers during the period. Mexico was
the leading single country export market for Japanese TCCSS, and subject producers' exports to
Mexico as a share of their total exports steadily increased throughout the period of review.180
In addition to being export oriented, the record shows that subject Japanese producers
view the U.S. market as attractive and would have a strong incentive to direct increased
volumes of TCCSS to the United States if the order were revoked. According to GTA data, which
include subject TCCSS as well as out-of-scope products, the U.S. market is the largest import
market in the world for TCCSS.181 Although subject imports of TCCSS were minimal during the
period of review, Japanese TCCSS producers maintained a substantial presence in the U.S.
market during the period through their exports of out-of-scope TCCSS products to U.S.
customers, giving them knowledge of the U.S. market and relationships with U.S. purchasers.182
175 CR/PR at Table IV-15.
176 CR/PR at Table IV-15.
177 CR/PR at Table IV-15.
178 CR/PR at Table IV-21. These data include official exports statistics under HS subheadings
7210.11, 7210.12, 7210.50, and 7212.10. Id. at Source.
179 CR/PR at Table IV-16. As a share of total exports, subject producers’ exports to Asia
decreased from *** percent in 2021 to *** percent in 2022 and *** percent in 2023. Id.
180 CR/PR at Table IV-16. Subject producers reported *** short tons of export shipments of
TCCSS to Mexico in 2021, *** short tons in 2022, and *** short tons in 2023. Id. Exports to Mexico
accounted for *** percent of their total exports of TCCSS in 2021, *** percent in 2022, and *** percent
in 2023. Id.
181 CR/PR at Table IV-22.
182 During the period of review, U.S. importers reported importing *** short tons of out-of-
scope tin mill products from Japan in 2021, *** short tons in 2022, and *** short tons in 2022. CR/PR at
Table IV-7. Japan accounted for the *** share of importers’ out-of-scope tin mill product imports during
the period of review, with out-of-scope products from Japan accounting for between *** and ***
percent of U.S. importers’ reported total imports of out-of-scope tin mill products during 2021-2023. Id.

33
The record in this review also indicates that U.S. prices were generally higher than prices in
other markets supplied by subject producers during the period of review.183 Responding U.S.
producers and importers with knowledge of global prices confirmed that prices for TCCSS in the
United States were higher than prices in other markets.184 Indeed, at the hearing, witnesses
appearing in opposition to continuation of the order acknowledged that the U.S. market is the
highest-priced market in the world for TCCSS, with one witness describing U.S. prices as higher
than other markets “by a substantial margin” and another estimating that U.S. prices were 30
percent higher than those in Europe.185 Moreover, the existence of third-country trade barriers
to subject imports would further enhance the relative attractiveness of the U.S. market to
subject producers in the event of revocation.186 We therefore find that Japanese TCCSS
producers would have an incentive to shift exports from other markets and, consistent with
their behavior in the original period of investigation, to increase exports of TCCSS to the United
States, if the order were revoked.
Additionally, purchasers and importers of TCCSS have expressed interest in purchasing
subject imports from Japan if the order were revoked.187 When asked about the likely impact of
revocation, five of seven responding importers and six of nine responding purchasers reported
that they would consider increasing their imports or purchases of TCCSS from Japan.188 Indeed,
as discussed above in Section III.B.C., the largest U.S. purchaser, ***, is currently engaged in
efforts to certify ***, the *** subject producer, to supply TCCSS. Additionally, Japanese
producer *** reported exporting small quantities of TCCSS from Japan to ***, during the period
of review ***.189 Moreover, as discussed above, Mexico was the leading export market for
Japanese TCCSS producers during the period of review. Thus, if the order were revoked, the
183 Subject producers reported that the average unit values (“AUVs”) of their exports to the
United States were higher than those of their exports to all other markets in 2022 and 2023, ***. CR/PR
at Table IV-16. GTA data concerning TCCSS, including subject TCCSS and out-of-scope products, show
that the AUVs of U.S. imports of TCCSS were higher than those of TCCSS imports in other markets in
2022 and 2023. CR/PR at Table IV-22.
184 CR/PR at IV-40. Two U.S. producers and five importers reported that they were aware of
TCCSS prices in non-U.S. markets and all responding firms reported that TCCSS prices in the United
States were higher than prices in other markets. Id.
185 Hearing Tr. at 163 (Arena), 164-65 (Dietrich), 165 (Hughes), 165 (Porter).
186 CR/PR at Table IV-20.
187 Indeed, ***. U.S. Steel Posthearing Br. at 2, Attachment B.
188 CR/PR at Table D-1 (responses of importers ***, and purchasers ***).
189 CR/PR at IV-2 n.5. *** also reported that it had arranged for importing *** short tons of
TCCSS from Japan in ***. CR/PR at IV-11 & Table IV-6.

34
Japanese industry, which is already exporting to Mexico, would likely be interested in the U.S.
market for TCCSS, which is in close proximity and a larger TCCSS market with higher prices.
We are not persuaded by Japanese Respondents’ arguments that subject imports would
not be significant if the order were revoked. As an initial matter, the record in this review does
not support their assertions that, if the order were revoked, subject imports would be limited
to niche or out-of-scope products that are not supplied by the domestic TCCSS producers.190 As
discussed above in Section III.B.3., there is substantial overlap in the product offerings by
domestic and subject producers.191 Additionally, as also discussed above, TCCSS accounted for
a *** of the subject producers' overall production and was relatively stable at these levels
during the period of review, with a slight increase in TCCSS as a share of their overall
production during the period.192 Further, the record suggests that U.S. demand for out-of-
scope tin mill products declined relative to U.S. demand for subject TCCSS during the period of
review.193
We likewise find unpersuasive Japanese Respondents’ arguments that there are barriers
to entry in the U.S. market that would prevent subject imports from increasing significantly if
the order were revoked. Japanese Respondents argue that the lengthy qualification process
required by U.S. purchasers would serve as a barrier preventing significantly increased volumes
of subject imports if the order were revoked.194 As discussed above in Section III.B.3.,
purchasers reported a wide array of qualification times, with the time to qualify a new supplier
reportedly taking anywhere from 30 to 540 days.195 We note that, as also discussed above in
Section III.A., the governing statute states that “the Commission shall consider that the effects
of revocation or termination may not be imminent, but may manifest themselves only over a
longer period of time.”196 Thus, we find that even at the high end of the qualification time
range, which is less than two years, the timeframe required for a purchaser to qualify a new
Japanese supplier would fall within the reasonably foreseeable future. We further note that, as
discussed above, and acknowledged by Japanese Respondents, the largest U.S. purchaser,
190 Japanese Respondents Posthearing Br. at 5; Japanese Respondents Posthearing Br. at 4-6.
191 See CR/PR at Tables IV-3, IV-4.
192 See CR/PR at Table IV-17.
193 Adding U.S. importers’ imports of out-of-scope tin mill (CR/PR at Table IV-7) to apparent U.S.
consumption of TCCSS (CR/PR at Table C-1) suggests that the share of the total U.S. market represented
by out-of-scope tin mill products decreased irregularly from *** percent in 2021 to *** percent in 2023.
194 Japanese Respondents Prehearing Br. at 43-44; Japanese Respondents Posthearing Br. at 4-6.
195 CR/PR at II-21. Five of the 16 firms reported 90 days or fewer and the remaining 11 firms
reported 180 days or longer. Id. at n.22.
196 19 U.S.C. § 1675a(a)(5).

35
Silgan, is currently undergoing the process of qualifying the *** subject producer *** to supply
it with TCCSS.197 Thus, we do not find that U.S. purchasers’ qualification processes would
prevent the volume of subject imports from increasing to a significant level in the reasonably
foreseeable future if the order were revoked.
We similarly find unavailing Japanese Respondents’ claim that the “well-established
supply chains” in the U.S. market, including purchasers' "decades-long" relationships with
domestic and nonsubject producers and their preference for long term contracts, would
constrain the likely volume of subject imports if the order were revoked.198 As discussed above,
subject producers and importers of subject merchandise have already established relationships
with U.S. purchasers of out-of-scope tin mill products. Numerous responding importers and
purchasers reported that they would consider increasing their imports and purchases of TCCSS
from Japan if the order were revoked, and ***, the largest U.S. purchaser, is already in the
process of qualifying subject producer ***. Moreover, given the overlap in product offerings
between domestic and subject producers, as well as the higher degree of substitutability for
products of the same type and the concentrated purchaser base for TCCSS in the United States,
subject imports would likely compete with domestic producers for contracts to supply TCCSS to
the same customers after revocation.
We likewise find unpersuasive Japanese Respondents’ argument that subject imports
would not increase to significant levels because subject producers would have no incentive to
shift away from supplying their longstanding existing customers in home and third-country
export markets in favor of increased exports of TCCSS to the United States.199 As discussed
above, subject producers have sufficient excess capacity to significantly increase their exports
of TCCSS to the U.S. market without reducing their shipments to existing customers in Japan
and third country markets. Furthermore, given the record evidence that prices are substantially
higher in the U.S. market than elsewhere, we find it likely that subject producers would have an
economic incentive to shift exports from existing customers in other markets to serve
customers in the United States, particularly given their existing relationships with U.S.
197 Hearing Tr. at 133, 136 (Arena); Japanese Respondents Prehearing Br. at 43-44; Japanese
Respondents Posthearing Br. at 4-6. Japanese Respondents also acknowledge that ***. Id. The record,
however, indicates that *** possessed available capacity; during the period of review, its capacity
utilization rate was *** percent in 2021, *** percent in 2022, and *** in 2023. Calculated from ***
Foreign Producer Questionnaire at II-3a.
198 Japanese Respondents Prehearing Br. at 41-43; Japanese Respondents Posthearing Br. at 4-6.
199 Japanese Respondents Prehearing Br. at 49-51, Exhibit 27; Japanese Respondents
Posthearing Br. at 7-8.

36
purchasers of out-of-scope tin mill products. Indeed, although Japanese Respondents argue
that subject producers’ relationships with customers in Mexico predate the imposition of the
order under review,200 those relationships did not prevent the volume and market share of
subject imports from increasing significantly during the original investigations, as the
Commission found.
Finally, we find unavailing Japanese Respondents’ claim that the Section 232 TRQ
applicable to subject imports from Japan will constrain subject import volumes and prevent
them from increasing to significant levels after revocation.201 As discussed in section III.B.3.
above, the TRQ does not limit the volume of subject imports; rather, the in-quota volume is
exempt from additional duties and out-of-quota volumes may still enter the United States,
subject to an additional duty of 25 percent. As discussed above, the record indicates that
TCCSS prices were substantially higher in the United States than in other markets during the
period, including 30 percent higher than in Europe, according to respondents’ own witness.202
Moreover, given subject producers excess capacity, there would be an incentive to increase
production to sell to the large, attractive U.S. market, even with the additional 25 percent duty.
We also are unpersuaded by Japanese Respondents’ assertion that subject producers would
have no incentive to fill the TRQ with subject imports rather than out-of-scope products if the
order were revoked.203 As discussed above, TCCSS accounted for a *** share of the subject
producers' overall production during the period of review, including *** percent in 2023,
indicating that their primary interest is in TCCSS production, and out-of-scope products account
for a small share of the U.S. market. Based on the attractiveness of the U.S. market and the
higher prices available there, and the subject producers’ current excess production capacity, we
find that if the order were revoked, subject producers would likely significantly increase the
volume of their exports of TCCSS to the United States both within the TRQ level and beyond,
even with the 25 percent duty applied to any out-of-quota imports. Indeed, similar Section 232
measures on imports from nonsubject countries have not prevented such imports from
increasing in volume in 2022 and gaining market share in both 2022 and 2023.204 As noted
200 Japanese Respondents Posthearing Br. at 8.
201 Japanese Respondents Prehearing Br. at 46-48; Japanese Respondents Posthearing Br. at 6-7.
202 Hearing Tr. at 164-65 (Dietrich).
203 Japanese Respondents Prehearing Br. at 46-48.
204 We recognize that nonsubject imports from Canada are exempt from Section 232 measures.
CR/PR at I-25 n.52. However, nonsubject imports from other subject sources, including China, the
Netherlands, Germany, Taiwan, Turkey, and the United Kingdom, increased notwithstanding the Section
232 measures applicable to such imports. See Tin Mill Products from Canada, China, Germany, and
(Continued…)

37
above, nonsubject imports now account for the largest share of the U.S. market,205 and they
were larger in volume and market share than in 2016, the last full year of available data prior to
the Section 232 measures being put in place in 2018.206
In sum, based on the significant volume and market share of subject imports during the
original investigations; the subject producers' continued presence in the U.S. market through
sales of out-of-scope tin mill products; the subject producers’ substantial capacity and excess
capacity, ability to product-shift, and their export orientation; and the attractiveness of the U.S.
market, we find that the likely volume of subject imports would be significant, both in absolute
terms and relative to consumption in the United States, if the order were revoked.
D. 	Likely Price Effects
1. 	The Original Investigation and Prior Five-Year Reviews
In the original investigation and related remand proceedings, the Commission found
that the domestic like product and subject imports were substitutable, that price was an
important factor in purchasing decisions, and that the U.S. market for TCCSS was price
sensitive.207 It found that there was significant underselling by subject imports, which
coincided with domestic price declines for TCCSS during the period of investigation.208 It
observed that the aggressive pricing by importers of subject merchandise was used by at least
some purchasers in their price negotiations with the domestic suppliers, and that the adverse
price effects of subject imports were also reflected in confirmed lost revenue allegations.209 It
South Korea, Inv. Nos. 701-TA-685 and 731-TA-1599-1601, 1603 (Final), USITC Pub. 5492 (Feb. 2024) at
Table IV-3 (showing that imports from several countries increased during 2020 through 2022).
205 CR/PR at Tables I-12, C-1.
206 In 2023, the volume of nonsubject imports was *** short tons and they accounted for ***
percent of apparent U.S. consumption. CR/PR at Tables IV-1, C-1. The volume of nonsubject imports in
2016 was 1,058,090, accounting for 43.1 percent apparent U.S. consumption. CR/PR at C-13.
207 Original Determination, USITC Pub. 3337 at 11-12; Second Remand Determination, USITC
Pub. 3674 at 32, 61-62.
208 Original Determination, USITC Pub. 3337 at 12; Second Remand Determination, USITC Pub.
3674 at 6-26, 61-62. Further analysis upon remand incorporated customer-specific prices, added the
volumes of sales won based on particular bids, and aggregated certain company-specific price data to
avoid the appearance of overstating the number of bid comparisons. This analysis generally showed
increasing levels of underselling by subject imports over the original period of investigation. See Second
Remand Determination, USITC Pub. 3674 at 6-26. On remand, the Commission further explained that
the underselling margins exhibited by the subject imports were not attributable to the domestic
industry’s lead-time price premium. Id. at 26-29.
209 Original Determination, USITC Pub. 3337 at 12-14.

38
concluded that subject imports generally undersold nonsubject imports toward the end of the
period of investigation, and that subject imports had a significant adverse effect on domestic
prices that was distinct from any adverse price effects of nonsubject imports.210 Given these
considerations, the Commission found that significant volumes of underpriced subject imports
had significant price-suppressing and price-depressing effects on prices for domestically
produced TCCSS.211
In the first five-year review, the Commission again found that the domestic like product
and subject imports were generally substitutable and that the U.S. market for TCCSS was price
sensitive.212 It found that Japanese producers would likely attempt to win sales contracts
through aggressive pricing if the order were revoked as they did prior to the imposition of the
order.213 It concluded that likely significant volumes of low-priced subject imports would have
adverse price effects on spot sales and would also likely depress prices that were agreed to
during negotiations for new contracts in the event of revocation.214 Finally, it observed that the
U.S. market for TCCSS was characterized by a small number of purchasers, and that even a few
low-priced sales of subject imports would have significant adverse price effects in a relatively
short period of time.215
In the second five-year review, the Commission reiterated that the domestic like
product and subject imports were generally substitutable and that the U.S. market for TCCSS
was price sensitive.216 It also found that the U.S. market remained characterized by a small
number of large purchasers, which may seek to enter into annual or longer-term contracts, as
well as a number of smaller purchasers.217 If the order were revoked, it concluded, subject
producers from Japan would be able to win sales and expand their U.S. market share through
spot sales, or by bidding for and winning contracts, and that successful bids would have an
immediate impact on spot sales, new contract negotiations, and existing contracts containing
meet-or-release or similar clauses.218 It observed that the credible threat of purchasers buying
subject imports could put pressure on domestic prices even when subject producers did not
210 Original Determination, USITC Pub. 3337 at 15-16.
211 Original Determination, USITC Pub. 3337 at 16; Second Remand Determination, USITC Pub.
3674 at 61-62.
212 First Review, USITC Pub. 3860 at 24-25.
213 First Review, USITC Pub. 3860 at 26.
214 First Review, USITC Pub. 3860 at 25-26.
215 First Review, USITC Pub. 3860 at 25-26.
216 Second Review, USITC Pub. 4325 at 24.
217 Second Review, USITC Pub. 4325 at 25.
218 Second Review, USITC Pub. 4325 at 25.

39
win a sale and that further downward pressure on domestic TCCSS prices would be particularly
harmful to U.S. producers given that the U.S. industry was experiencing a cost/price squeeze
even without the presence of subject imports.219 Given these considerations, it concluded that
subject imports were likely to undersell and price aggressively in order to win sales with
purchasers and would likely have significant depressing and/or suppressing effects on the
prices of the domestic like product.220
In the third five-year review, the Commission found that there was at least a moderate
degree of substitutability between domestically produced TCCSS and subject merchandise and
that price was an important factor in purchasing decisions for TCCSS.221 Given the absence of
subject imports from the U.S. market, the record did not contain any price comparison data for
subject imports and domestically produced TCCSS during the period of review.222 The
Commission found that, in light of the Japanese TCCSS industry’s export orientation, the
substitutability between domestically produced TCCSS and subject merchandise, and the
importance of price in purchasing decisions, Japanese exporters had the same incentive and
ability to undersell the domestic product to gain U.S. market share as they did during the
original investigation.223 It noted that Japanese TCCSS producers were exporting to third
country markets at AUVs well below those prevailing in the U.S. market and would therefore be
capable of capitalizing on higher U.S. prices while still underselling the domestic industry in
order to gain market share.224 The Commission concluded that the increased volumes of low-
priced subject imports that were likely after revocation would likely force the domestic industry
to cut prices or forego price increases or else lose sales to subject imports.225 Accordingly, it
found that subject imports from Japan would likely undersell the domestic like product to a
significant degree after revocation, gaining market share and/or having significant price
depressing or suppressing effects.226
219 Second Review, USITC Pub. 4325 at 25.
220 Second Review, USITC Pub. 4325 at 25.
221 Third Review, USITC Pub. 4795 at 25.
222 Third Review, USITC Pub. 4795 at 25.
223 Third Review, USITC Pub. 4795 at 25.
224 Third Review, USITC Pub. 4795 at 26.
225 Third Review, USITC Pub. 4795 at 26.
226 Third Review, USITC Pub. 4795 at 26.

40
2. 	The Current Review
As discussed above in Section III.B.3., we find that there is at least a moderate degree of
substitutability between domestically produced TCCSS and subject imports and that price is an
important factor in purchasing decisions for TCCSS.
The Commission requested quarterly pricing data on four TCCSS products shipped to
unrelated U.S. customers during period of review.227 All three U.S. producers and *** importer
of subject merchandise (***) provided usable pricing data for sales of the four requested
products, although not all firms reported pricing for all products for all quarters, and there was
particularly limited data available for subject imports given the minimal volume of subject
imports in the U.S. market during the period of review. Pricing data reported by these firms
accounted for *** percent of U.S. producers’ U.S. shipments of TCCSS and *** percent of U.S.
shipments of subject imports from Japan in 2023.228 The limited volume of subject imports
oversold the domestic like product in all four available quarterly comparisons, involving ***
short tons, at margins ranging from *** to *** percent.229
We have also considered price trends. Prices for domestically produced TCCSS for all
four pricing products increased overall between *** and *** percent during the period of
review.230 Subject import pricing data were only available for pricing products 1 and 2 for the
***, and subject import prices were lower in in fourth quarter of 2023 than in the fourth
quarter of 2022.231
We find that subject imports are likely to undersell the domestic like product to a
significant degree if the order were revoked. As discussed above, during the original
227 CR/PR at V-7. The four pricing products were as follows:
Product 1.-- Single reduced, electrolytic tinplate with base box weights
of 75–95 lbs. inclusive and less than 41 inches in width, in coils.
Product 2.-- Double reduced, electrolytic tinplate with base box weights
of 55–65 lbs. inclusive and less than 41 inches in width, in coils.
Product 3.-- Single reduced, electrolytic chromium-coated steel with
base box weights of 65–80 lbs. inclusive and less than 41 inches in
width, in coils.
Product 4.-- Double reduced, electrolytic chromium-coated steel with
base box weights of 55–65 lbs. inclusive and less than 41 inches in
width, in coils.
Id.
228 CR/PR at V-7.
229 CR/PR at Tables V-4 – V-9.
230 CR/PR at V-14.
231 CR/PR at Tables V-4, V-5.

41
investigation, the Commission found that subject imports undersold the domestic like product
to a significant degree and observed that aggressive pricing practices had enabled subject
imports to gain market share.232 In light of the Japanese TCCSS industry’s excess capacity, its
export orientation, the substitutability between domestically produced TCCSS and subject
merchandise, the importance of price in purchasing decisions, and the attractiveness of the U.S.
market, Japanese exporters have the same incentive and ability to undersell the domestic
product to gain U.S. market share as they did at the time of the original investigation.233 While
232 Japanese Respondents’ argument that the Commission’s price effects findings in the original
investigation “no longer apply,” Japanese Respondents Posthearing Br. at 10, is without merit. As
discussed above in Section III.A., the statute explicitly directs the Commission to consider its findings in
the original investigation.
233 Citing the Commission's recent negative determinations in the investigations of tin mill
products from Canada, China, and Germany, in particular the Commission’s findings in its material injury
and threat analyses, Japanese Respondents argue that the Commission should similarly find that subject
imports from Japan are not likely to not compete on the basis of price. Japanese Respondents
Prehearing Br. at 22, 52-56. In doing so, Japanese Respondents overlook that the Commission found in
the recent tin mill products investigations that subject imports from China, Canada, and Germany had
predominantly oversold the domestic like product, with non-price reasons explaining those imports’
gain in market share, whereas in this review the Commission finds that subject imports from Japan are
likely to undersell the domestic like product to a significant degree. Tin Mill Products from Canada,
China, Germany, and South Korea, Inv. Nos. 701-TA-685 and 731-TA-1599-1601, 1603 (Final), USITC Pub.
5492 (Feb. 2024) at 38-62. With subject imports likely to undersell the domestic like product to a
significant degree to gain market share, and given the importance of price in purchasing decisions, we
do not agree that in the event of revocation purchases of subject imports from Japan would be for non-
price based reasons. Moreover, Japanese Respondents misconstrue the Commission’s finding in the
recent tin mill investigations on imports from Canada, China, and Germany that the gain in market share
by imports from those countries was for non-priced reasons as indicating an absence of price-based
competition in the U.S. tin mill market at large. That is not what the Commission found in those
investigations. Further, the limited availability of certain product types from the domestic industry that
were being imported from different sources was a relevant non-price factor that affected the
Commission’s analysis in the recent investigations on tin mill products from Canada, China, and
Germany, but the record in the current review shows that there is a substantial overlap in the TCCSS
products offered by the domestic industry and subject Japanese producers, particularly with respect to
width and non-D&I products. Thus, the record here indicates that competition between the domestic
like product and subject imports upon revocation would likely be heavily price-based.
We also find unpersuasive Japanese Respondents' argument that the Commission's recent
finding that imports of tin mill products from Canada, China, and Germany had no adverse price effects
means that the comparatively smaller likely volume of subject imports could also have no adverse price
effects. While the Commission found that imports from Canada, China, and Germany predominantly
oversold the domestic like product in its recent investigations, it found in the original investigation of
TCCSS from Japan that subject imports had significantly undersold the domestic like product to gain
market share. As discussed above, we find that the volume of subject imports is likely to be significant
(Continued…)

42
the limited volume of subject imports in the U.S. market during the period of review oversold
the domestic like product, as discussed above, the record indicates that Japanese TCCSS
producers are selling in other markets at AUVs well below prevailing prices in the U.S. market
and therefore would have additional incentive to obtain higher prices on exports to the U.S.
market while still being able to price below the domestic industry in order to gain market share.
Absent the discipline of the order, the likely significant volume of low-priced subject imports
would likely force the domestic industry to either reduce its prices, forego price increases that
would otherwise have occurred, or risk losing market share to subject imports, as occurred in
the original investigation.234 Thus, we find that if the order were revoked, the significant
volume of low-priced subject imports would likely have significant adverse price effects within a
reasonably foreseeable time.235
upon revocation. Given that such imports are likely to compete aggressively on price in order to gain
market share as in the original investigation, increased volumes of low-priced subject imports are likely
to have significant price effects, even if comparatively lower in volume than nonsubject imports.
234 We are unpersuaded by Japanese Respondents’ argument that the absence of evidence of
price depression and price suppression during the period of review precludes a finding of likely
significant price effects by subject imports after revocation. Japanese Respondents Prehearing Br. at 57-
61, 63; Japanese Respondents Posthearing Br. at 9-10. As discussed above, subject imports are likely to
resume underselling after revocation as a means of gaining market share. Given the importance of price
and the substitutability of subject imports and the domestic like product, the underselling is likely to
cause subject imports to capture market share from the domestic industry and/or depress or suppress
prices for the domestic like product. The absence during the period of review (when subject imports
were under the discipline of the order) of evidence that subject imports depressed or suppressed
domestic producer prices, and the Commission’s finding in its recent investigation of tin mill products
from Canada, China, and Germany that those nonsubject imports did not have significant price effects,
does not address what is likely to occur in the event of revocation when subject imports from Japan
resume underselling. We similarly find unpersuasive Japanese Respondents' argument that the
overselling by subject imports during the period of review indicates that subject imports would be
limited to certain high value niche products if the order were revoked. Japanese Respondents
Prehearing Br. at 63-64. Subject import prices under the discipline of the order are not necessarily
predictive of subject import prices after revocation. As discussed above, there is substantial overlap in
the types of TCCSS supplied by the domestic industry and subject producers and price is an important
purchasing factor, and we find that subject imports will compete directly and aggressively with the
domestic like product based on price, as they did in the original investigation.
235 We also find that the domestic industry would not be insulated from subject import
competition by the fact that the domestic like product was sold predominantly ***, while subject
imports were sold ***, during the period of review. CR/PR at Table V-3. These spot sales were related
to very small volumes of subject imports pursuant to a qualification process, and therefore, are not
indicative of likely behavior for larger, commercial volumes of subject imports. As discussed above in
Section III.B.3., for sales to other export markets, *** percent of Japanese producers’ sales were on a
short-term contract basis and *** percent were spot sales, with the remainder sold under annual
(Continued…)

43
E. 	Likely Impact
1. 	The Original Investigation and Prior Five-Year Reviews
In the original investigation and related remand proceedings, the Commission found
that subject imports had a significant adverse impact on the domestic industry.236 It
emphasized that most of the domestic industry’s output, employment, and financial
performance indicia declined overall during the period of investigation and noted that the
industry’s financial performance was lowest when subject import volumes peaked.237 It
rejected respondents’ claim that the majority of the increase in the volume of subject imports
was by a few large customers for non-price reasons.238 It also found that the significant adverse
impact by subject imports was not offset or outweighed by other factors, including the
domestic industry’s quality and delivery issues, lead time advantages of domestic producers,
and nonsubject imports.239
In the first review, the Commission found that revocation of the orders would likely
result in a significant volume of low-priced subject imports that would likely have a significant
adverse impact on the domestic industry.240 It found that the domestic industry was
vulnerable, especially given flat or declining demand trends, the price sensitive nature of the
U.S. market, the cost/price squeeze the industry was experiencing, and the industry’s
contracts. CR/PR at V-5. We also note that, for sales to the Japanese market, their sales were roughly
evenly split among long-term contracts, spot sales, and short-term contracts. Id.
Further, given the overlap in product offerings and customers, subject imports would likely
compete with domestic producers for contracts to supply TCCSS to the same customers if the order
were revoked. Moreover, given the limited number of large purchasers and the comparable products
that we expect Japanese producers would be able to provide them, even smaller sales or offers at
aggressive pricing can negatively impact domestic producers’ negotiations for larger contract volumes.
Consistent with the Commission’s findings in prior reviews, we find that the small number of large U.S.
purchasers would likely use low-priced subject imports to leverage price concessions from the domestic
industry if the order were revoked. See Second Remand Determination, USITC Pub. 3674 at 33-36.; see
also U.S. Steel Prehearing Br. at 35-37; Cleveland-Cliffs Prehearing Br. at 38-41. Indeed, the record
indicates that purchasers sought price concessions from domestic producers during the period of
review, underscoring the importance of price in purchasing decisions. See U.S. Steel Posthearing Br.,
Exhibit 1, Attachment B (***).
236 Original Determination, USITC Pub. 3337 at 16-19; Second Remand Determination, USITC
Pub. 3674 at 44-62.
237 Original Determination, USITC Pub. 3337 at 17-18.
238 Original Determination, USITC Pub. 3337 at 18.
239 Second Remand Determination, USITC Pub. 3674 at 44-62.
240 First Review, USITC Pub. 3860 at 27-30.

44
consistently poor financial performance during the period of review.241 Emphasizing that the
Japanese industry remained exported-oriented with excess capacity, as well as the
attractiveness of the U.S. market, the Commission found that the likely resumption of
significant volumes of low-priced subject imports would likely result in continuation or
recurrence of material injury to the domestic industry.242 Rejecting respondents’ assertion that
subject imports would compete with the domestic like product only to a limited extent, the
Commission found that the Japanese producers had indicated that they were still able to
produce TCCSS in all varieties and that there was no evidence of any change in the
substitutability or high quality of Japanese TCCSS.243
In the second review, the Commission found that the domestic industry was vulnerable
due to several factors, including declining demand for TCCSS, the price sensitivity of the U.S.
market, the domestic industry’s cost-price squeeze, and the fact that many domestic industry
performance indicia declined during the period of review.244 Given these considerations, the
Commission concluded that the likely aggressive pricing of the likely increased volumes of
subject imports would likely lead the domestic industry either to cut prices for the domestic like
product or lose sales.245 Under either scenario, the Commission found, the industry’s revenues
and operating performance would decline significantly and, thus, revocation of the orders
would likely have a significant adverse impact on the domestic industry.246
In the third review, the Commission found that the domestic industry continued to
struggle and remained vulnerable.247 The Commission observed that the domestic industry’s
performance declined by most measures during the period of review.248 The Commission
concluded that the deteriorating demand conditions during the current review period were not
likely to improve significantly in the reasonably foreseeable future, leaving the domestic
industry particularly susceptible to injury from the reduced sales or lower prices likely to result
from renewed competition with low-priced subject imports.249
The Commission found that revocation of the order would likely result in a significant
increase in the volume of low-priced subject imports that would likely have adverse price
241 First Review, USITC Pub. 3860 at 29-30.
242 First Review, USITC Pub. 3860 at 29-30.
243 First Review, USITC Pub. 3860 at 29-30.
244 Second Review, USITC Pub. 4325 at 27-28.
245 Second Review, USITC Pub. 4325 at 29.
246 Second Review, USITC Pub. 4325 at 29-30.
247 Third Review, USITC Pub. 4795 at 28-29.
248 Third Review, USITC Pub. 4795 at 29.
249 Third Review, USITC Pub. 4795 at 29.

45
effects on the domestic industry. It further found that the likely significant volume of subject
imports, coupled with their adverse price effects, would likely have a significant impact on the
domestic industry upon revocation of the order within a reasonably foreseeable time.250
The Commission rejected Japanese Respondents’ argument that subject imports would
not likely have a significant adverse impact on the domestic industry due to the Section 232
measure.251 The Commission concluded that the limited evidence on the record did not
indicate that the Section 232 tariffs had resulted in significant changes in market conditions for
the domestic TCCSS industry as of the closing of the record.252
2. 	The Current Review
During the period of review, the domestic industry’s output and employment indicators
generally declined, while its financial performance generally improved from 2021 to 2022 but
subsequently declined from 2022 to 2023.
The domestic industry’s capacity declined by *** percent, from *** short tons in 2021
to *** short tons in 2022 and *** short tons in 2023.253 The industry’s production declined by
*** percent, from *** short tons in 2021 to *** short tons in 2022 and *** in 2023.254
Consequently, the domestic industry’s capacity utilization declined by *** percentage points,
decreasing from *** percent in 2021 to *** percent in 2022 and *** percent in 2023.255
The domestic industry’s employment indicia generally declined during the period of
investigation: the number of production-related workers (“PRWs”) in 2023 was *** percent
lower than in 2021,256 productivity declined by *** percent,257 total hours worked irregularly
decreased by *** percent during this period,258 and wages paid irregularly decreased by ***
250 Third Review, USITC Pub. 4795 at 29-30.
251 Third Review, USITC Pub. 4795 at 30.
252 Third Review, USITC Pub. 4795 at 30.
253 CR/PR at Tables III-5, C-1.
254 CR/PR at Tables III-5, C-1.
255 CR/PR at Tables III-5, C-1.
256 PRWs initially increased from *** in 2021 to *** in 2022 and then decreased to *** in 2023.
CR/PR at Tables III-9, C-1.
257 Productivity declined from *** short tons per 1,000 hours in 2021 to *** short tons per 1,000
hours in 2022 and *** short tons per 1,000 hours in 2023. CR/PR at Tables III-9, C-1.
258 Total hours worked by PRWs increased from *** hours in 2021 to *** hours in 2022, before
decreasing to *** hours in 2023. CR/PR at Tables III-9, C-1.

46
percent.259 Hourly wages increased by *** percent260 and unit labor costs increased by ***
percent.261
The domestic industry’s U.S. shipments declined by *** percent, from *** short tons in
2021 to *** short tons in 2022 and *** short tons in 2023.262 The industry’s overall market
share declined by *** percentage points, from *** percent in 2021 to *** percent in 2022 and
*** percent in 2023.263 The industry’s end-of-period inventories increased irregularly by ***
percent, increasing from *** short tons in 2021 to *** short tons in 2022 and then decreasing
to *** short tons in 2023.264
The domestic industry's financial performance improved by most measures from 2021
to 2022 but subsequently declined from 2022 to 2023. The domestic industry’s net sales value
decreased irregularly by *** percent from 2021 to 2023, increasing from $*** in 2021 to $***
in 2022 before decreasing to $*** in 2022.265 The domestic industry’s gross profits increased
*** percent over the period of review from $*** in 2021 to $*** in 2022 before declining to
$*** in 2023.266 The domestic industry’s operating income increased from $*** in 2021 to
$*** in 2022 before decreasing to $*** in 2023.267 Similarly, the domestic industry’s operating
income margin improved from *** percent in 2021 to *** percent in 2022 before decreasing to
*** percent in 2023.268 The domestic industry’s net income increased from negative $*** in
2021 to $*** in 2022 before declining to $*** in 2023.269 Similarly, the domestic industry’s net
income margin improved from *** percent in 2021 to *** percent in 2022 before declining to
*** percent in 2023.270
The domestic industry’s capital expenditures increased from $*** in 2021 to $*** in
2022 before declining to $*** in 2023, a level *** percent lower than in 2021.271 Research and
259 Total wages paid to PRWs initially increased from $*** in 2021 to $*** in 2022 and then
decreased to $*** in 2023. CR/PR at Tables III-9, C-1.
260 Hourly wages increased from $*** per hour in 2021 to $*** per hour in 2022 and $*** per
hour in 2023. CR/PR at Tables III-9, C-1.
261 Unit labor costs increased from $*** per short ton in 2021 to $*** per short ton in 2022 and
$*** per short ton in 2023. CR/PR at Tables III-9, C-1.
262 CR/PR at Tables III-6, C-1.
263 CR/PR at Tables IV-12, C-1.
264 CR/PR at Tables III-7, C-1.
265 CR/PR at Tables III-10, C-1.
266 CR/PR at Tables III-10, C-1.
267 CR/PR at Tables III-10, C-1.
268 CR/PR at Tables III-10, C-1.
269 CR/PR at Tables III-10, C-1.
270 CR/PR at Tables III-10, C-1.
271 CR/PR at Tables III-13, C-1.

47
development expenses increased throughout the period of review from $*** in 2021 to $*** in
2022 and $*** in 2023.272 The industry’s average operating return on assets increased from
negative *** percent in 2021 to *** percent in 2022 before declining to *** percent in 2022.273
In addition to the domestic industry’s declines output and employment indicators
discussed above, the domestic industry also closed or idled several TCCSS facilities. In
particular, Cleveland-Cliffs reported that it indefinitely idled its Weirton facility in April 2024.274
Cleveland-Cliffs states that, while it has indefinitely idled the Weirton facility, the facility is not
for sale “in the hopes of an eventual restart.”275 Cleveland-Cliffs claims that indefinitely idling
the facility means that it will not be making any products there, but will maintain the
equipment so that if market conditions justify restarting the facility, it can do so.276 277
As discussed above, U.S. Steel also idled several of its facilities but likewise reported that
it retained the ability to bring additional capacity online imminently, if market conditions
warrant.278 U.S. Steel similarly indicated that the order on TCCSS from Japan has been *** and
that revocation of the order ***.279
272 CR/PR at Tables III-14, C-1.
273 CR/PR at Tables III-18, C-1.
274 Cleveland-Cliffs Prehearing Br. at 48-49.
275 Cleveland-Cliffs Posthearing Br., Exhibit 1 at paras. 10-12.
276 Hearing Tr. at 44-45 (Smith). According to Cleveland-Cliffs, ***. Cleveland-Cliffs Posthearing
Br., Exhibit 1 at paras. 10-12; see also CR/PR at Table D-1.
277 We do not agree with Japanese Respondents that we should consider only the domestic
producers that are currently producing TCCSS in our analysis. Japanese Respondents Prehearing Br. at
78-79. As discussed above, Cleveland-Cliffs was the second largest domestic producer during the period
of review and is continuing to maintain the Weirton facility in the hope that market conditions will
improve to permit its reopening. Thus, even though it is not currently producing TCCSS, we find it
appropriate to include its performance and experience as part of the domestic industry in our forward-
looking analysis.
278 U.S. Steel Prehearing Br. at 29; U.S. Steel Posthearing Br. at 5-6. The parties dispute the
cause of U.S. Steel’s closure of its USS-UPI facility and the effect that closure has had on the U.S. market.
Japanese Respondents contend that the closure was for strategic reasons and left a hole in the market
with respect to domestic supply, while U.S. Steel contends that it has not refused to supply purchasers
with TCCSS. We note that ***. U.S. Steel Posthearing Br., Exhibit 1, Attachment B. This illustrates that
domestic producers faced pressure during the period of review to keep prices low to maintain the
volume necessary to keep their facilities operating. Such pressure is likely to intensify if the order is
revoked and a significant volume of low-priced subject imports compete aggressively for market share.
279 CR/PR at Table D-1.

48
The smallest U.S. producer, Ohio Coatings, *** throughout the period of review but
reported ***.280 Ohio Coatings also reported that the order on TCCSS ***.281
While the domestic industry’s profitability improved somewhat overall over the period
of review, its ratio of operating income to net sales declined from *** percent in 2022 to ***
percent in 2023. In view of the domestic industry's relatively low profitability and declining
performance by most other measures, and in particular the industry's declining output and
employment and the idling of production facilities we find that the domestic industry is
currently in a vulnerable condition.282 Several other factors also contributed to the domestic
industry's vulnerability. Demand conditions deteriorated throughout the current review period
and are not expected to improve significantly in the reasonably foreseeable future. In this
declining market, the domestic industry lost market share to increasing volumes of nonsubject
imports. These conditions have left the domestic industry particularly susceptible to injury
from reduced sales or lower prices as a result of the intensified competition from subject
imports that would likely result from revocation of the order.
As discussed above, we have found that if the order were revoked, the volume of
subject imports would likely be significant within a reasonably foreseeable time. We have also
found that the significant volume of subject imports would likely undersell the domestic like
280 CR/PR at Table III-5. Japanese Respondents argue that Ohio Coatings’ reduction in supply
was due to Cleveland-Cliffs’ and U.S. Steel’s decisions not to supply Ohio Coatings with black plate
during the period of review. Japanese Respondents Prehearing Br. at 71-72; Japanese Posthearing Br. at
13. Regardless of this issue, Ohio Coatings indicated that ***. CR/PR at Tables III-4, D-1.
281 CR/PR at Table D-1.
282 We are unpersuaded by the Japanese Respondents' argument that the domestic industry is
not vulnerable to injury from subject imports inter alia because Ohio Coatings’ difficulties obtaining
black plate during the period of review were attributable to the domestic industry's refusal to supply it
with black plate. Japanese Respondents Prehearing Br. at 71-72; Japanese Posthearing Br. at 13. The
Commission may find a domestic industry vulnerable irrespective of whether subject imports
contributed to the vulnerability. See, e.g., Consolidated Fibers, Inc. v. United States, 571 F. Supp. 2d
1355, 1365 (Ct. Int’l Trade 2008) (noting that the Commission’s task is not to determine whether the
subject imports significantly contributed to the decline of the domestic industry during the {period of
review}” and that “the antidumping duty orders under review imposed duties on subject imports
{making} it less likely that subject imports would be source of any domestic industry vulnerability”).
Furthermore, notwithstanding any problems that Ohio Coatings may have experienced in sourcing black
plate, its share of the domestic industry's production increased from *** percent in 2021 to *** percent
in 2023. CR/PR at Table III-5. Ohio Coatings reported that revocation of the order would ***. CR/PR at
Table D-1. In any event, Ohio Coatings accounted for only *** percent of the domestic industry’s
production in 2023, so even if it were faced with injury solely due to the lack of black plate supply, that
would not undermine a finding of vulnerability and likely material injury for the domestic industry as a
whole.

49
product to a significant degree, forcing the domestic industry to either cut prices, forego
needed price increases, or else lose market share to subject imports. The likely significant
volume of cumulated subject imports, coupled with their likely significant price effects, would
have a direct adverse impact on the domestic industry’s production, shipments, profitability,
and employment, as well as its ability to raise capital and make and maintain necessary capital
investments. Consequently, we conclude that if the order were revoked, subject imports would
be likely to have an adverse impact on the domestic industry within a reasonably foreseeable
time.283
We have also considered the role of nonsubject imports in the U.S. market. As
discussed in Section III.B.2. above, nonsubject imports increased in volume and market share
during the period of review to account for the largest source of supply of TCCSS to the U.S.
market by the end of the period, with a *** percent share of apparent U.S. consumption in
2023.284 Notwithstanding this, the record does not indicate that the presence of nonsubject
imports would prevent subject imports from Japan from significantly increasing their presence
in the U.S. market in the event of revocation of the order, given the available capacity and the
export orientation of the subject industry, as well as the relative attractiveness of the U.S.
market. Given the domestic industry's *** percent share of apparent U.S. consumption in
2023, as well as the substitutability between subject imports and the domestic like product,
their overlap in terms of product offerings and purchasers, and the importance of price to
purchasing decisions, it is likely that the significant increase in low-priced subject imports would
come at least in part at the expense of the domestic industry, and/or depress or suppress prices
for the domestic like product. For these reasons, we find that any effects of nonsubject imports
would be distinct from the likely effects attributable to subject imports and that nonsubject
283 We are unpersuaded by Japanese Respondents’ argument that because the domestic
industry has allegedly shown no measurable improvement since imposition of the order, there can be
no causal link between the industry’s performance and continuation of the order. Japanese
Respondents Prehearing Br. at 76-77; Japanese Respondents Posthearing Br. at 14. Japanese
Respondents misapprehend the Commission’s analysis in a five-year review. While we consider whether
any improvement in the state of the industry is related to the order and the domestic industry’s
performance during the period of review informs our forward-looking analysis, particularly in terms of
assessing an industry’s vulnerability and the likely effect that revocation of an order will have on
domestic producers, an industry’s poor performance or vulnerable condition with the order in place
does not mandate a finding that subject imports could have no effect after revocation. To the contrary,
a vulnerable domestic industry would be less capable of withstanding intensified competition from low-
priced subject imports after revocation than an industry that is not vulnerable.
284 CR/PR at Tables I-12, C-1.

50
imports would not prevent subject imports from having a significant impact on the domestic
industry.285
We recognize that apparent U.S. consumption was *** percent lower in 2023 than in
2021.286 As discussed in section III.B.1 above, demand for TCCSS has declined due to the
increased use of substitute materials, and most market participants reported expecting demand
for TCCSS to remain stable or decline over the next two years.287 To the extent that demand
continues to decline, the increase in low-priced subject imports that is likely after revocation
would exacerbate the effects of declining demand on the domestic industry.
We are not persuaded by Japanese Respondents' argument that our recent negative
determinations in investigations concerning nonsubject imports from Canada, China, and
Germany somehow mandate a negative determination in this review. Specifically, Japanese
Respondents highlight the Commission's finding from those investigations that the domestic
industry's loss of market share to those imports resulted from widespread issues concerning
the availability and quality of domestically produced tin mill products, forcing purchasers to
turn to imports,288 and point to questionnaire responses and testimony on the record of this
review indicating that purchasers were unable to obtain TCCSS from domestic producers.289
Japanese Respondents contend that because these issues are likely to persist after revocation,
given the lengthy process that domestic producers would need to undergo to become qualified
to supply additional TCCSS, subject imports are likely to serve demand unmet by the domestic
industry after revocation and therefore have no impact on the domestic industry.290
The facts on the record of this review are distinguishable from those at issue in the
recent investigations of tin mill products from Canada, China, and Germany in several
285 Even if nonsubject imports or other factors are likely to contribute to a domestic industry's
injury after revocation, the Commission may determine that revocation of the order is likely to result in
the continuation or recurrence of material injury if subject imports are more than a minimal or
tangential cause of the injury. See, e.g., Nippon Steel Corp. v. United States, 345 F.3d 1379, 1381 (Fed.
Cir. 2003); see also SAA at 885 (factors other than subject imports may be causing injury to the industry
but “also may demonstrate that an industry is facing difficulties from a variety of sources and is
vulnerable to dumped or subsidized imports. . . If the Commission finds that an industry is vulnerable to
injury from subject imports, it may determine that injury is likely to continue or recur, even if other
causes, as well as future imports, are likely to contribute to future injury”).
286 See CR/PR at Table C-1.
287 CR/PR at II-17 & Tables II-7.
288 Japanese Respondents Prehearing Br. at 72-77.
289 Japanese Respondents Prehearing Br. at 74-75, Appendices C (Sonoco Declaration), E
(Trivium Declaration) (also citing *** Purchaser Questionnaire).
290 Japanese Respondents Prehearing Br. at 76-77.

51
important respects. First, as discussed above, the Commission found that tin mill products
imported from Canada, China, and Germany had predominantly oversold the domestic like
product and had gained market share from the domestic industry for non-price reasons,
including the domestic industry's inability to supply certain products available only from those
countries.291 By contrast, the record of this review indicates that there is substantial overlap in
the types of TCCSS offered by domestic industry and the subject Japanese producers, making it
likely that subject imports would compete with the domestic like product primarily on the basis
of price after revocation. Furthermore, unlike the overselling on the record of the recent tin
mill products investigations, we assess the likely price effects of subject imports after
revocation in this review with reference to the Commission's finding in the original investigation
that subject imports undersold the domestic like product to a significant degree to gain market
share.292 We have found that subject imports are likely to resume their underselling strategy
from the original investigations if the order were revoked, as a means of gaining market share.
Although we recognize that the record in this review indicates that the domestic
industry experienced some supply constraints and certain purchasers reported being unable to
obtain TCCSS from domestic sources, we find that domestic supply constraints would not likely
prevent subject imports from having a significant adverse impact on the domestic industry
within a reasonably foreseeable time.293 U.S. Steel and Ohio Coatings possess sufficient
capacity, including unused capacity, to at least maintain or even increase the domestic
industry's share of apparent U.S. consumption from 2023 levels.294 As we have found, the
significant increase in subject import volume that is likely after revocation would likely come at
least partly at the domestic industry's expense, particularly given the substantial overlap
between the industry's TCCSS product offerings and those of subject producers and ***. Even
to the extent that domestic supply constraints continue, increased volumes of low-priced
subject imports are likely to depress or suppress prices for the domestic like product on the
sales that domestic producers are capable of supplying.
In sum, we conclude that if the order were revoked, subject imports from Japan would
likely have a significant adverse impact on the domestic industry within a reasonably
foreseeable time.
291 See Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-685
and 731-TA-1599-1601, 1603 (Final), USITC Pub. 5492 (Feb. 2024) at 38-47.
292 19 U.S.C. § 1675a(a)(1).
293 CR/PR at II-9 – II-11.
294 CR/PR at Table III-5. U.S. Steel and Ohio Coatings had a combined capacity of *** short tons
in 2023. Id.

52
Conclusion
For the above-stated reasons, we determine that revocation of the antidumping order
on TCCSS would be likely to lead to continuation or recurrence of material injury to an industry
in the United States within a reasonably foreseeable time.

I-1
Part I: Introduction
Background
On June 1, 2023, the U.S. International Trade Commission (“Commission” or “USITC”)
gave notice, pursuant to section 751(c) of the Tariff Act of 1930, as amended (“the Act”),1 that
it had instituted a review to determine whether revocation of the antidumping duty order on
tin- and chromium-coated steel sheet (“TCCSS”) from Japan would be likely to lead to
continuation or recurrence of material injury to a domestic industry.2 3 On September 5, 2023,
the Commission determined that it would conduct a full review pursuant to section 751(c)(5) of
the Act.4 Table I-1 presents information relating to the background and schedule of this
proceeding.5
1 19 U.S.C. 1675(c).
2 88 FR 35920, June 1, 2023. All interested parties were requested to respond to this notice by
submitting the information requested by the Commission.
3 In accordance with section 751(c) of the Act, the U.S. Department of Commerce (“Commerce”)
published a notice of initiation of a five-year sunset review of the subject antidumping duty order. 88 FR
35832, June 1, 2023.
4 88 FR 64464, September 19, 2023. The Commission found that both the domestic and respondent
interested party group responses to its notice of institution were adequate and determined that it
should proceed to a full review of the antidumping duty order.
5 The Commission’s notice of institution, notice to conduct a full review, and scheduling notice are
referenced in appendix A and may also be found at the Commission’s web site (www.usitc.gov).
Commissioners’ votes on whether to conduct an expedited or a full review may also be found at the web
site. Appendix B presents a list of witnesses appearing at the Commission’s hearing.

I-2
Table I-1
TCCSS: Information relating to the background and schedule of this proceeding
Effective date 	Action
August 28, 2000
Commerce’s antidumping duty order on TCCSS from Japan
(65 FR 52067, August 28, 2000)
July 21, 2006
Commerce’s continuation of the antidumping order following affirmative
determinations by Commerce and the Commission in their first review
(71 FR 41422, July 21, 2006)
June 12, 2012
Commerce’s continuation of the antidumping order following affirmative
determinations by Commerce and the Commission in their second review
(77 FR 34938, June 12, 2012)
July 11, 2018
Commerce’s continuation of the antidumping order following affirmative
determinations by Commerce and the Commission in their third review
(83 FR 32074, July 11, 2018)
June 1, 2023
Commerce’s initiation of the fourth five-year review on TCCSS from Japan
(88 FR 35832, June 1, 2023)
June 1, 2023
Commission’s institution of the fourth five-year review on TCCSS from Japan
(88 FR 35920, June 1, 2023)
September 5, 2023
Commission’s determination to conduct a full five-year review
(88 FR 64464, September 19, 2023)
October 5, 2023
Commerce’s final results of its expedited five-year review
(88 FR 69133, October 5, 2023)
October 25, 2023 	Commission’s scheduling of a full review (88 FR 74209, October 30, 2023)
April 9, 2024 	Commission’s hearing
May 10, 2024 	Commission’s vote
May 28, 2024 	Commission’s determination and views
The original investigation
The original investigation resulted from a petition filed on October 28, 1999, with
Commerce and the Commission, by Weirton Steel Corp., Weirton, West Virginia, the
Independent Steelworkers Union, and the United Steelworkers of America, AFL-CIO, alleging
that an industry in the United States was materially injured and threatened with material injury
by reason of less-than-fair-value (“LTFV”) imports of TCCSS from Japan.6 Following notification
of a final determination by Commerce that imports of TCCSS from Japan were being sold at
LTFV,7 the Commission determined on August 9, 2000 that a domestic industry was materially
injured by reason of LTFV imports of TCCSS from Japan.8 Commerce published the antidumping
duty order on TCCSS from Japan on August 28, 2000.9
6 Tin- and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Final), USITC Publication
3337, August 2000 (“Original publication”), pp. 1 and I-1.
7 65 FR 39364, June 26, 2000.
8 65 FR 50005, August 16, 2000. Chairman Koplan and Commissioner Askey dissented.
9 65 FR 52067, August 28, 2000.

I-3
Subsequent remand proceedings
The Japanese respondents appealed the Commission’s original affirmative material
injury determination to the U.S. Court of International Trade (“CIT”). On December 31, 2001,
the CIT remanded the case to the Commission.10 In the first remand, the Commission again
made an affirmative injury determination.11 On August 9, 2002, the CIT remanded the case to
the Commission for a second time and expressly ordered the Commission to enter a negative
injury determination.12 The Commission appealed the CIT’s order. On October 3, 2002, the
Federal Circuit vacated the CIT’s decision and ordered a remand to the Commission.13
In its second remand determination, the Commission again made an affirmative
material injury determination.14 On October 14, 2004, the CIT affirmed some aspects of the
Commission’s decision, but rejected others, and issued a remand with instructions to issue a
negative material injury determination.15
On December 13, 2004, the Commission issued its third remand determination, making
negative injury and threat of injury determinations, and noted that it would not have made
such determinations in the absence of the CIT’s order.16 On March 25, 2005, the CIT affirmed
the negative determinations.17
The Commission appealed the CIT’s judgment to the Federal Circuit.18 On August 10,
2006, the Federal Circuit reversed the CIT’s decision, instructed the CIT to vacate the
Commission’s negative injury and threat of injury determinations, and directed the CIT to
reinstate the Commission’s affirmative material injury determination.19 On November 16, 2006,
10 Nippon Steel Corp. v. United States, 182 F. Supp. 2d. 1330 (Ct. Int’l Trade 2001).
11 Tin- and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Final) (Remand), USITC
Publication 3493, March 2002 (“First Remand Determination”), p. 1.
12 Nippon Steel Corp. v. United States, 223 F. Supp. 2d. 1349, 1372 (Ct. Int’l Trade 2002).
13 Nippon Steel Corp. v. United States, 345 F.3d 1379 (Fed. Cir. 2003).
14 Tin- and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Final) (Second Remand),
USITC Publication 3674, February 2004 (“Second Remand Determination”), p. 1.
15 Nippon Steel Corp. v. United States, 350 F. Supp. 2d 1186 (Ct. Int’l Trade 2004).
16 Tin- and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Final) (Third Remand),
USITC Publication 3751, December 2004 (“Third Remand Determination”), p. 1.
17 Nippon Steel Corp. v. United States, Slip Op. 2005-038 (Ct. Int’l Trade 2005).
18 On July 1, 2005, Commerce initiated and the Commission instituted the first five-year review on
TCCSS from Japan (70 FR 38101, 38210). As the Commission’s appeal was pending before the Federal
Circuit, the order on TCCSS from Japan remained in place and the five-year review continued. Tin- and
Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Review), USITC Publication 3860, June
2006 (“First review publication”), p. 4. For additional information, see the “First five-year review”
section below.
19 Nippon Steel Corp. v. United States, 458 F.3d 1345 (Fed. Cir. 2006).

I-4
in accordance with the Federal Circuit’s mandate, the CIT reinstated and sustained the
Commission’s second remand determination and its affirmative material injury
determination.20
Subsequent five-year reviews
First five-year review
On October 4, 2005, the Commission determined that it would conduct a full review of
the antidumping duty order on TCCSS from Japan.21 On November 7, 2005, Commerce
determined that revocation of the antidumping duty order on TCCSS from Japan would be likely
to lead to continuation or recurrence of dumping.22 On June 26, 2006, the Commission
determined that material injury would be likely to continue or recur within a reasonably
foreseeable time.23 Following affirmative determinations in the five-year review by Commerce
and the Commission, effective July 21, 2006, Commerce issued a continuation of the
antidumping duty order on imports of TCCSS from Japan.24
Second five-year review
On September 6, 2011, the Commission determined that it would conduct a full review
of the antidumping duty order on TCCSS from Japan.25 On September 28, 2011, Commerce
determined that revocation of the antidumping duty order on TCCSS from Japan would be likely
to lead to continuation or recurrence of dumping.26 On May 25, 2012, the Commission
determined that material injury would be likely to continue or recur within a reasonably
foreseeable time.27 Following affirmative determinations in the five-year review by Commerce
and the Commission, effective June 12, 2012, Commerce issued a continuation of the
antidumping duty order on imports of TCCSS from Japan.28
20 Nippon Steel Corp. v. United States, 433 F. Supp. 2d 1336 (Ct. Int’l Trade 2006).
21 70 FR 60110, October 14, 2005.
22 70 FR 67448, November 7, 2005.
23 71 FR 37944, July 3, 2006; First review publication, p. 1.
24 71 FR 41422, July 21, 2006.
25 76 FR 58536, September 21, 2011.
26 76 FR 60001, September 28, 2011.
27 77 FR 32998, June 4, 2012; and Tin- and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-
TA-860 (Second Review), USITC Publication 4325, May 2012 (“Second review publication”), p. 1.
28 77 FR 34938, June 12, 2012.

I-5
Third five-year review
On August 4, 2017, the Commission determined that it would conduct a full review of
the antidumping duty order on TCCSS from Japan.29 On September 5, 2017, Commerce
determined that revocation of the antidumping duty order on TCCSS from Japan would be likely
to lead to continuation or recurrence of dumping.30 On June 19, 2018, the Commission
determined that material injury would be likely to continue or recur within a reasonably
foreseeable time.31 Following affirmative determinations in the five-year review by Commerce
and the Commission, effective July 11, 2018, Commerce issued a continuation of the
antidumping duty order on imports of TCCSS from Japan.32
Previous and related investigations
The Commission has conducted a number of previous import injury investigations on
TCCSS or similar merchandise, as presented in table I-2.
Table I-2
TCCSS: Previous and related Commission proceedings and current status
Date 	Number 	Country 	Product
ITC original
determination 	Current status
1984 	TA-201-51 	Global
Carbon and
alloy steel 	Affirmative
No safeguard measures
implemented (see table notes).
2001 	TA-201-73 	Global
Carbon and
alloy steel 	Affirmative
President implemented
safeguard measures; measures
terminated, 12/4/2003 (see
table notes).
2022 	--- 	Japan 	TCCSS 	---
ITC declined request to institute
a changed circumstances
review, 9/19/2023.
Table continued.
29 82 FR 40168, August 24, 2017.
30 82 FR 41933, September 5, 2017.
31 83 FR 29568, June 25, 2018; and Tin- and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-
TA-860 (Third Review), USITC Publication 4795, June 2018 (“Third review publication”), p. 1.
32 83 FR 32074, July 11, 2018.

I-6
Table I-2 Continued.
TCCSS: Previous and related Commission proceedings and current status
Date 	Number 	Country 	Product
ITC original
determination 	Current status
2023 	701-TA-685 	China
Tin mill
products 	Negative 	No order issued, 2/26/2024.
2023 	731-TA-1599 	Canada
Tin mill
products 	Negative 	No order issued, 2/26/2024.
2023 	731-TA-1600 	China
Tin mill
products 	Negative 	No order issued, 2/26/2024.
2023 	731-TA-1601 	Germany
Tin mill
products 	Negative 	No order issued, 2/26/2024.
2023 	731-TA-1602 	Netherlands
Tin mill
products 	---
Commerce negative final
determination; ITC terminated
investigation, 1/10/2024.
2023 	731-TA-1603 	South Korea
Tin mill
products
Terminated
(Negligible)
ITC found subject imports
negligible (see table notes);
ITC terminated investigation,
2/26/2024.
2023 	731-TA-1604 	Taiwan
Tin mill
products 	---
Commerce negative final
determination; ITC terminated
investigation, 1/10/2024.
2023 	731-TA-1605 	Turkey
Tin mill
products 	---
Commerce negative final
determination; ITC terminated
investigation, 1/10/2024.
2023 	731-TA-1606
United
Kingdom
Tin mill
products 	---
Commerce negative final
determination; ITC terminated
investigation, 1/10/2024.
Source: U.S. International Trade Commission publications and Federal Register notices.
Note: “Date” refers to the year in which the proceeding was instituted by the Commission.
Note: In Investigation No. TA-201-51, the President opted to continue to pursue negotiated settlements
with steel exporting states.
Note: In Investigation No. TA-201-73, the Commission was equally divided in its determination regarding
carbon and alloy steel tin mill products. In instances where the Commission is equally divided, the
determination of either group of the Commissioners may be considered by the President to be the
determination of the Commission. The President, effective March 20, 2002, implemented safeguard
measures on certain carbon and alloy steel tin mill products. On December 4, 2003, the President
terminated these safeguard measures due to changed circumstances. 68 FR 68483, December 8, 2003.
Note: In Investigation No. 731-TA-1603, Commerce issued a final weighted-average dumping margin of
0.00 percent for KG Dongbu, the largest TCCSS exporter in South Korea, and 2.69 percent for all others.
Consequently, only imports from all others were relevant to the Commission’s negligibility analysis.

I-7
Summary data
Table I-3 presents a summary of data for the terminal year of the original investigation
(1999), subsequent full five-year reviews (2005, 2011, and 2016), and the current proceeding
(2023).33 Between 1999 and 2023, the quantity of apparent U.S. consumption was lower in
each successive terminal year, and overall decreased by more than half. U.S. imports of TCCSS
from Japan accounted for a very limited share of the U.S. market after 1999. U.S. imports from
nonsubject sources accounted for an expanding share of the U.S. market, while U.S. shipments
by U.S. producers accounted for a contracting share of the market. In 2023, U.S. imports from
nonsubject sources accounted for the largest share of the U.S. market for TCCSS.
U.S. producers’ U.S. shipments of TCCSS declined by *** percent from 3.2 million short
tons in 1999 to *** short tons in 2023. In 1999, U.S. importers’ U.S. shipments of TCCSS from
Japan were reported to be 329,645 shorts tons. Following the imposition of the antidumping
duty order on TCCSS from Japan, subject imports were reported to be zero in each terminal
year covered by the first, second, and third five-year reviews. In the current proceeding, U.S.
importers’ U.S shipments of TCCSS from Japan were reported to be *** short tons in 2023.
Altogether, importers’ U.S. imports/U.S. shipments of TCCSS from Japan were *** percent
lower in 2023 than in 1999.Importers’ U.S. imports/U.S. shipments of TCCSS from nonsubject
sources, in contrast, increased by *** percent from *** short tons in 1999 to *** shorts in
2023.
In terms of U.S. producers’ operations on TCCSS, capacity and production decreased by
*** percent and *** percent, respectively, between 1999 and 2023. U.S. producers’ capacity
utilization was 74.5 percent in 1999 compared to *** percent in 2023, a decrease of ***
percentage points. In 2023, the U.S. TCCSS industry employed *** production workers earning
$*** per hour in wages. Although wage rates were more than double the level in 1999, the
number of production workers, and hours worked by such workers, was substantially lower in
2023 than in 1999. In terms of profitability, the U.S. TCCSS industry generated an operating
income margin of *** percent in 2023, following operating losses in 1999, 2005, 2011, and
2016.
33 For a detailed discussion of data coverage in previous proceedings and in the current five-year
review, please see “U.S. producers” and “U.S. importers” sections of Part I of this report.

I-8
Table I-3
TCCSS: Comparative data from the original investigation, subsequent reviews and current
proceeding, 1999, 2005, 2011, 2016, and 2023
Quantity in short tons; value in 1,000 dollars; unit values in dollars per short ton; shares/ratios in percent
Item 	Measure 	1999 	2005 	2011 	2016 	2023
U.S. apparent
consumption 	Quantity 	*** 	3,150,528 	2,683,441 	2,454,209 	1,889,860
U.S. producers
market share
Share of
quantity 	*** 	82.1 	80.7 	56.9 	***
Japan market
share
Share of
quantity 	*** 	--- 	--- 	--- 	***
Nonsubject market
share
Share of
quantity 	*** 	17.9 	19.3 	43.1 	***
All import sources
market share
Share of
quantity 	*** 	17.9 	19.3 	43.1 	***
U.S. apparent
consumption 	Value 	*** 	2,382,943 	2,778,297 	2,199,419 	3,478,681
U.S. producers
market share
Share of
value 	*** 	81.1 	78.9 	58.4 	***
Japan market
share
Share of
value 	*** 	--- 	--- 	--- 	***
Nonsubject market
share
Share of
value 	*** 	18.9 	21.1 	41.6 	***
All import sources
market share
Share of
value 	*** 	18.9 	21.1 	41.6 	***
Japan imports 	Quantity 	329,645 	--- 	--- 	--- 	***
Japan imports 	Value 	196,185 	--- 	--- 	--- 	***
Japan imports 	Unit value 	$595 	--- 	--- 	--- 	***
Nonsubject imports 	Quantity 	*** 	563,173 	518,383 	1,058,090 	***
Nonsubject imports 	Value 	*** 	450,765 	586,977 	914,025 	***
Nonsubject imports 	Unit value 	*** 	$800 	$1,132 	$864 	***
All import sources 	Quantity 	*** 	563,173 	518,383 	1,058,090 	***
All import sources 	Value 	*** 	450,765 	586,977 	914,025 	***
All import sources 	Unit value 	*** 	$800 	$1,132 	$864 	***
Table continued.

I-9
Table I-3 Continued
TCCSS: Comparative data from the original investigation, subsequent reviews, and current
proceeding 1999, 2005, 2011, 2016, and 2023
Quantity in short tons; value in 1,000 dollars; unit values in dollars per short ton; shares/ratios in percent
Item 	Measure 	1999 	2005 	2011 	2016 	2023
Capacity 	Quantity 	4,607,145 	3,670,240 	3,543,000 	3,068,000 	***
Production 	Quantity 	3,433,592 	2,738,382 	2,168,240 	1,374,409 	***
Capacity utilization 	Ratio 	74.5 	74.6 	61.2 	44.8 	***
Producer U.S.
shipments 	Quantity 	3,227,134 	2,587,355 	2,165,058 	1,396,119 	***
Producer U.S.
shipments 	Value 	1,898,063 	1,932,178 	2,191,320 	1,285,394 	***
Producer U.S.
shipments 	Unit value 	$588 	$747 	$1,012 	$921 	***
Producer
inventories 	Quantity 	346,375 	307,218 	297,562 	167,428 	***
Producer
inventory ratio to
total shipments 	Ratio 	10.0 	11.4 	*** 	*** 	***
Production
workers (number) 	Noted in label 	6,004 	3,769 	2,984 	2,343 	***
Hours worked (in
1,000 hours) 	Noted in label 	13,297 	7,665 	6,183 	4,537 	***
Wages paid
(1,000 dollars) 	Value 	344,320 	232,355 	191,594 	202,886 	***
Hourly wages
(dollars per hour) 	Value 	$25.89 	$30.31 	$30.99 	$44.72 	***
Productivity (short
tons per 1,000
hours) 	Noted in label 	258.2 	357.3 	350.7 	302.9 	***
Table continued.

I-10
Table I-3 Continued
TCCSS: Comparative data from the original investigation, subsequent reviews, and current
proceeding, 1999, 2005, 2011, 2016, and 2023
Quantity in short tons; value in 1,000 dollars; unit values in dollars per short ton; shares/ratios in percent
Item 	Measure 	1999 	2005 	2011 	2016 	2023
Net sales 	Quantity 	3,472,054 	2,695,138 	2,166,858 	1,396,982 	***
Net sales 	Value 	2,034,967 	2,016,252 	2,193,349 	1,286,257 	***
Net sales 	Unit value 	$586 	$748 	$1,012 	$921 	***
Cost of goods sold 	Value 	2,061,471 	1,920,750 	2,283,740 	1,279,130 	***
Gross profit or
(loss) 	Value 	(26,504) 	95,502 	(90,391) 	7,127 	***
SG&A expense 	Value 	105,980 	110,244 	108,403 	34,180 	***
Operating income
or (loss) 	Value 	(132,484) 	(14,742) 	(198,794) 	(27,053) 	***
Unit COGS 	Unit value 	$594 	$713 	$1,054 	$916 	***
Unit operating
income 	Unit value 	($38) 	($5) 	($92) 	($19) 	***
COGS/ Sales 	Ratio 	101.3 	95.3 	104.1 	99.4 	***
Operating income
or (loss)/ Sales 	Ratio 	(6.5) 	(0.7) 	(9.1) 	(2.1) 	***
Source: Office of Investigations memoranda INV-X-160 (July 18, 2000), INV-X-164 (July 24, 2000), INV-
X-172 (July 26, 2000), INV-DD-073 (May 30, 2006), INV-DD-078 (June 6, 2006), INV-DD-082 (June 12,
2006), INV-KK-084 (May 3, 2012), INV-QQ-058 (May 11, 2018); original publication and subsequent five-
year review publications; and compiled from data submitted in response to Commission questionnaires.
Note: For 1999, 2005, and 2023, apparent U.S. consumption was derived from U.S. importers’ U.S.
shipments of imports compiled from responses to Commission questionnaires. For 2011 and 2016,
apparent U.S. consumption was derived from official U.S. import statistics adjusted by information from
responses to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

I-11
Table I-4 presents U.S. producers’ U.S. shipments and importers’ U.S. imports / U.S.
shipments of imports from 2017 through 2023, the years covered by the current five-year
review. U.S. producers’ U.S. shipments decreased irregularly between 2017 and 2023. U.S.
producers’ U.S. shipments increased by *** percent from *** short tons in 2017 to a peak of
*** short tons in 2020, then declined in each successive year. In 2023, U.S. producers’ U.S.
shipments were *** short tons, *** percent lower than in 2017.
Importers’ U.S. imports/U.S shipments of TCCSS from Japan were *** during 2017-21. In
2022 and 2023, U.S. importers’ U.S. shipments of TCCSS from Japan were ***. Importers’ U.S.
imports/U.S. shipments of TCCSS from nonsubject sources increased irregularly. Importers’ U.S.
imports/U.S. shipments of TCCSS from nonsubject sources declined from 2017 to 2018, then
increased through 2022, before declining in 2023 from their peak level in 2022. Altogether,
importers’ U.S. imports/U.S. shipments of TCCSS from nonsubject sources increased by ***
percent during 2017-23.
Table I-4
TCCSS: U.S. producers' U.S. shipments and U.S. importers' imports and U.S. shipments data,
2017-23
Quantity in short tons
Source 	2017 	2018 	2019 	2020 	2021 	2022 	2023
U.S.
producers 	*** 	*** 	*** 	*** 	*** 	*** 	***
Japan 	*** 	*** 	*** 	*** 	*** 	*** 	***
Nonsubject
sources 	*** 	*** 	*** 	*** 	*** 	*** 	***
All import
sources 	*** 	*** 	*** 	*** 	*** 	*** 	***
All sources 	2,420,290 	2,283,038 	2,010,616 	2,452,425 	2,494,413 	2,322,143 	1,889,860
Source: Compiled from data submitted in response to Commission questionnaires.
Note: For 2017-20, import data reflects U.S. importers’ actual imports into the United States. For 2021-23,
import data reflects U.S. importers’ U.S. shipments of imports.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

I-12
Figure I-1 presents apparent U.S. consumption for the terminal year of the original
investigation and subsequent five-year reviews (see table I-3), as well as apparent U.S.
consumption for the years under review in this proceeding (see table I-4).
Figure I-1
TCCSS: Historical apparent U.S. consumption based on quantity, 1999, 2005, 2011, 2016, and
2017-23
* 	* 	* 	* 	* 	* 	*
Source: Office of Investigations memoranda INV-X-160 (July 18, 2000), INV-X-164 (July 24, 2000), INV-
X-172 (July 26, 2000), INV-DD-073 (May 30, 2006), INV-DD-078 (June 6, 2006), INV-DD-082 (June 12,
2006), INV-KK-084 (May 3, 2012), INV-QQ-058 (May 11, 2018); original publication and subsequent five-
year review publications; and compiled from data submitted in response to Commission questionnaires.
Statutory criteria
Section 751(c) of the Act requires Commerce and the Commission to conduct a review
no later than five years after the issuance of an antidumping or countervailing duty order or the
suspension of an investigation to determine whether revocation of the order or termination of
the suspended investigation “would be likely to lead to continuation or recurrence of dumping
or a countervailable subsidy (as the case may be) and of material injury.”
Section 752(a) of the Act provides that in making its determination of likelihood of
continuation or recurrence of material injury--

I-13
(1) IN GENERAL.-- . . . the Commission shall determine whether revocation
of an order, or termination of a suspended investigation, would be likely
to lead to continuation or recurrence of material injury within a
reasonably foreseeable time. The Commission shall consider the likely
volume, price effect, and impact of imports of the subject merchandise on
the industry if the order is revoked or the suspended investigation is
terminated. The Commission shall take into account--
(A) its prior injury determinations, including the volume, price effect,
and impact of imports of the subject merchandise on the industry
before the order was issued or the suspension agreement was
accepted,
(B) whether any improvement in the state of the industry is related to
the order or the suspension agreement,
(C) whether the industry is vulnerable to material injury if the order is
revoked or the suspension agreement is terminated, and
(D) in an antidumping proceeding . . ., (Commerce’s findings)
regarding duty absorption . . ..
(2) VOLUME.--In evaluating the likely volume of imports of the subject
merchandise if the order is revoked or the suspended investigation is
terminated, the Commission shall consider whether the likely volume of
imports of the subject merchandise would be significant if the order is
revoked or the suspended investigation is terminated, either in absolute
terms or relative to production or consumption in the United States. In so
doing, the Commission shall consider all relevant economic factors,
including--
(A) any likely increase in production capacity or existing unused
production capacity in the exporting country,
(B) existing inventories of the subject merchandise, or likely increases
in inventories,
(C) the existence of barriers to the importation of such merchandise
into countries other than the United States, and
(D) the potential for product-shifting if production facilities in the
foreign country, which can be used to produce the subject
merchandise, are currently being used to produce other products.

I-14
(3) PRICE.--In evaluating the likely price effects of imports of the subject
merchandise if the order is revoked or the suspended investigation is
terminated, the Commission shall consider whether--
(A) there is likely to be significant price underselling by imports of the
subject merchandise as compared to domestic like products, and
(B) imports of the subject merchandise are likely to enter the United
States at prices that otherwise would have a significant depressing or
suppressing effect on the price of domestic like products.
(4) IMPACT ON THE INDUSTRY.--In evaluating the likely impact of imports
of the subject merchandise on the industry if the order is revoked or the
suspended investigation is terminated, the Commission shall consider all
relevant economic factors which are likely to have a bearing on the state
of the industry in the United States, including, but not limited to–
(A) likely declines in output, sales, market share, profits, productivity,
return on investments, and utilization of capacity,
(B) likely negative effects on cash flow, inventories, employment,
wages, growth, ability to raise capital, and investment, and
(C) likely negative effects on the existing development and production
efforts of the industry, including efforts to develop a derivative or
more advanced version of the domestic like product.
The Commission shall evaluate all such relevant economic factors . . .
within the context of the business cycle and the conditions of competition
that are distinctive to the affected industry.
Section 752(a)(6) of the Act states further that in making its determination, “the
Commission may consider the magnitude of the margin of dumping or the magnitude of the net
countervailable subsidy. If a countervailable subsidy is involved, the Commission shall consider
information regarding the nature of the countervailable subsidy and whether the subsidy is a
subsidy described in Article 3 or 6.1 of the Subsidies Agreement.”

I-15
Organization of report
Information obtained during the course of the review that relates to the statutory
criteria is presented throughout this report. A summary of trade and financial data for TCCSS as
collected in the original investigation, prior reviews, and the current proceeding is presented in
appendix C. U.S. industry data are based on the questionnaire responses of three U.S.
producers of TCCSS which accounted for all known U.S. production of TCCSS in 2023. Data on
U.S. TCCSS imports and related information are based on the questionnaire responses of 21
importers, which accounted for the vast majority of TCCSS imports from Japan and all other
sources in 2023. U.S. purchaser data and related information are based on the questionnaire
responses of 22 U.S. purchasers of TCCSS. Foreign industry data and related information are
based on the questionnaire responses of three subject foreign producers which accounted for
all production of TCCSS in Japan in 2023. Responses by U.S. producers, importers, purchasers,
and foreign producers of TCCSS to a series of questions concerning the significance of the
existing antidumping duty order and the likely effects of revocation of such order are presented
in appendix D.
Commerce’s reviews34
Administrative reviews
Since the antidumping duty order on TCCSS from Japan was issued, there have been no
completed administrative reviews.35
34 Commerce has issued no duty absorption findings, company revocations, and anti-circumvention
findings since the imposition of the order. See 88 FR 69133, October 5, 2023 and accompanying Issues
and Decision Memorandum for the Final Results of the Expedited Fourth Sunset Review of the
Antidumping Duty Order on Certain Tin Mill Products from Japan, September 28, 2023.
35 Since the antidumping duty order on TCCSS from Japan was issued, Commerce has initiated five
administrative reviews. All five administrative reviews, however, were rescinded. 76 FR 14902, March
18, 2011; 77 FR 5767, February 6, 2012; 84 FR 63618, November 18, 2019; 85 FR 71879, November 12,
2020; and 88 FR 6233, January 31, 2023.

I-16
Changed circumstances reviews
Commerce has completed three changed circumstances reviews regarding imports of
TCCSS from Japan since the issuance of the order. During the first changed circumstances
review in 2001, Commerce determined that changed circumstances with respect to certain
chromium coated steel did not exist to warrant revocation of the order in part.36 During the
second changed circumstances review in 2002, Commerce determined that changed
circumstances with respect to certain tin-free steel existed and revoked the order in part.37
During the third changed circumstances review in 2003, Commerce determined that changed
circumstances with respect to certain laminated tin-free steel existed and revoked the order in
part.38
36 66 FR 52109, October 12, 2001. Domestic interested parties requested that Commerce revoke the
order in part with respect to imports of merchandise which met the following specifications: “double
reduced (CADR8 temper) electrolytically chromium coated steel with chromium oxide at a level of 1.6
mg/sq. ft. (#0.9), having a base box weight of 60 pounds (nominal thickness of 0.0066 inch (#5%
tolerance)), and a surface with a 7C stone finish, lubricated with butyl stearate oil (BSO) or dioctyl
sebacate oil (DOS) with the level ranging from 0.22 to 0.32 gm/base box. The material is 31½ inches in
actual width -0/+ 1⁄16 inch width tolerance) and made from fully deoxidized (killed) continuous cast and
continuous annealed steel that is free of detrimental non-metallic inclusions (i.e., clean steel) with
earring hazard minimized. The maximum edge wave is 1⁄8 inch, with crossbow controllable to less than
2 inches per sheet. The maximum camber per three feet is 0.020 inch, the maximum burr is 0.001 inch,
and the maximum pinholes per coil is 0.2%. The maximum coil weight is 25,000 pounds, with an interior
coil diameter of 16 inches to 161⁄2 inches, and an exterior coil diameter of 36 inches to 60 inches. When
loaded for shipment, the coil is placed on the pallet with the eye of the coil standing vertical, with each
side of the pallet being 60 inches having 4 x 4 runners, and outside runners placed a minimum of 37
inches apart.” Commerce determined that changed circumstances with respect to this merchandise did
not exist to warrant revocation of the order in part. Id.
37 67 FR 44177, July 1, 2002. Commerce partially revoked the order on TCCSS from Japan with respect
to all entries of tin-free steel which met the following specifications: “steel coated with a metallic
chromium layer between 100–200 mg/m 2 and a chromium oxide layer between 5–30 mg/m 2
; chemical
composition of 0.05% maximum carbon, 0.03% maximum silicon, 0.60% maximum manganese, 0.02%
maximum phosphorous, and 0.02% maximum sulfur; magnetic flux density (‘‘Br’’) of 10 kg minimum and
a coercive force (‘‘Hc’’) of 3.8 Oe minimum.” Id.
38 68 FR 6412, February 7, 2003. Commerce partially revoked the order on TCCSS from Japan with
respect to all entries of certain laminated tin-free steel which met the following specifications: “tin-free
steel laminated on one or both sides of the surface with a polyester film, consisting of two layers (an
amorphous layer and an outer crystal layer), that contains no more than the indicated amounts of the
following environmental hormones: 1 mg/kg BADGE (BisPhenol—A Di-glycidyl Ether), 1 mg/kg BFDGE
(BisPhenol—F Di-glycidyl Ether), and 3 mg/kg BPA (BisPhenol—A).” Id.

I-17
Scope rulings
Commerce has conducted four scope rulings with respect to TCCSS from Japan. On
October 12, 2001, Commerce determined that double-reduced electrolytically chromium
coated steel was within the scope of the order.39 On March 21, 2002, Commerce determined
that double-reduced electrolytic tin plate meeting the requirements of ASTM specification A
626/A 626M, and double reduced tin-free meeting the requirements of ASTM specification A
657/A 657M, produced in Taiwan from Japanese black plate, were outside the scope of the
order.40 On August 27, 2002, Commerce determined that tin-free single reduced electrolytically
chromium coated steel was within the scope of the order.41 On January 7, 2005, Commerce
concluded that certain electrolytic tin plate and tin free steel products, made in Colombia by
Hojalata y Laminados S.A. from Japanese single-reduced black plate and double-reduced black
plate, were excluded from the scope of the order.42
39 68 FR 7772, February 18, 2003.
40 68 FR 7772, February 18, 2003.
41 68 FR 7772, February 18, 2003.
42 70 FR 41374, July 19, 2005.

I-18
Five-year reviews
On August 9, 2000, Commerce issued the antidumping duty order on TCCSS from Japan.
Table I-5 presents the dumping margins calculated by Commerce in its original investigation.
Table I-5
TCCSS: Commerce’s original dumping margins for producers/exporters in Japan
Producer/exporter 	Original margin (percent)
Kawasaki Steel Corp. 	95.29
Nippon Steel Corp. 	95.29
NKK Corp. 	95.29
Toyo Kohan Co., Ltd. 	95.29
All others 	32.52
Source: 65 FR 39364, June 26, 2000 and 65 FR 52067, August 28, 2000.
Note: In 2002, Kawasaki Steel Corp. and NKK Corp. merged to established JFE Holdings Co. and in
2003 JFE Holding Co. established JFE Steel Corp., a producer of TCCSS in Japan. First review
publication, p. IV-6; second review publication, p. I-13; third review publication, p. I-14.
During the first and second five-year reviews, Commerce determined that revocation of
the antidumping duty order on TCCSS from Japan would likely lead to continuation or
recurrence of dumping, and that the magnitude of the dumping margins likely to prevail would
be weighted-average dumping margins of 95.29 percent for Kawasaki Steel Corp., Nippon Steel
Corp., NKK Corp., and Toyo Kohan Co., Ltd., and margins of 32.52 precent for all others.43
During the third five-year review and in this current fourth five-year review, Commerce
determined that revocation of the antidumping duty order on TCCSS from Japan would be likely
to lead to continuation or recurrence of dumping, and that the magnitude of the dumping
margins likely to prevail would be weighted-average dumping margins up to 95.29 percent.44
43 70 FR 67448, November 7, 2005; 76 FR 60001, September 28, 2011.
44 82 FR 41933, September 5, 2017; 88 FR 69133, October 5, 2023.

I-19
The subject merchandise
Commerce’s scope
In the current proceeding, Commerce has defined the scope as follows:
The products covered by the order are tin mill flat-rolled products that are
coated or plated with tin, chromium or chromium oxides. Flat-rolled steel
products coated with tin are known as tin plate. Flat-rolled steel products
coated with chromium or chromium oxides are known as tin-free steel or
electrolytic chromium-coated steel. The scope includes all the noted tin
mill products regardless of thickness, width, form (in coils or cut sheets),
coating type (electrolytic or otherwise), edge (trimmed, untrimmed or
further processed, such and scroll cut), coating thickness, surface finish,
temper, coating metal (tin, chromium, chromium oxide), reduction
(single- or double-reduced), and whether or not coated with a plastic
material.
All products that meet the written physical description are within the
scope of the Order unless specifically excluded. The following products, by
way of example, are outside and/or specifically excluded from the scope
of the order:
• 	Single reduced electrolytically chromium coated steel with a thickness
0.238 mm (85 pound base box) (± 10%) or 0.251 mm (90 pound base
box) (± 10%) or 0.255 mm (±10%) with 770 mm (minimum width) (±
1.588 mm) by 900 mm (maximum length if sheared) sheet size or
30.6875 inches (minimum width) (± 1/16 inch) and 35.4 inches
(maximum length if sheared) sheet size; with type MR or higher (per
ASTM) A623 steel chemistry; batch annealed at T2 1/2 anneal temper,
with a yield strength of 31 to 42 kpsi (214 to 290 Mpa); with a tensile
strength of 43 to 58 kpsi (296 to 400 Mpa); with a chrome coating
restricted to 32 to 150 mg/m²; with a chrome oxide coating restricted
to 6 to 25 mg/m² with a modified 7B ground roll finish or blasted roll
finish; with roughness average (Ra) 0.10 to 0.35 micrometers,
measured with a stylus instrument with a stylus radius of 2 to 5
microns, a trace length of 5.6 mm, and a cut-off of 0.8 mm, and the
measurement traces shall be made perpendicular to the rolling
direction; with an oil level of 0.17 to 0.37 grams/base box as type
BSO, or 2.5 to 5.5 mg/m² as type DOS, or 3.5 to 6.5 mg/m² as type

I-20
ATBC; with electrical conductivity of static probe voltage drop of 0.46
volts drop maximum, and with electrical conductivity degradation to
0.70 volts drop maximum after stoving (heating to 400 degrees F for
100 minutes followed by a cool to room temperature).
• 	Single reduced electrolytically chromium-or tin-coated steel in the
gauges of 0.0040 inch nominal, 0.0045 inch nominal, 0.0050 inch
nominal, 0.0061 inch nominal (55 pound base box weight), 0.0066
inch nominal (60 pound base box weight), and 0.0072 inch nominal
(65 pound base box weight), regardless of width, temper, finish,
coating or other properties.
• 	Single reduced electrolytically chromium coated steel in the gauge of
0.024 inch, with widths of 27.0 inches or 31.5 inches, and with T-1
temper properties.
• 	Single reduced electrolytically chromium coated steel, with a chemical
composition of 0.005% max carbon, 0.030% max silicon, 0.25% max
manganese, 0.025% max phosphorous, 0.025% max sulfur, 0.070%
max aluminum, and the balance iron, with a metallic chromium layer
of 70-130 mg/m², with a chromium oxide layer of 5-30 mg/m² , with a
tensile strength of 260-440 N/mm², with an elongation of 28-48%,
with a hardness (HR-30T) of 40-58, with a surface roughness of 0.5-
1.5 microns Ra, with magnetic properties of Bm (KG)10.0 minimum, Br
(KG) 8.0 minimum, Hc (Oe) 2.5-3.8, and MU 1400 minimum, as
measured with a Riken Denshi DC magnetic characteristic measuring
machine, Model BHU-60.
• 	Bright finish tin-coated sheet with a thickness equal to or exceeding
0.0299 inch, coated to thickness of 3/4 pound (0.000045 inch) and 1
pound (0.00006 inch).
• 	Electrolytically chromium coated steel having ultra flat shape defined
as oil can maximum depth of 5/64 inch (2.0 mm) and edge wave
maximum of 5/64 inch (2.0 mm) and no wave to penetrate more than
2.0 inches (51.0 mm) from the strip edge and coilset or curling
requirements of average maximum of 5/64 inch (2.0 mm) (based on
six readings, three across each cut edge of a 24 inches (61 cm) long
sample with no single reading exceeding 4/32 inch (3.2 mm) and no

I-21
more than two readings at 4/32 inch (3.2 mm)) and (for 85 pound
base box item only: crossbuckle maximums of 0.001 inch (0.0025 mm)
average having no reading above 0.005 inch (0.127 mm)), with a
camber maximum of 1/4 inch (6.3 mm) per 20 feet (6.1 meters),
capable of being bent 120 degrees on a 0.002 inch radius without
cracking, with a chromium coating weight of metallic chromium at
100 mg/m² and chromium oxide of 10 mg/m², with a chemistry of
0.13% maximum carbon, 0.60% maximum manganese, 0.15%
maximum silicon, 0.20% maximum copper, 0.04% maximum
phosphorous, 0.05% maximum sulfur, and 0.20% maximum
aluminum, with a surface finish of Stone Finish 7C, with a DOS-A oil at
an aim level of 2 mg/square meter, with not more than 15
inclusions/foreign matter in 15 feet (4.6 meters) (with inclusions not
to exceed 1/32 inch (0.8 mm) in width and 3/64 inch (1.2 mm) in
length), with thickness/temper combinations of either 60 pound base
box (0.0066 inch) double reduced CADR8 temper in widths of 25.00
inches, 27.00 inches, 27.50 inches, 28.00 inches, 28.25 inches, 28.50
inches, 29.50 inches, 29.75 inches, 30.25 inches, 31.00 inches, 32.75
inches, 33.75 inches, 35.75 inches, 36.25 inches, 39.00 inches, or 43.00
inches, or 85 pound base box (0.0094 inch) single reduced CAT4
temper in widths of 25.00 inches, 27.00 inches, 28.00 inches, 30.00
inches, 33.00 inches, 33.75 inches, 35.75 inches, 36.25 inches, or 43.00
inches, with width tolerance of 1/8 inch, with a thickness tolerance of
0.0005 inch, with a maximum coil weight of 20,000 pounds (9071.0
kg), with a minimum coil weight of 18,000 pounds (8164.8 kg) with a
coil inside diameter of 16 inches (40.64 cm) with a steel core, with a
coil maximum outside diameter of 59.5 inches (151.13 cm), with a
maximum of one weld (identified with a paper flag) per coil, with a
surface free of scratches, holes, and rust.
• 	Electrolytically tin coated steel having differential coating with 1.00
pound/base box equivalent on the heavy side, with varied coating
equivalents in the lighter side (detailed below), with a continuous cast
steel chemistry of type MR, with a surface finish of type 7B or 7C, with
a surface passivation of 0.7 mg/square foot of chromium applied as a
cathodic dichromate treatment, with coil form having restricted oil

I-22
film weights of 0.3- 0.4 grams/base box of type DOS-A oil, coil inside
diameter ranging from 15.5 to 17 inches, coil outside diameter of a
maximum 64 inches, with a maximum coil weight of 25,000 pounds,
and with temper/coating/dimension combinations of: (1) CAT 4
temper, 1.00/.050 pound/base box coating, 70 pound/base box
(0.0077 inch) thickness, and 33.1875 inch ordered width; or (2) CAT5
temper, 1.00/0.50 pound/base box coating, 75 pound/base box
(0.0082 inch) thickness, and 34.9375 inch or 34.1875 inch ordered
width; or (3) CAT5 temper, 1.00/0.50 pound/base box coating, 107
pound/base box (0.0118 inch) thickness, and 30.5625 inch or 35.5625
inch ordered width; or (4) CADR8 temper, 1.00/0.50 pound/base box
coating, 85 pound/base box (0.0093 inch) thickness, and 35.5625 inch
ordered width; or (5) CADR8 temper, 1.00/0.25 pound/base box
coating, 60 pound/base box (0.0066 inch) thickness, and 35.9375 inch
ordered width; or (6) CADR8 temper, 1.00/0.25 pound/base box
coating, 70 pound/base box (0.0077 inch) thickness, and 32.9375 inch,
33.125 inch, or 35.1875 inch ordered width.
• 	Electrolytically tin coated steel having differential coating with 1.00
pound/base box equivalent on the heavy side, with varied coating
equivalents on the lighter side (detailed below), with a continuous
cast steel chemistry of type MR, with a surface finish of type 7B or 7C,
with a surface passivation of 0.5 mg/square foot of chromium applied
as a cathodic dichromate treatment, with ultra flat scroll cut sheet
form, with CAT 5 temper with 1.00/0.10 pound/base box coating, with
alithograph logo printed in a uniform pattern on the 0.10 pound
coating side with a clear protective coat, with both sides waxed to a
level of 15-20 mg/216 sq. in., with ordered dimension combinations of
(1) 75 pound/base box (0.0082 inch) thickness and 34.9375 inch x
31.748 inch scroll cut dimensions; or (2) 75 pound/base box (0.0082
inch) thickness and 34.1875 inch x 29.076 inch scroll cut dimensions;
or (3) 107 pound/base box (0.0118 inch) thickness and 30.5625 inch x
34.125 inch scroll cut dimension.

I-23
• 	Tin-free steel coated with a metallic chromium layer between 100-200
mg/m² and a chromium oxide layer between 5-30 mg/m²; chemical
composition of 0.05% maximum carbon, 0.03% maximum silicon,
0.60% maximum manganese, 0.02% maximum phosphorous, and
0.02% maximum sulfur; magnetic flux density (“Br”) of 10 kg
minimum and a coercive force (“Hc”) of 3.8 Oe minimum.
• 	Tin-free steel laminated on one or both sides of the surface with a
polyester film, consisting of two layers (an amorphous layer and an
outer crystal layer), that contains no more than the indicated amounts
of the following environmental hormones: 1 mg/kg BADGE (BisPhenol
– A Di-glycidyl Ether), 1 mg/kg BFDGE (BisPhenol – F Di-glycidyl Ether),
and 3 mg/kg BPA (BisPhenol – A).
Merchandise subject to the Order is typically classified under subheadings
in the 7210.11.0000, 7210.12.0000, 7210.50.0000, 7212.10.0000, and
7212.50.0000 if of non-alloy steel and under HTSUS subheadings
7225.99.0090, and 7226.99.0180 if of alloy steel of the Harmonized Tariff
Schedule of the United States (HTSUS). While HTSUS subheadings and
ASTM specifications are provided for convenience and customs purposes,
the written description of the scope if dispositive.45 46
45 88 FR 69133, October 5, 2023; and Commerce’s Issues and Decision Memorandum for the Final
Results of the Expedited Fourth Sunset Review of the Antidumping Duty Order on Certain Tin Mill
Products from Japan, September 28, 2023 (see EDIS # 805435).
46 HTSUS 7210.50.0000 has been subsequently annotated by statistical reporting numbers
7210.50.0020 and 7210.50.0090.

I-24
Tariff treatment
TCCSS is currently imported under Harmonized Tariff Schedule of the United States
(“HTSUS” or “HTS”) statistical reporting numbers 7210.11.0000, 7210.12.0000, 7210.50.0020,
7210.50.0090, 7212.10.0000, and 7212.50.0000 if of non-alloy steel and under HTS statistical
reporting numbers 7225.99.0090 and 7226.99.0180 if of alloy steel.47 The 2024 general rate of
duty is “Free.”48 Decisions on the tariff classification and treatment of imported goods are
within the authority of U.S. Customs and Border Protection (“CBP”).
Effective September 1, 2019, TCCSS originating in China, a nonsubject country, was
subject to an additional 15 percent ad valorem duty under section 301 of the Trade Act of 1974.
Effective February 14, 2020, the section 301 duty for TCCSS was reduced to 7.5 percent.49
Products of China subject to section 301 tariffs also continue to be subject to all applicable
duties and charges, as well as the additional ad valorem rate of duty imposed by the HTS
heading.50
47 Prior to July 1, 2021, TCCSS was imported under HTS subheading 7210.50.0000; after that date this
subheading was annotated with establishment of HTS statistical reporting numbers 7210.50.0020 and
7210.50.0090. USITC (2021) Basic Revision 5, Publication 5213, July 2021, Change Record, p. 4.
48 USITC, HTSUS (2024) Revision 1, USITC Publication 5491, January 2024, pp. 72-17, 72-19, 72-41, 72-
42, 72-47.
49 84 FR 43304, August 20, 2019; 84 FR 45821, August 30, 2019; 85 FR 3741, January 22, 2020. See
also HTS heading 9903.88.15 and U.S. notes 20(r) and 20(s) to subchapter III of chapter 99 and related
tariff provisions for this duty treatment. USITC, HTSUS (2024) Revision 1, USITC Publication 5491,
January 2024, pp. 72-47, 99-III-87 – 99-III-88, 99-III-97 – 99-III-98, 99-III-241 – 99-III-244, 99-III-246 – 99-
III-247, 99-III-303, 99-III-305 – 99-III-309.
50 See U.S. note 20(r). USITC, HTSUS (2024) Revision 1, USITC Publication 5491, January 2024, pp. 99-
III-87, 99-III-303.
See also the next paragraph for the 25 percent additional section 232 duties on steel articles
originating in China.

I-25
Effective March 23, 2018, TCCSS originating in Japan was subject to an additional 25
percent ad valorem duty under section 232 of the Trade Expansion Act of 1962, as amended.
Effective April 1, 2022, TCCSS originating in Japan became subject to a tariff-rate quota (“TRQ”)
with imports above the quota level subject to section 232 duties. The TRQ categories for
tinplate and tin-free steel originating in Japan covers TCCSS and out-of-scope products.51
Otherwise, TCCSS originating in any other U.S. trade partner, not otherwise granted
exemptions, absolute quotas, or TRQs, is subject to these 25 percent additional duties.52
Products subject to section 232 tariffs also continue to be subject to all applicable duties and
charges, as well as the additional ad valorem rate of duty imposed by the respective HTS
headings and subheadings.53
51 CBP, “2023 4th Quarter Tariff Rate Quota for Steel Articles of Japan or the United Kingdom,” Quota
Bulletin No. QB 23-624, January 5, 2023, https://www.cbp.gov/trade/quota/bulletins/qb-23-624-2023;
CBP, “Japan or United Kingdom Sec 232 Steel Tariff Rate Quota (TRQ) Quarter 2 Usage / Quarter 4 Limits
2023,” September 21, 2023, https://www.cbp.gov/sites/default/files/assets/documents/2023-
Sep/Japan_UK_Steel_TRQ_Q2_Usage_Q4_Limits_2023.pdf; CBP, "Japan or United Kingdom Sec 232
Steel Tariff Rate Quota (TRQ) Quarter 1 Usage / Quarter 3 Limits 2023,” June 20, 2023,
https://www.cbp.gov/sites/default/files/assets/documents/2023-
Jun/Japan_UK_Steel_TRQ_Q1_Usage_Q3_Limits_2023.pdf.
83 FR 11625, March 15, 2018. See also HTS heading 9903.80.01, HTS subheadings 9903.81.34,
9903.81.35, and U.S. notes 16(a) and 16(g) to subchapter III of chapter 99 and related tariff provisions
for this duty treatment. USITC, HTSUS (2024) Revision 1, USITC Publication 5491, January 2024, pp. 72-
47, 99-III-5, 99-III-8, 99-III-272, 99-III-287, 99-III-292.
52 Section 232 import duties on steel articles currently cover all countries of origin except Argentina,
Australia, Brazil, Canada, Mexico, and South Korea. Imports from Australia, Canada, and Mexico are
exempt from section 232 duties and quotas on steel articles, while imports originating in Argentina,
Brazil, and South Korea are exempt from duties but are instead subject to absolute quotas. EU member
countries (effective January 1, 2022, to December 31, 2025), Japan (effective April 1, 2022), and the
United Kingdom (effective June 1, 2022) are currently subject to tariff-rate quotas (“TRQs”) for steel
articles, and imports that exceed the TRQ limits are subject to the section 232 tariffs. Section 232 import
duties on steel articles originating in Turkey were temporarily raised from 25 percent to 50 percent,
effective August 13, 2018, but restored to 25 percent effective May 21, 2019. In addition, section 232
duties on steel articles originating in Ukraine are suspended, effective June 1, 2022, to June 1, 2024. 83
FR 11625, March 15, 2018; 83 FR 13361, March 28, 2018; 83 FR 20683, May 7, 2018; 83 FR 25857, June
5, 2018; 83 FR 40429, August 15, 2018; 84 FR 23421, May 21, 2019; 84 FR 23987, May 23, 2019; 87 FR
11, January 3, 2022; 87 FR 19351, April 1, 2022; 87 FR 33407, June 2, 2022; 87 FR 33591, June 3, 2022;
88 FR 36437, June 5, 2023; 89 FR 227, January 3, 2024. See HTS heading 9903.80.01 and U.S. notes
16(a), 16(b), 16(e), 16(f), and 16(g) to subchapter III of chapter 99 and related tariff provisions for this
duty treatment. USITC, HTSUS (2024) Revision 1, USITC Publication 5491, January 2024, pp. 72-47, 99-III-
5 – 99-III-8, 99-III-272 – 99-III-273, 99-III-279 – 99-III-280, 99-III-287, 99-III-292 – 99-III-293.
53 See U.S. note 16(a). USITC, HTSUS (2024) Revision 1, USITC Publication 5491, January 2024, pp. 99-
III-5, 99-III-272.

I-26
Under section 232 of the Trade Expansion Act of 1962, as amended, the President
authorized the Secretary of Commerce, in consultation with other appropriate federal agency
heads, to provide relief from the additional duties for any steel articles determined “…not to be
produced in the United States in a sufficient and reasonably available amount or of a
satisfactory quality and is also authorized to provide such relief based upon specific national
security considerations. Such relief shall be provided for any article only after a request for
exclusion is made by a directly affected party located in the United States.”54 Commerce
reviews all exclusion requests and any objections, rebuttals, and sur-rebuttals to the requests
and determines whether the items warrant an exclusion based on the above criteria.55
Excluded steel articles, including any TCCSS, do not count toward filling the TRQs for the
EU member countries, effective January 1, 2022.56 Conversely, these “quota exclusion entries”
do count toward filling the quotas for Argentina, Brazil, and South Korea, effective August 30,
2018;57 and the TRQs for Japan, effective April 1, 2022;58 and the TRQs for the United Kingdom,
effective June 1, 2022.59 Imports of excluded products (“quota exclusion entries”) are counted
against the quarterly quota in place at the time of entry and count toward the annual quota.
However, as the excluded products are exempt from both the quarterly and annual quotas,
they continue to be accepted until closure of the annual quota. CBP tracks and reports
exclusion quantities quarterly or “exclusion quota overflow” quantities annually.60
54 83 FR 45025, September 4, 2018.
55 U.S. Bureau of Industry and Security (“BIS”), “Section 232 National Security Investigation of Steel
Imports, Information on the Exclusion Process,” December 20, 2022,
https://www.bis.doc.gov/index.php/232-steel. See also HTS heading 9903.80.01, HTS subheadings
9903.80.60 – 9903.80.62, HTS heading 9903.81.80, and U.S. notes 16(c) and 16(d) to subchapter III of
chapter 99 and related tariff provisions for this duty treatment. USITC, HTSUS (2024) Revision 1,
Publication 5491, January 2024, pp. 99-III-7, 99-III-279, 99-III-292.
56 87 FR 11, January 3, 2022; CBP, “2023 Fourth Quarter Tariff Rate Quota (TRQ) for Steel Mill Articles
of European Union (EU) Member Countries,” Quota Bulletin No. QB 23-614, January 5, 2024,
https://www.cbp.gov/trade/quota/bulletins/qb-23-614-2023.
57 83 FR 45025, September 4, 2018.
58 87 FR 19351, April 1, 2022.
59 87 FR 33591, June 3, 2022.
60 Exclusion quota overflow quantities are designated with the “ALXC” suffix in the CBC quota fill
reports for Argentina, Brazil, and South Korea; and with the “STXC” suffix for the reports for Japan and
the United Kingdom. CBP, “2023 Fourth Quarter Absolute Quota for Steel Mill Articles of Argentina,
Brazil, and South Korea,” Quota Bulletin No. QB 23-604, September 21, 2023,
https://www.cbp.gov/trade/quota/bulletins/qb-23-604-2023; CBP, “2023 4th Quarter Tariff Rate Quota
for Steel Articles of Japan or the United Kingdom,” Quota Bulletin No. QB 23-624, January 5, 2024,
https://www.cbp.gov/trade/quota/bulletins/qb-23-624-2023.

I-27
Table I-6 presents the section 232 steel absolute quota and TRQ limits, usages, and fill
rates for imports originating in Japan during 2022. Likewise, table I-7 presents these limits,
usages, and fill rates for 2023. The purchaser respondents note that the TRQ for tin-free steel
(“TFS”) also includes out-of-scope laminated TFS. Commerce granted numerous product
exclusions for laminated TFS since the Section 232 measures entered into effect, including
dozens of such product exclusions in the past six months for major U.S. steel can
manufacturers, including Crown Cork & Seal USA Inc. (“Crown”), Silgan Containers
Manufacturing Corp. (“Silgan”), Sonoco Products Co. (“Sonoco”), and Trivium Packaging USA
Inc. (“Trivium”).61
Table I-6
TCCSS and other tin mill products: Japan, section 232 steel TRQ limits, usages, and fill rates; and
product exclusions, 2022
Limits, usages, and exclusions in short tons; fill rates in percent
Source 	Quota type 	Item Tin-free
steel Tinplate 	Total
Japan 	Tariff-rate 	Limit 	56,023 	96 	56,119
Japan 	Tariff-rate 	Usage 	26,246 	25 	26,271
Japan 	Tariff-rate 	Fill rate 	46.8 	26.0 	46.8
Japan 	Tariff-rate 	Exclusions 	56,804 	0 	56,804
Sources: CBP, “2022 4th Quarter Tariff Rate Quota for Steel Articles of Japan or the United Kingdom,”
Quota Bulletin No. QB 22-624, December 16, 2022, https://www.cbp.gov/trade/quota/bulletins/qb-22-624-
2022; CBP, “2022 Tariff Rate Quota (TRQ) for Steel Articles of Japan or the United Kingdom,” Quota
Bulletin No. QB 22-623, December 16, 2022, https://www.cbp.gov/trade/quota/bulletins/QB%2022-623;
CBP, “2022 Tariff Rate Quota (TRQ) for Steel Articles of Japan,” Quota Bulletin No. QB 22-622,
December 28, 2022, https://www.cbp.gov/trade/quota/bulletins/qb-22-622-2022-tariff-rate-quota-trq-steel-
articles-japan; CBP, “Japan and United Kingdom Steel TRQ 2022 Annual Totals,” October 2, 2023,
https://www.cbp.gov/sites/default/files/assets/documents/2023-
Oct/Japan_and_UK_Steel_TRQ_2022_Annual%20Totals.pdf.
Note: CBP Quota ID categories with HTS subheadings for TCCSS:
Japan TRQs— 9903.80.34: Tin-free steel (HTS 7210.50.00) and 9903.81.35: Tinplate (HTS 7210.11.00,
7210.12.00, 7212.10.00).
Other HTS subheadings for TCCSS are included in Quota ID categories, containing numerous other HTS
subheadings for nonsubject products, 9903.81.28: Cold-rolled sheet, 9903.81.29: Cold-rolled strip, and
9903.81.33: Flat-rolled products, coated.
Usages are recorded for the second through fourth quarters of 2022. Effective April 1, 2022, steel articles,
including TCCSS and other tin mill products, originating in Japan became subject to TRQs with imports
above the quota levels subject to section 232 duties. 83 FR 11625, March 15, 2018.
61 Japanese respondents’ prehearing brief, March 28, 2024, pp. 46–47; exhs. 24–26; hearing
transcript, April 9, 2024, pp. 114–115 (Dietrich), 124 (Madrecki), 152 (Stringer), 230 (McNamera); U.S.
Steel’s posthearing brief, April 16, 2024, exh. 9: Purchaser 232 Exclusion Requests.
For more information about laminated TFS, see the “Description and applications” and
“Manufacturing processes” sections below.

I-28
Table I-7
TCCSS and other tin mill products: Japan, section 232 steel TRQ limits, usages, and fill rates; and
product exclusions, 2023
Limits, usages, and exclusions in short tons; fill rates in percent
Source 	Quota type 	Item Tin-free
steel Tinplate 	Total
Japan 	Tariff-rate 	Limit 	56,023 	96 	56,119
Japan 	Tariff-rate 	Usage 	52,581 	75 	52,656
Japan 	Tariff-rate 	Fill rate 	93.9 	78.2 	93.8
Japan 	Tariff-rate 	Exclusions 	14,489 	0 	14,489
Sources: CBP, “2023 4th Quarter Tariff Rate Quota for Steel Articles of Japan or the United Kingdom,”
Quota Bulletin No. QB 23-624, January 5, 2023, https://www.cbp.gov/trade/quota/bulletins/qb-23-624-
2023; CBP, “Japan or United Kingdom Sec 232 Steel Tariff Rate Quota (TRQ) Quarter 2 Usage / Quarter
4 Limits 2023,” September 21, 2023, https://www.cbp.gov/sites/default/files/assets/documents/2023-
Sep/Japan_UK_Steel_TRQ_Q2_Usage_Q4_Limits_2023.pdf; CBP, “Japan or United Kingdom Sec 232
Steel Tariff Rate Quota (TRQ) Quarter 1 Usage / Quarter 3 Limits 2023,” June 20, 2023,
https://www.cbp.gov/sites/default/files/assets/documents/2023-
Jun/Japan_UK_Steel_TRQ_Q1_Usage_Q3_Limits_2023.pdf; CBP, “Japan and United Kingdom Steel
TRQ 2023 Annual Totals,” February 12, 2024,
https://www.cbp.gov/sites/default/files/assets/documents/2024-
Feb/Japan_and_UK_Steel_TRQ_2023_Annual_Totals.pdf.
Note: CBP Quota ID Nos. (HTS subheadings):
Japan TRQs-- 9903.80.74: Tin-free steel (HTS 7210.50.00) and 9903.80.75: Tinplate (HTS 7210.11.00,
7210.12.00, 7212.10.00).
Other HTS subheadings for TCCSS are included in Quota ID categories, containing numerous other HTS
subheadings for nonsubject products, 9903.81.28: Cold-rolled sheet, 9903.81.29: Cold-rolled strip, and
9903.81.33: Flat-rolled products, coated.

I-29
The product62
Description and applications
Tinplate
Tinplate is a tin-coated flat-rolled steel product that is manufactured from black plate,
an uncoated flat-rolled steel which is the substrate material for tin mill products. To produce
tinplate, the black plate is coated on both sides with commercially pure tin via electrolytic
deposition (figure I-2). Tin coatings vary by thickness, depending on intended end use. A
common commercial weight for tin is 20 pounds/base box.63 Tinplate is also available with
different coating weights on the two sides of the sheet. Single-reduced (or conventional)
electrolytic tinplate is commonly produced via cold rolling in thicknesses of 0.49 mm and lighter
while double-reduced electrolytic tinplate is normally produced via cold rolling and annealing,
followed by further cold reduction in thicknesses of 0.29 mm and lighter. Tinplate is
manufactured to several ASTM Standard Specifications, including A599,64 A623,65 A624,66 and
A626.67
62 Unless otherwise noted, this information is based on third review publication, pp. I-17 – I-19; and
Tin Mill Products from Canada, China, Germany, and South Korea, Investigation Nos. 701-TA-685 and
731-TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, pp. I-21 – I-26.
63 A base box (or basis box) is a unit of area equivalent to 31,360 square inches (217.78 square feet or
20.23 square meters) consisting of 112 tinplate sheets, each measuring 14 inches (356 mm) by 20 inches
(508 mm). The corresponding surface area (on both sides) of a base box is 62,720 square inches (435.56
square feet or 40.46 square meters). The weight of the tinplate coating is expressed in terms of pounds
per base box (lbs/bb). Satyendra Kumar Sarna, “Tinplate,” ISPAT Guru, July 14, 2013,
https://www.ispatguru.com/tinplate/; and ITRI Ltd., “Thickness” and “The Tin Coating,” Guide to
Tinplate, August 2019, pp. 27, 30, https://www.tinplategroup.com/wp-
content/uploads/2019/08/Guide-toTinplate.pdf.
For more details about how to calculate the equivalent number of base boxes, see: ASTM
International, “Annex AI. Abbreviated Ratio Tables for Tin Mill Products,” in “A623-11: Standard
Specification for Tin Mill Products, General Requirements,” Annual Book of ASTM Standards 2017,
Section 1 Iron and Steel Products, Volume 01.06 Coated Products, 2017, pp. 122–134.
64 ASTM International, “A599/A599M-07 (Reapproved 2012): Standard Specification for Tin Mill
Products, Electrolytic Tin-Coated, Cold-Rolled Sheet,” Annual Book of ASTM Standards 2017, Section 1
Iron and Steel Products, Volume 01.06 Coated Products, 2017, pp. 108–110.
65 ASTM International, “A623-11: Standard Specification for Tin Mill Products, General
Requirements,” Annual Book of ASTM Standards 2017, Section 1 Iron and Steel Products, Volume 01.06
Coated Products, 2017, pp. 117–121; “A623M-11: Standard Specification for Tin Mill Products, General
Requirements (Metric),” pp. 155–160.

I-30
Figure I-2
Tin-coated steel sheet: Tin coating layers
Source: Satyendra Kumar Sarna, “Tinplate,” ISPAT Guru, July 14, 2013,
https://www.ispatguru.com/tinplate/.
Single-reduced tinplate is produced with different surface finishes. The five following
basic surface finishes are available, but a bright or stone finish is most common for general can-
making operations.
• 	Bright finish– Consists of a surface provided by a flow-brightened tin coating on a
smooth finish steel base. Bright finishes are normally for general use.
• 	Light stone finish– Consists of a surface provided by a flow-brightened tin coating on
a steel base finish characterized by a light directional pattern.
• 	Stone finish– Consists of a surface provided by a flow-brightened tin coating on a
steel base finish characterized by a directional pattern. This type of finish makes the
scratches of printing and can making less conspicuous.
• 	Matte finish– Consists of a surface provided by an un-melted coating normally on a
shot blast finish steel base. This is dull type of finish and mainly used for making
bottle crowns.
(…continued)
66 ASTM International, “A624/A624M-13: Standard Specification for Tin Mill Products, Electrolytic Tin
Plate, Single Reduced,” Annual Book of ASTM Standards 2017, Section 1 Iron and Steel Products, Volume
01.06 Coated Products, 2017, pp. 181–185.
67 ASTM International, “A626/A626M-13: Standard Specification for Tin Mill Products, Electrolytic Tin
Plate, Double Reduced,” Annual Book of ASTM Standards 2017, Section 1 Iron and Steel Products,
Volume 01.06 Coated Products, 2017, pp. 188–192.

I-31
• 	Silver finish– Consists of a matte finish product which has been flow melted. This
type of finish is also called satin finish. This is a rough dull finish mainly used for
making artistic cans.
Double reduced tinplate is customarily supplied with a stone finish; however, it is also
available with an unmelted tin coating.
Chromium-coated steel sheet
Chromium-coated steel sheet, also known in the industry as “tin-free steel” or “TFS,”
generally consists of black plate that is further processed via the electrolytic deposition of
chromium metal and chromium oxide on both sides (figure I-3). Like tinplate, single-reduced
chromium-coated steel sheet is commonly available in thicknesses of 0.38 mm and lighter,
while double-reduced electrolytic chromium-coated steel sheet is normally available in
thicknesses of 0.28 mm and lighter. Minimum and maximum coating weights for chromium-
coated steel sheet range from 3 to 13 milligrams per square foot of metallic chromium and 0.7
to 2.5 milligrams per square foot of chromium oxide. Chromium-coated steel sheet is
manufactured to ASTM Standard Specification A657.68
Figure I-3
Chromium-coated steel sheet: Tin-free coating layers
Source: Satyendra Kumar Sarna, “Tin-free Steel,” ISPAT Guru, July 31, 2013,
https://www.ispatguru.com/tin-free-steel/.
68 ASTM International, “A657/A657M-13: Standard Specification for Tin Mill Products, Black Plate,
Electrolytic Chromium-Coated, Single and Double Reduced,” Annual Book of ASTM Standards 2017,
Section 1 Iron and Steel Products, Volume 01.06 Coated Products, 2017, pp. 225–232.

I-32
Some TFS can also be surface coated, lacquered, or laminated. Lamination, in particular,
provides high formability to minimize potential damage to the resin coating, corrosion
resistance, and low surface adhesion to readily release the contents of steel containers.69
Laminated TFS is utilized for food and beverage containers, lug caps (threaded lids for glass
containers), and aerosol cans.70 According to a witness for Crown, there is no substitute for
laminated TFS in the production of fish and pet food cans to prevent black sulfur staining of
protein-rich products. Moreover, proper application of the laminated resin film and
maintenance of bisphenol limits are critical to can performance and food safety, corrosion
resistance, and proper shelf life.71 However, the scope of Commerce’s order excludes laminated
TFS that meets the content limitations for “environmental hormones” (i.e., hazardous
bisphenols72). This out-of-scope laminated TFS is coated with either a polyethylene
terephthalate (“PET”), polypropylene (“PP”), or polyethylene (“PE”) film.73 A witness for Trivium
does not consider coated or lacquered TFS, available from domestic producers, as an
acceptable substitute for many can and end uses, especially due to documented safety, shelf
life, and corrosion-resistance issues.74 All three Japanese respondents produce laminated TFS
and *** export this higher value-added product to the U.S. market.75 According to Crown’s
product exclusion request, “US mills do not have the capability to produce polymer laminated
steel and have shown no interest in adding that capability.”76
69 Katsumi Kojima, “Typical Products and Manufacturing Processes of Can Materials in JFE Steel,” JFE
Technical Report, vol. 23, March 2018, pp. 2–3, https://www.jfe-
steel.co.jp/en/research/report/023/pdf/023-02.pdf.
For more details about laminated TFS, see e.g., JFE Steel’s “JFE Universal Bright” laminated steel
sheet in JFE Steel, Tin Mill Products: JFE Advanced Technology for Tin Mill Products, no date, pp. 5–6,
17–20; Japanese respondents’ prehearing brief, March 28, 2024, exh. 21.
70 TCC Steel, “Products Laminated Steel (LAMI)” webpage, ©2019,
https://www.tccsteel.com/en/business/laminated, retrieved April 12, 2024.
71 Hearing transcript, April 9, 2024, p. 102 (Hughes).
72 Bisphenols, used to produce polymers and resins, are “endocrine disrupting chemicals” or “EDCs.”
Daniel Ruiz and Heather Patisaul, “Endocrine-Disrupting Chemicals (EDCs),” Endocrine Society, January
24, 2022, https://www.endocrine.org/patient-engagement/endocrine-library/edcs.
73 TCC Steel, “Laminated Steel (LAMI-T),” Product Catalog, no date, pp. 16–17,
https://www.tccsteel.com/download/TCCSTEEL_Product_Catalog.pdf, retrieved April 12, 2024.
74 Hearing transcript, April 9, 2024, p. 114 (Dietrich).
75 Japanese respondents’ posthearing brief, April 16, 2024, p. 3.
76 Japanese respondents’ prehearing brief, March 28, 2024, p. 47, exh. 25; hearing transcript, April 9,
2024, p. 102 (Hughes).

I-33
Applications
Major end uses of tinplate are in the manufacture of welded or drawn cans for food,
beverages, aerosols, and paint. Tinplate is used for drawn can bodies because of its corrosion-
resistant qualities. Chromium-coated steel sheet is used for can ends that require less
resistance to corrosion, given that the ends have less contact with the contents of the can.
Moreover, tinplate is used for the can itself because it imparts a shinier surface than chromium
coating while chromium-coated steel sheet, with its duller surface finish, is considered
adequate for use in the can ends. Chromium-coated steel sheet is used primarily for two-piece
drawn cans and ends for beer and soft drinks, as well as ends for food cans and caps and crown
closures for glass containers. According to respondent interested party Nippon Steel, U.S. and
global demand for canned goods, the main end use for TCCSS products, has substantially
increased since the last review due to the COVID-19 pandemic and increasing consumer
interest.77
Steel cans for food and drinks are constructed from either two or three pieces. Three-
piece cans consist of a cylindrical body rolled from a rectangular piece of coated steel sheet
with a longitudinal seam (usually formed by welding) together with two can ends, which are
crimped over each end of the open cylindrical body. Two-piece cans have only one seam
around the top end of the cylindrical can body where a can end is crimped over to close the
can. Manufacturing two-piece cans— referred to as either “drawn and ironed” (“D&I”) or
“drawn and wall-ironed” (“DWI”) cans— begins with drawing the disk into a shallow “cup.” The
cup is further shaped by “drawing (elongating) and ironing (thinning)” by passing through a
series of progressively smaller diameter tungsten carbide rings (dies) that lengthen its height,
reduce its diameter, thin its wall, and shape its top and base to form the base and body of the
can from a single piece of steel.78
77 Nippon Steel’s response to the notice of institution, July 3, 2023, p. 15.
78 Metal Packaging Manufacturers Association (“MPMA”), “How Cans Are Made,” ©2023,
https://www.mpma.org.uk/information/how-cans-are-made/#:~:text=Drawn, retrieved June 13, 2023;
MPMA, “How a Three-piece Welded Food Can is Made,” ©2023, https://www.mpma.org.uk/wp-
content/uploads/3-Piece-Food-Cans-1.pdf, retrieved June 13, 2023; MPMA, “How a Two-piece Drawn
and Wall-ironed Food Can is Made,” ©2023, https://www.mpma.org.uk/wp-content/uploads/HOW-
2piecefood-low-res.pdf, retrieved June 13, 2023; MPMA, “How a Two-Piece Draw and Wall-Ironed
Drinks Can is Made,” ©2023, https://www.mpma.org.uk/wp-content/uploads/2-Piece-Drinks-Cans.pdf,
retrieved June 13, 2023; and ITRI Ltd., “Drawn and Wall-Ironed Cans,” Guide to Tinplate, August 2019,
pp. 49–53, https://www.tinplategroup.com/wp-content/uploads/2019/08/Guide-toTinplate.pdf.

I-34
According to the Can Manufacturers Institute (“CMI”), a trade association composed of
many of the leading U.S. metal can manufacturers, demand has been shifting away from three-
piece cans toward two-piece cans over the past decade, a trend that accelerated during the
COVID-19 pandemic. Some can producers consider two-piece cans as lighter and faster to
produce, offer superior quality standards, and a simpler supply chain than three-piece cans.
Industry data collected by CMI showing a trend away from three-piece and toward two-piece
food cans from 2015 to 2022, with two-piece cans accounting for 75 percent of food cans
produced in the United States in 2022.79
Tinplate is sometimes sold in wider widths for two-piece cans than for other
applications. Some U.S. can manufacturers utilize wider tinplate (typically greater than 44.5
inches) for more efficient can production. Wider width tin mill products allow can
manufacturers to punch more can blanks per row across the sheet in their manufacturing
process.80
Manufacturing processes81
Both tinplate and chromium-coated steel sheet are manufactured in five major steps
(figure I-4). The manufacturing processes for both products and the production workers
employed are identical until the final coating step. Producers need not engage in all five
production steps, as steel inputs can be obtained from outside sources.
79 Tin Mill Products from Canada, China, Germany, and South Korea, Investigation Nos. 701-TA-685
and 731-TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, p. I-24.
80 Tin Mill Products from Canada, China, Germany, and South Korea, Investigation Nos. 701-TA-685
and 731-TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, pp. I-24 – I-25.
According to a witness for Crown, domestic producers offering their narrower TCCSS sheets for
Crown’s two-piece DWI can-making machines designed to utilize wider sheets is considered a request to
operate less efficiently at a greater cost. Hearing transcript, April 9, 2024, p. 104 (Hughes).
81 Unless otherwise noted, this information is based on the third review publication, pp. I-19 – I-22;
and Tin Mill Products from Canada, China, Germany, and South Korea, Investigation Nos. 701-TA-685
and 731-TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, pp. I-26 – I-30.

I-35
Figure I-4
TCCSS: Manufacturing flow diagram
Source: Steel Mills of the World, “The Manufacturing Route for Tinplate Products,”
https://www.steelmillsoftheworld.com/products/cs/tinplatecoils/Tinplate_manufacturing_route.pdf,
retrieved June 13, 2023.
Note: BA=batch annealing, CA=continuous annealing, SR=single reduction, and DR=double reduction.

I-36
Hot rolling and cold reduction
Both tinplate and chromium-coated steel sheet are produced from molten steel that is
either cast into slabs or poured as ingots which are rolled into slabs in a separate mill. While
hot, the slabs are reduced in thickness and greatly elongated by further rolling through a series
of roughing and finishing stands in a hot-strip mill. The hot strip passes between rolls in
successive roll stands being reduced to a predetermined thickness, typically between 1.6 and
2.5 mm. On leaving the last finishing stand, the strip is coiled. After cooling, the hot-rolled strip
is uncoiled and pickled by passing it through a series of tanks or sprays of diluted acid to
remove the oxide scale formed during the hot-rolling process. The pickled strip is then typically
dried, oiled, and recoiled. The oil serves as a protection against rusting prior to, and as a
lubricant during, cold reduction. The hot-rolled and pickled strip is cold reduced by passing it
through a series of rolls, in much the same manner as in the hot-rolling operation, except that a
lubricant is applied between the stands as an aid in reduction and to prevent undue heating of
the rolls and strip. The cold-reduction process work hardens the strip, requiring it to be
subsequently annealed.
Annealing
There are two basic types of annealing operations for cold-reduced strip: batch
annealing and continuous annealing. In batch annealing (“BA” in figure I-4), the coiled strips are
placed in a sealed container and slowly heated to, and cooled from, a subcritical temperature
to soften the steel and to relieve stresses produced during rolling. A relatively bright surface
finish is attained, and oxidation is reduced by the introduction of an inert or slightly reducing
gas into the container during the operation. Batch annealing produces a steel product with
greater flexibility. Continuous annealing (“CA” in figure I-4) is accomplished by passing the cold-
reduced strip through a series of vertical passes within a furnace consisting of heating, soaking,
and cooling zones. Continuous annealing results in a steel product with less flexibility than
batch-annealed steel. The strip is heated rapidly to the desired temperature and cooled before
leaving the furnace.
Temper rolling
After annealing, single-reduced strip is rolled in one or more passes through a temper
mill (“SR” in figure I-4). The object of temper rolling is to improve mechanical and surface
properties by imparting the desire degree of stiffness and hardness, minimizing fluting and
stretcher straining, and producing the desired surface type or texture.

I-37
Additional cold reduction
Double-reduced strip (“DR” in figure I-4) is typically not temper rolled; instead, it is
subjected to a second cold-reduction process after annealing to impart mechanical and surface
properties to the steel. This reduction is accomplished by passing the strip through either a
single or a series of rollers, using a suitable lubricant. This second cold reduction supplies the
final thickness and finish and the desired stiffness, strength, and flatness and produces a
stronger, lighter weight product. After final reduction, the coils are ready to be trimmed and
sheared, which occurs in a series of operations. Because this “black plate” is highly susceptible
to rusting in storage and transportation, it is typically oiled, or chemically treated and then
oiled, after cold reduction. The oil is then removed prior to coating.82
Coating
The continuous electroplating process has replaced the hot-dip process worldwide.
Advantages of the electroplating include a high degree of coating thickness control, differential
coating thicknesses on each side of a steel substrate, higher output rates, superior coating
quality, and lower production costs. Further, improvements to both plating technology and
steel chemistry allowed for reductions to the steel base and tin coating, with the latter ranging
from 0.1 to 1.5 micrometers (microns), depending upon the end use application.83 In the
continuous electroplating process, the temper-rolled or double-reduced coiled strip is loaded
onto one of the two uncoilers required for continuous operations. To allow successive coils to
be held stationary for welding together the trailing and leading ends without shutting down the
entire coating line, adjustable entry and exit looping towers (or accumulators) that can hold
varying lengths of uncoiled strip, often up to 600 meters (1,968 feet) (figure I-5).84 To plate each
side in succession, the strip passes through either a series of vertical plating cells or thorough
82 According to counsel for the Japanese respondent interested parties in the third review, tin
product mills typically have greater capacity for producing black plate than tin mill steel products, not
only to accommodate production yield losses, but also for sale as tin mill black plate to another tin mill
facility or to other manufacturers.
83 ITRI Ltd., “Electrolytic Tinning,” Guide to Tinplate, August 2019, p. 14,
https://www.tinplategroup.com/wp-content/uploads/2019/08/Guide-toTinplate.pdf; and Satyendra
Kumar Sarna, “Tinplate and Process of Tinning,” ISPAT Guru, June 22, 2019,
https://www.ispatguru.com/tinplate-and-process-of-tinning/.
84 Modern electroplating lines also include side trimmers to cut the strip to the desired width and
tension (or stretch) levelers that apply controlled tension across the strip to remove distortions.
Satyendra Kumar Sarna, “Tinplate and Process of Tinning,” ISPAT Guru, June 22, 2019,
https://www.ispatguru.com/tinplate-and-process-of-tinning/.

I-38
lower and upper horizontal plating units.85 Individual plating cells are arranged in tandem
plating cells and contain the plating solution, either a stannous tin (Sn +2 ) sulphonic acid or
halogen solution for tinplate, or a chromate chromic acid solution for chromium-coated steel
sheet. A conductor roll at the end of each cell rides along the top surface of the strip and serves
as the cathode, while the tin- or chromium-coating material is deposited in the bottom of each
cell and serves as the anode. The coating material dissolves into the plating solution and is
electrochemically deposited on the steel substrate. The electroplating process is followed by
rinsing, drying, quenching, and applying a lubricating film.
Figure I-5
TCCSS: Continuous electroplating process flow diagram
Source: Satyendra Kumar Sarna, “Tinplate and Process of Tinning,” ISPAT Guru, June 22, 2019,
https://www.ispatguru.com/tinplate-and-process-of-tinning/.
85 For more details, see, e.g., H. López, A. M. López, G. Ojea, I. Machón, N. de Abajo, and V. Torre,
“Control of Coating Thickness in a Tinplate Line,” 15th International Federation of Automatic Control
(“IFAC”) Proceedings, vol. 35, issue 1, 2002, p. 161,
https://www.sciencedirect.com/science/article/pii/S1474667015395999; World of Steel, “Electrolytic
Tinning Process,” no date, https://www.worldofsteel.com/pages/electrolytic-tinning-process/, retrieved
February 13, 2024; ITRI Ltd., “Electrolytic Tinning,” Guide to Tinplate, August 2019, p. 14,
https://www.tinplategroup.com/wp-content/uploads/2019/08/Guide-toTinplate.pdf; and Satyendra
Kumar Sarna, “Tinplate and Process of Tinning,” ISPAT Guru, June 229, 2019,
https://www.ispatguru.com/tinplate-and-process-of-tinning/.

I-39
Tinplate and chromium-coated steel sheet are produced in varying coating weights and
can be differentially coated on opposite sides, where the heavier coated surface is employed as
the more protected inside of containers.86 Most producers that manufacture both tinplate and
chromium-coated steel sheet do so in the same mill, but on different coating lines. Although
the coating process is similar for both tinplate and chromium-coated steel sheet, it is
impractical to shift product to another production line because of the expense that would be
involved in retrofitting the production line. The Japanese respondents apply the resin film to
out-of-scope laminated TFS on a separate coating line in a subsequent production step after the
tin-free coating line.87
After coating, the coiled sheets are further processed, typically by the can
manufacturers (the end users) and in a location close to the packing facility. Here the coil may
be cut into sheets or slit into several coils of narrow width and decorated by applying lacquer to
either one or both sides, before being sliced into can bodies and welded into a can.
86 The coating thickness is controlled by both the line speed through and electrical current flow
(amperage) within the plating cells. H. López, A. M. López, G. Ojea, I. Machón, N. de Abajo, and V. Torre,
“Control of Coating Thickness in a Tinplate Line,” 15th International Federation of Automatic Control
(“IFAC”) Proceedings, vol. 35, issue 1, 2002, p. 161,
https://www.sciencedirect.com/science/article/pii/S1474667015395999.
87 Japanese respondents’ prehearing brief, March 28, 2024, pp. 39–40. According to a witness for
Crown, producing laminated TFS is more labor-intensive and technically advanced than standard TCCSS
products. Hearing transcript, April 9, 2024, p. 102 (Hughes).

I-40
Domestic like product issues
In its original determination and its full first, second, and third five-year review
determinations, the Commission defined the domestic like product as TCCSS corresponding to
Commerce’s definition of the scope.88 In its notice of institution in this current five-year review,
the Commission solicited comments from interested parties regarding the appropriate
domestic like product and domestic industry.89 Domestic interested parties Cleveland-Cliffs and
U.S. Steel commented on the Commission’s definition of the domestic like product and both
indicated that they agreed with the Commission’s previous definitions of the domestic like
product.90 Japanese respondent interested parties JFE Steel, Nippon Steel, and Toyo Kohan also
commented on the Commission’s definition of the domestic like product and all stated that
they do not take a position on the definition of the domestic like product.91 No party requested
that the Commission collect data concerning other possible domestic like products in their
comments on the Commission’s draft questionnaires.92
88 Original publication, p. 5; first review publication, p. 6; second review publication, p. 6.; and third
review publication, p. 6.
89 88 FR 35920, June 1, 2023.
90 Cleveland-Cliffs’ response to the notice of institution, July 3, 2023, p. 40; Cleveland-Cliffs’
prehearing brief, March 28, 2024, pp. 13-15; U.S. Steel’s response to the notice of institution, July 7,
2023, pp. 21-22; U.S. Steel’s prehearing brief, March 28, 2024, pp. 4-6.
91 JFE Steel’s response to the notice of institution, June 30, 2023, p. 10; Nippon Steel’s response to
the notice of institution, July 3, 2023, p. 16; Toyo Kohan’s response to the notice of institution, July 3,
2023, p. 6.
92 See generally Cleveland-Cliff’s comments on draft questionnaires, December 11, 2023; U.S. Steel’s
comments on draft questionnaires, December 11, 2023; and Nippon Steel and Toyo Kohan’s joint
comments on draft questionnaires, December 11, 2023. JFE Steel did not provide comments on the draft
questionnaires.

I-41
U.S. market participants
U.S. producers
During the final phase of the original investigation, the Commission received U.S.
producer questionnaires from seven firms, which accounted for all known U.S. production of
TCCSS in the United States during 1999.93 During the first five-year review, the Commission
received U.S. producer questionnaires from four firms, which accounted for all known
production of TCCSS in the United States during 2005.94 During the second five-year review, the
Commission received U.S. producer questionnaires from five firms, which accounted for all
known production of TCCSS in the United States during 2011.95 During the third five-year
review, the Commission received U.S. producer questionnaires from four firms, which
accounted for all known production of TCCSS in the United States during 2016.96
In this current fourth five-year review, the Commission issued U.S. producers’
questionnaires to three firms. The Commission received usable questionnaires from all three
firms, which accounted for all known U.S. production of TCCSS in 2023.97 Table I-8 presents a
list of the current domestic producers of product and each company’s position on continuation
of the order, production locations, and share of reported production of TCCSS in 2023.
Table I-8
TCCSS: U.S. producers, positions on the order, U.S. production location, and shares of reported
U.S. production, 2023
Share in percent
Firm 	Position on order 	Production locations 	Share of production
Cleveland-Cliffs 	*** 	Weirton, WV 	***
Ohio Coatings 	*** 	Yorkville, OH 	***
U.S. Steel 	***
Gary, IN; 	Portage, IN;
East Chicago, IN; 	Pittsburg, CA 	***
All firms 	Various 	Various 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Table I-9 presents U.S. producers’ reported affiliations and relationships to firms
engaged in the production of TCCSS or engaged in the exportation/importation of TCCSS into
the United States.
93 Original publication, p. III-1.
94 First review publication, pp. I-12 and I-21.
95 Second review publication, pp. I-11-I-12.
96 Third review publication, p. I-12.
97 On April 20, 2024, Cleveland-Cliffs permanently idled its TCCSS operations at its Weirton, West
Virginia plant. See Part III of this report for more information.

I-42
Table I-9
TCCSS: U.S. producers’ ownership, related and/or affiliated firms
Reporting firm 	Relationship type and related firm 	Details of relationship
*** 	*** 	***
*** 	*** 	***
*** 	*** 	***
*** 	*** 	***
*** 	*** 	***
*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
U.S. Steel is related to U.S. Steel Kosice, a TCCSS producer in Slovakia,98 and in 2020 it
acquired USS-UPI, a TCCSS producer in the United States.99 U.S. Steel has announced plans to
merge with Nippon Steel, a TCCSS producer in Japan, pending U.S. governmental regulatory
approval.100 Ohio Coatings is a 50-50 joint venture owned by Esmark, Inc., a steel holdings
company, and TCC Steel, a TCCSS producer in South Korea.101 Ohio Coatings is also related to
Nippon Steel Trading Americas, Inc., a U.S. importer of TCCSS ***.102
Historical overview of the U.S. TCCSS industry
Table I-10 presents a chronological overview of the U.S. TCCSS industry, including
current and past producers, their production facilities, and operational status since imposition
of the antidumping duty order on TCCSS from Japan in 2000.
98 U.S. Steel Kosice, “About Us,” retrieved March 1, 2024, https://www.usske.sk/en/about-
us/corporation-u-s-steel; U.S. Steel Kosice, “Tin Mill,” retrieved March 1, 2023,
https://www.usske.sk/en/products/tin-mill.
99 U.S. Steel, “U.S. Steel Acquires Remaining 50 Percent Ownership Interest in USS-POSCO Industries
(UPI) from POSCO-California Corporation,” March 1, 2020, https://www.globenewswire.com/news-
release/2020/03/01/1993067/0/en/U-S-Steel-Acquires-Remaining-50-Percent-Ownership-Interest-in-
USS-POSCO-Industries-UPI-From-POSCO-California-Corporation.html.
100 U.S. Steel, “U. S. Steel Stockholders Approve Transaction with Nippon Steel Corporation (NSC),”
April 12, 2024, https://investors.ussteel.com/news-events/news-releases/detail/673/u-s-steel-
stockholders-approve-transaction-with-nippon.
101 Samuel Spatter, “Esmark Inc. Buys Ohio Steel Plant,” TRIB Live, October 12, 2012,
https://archive.triblive.com/business/local-stories/esmark-inc-buys-ohio-steel-plant/.
102 For a historical perspective on this relationship, Wheeling-Pittsburgh reported on p. 10 of its SEC
Form 10-K Report for Fiscal Year Ending December 31, 2006, that Nippon Steel Trading Americas, Inc.
holds nonvoting preferred stock in Ohio Coatings. Wheeling-Pittsburgh, SEC Form 10-K Report for Fiscal
Year Ending December 31, 2006, March 20, 2007,
https://www.sec.gov/Archives/edgar/data/941738/000095015207002330/l24082ae10vk.htm.

I-43
Table I-10
TCCSS: Historical overview of the U.S. TCCSS industry since January 1, 2000
Facility
(current status) 2000–03 	2004–07
Aliquippa, PA
(U.S. Steel, closed)
LTV Corp. bankruptcy filing (December
2000).
U.S. Steel facility acquisition (March
2001); facility closure (late-2001).
Closed facility.
East Chicago, IN
(U.S. Steel, closed)
LTV bankruptcy filing (December 2000).
U.S. Steel facility acquisition (March
2001).
U.S. Steel operating facility.
Fairless Hills, PA
(U.S. Steel, closed)
U.S. Steel facility closure (late-2001). 	Closed facility.
Gary, IN
(U.S. Steel,
indefinitely idled)
U.S. Steel operating facility. 	U.S. Steel operating facility.
Pittsburg, CA
(U.S. Steel,
indefinitely idled)
USS-POSCO Industries ("UPI")
operating facility, as a joint venture
between U.S. Steel and POSCO (South
Korea).
UPI operating joint-venture facility.
Portage (Midwest), IN
(U.S. Steel,
operating)
National Steel Corp. ("National")
bankruptcy filing (March 2002).
U.S. Steel facility acquisition (May 2003).
U.S. Steel operating facility.
Sparrows Point, MD
(RG Steel, closed)
Bethlehem Steel Corp. ("Bethlehem")
bankruptcy filing (October 2001.
International Steel Group ("ISG") facility
acquisition (May 2003).
Mittal Steel NV ("Mittal") acquisition
of ISG (April 2005);
Mittal shuts down the chromium-
coating line but continues operating
the tin plating line (October 2005).
ArcelorMittal S.A. formed from
Mittal's acquisition of Arcelor S.A.,
but U.S. regulators required
divestiture of the Dofasco (Canada),
Sparrows Point, MD, or Weirton, WV,
facility (June 2006).
Weirton, WV
(Cleveland-Cliffs,
indefinitely idled)
Weirton Steel Corp. ("Weirton")
bankruptcy filing (May 2003).
ISG facility acquisition (May 2004).
Mittal acquisition of ISG (April 2005).
Mittal shuts down steelmaking (early-
2006).
ArcelorMittal S.A. formed from Mittal
Steel's acquisition of Arcelor S.A.
(June 2006).
ArcelorMittal shuts down hot-rolling
operations but continued tinplate
production (December 2007).
Yorkville, OH
(Esmark and TCC
Steel joint venture,
operating)
Ohio Coatings Co. operating joint-
venture facility of Wheeling-Pittsburgh
Corp. and Dongyang Tinplate Co. Ltd.
("Dongyang," South Korea).
TCC Steel Co. Ltd. is the new name for
Dongyang (March 2003).
Wheeling-Pittsburgh bankruptcy filing
(November 2000); and emergence from
bankruptcy protection (August 2003).
Ohio Coatings operating joint-venture
facility.
Esmark Inc. acquisition of Wheeling-
Pittsburgh (December 2006),
completed (July 2007).
Table continued.

I-44
Table I-10 Continued
TCCSS: Historical overview of the U.S. TCCSS industry since January 1, 2000
Facility
(current status) 2008–11 	2012–15
Aliquippa, PA
(U.S. Steel, closed)
Closed facility. 	Closed facility.
East Chicago, IN
(U.S. Steel, closed)
U.S. Steel operating facility. 	U.S. Steel announced temporarily idling
of tin mill operations (March 2015).
Fairless Hills, PA
(U.S. Steel, closed)
Closed facility. 	Closed facility.
Gary, IN
(U.S. Steel,
indefinitely idled)
U.S. Steel operating facility. 	U.S. Steel operating facility.
Pittsburg, CA
(U.S. Steel,
indefinitely idled)
UPI operating joint-venture facility. 	UPI operating joint-venture facility.
Portage (Midwest), IN
(U.S. Steel,
operating)
U.S. Steel operating facility. 	U.S. Steel operating facility.
Sparrows Point, MD
(RG Steel, closed)
Severstal Holdings LLC facility
acquisition ("Severstal," May 2008).
RG Steel Corp. LLC acquisition of
Severstal’s U.S. facilities (March
2011); temporary operations
shutdown due to fire (October 2011);
steelmaking and hot-rolling operations
shut down, reportedly to conserve
cash (December 2011).
RG Steel resumed production operations
after receiving a cash infusion from
equity firm Cerberus Capital
Management LP (January 2012);
production operations idled (April 2012);
bankruptcy filing shuts down facility (May
2012).
Closed facility site sold to Sparrows
Point Terminal for redevelopment into an
industrial business park (September
2014).
Weirton, WV
(Cleveland-Cliffs,
indefinitely idled)
ArcelorMittal operating facility. 	ArcelorMittal operating facility.
Yorkville, OH
(Esmark and TCC
Steel joint venture,
operating)
Ohio Coatings operating joint-venture
facility.
Severstahl acquisition of Esmark
(August 2008).
RG Steel acquisition of Severstal's
joint-venture share (March 2011).
RG Steel bankruptcy filing idled tin mill
operations (May 2012).
Esmark joint-venture share re-
acquisition (October 2012) with plans to
restart tin mill operations (in January
2013).
Table continued.

I-45
Table I-10 Continued
TCCSS: Historical overview of the U.S. TCCSS industry since January 1, 2000
Facility
(current status) 2016–19 	2020 onward
Aliquippa, PA
(U.S. Steel, closed)
Closed facility. 	Closed facility.
East Chicago, IN
(U.S. Steel, closed)
U.S. Steel resumed production
operations citing improved market
conditions (June 2016).
U.S. Steel indefinitely idled tin mill
operations (by mid-November 2019).
U.S. Steel permanently closed tin mill
operations (March 2022). Tin mill
operations shifted to the Portage and
Gary facilities.
Fairless Hills, PA
(U.S. Steel, closed)
Closed facility. 	Closed facility.
Gary, IN
(U.S. Steel,
indefinitely idled)
U.S. Steel announced capital
investments for facility revitalization
including tin mill operations (August
2018).
U.S. Steel idled one tin mill line (August
2022) and finally indefinitely idled most
tin mill operations (December 2022).
Pittsburg, CA
(U.S. Steel,
indefinitely idled)
UPI operating joint-venture facility. 	U.S. Steel acquired full ownership of UPI
from former joint-venture partner POSCO
(February 2020);
UPI final facility indefinite idling
(December 2023).
Portage (Midwest), IN
(U.S. Steel,
operating)
U.S. Steel completed repairs and
restarted chromium-coating
operations after a process release of
hexavalent chromium (April 2017).
U.S. Steel operating facility.
Sparrows Point, MD
(RG Steel, closed)
Closed facility. 	Closed facility.
Weirton, WV
(Cleveland-Cliffs,
indefinitely idled)
ArcelorMittal sold-off 1,100 acres of
unused facility property to Frontier
Group for industrial redevelopment
and stated that tin mill operations will
continue (February 2017).
Cleveland-Cliffs Inc. facility acquisition
(December 2020), announced plans to
idle the facility (February 2024), with all
operations ceased and the facility
indefinitely idled (mid-late April 2024).
Yorkville, OH
(Esmark and TCC
Steel joint venture,
operating)
Ohio Coatings operating joint-venture
facility.
Ohio Coatings operating joint-venture
facility.
Table continued.

I-46
Table I-10 Continued
TCCSS: Historical overview of the U.S. TCCSS industry since January 1, 2000
Source: Tin and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Third Review), USITC
Publication 4795, June 2018, pp. III-1 – III-6; Inv. No. 731-TA-860 (Second Review), USITC Publication
4325, May 2012, pp. I-19 – I-21, III-1 – III-2; Inv. No. 731-TA-860 (Review), USITC Publication 3860,
June 2006, pp. I-21 – I-24; Inv. No. 731 -TA-860 (Final), USITC Publication 3337, August 2000, pp. III-1 –
III-2; TCC, "TCC Steel Looks Forward to Celebrating the Centennial Anniversary," ©2019,
https://www.tccsteel.com/en/company/message, retrieved February 27, 2024; TCC, "History, 1992–2009,"
©2019, https://www.tccsteel.com/en/company/history/11/3 , retrieved February 27, 2024; Goldman
Sachs, "Goldman Sachs Advises Mittal Steel on Historic Acquisition of Arcelor SA," ©2024,
https://www.goldmansachs.com/our-firm/history/moments/2006-arcelor-mittal.html, retrieved February 27,
2024; Samuel Spatter, "Esmark Inc. Buys Ohio Steel Plant," TRIB Live, October 12, 2012,
https://archive.triblive.com/business/local-stories/esmark-inc-buys-ohio-steel-plant/;
Len Boselovic, "Steel Company Esmark Restarting Ohio Plant," Pittsburgh Post-Gazette, October 13,
2012, https://www.esmarksteelgroup.com/esg/steel-company-esmark-restarting-ohio-plant/;
Wheeling-Pittsburgh, SEC Form 10-K Report for Fiscal Year Ending December 31, 2006, March 20,
2007, https://www.sec.gov/Archives/edgar/data/941738/000095015207002330/l24082ae10vk.htm;
Caroline Humer, "Esmark Plans for Wheeling-Pittsburgh, Reuters, August 9, 2007,
https://www.reuters.com/article/specialeventii-mining-summit-esmark-dc/esmark-plans-for-wheeling-
pittsburgh-idUKN2242618820070522/;
Severstal, "Severstal Completes Acquisition of Esmark Incorporated," August 5, 2008,
https://www.sec.gov/Archives/edgar/data/1392600/000104746908008717/a2187205zex-99_a5h.htm;
PR Newswire, "RG Steel Completes Purchase of Three Steel Companies With Capacity of 7.5 Million
Tons," March 31, 2011, https://www.prnewswire.com/news-releases/rg-steel-completes-purchase-of-
three-steel-companies-with-capacity-of-75-million-tons-119026734.html;
Craig Howell, “Cleveland Cliffs in Weirton Idled,” The Marietta Times (Marietta, Ohio), April 22, 2024,
https://www.mariettatimes.com/news/local-news/2024/04/cleveland-cliffs-in-weirton-idled/;
*** questionnaire response, Attachment D.
Cleveland-Cliffs, prehearing brief, March 28, 2024, pp. 1–2, exhs. 1, 4;
U.S. Steel, prehearing brief, March 28, 2024, pp, 11–12, exh. 1;
Japanese respondents’ prehearing brief, March 28, 2024, p. 9, exh. 6;
Hearing transcript, April 9, 2024, pp. 18 (Kopf), 23, 25–27 (Smith).
Note: The current status for each facility in the first column includes the current or last corporate owner(s)
and current or last operating, idled, or closure status.

I-47
U.S. importers
During the final phase of the original investigation, the Commission received usable data
from 18 firms representing virtually 100 percent of imports of TCCSS from Japan.103 During the
first five-year review, the Commission received useable data from 27 firms, which accounted
for virtually all imports of TCCSS from Japan during 2000-05.104 During the second five-year
review, the Commission received U.S. importer questionnaires from 21 firms, which accounted
for virtually all imports of TCCSS from Japan during 2011.105 During the third five-year review,
the Commission received U.S. importer questionnaires from 10 firms, which accounted for
approximately 60 percent of U.S. imports of TCCSS during 2016.106
In the current proceeding, the Commission issued an importer questionnaire to 29 firms
believed to be U.S. importers of TCCSS. The Commission received 21 questionnaire responses
from firms which import TCCSS into the United States, as well as five questionnaire responses
from firms which import excluded tin mill products.107 The responding firms’ imports accounted
for the vast majority of TCCSS imports from Japan and all other sources in 2023. Table I-11 lists
all responding U.S. importers of TCCSS from Japan and other sources, their headquarters, and
their shares of U.S. imports in 2023.
103 Original publication, pp. I-1 and IV-1.
104 First review publication, pp. I-12 fn. 61 and I-24.
105 Second review publication, p. I-12.
106 Third review publication, pp. I-12 and IV-1.
107 These five firms included: ***. Since these firms reported that they only imported excluded tin
mill products they are not presented in the U.S. importers table below.

I-48
Table I-11
TCCSS: U.S. importers, their headquarters, and share of imports within each source, 2023
Share in percent
Firm 	Headquarters 	Japan
Nonsubject
sources
All import
sources
ArcelorMittal Dofasco 	Hamilton, Canada 	*** 	*** 	***
Arcelormittal International 	Chicago, IL 	*** 	*** 	***
CCA 	Blandon, PA 	*** 	*** 	***
CSN 	Chicago, IL 	*** 	*** 	***
Duferco Steel 	Houston, TX 	*** 	*** 	***
EP Steel 	South River, NJ 	*** 	*** 	***
JFE Shoji America 	Long Beach, CA 	*** 	*** 	***
Kemeny 	Fort Myers, FL 	*** 	*** 	***
KG Steel Americas 	Fountain Valley, CA 	*** 	*** 	***
Lakeside Metals 	Willowbrook, IL 	*** 	*** 	***
Metal One 	Rosemont, IL 	*** 	*** 	***
Nippon Steel Americas 	Schaumburg, IL 	*** 	*** 	***
Reynolds Services 	Greenville, PA 	*** 	*** 	***
Songlin 	Buena Park, CA 	*** 	*** 	***
Tata International 	Schaumburg, IL 	*** 	*** 	***
Tata Steel Ijmuiden 	Ijmuiden, Netherlands 	*** 	*** 	***
Tata Steel UK 	London, England 	*** 	*** 	***
TCC America 	Torrance, CA 	*** 	*** 	***
Titan 	Baltimore, MD 	*** 	*** 	***
TKSNA 	Southfield, MI 	*** 	*** 	***
Trivium 	Rosemont, IL 	*** 	*** 	***
All firms 	Various 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

I-49
U.S. purchasers
The Commission received 22 usable questionnaire responses from firms that have
purchased TCCSS since January 1, 2017.108 109 Twelve purchasers are can producers, two are
other end users (***), four are distributors, and five reported being other types of users
(including food processor, trader, and steel processor).110 The largest responding purchasers
were ***.
108 The following firms provided purchaser questionnaire responses: ***.
109 Of the 22 responding purchasers, 17 purchased the domestic product, one (***) purchased
imports of the subject merchandise from Japan, and 18 purchased imports of TCCSS from other sources.
110 Some firms reported more than one role.

I-50
Apparent U.S. consumption and market shares
Quantity
Table I-12 and figure I-6 present data by quantity on apparent U.S. consumption and
U.S. market shares for TCCSS during 2021-23. The quantity of apparent U.S. consumption
declined by 6.9 percent between 2021 and 2022 and by 18.6 percent between 2022 and 2023.
U.S. producers’ U.S. shipments decreased by *** percent from *** short tons in 2021 to ***
short tons in 2023. Importers’ U.S. shipments of TCCSS from Japan increased from *** short
tons in 2021 to *** short tons in 2022 to *** short tons in 2023. However, the market share of
these shipments was *** percent in each calendar year. Importers’ U.S. shipments of TCCSS
from nonsubject sources were *** short tons in 2021, *** short tons in 2022, and *** short
tons in 2023.
Table I-12
TCCSS: Apparent U.S. consumption and market shares based on quantity, by period and source
Quantity in short tons; shares in percent
Source 	Measure 	2021 	2022 	2023
U.S. producers 	Quantity 	*** 	*** 	***
Japan 	Quantity 	*** 	*** 	***
Nonsubject sources 	Quantity 	*** 	*** 	***
All import sources 	Quantity 	*** 	*** 	***
All sources 	Quantity 	2,494,413 	2,322,143 	1,889,860
U.S. producers 	Share 	*** 	*** 	***
Japan 	Share 	*** 	*** 	***
Nonsubject sources 	Share 	*** 	*** 	***
All import sources 	Share 	*** 	*** 	***
All sources 	Share 	100.0 	100.0 	100.0
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

I-51
Figure I-6
TCCSS: Apparent U.S. consumption based on quantity, by period and source
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires.

I-52
Value
Table I-13 and figure I-7 present data by value on apparent U.S. consumption and U.S.
market shares for TCCSS during 2021-23. The value of apparent U.S. consumption increased
sharply between 2021 and 2022, then decreased in 2023. The value of U.S. producers’ U.S.
shipment of TCCSS decreased irregularly by *** percent during 2021-23, starting at $*** in
2021 then increasing to $*** in 2022 before decreasing to $*** in 2023. Conversely, importers’
U.S. shipments of TCCSS from Japan and nonsubject sources increased. Importers’ U.S.
shipments of TCCSS from Japan were *** in 2021 before rising to $*** in 2022 and to $*** in
2023. Importers’ U.S. shipments of TCCSS from nonsubject sources increased irregularly by ***
percent during 2021-23 from $*** in 2021 to $*** in 2022 then decreasing to $*** in 2023.
Table I-13
TCCSS: Apparent U.S. consumption and market shares based on value, by period and source
Value in 1,000 dollars; shares in percent
Source 	Measure 	2021 	2022 	2023
U.S. producers 	Value 	*** 	*** 	***
Japan 	Value 	*** 	*** 	***
Nonsubject sources 	Value 	*** 	*** 	***
All import sources 	Value 	*** 	*** 	***
All sources 	Value 	2,907,642 	4,705,717 	3,478,681
U.S. producers 	Share of value 	*** 	*** 	***
Japan 	Share of value 	*** 	*** 	***
Nonsubject sources 	Share of value 	*** 	*** 	***
All import sources 	Share of value 	*** 	*** 	***
All sources 	Share of value 	100.0 	100.0 	100.0
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

I-53
Figure I-7
TCCSS: Apparent U.S. consumption based on value, by period and source
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires.

II-1
Part II: Conditions of competition in the U.S. market
U.S. market characteristics
TCCSS is a component in the manufacturing of containers, especially cans. The largest
use for TCCSS is for food cans, both household and for restaurants, but also for cans used for
aerosol sprays and paint. TCCSS faces competition from substitute materials as well as pressure
from can manufacturers to reduce the weight of tin mill products used per container.1
All 3 U.S. producers, 7 of 22 importers, and 11 of 21 responding purchasers indicated
that the market was subject to distinctive conditions of competition other than business cycles.
Responses from all three groups identified competition from substitute products (e.g.,
aluminum, paper, glass, and plastic packaging) as contributing to the distinctive competitive
conditions. Importer *** reported other steel products, such as cold-rolled, hot-dipped
galvanized, and electro-galvanized steel can often be used as substitutes in some TCCSS
applications, which leads to demand shifts in certain markets and/or applications.
Two purchasers reported section 232 measures as having a distinct impact on the
market, with *** indicating the unique impacts from section 232 measures resulted from the
limited number of suppliers of TCCSS in the domestic market. Three purchasers reported the
links between TCCSS and can manufacturing. For example, *** reported increased tinplate and
can manufacturing costs has led to a “dramatic increase” in imports of food-filled cans.
The TCCSS market was supplied by U.S. producers and by imports from nonsubject
sources during 2021 through 2023. Imports of TCCSS from Japan, in contrast, were limited
during these years. The quantity of apparent U.S. consumption of TCCSS decreased in 2022
(from 2.5 million to 2.3 million short tons) and, more sharply, in 2023 (from 2.3 million to 1.9
million short tons). Overall, apparent U.S. consumption in 2023 was 24.2 percent lower than in
2021 in terms of quantity.
Impact of section 301 tariffs and section 232 measures
Firms were asked to report the impact of section 301 tariffs on Chinese-origin products
on the TCCSS market in the United States, including effects on TCCSS cost, price, supply, and
demand. Two of three U.S. producers, 4 of 23 importers, and 5 of 22 purchasers reported that
1 Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-685 and 731-TA-
1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, p. II-1.

II-2
the section 301 tariffs had an impact on the U.S. TCCSS market; five importers, four purchasers,
and three foreign producers reported the section 301 tariffs did not have an impact; and 1 U.S.
producer, 14 importers, and 13 purchasers did not know.
Firms were also asked to report the impact of the section 232 measures on steel and
aluminum on the U.S. TCCSS market on overall demand, supply, prices and raw material costs
(table II-1). All three U.S. producers, 16 of 23 importers, and 15 of 22 purchasers reported that
the section 232 measures had an impact on impact the TCCSS market in the United States. The
majority of responding firms reported there was no change in overall demand in the TCCSS
market due to the section 232 measures; those that did report a change in overall U.S. demand
reported factors other than the section 232 measures as causing that change.2
U.S. producers reported that domestic and imported supply of TCCSS fluctuated but
were mixed as to whether supply fluctuated up or down during 2017-23. U.S. producer ***
reported that the section 232 measures are not sufficient to prevent further harm, given the
lack of orders seen at its *** facility.3 Most importers reported that there was no change in
domestic supply due to the section 232 measures and that import supply either declined
steadily or fluctuated down. Importer/purchaser *** reported that it had hoped the measures
would result in increased investments and capacity by U.S. producers, but the opposite
occurred. It continued that there was no change in the aggregate supply of imports, though the
sources shifted depending on section 232 exclusions, exemptions, and quotas. Most purchasers
also reported that there was no change in domestic supply due to the section 232 measures,
but most also reported no change in the supply of TCCSS imports.
2 These factors are discussed below in “Demand trends”.
3 ***. The Commission received responses to its questionnaires for this proceeding prior to ***
announcement regarding ***. ***.

II-3
Table II-1
TCCSS: Count of firms' responses regarding the impact of the 232 measures on steel and
aluminum imports
Impact on 	Firm type
Steadily
increase
Fluctuate
up 	No change
Fluctuate
down
Steadily
decrease
Demand 	U.S. producers 	0 	0 	2 	0 	0
Demand 	Importers 	1 	2 	8 	4 	1
Demand 	Purchasers 	0 	2 	10 	2 	0
Domestic supply 	U.S. producers 	0 	1 	0 	1 	0
Domestic supply 	Importers 	1 	3 	9 	1 	2
Domestic supply 	Purchasers 	1 	0 	9 	2 	2
Imported supply 	U.S. producers 	0 	1 	0 	1 	0
Imported supply 	Importers 	1 	2 	4 	6 	3
Imported supply 	Purchasers 	1 	5 	8 	0 	0
Prices 	U.S. producers 	0 	1 	0 	1 	0
Prices 	Importers 	6 	10 	0 	1 	0
Prices 	Purchasers 	5 	8 	2 	0 	0
Raw material cost 	U.S. producers 	0 	0 	1 	1 	0
Raw material cost 	Importers 	4 	4 	7 	0 	0
Raw material cost 	Purchasers 	3 	4 	7 	0 	0
Source: Compiled from data submitted in response to Commission questionnaires.
Most firms (one U.S. producer, 10 importers, and 8 purchasers) reported that prices
fluctuated upward, while an additional 6 importers and 5 purchasers reported that prices
steadily increased. Several purchasers reported increased prices as the result of section 232
measures. U.S. importer/purchaser *** and purchaser *** reported that market prices
increased approximately by the tariff percent. *** and U.S. importer/purchaser *** reported
that U.S. producers did not boost production/increase capacity after the section 232 measures
went into effect. U.S. producer *** reported that section 232 measures resulted in a sharp
increase in prices for TCCSS during 2021-22, but that prices fell in subsequent years.
With respect to raw materials, *** also reported 232 measures “significantly limited” its
ability to source *** from offshore sources but did not link this impact to specific price effects.
Separately, purchaser *** reported that the section 232 measures allowed Cleveland-Cliffs and
U.S. Steel to effectively choke supply to Ohio Coatings, which requires black plate to make
TCCSS, and that Cleveland-Cliffs reportedly refused to sell Ohio Coatings the substrate and that
U.S. Steel only sold a fraction of the total volume Ohio Coatings could consume. It also noted
that Ohio Coatings’ efforts to source black plate offshore were severely hampered by the
section 232 tariffs including efforts by Weirton (Cleveland-Cliffs’) and U.S. Steel to contest Ohio
Coatings’ applications for exclusions. Relatedly, U.S.

II-4
producer *** reported that “black plate seems to be readily available if the buyer is willing to
pay a market-based price.”4
One foreign producer, *** reported that the section 232 measures impacted its exports
to the United States, stating that even though Japanese producers shifted focus to other
markets following the antidumping orders, the section 232 measures further reduced the
incentive for Japanese producers to increase exports of subject TCCSS to the United States.
Channels of distribution
U.S. producers and importers sold mainly to can manufacturers, as shown in table II-2.
Table II-2
TCCSS: Share of U.S. shipments by source, channel of distribution, and period
Shares in percent
Source 	Channel 	2021 	2022 	2023
United States 	Distributors 	*** 	*** 	***
United States 	Can manufacturers 	*** 	*** 	***
United States 	Other end users 	*** 	*** 	***
Japan 	Distributors 	*** 	*** 	***
Japan 	Can manufacturers 	*** 	*** 	***
Japan 	Other end users 	*** 	*** 	***
Nonsubject sources 	Distributors 	*** 	*** 	***
Nonsubject sources 	Can manufacturers 	*** 	*** 	***
Nonsubject sources 	Other end users 	*** 	*** 	***
All import sources 	Distributors 	*** 	*** 	***
All import sources 	Can manufacturers 	*** 	*** 	***
All import sources 	Other end users 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
4 ***. Cleveland-Cliffs’ posthearing brief, exhibit 1, p. 2.

II-5
Geographic distribution
U.S. producers reported selling TCCSS to all regions in the contiguous United States
(table II-3). For U.S. producers, *** percent of sales were within 100 miles of their production
facility, *** percent were between 101 and 1,000 miles, and *** percent were over 1,000
miles. Subject importers sold *** of their U.S. point of shipment.
Table II-3
TCCSS: Count of U.S. producers’ and U.S. importers’ geographic markets
Region 	U.S. producers 	Japan
Northeast 	3 	***
Midwest 	3 	***
Southeast 	3 	***
Central Southwest 	2 	***
Mountain 	1 	***
Pacific Coast 	3 	***
Other 	0 	***
All regions (except Other) 	1 	***
Reporting firms 	3 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Other U.S. markets include AK, HI, PR, and VI.
Supply and demand considerations
U.S. supply
Table II-4 provides a summary of the supply factors regarding TCCSS from U.S. producers
and Japan. While U.S. producers’ production capacity was *** than Japanese producers’,
Japanese capacity utilization rates were *** than U.S. producers’ during 2021-23.

II-6
Table II-4
TCCSS: Supply factors that affect the ability to increase shipments to the U.S. market, by country
Quantity in short tons; ratio and share in percent
Factor 	Measure 	United States 	Japan
Capacity 2021 	Quantity 	*** 	***
Capacity 2023 	Quantity 	*** 	***
Capacity utilization 2021 	Ratio 	*** 	***
Capacity utilization 2023 	Ratio 	*** 	***
Inventories to total shipments 2021 	Ratio 	*** 	***
Inventories to total shipments 2023 	Ratio 	*** 	***
Home market shipments 2023 	Share 	*** 	***
Non-US export market shipments 2023 	Share 	*** 	***
Ability to shift production 	Count 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Responding U.S. producers accounted for all of U.S. production of TCCSS in 2023. Responding
foreign producer/exporter firms accounted for all U.S. imports of TCCSS from Japan to the United States
during 2023. For additional data on the number of responding firms and their share of U.S. production
and of U.S. imports from Japan, please refer to Part I, “Summary Data and Data Sources.”
Note: *** when asked about the ability to shift production between TCCSS and other products using the
same equipment and labor.
Domestic production
Based on available capacity information, U.S. producers of TCCSS have the ability to
respond to changes in demand with moderate-to-large changes in the quantity of shipments of
U.S.-produced TCCSS to the U.S. market.5 The main contributing factors to this degree of
responsiveness of supply are the availability of unused capacity and elevated levels of
inventories. Factors mitigating responsiveness of supply include a limited ability to shift
shipments from export markets and no ability to shift production to or from alternate products.
5 On February 15, 2024, U.S. producer Cleveland-Cliffs announced that its facility in Weirton, West
Virginia will be indefinitely idled. The facility was indefinitely idled as of April 20, 2024. Cleveland Cliffs in
Weirton Idled, https://www.mariettatimes.com/news/local-news/2024/04/cleveland-cliffs-in-weirton-
idled/, retrieved April 22, 2024. This production location was responsible for *** percent of domestic
production in 2023 (table I-8). As a result of this event, there will likely be a decrease in the ability to
respond to changes in demand with changes in the quantity of shipments of U.S.-produced TCCSS to the
U.S. market. Cleveland-Cliffs has stated that the facility would reopen if there are “firm orders.” Hearing
transcript, p. 44 (Smith).

II-7
While U.S. capacity and production both decreased during 2021 to 2023,6 a larger
relative decline in production resulted in lower capacity utilization.7 U.S. producers’ U.S.
shipments decreased by *** percent from 2021 to 2023. The ratio of ending inventories to total
shipments increased by *** percentage points from 2021 to 2023. Exports comprised a very
small share of U.S. producer shipments (less than *** percent) throughout the period.
*** U.S. producers reported being unable to produce other products on the same
equipment used to product TCCSS. ***.8
Subject imports from Japan
Based on available information, producers of TCCSS from Japan have the ability to
respond to changes in demand with moderate-to-large changes in the quantity of shipments of
TCCSS to the U.S. market. The main contributing factors to this degree of responsiveness of
supply are the availability of some unused capacity, ability to shift shipments from alternate
markets, and ability to shift production to or from alternate products. Factors mitigating
responsiveness of supply include limited availability of inventories.
Japanese producers’ capacity and production declined at different rates between 2021
and 2023, leading to fluctuating but increased capacity utilization during the period. Japanese
producers shipped *** quantities to the United States; their major export markets during 2021-
23 were ***.9 Other products that responding foreign producers reportedly can produce on the
same equipment as TCCSS are laminated TFS, ***
6 In 2022, U.S. Steel indefinitely idled productions lines at its East Chicago Tin and Gary Works plants.
7 Capacity decreased by *** percent and production decreased by *** percent between 2021 and
2023.
8 ***.
9 As noted in Part IV and the hearing, Mexico has been the top export market of subject product from
Japan in recent years. Hearing transcript, p. 9 (Brunda).

II-8
***. Factors affecting foreign producers’ ability to shift production include profitability of other
products (i.e., film laminated steel has a higher profit margin), responsibility to supply regular
customers, and demand.
Imports from nonsubject sources
Nonsubject imports accounted for virtually all of U.S. imports in 2023. The largest
nonsubject sources of TCCSS were the Netherlands, Germany, and Canada. These three
countries accounted for 67.2 percent of the quantity of total U.S. imports of TCCSS in 2023.10
Changes in availability from subject and nonsubject sources
Most firms reported that there had not been changes in the availability of imports of
TCCSS from Japan since January 1, 2017, and most do not anticipate a change in the availability
of these imports. One U.S. producer, two importers, and three purchasers reported that there
were changes in the availability of subject imports between 2017 and 2020. One U.S. producer,
two importers, and three purchasers reported that there were changes to the availability of
subject imports between 2021 and 2023. No U.S. producers, one importer, and three
purchasers reported that they anticipate changes to the availability of subject imports. The few
firms reporting changes in availability cited the impact of section 232 measures, supply chain
issues, and the increase of specialized, out-of-scope laminated TFS imports.
Two U.S. producers, seven importers, and six purchasers reported that there were
changes in the availability of imports of TCCSS from nonsubject sources between 2017 and
2020. Some firms noted that there was new and increased capacity in Asia and Europe while
others reported that the availability of imports from nonsubject sources was impacted by the
section 232 measures and supply chain issues. Three U.S. producers, ten importers, and seven
purchasers reported that there were changes in the availability of nonsubject imports between
2021 and 2023. Firms again cited increased imports as firms became familiar with the section
232 measures and supply chain issues eased, while others reported that the then-ongoing
antidumping and countervailing duty investigation on tin mill products from Canada, China,
Germany, and South Korea impeded imports.11 One U.S. producer, eight importers, and five
10 Compiled from official U.S. import statistics of the U.S. Department of Commerce Census Bureau
using statistical reporting numbers 7210.11.0000, 7210.12.0000, 7210.50.0000, 7210.50.0020,
7210.50.0090, and 7212.10.0000, accessed February 22, 2024.
11 The original petition for that proceeding included four other countries: the Netherlands, Taiwan,
Turkey, and the United Kingdom—imports from those sources may have also been impacted.

II-9
purchasers reported that they anticipate changes to the availability of imports of TCCSS from
nonsubject sources.
New suppliers
Eight of 21 responding purchasers indicated that new suppliers entered the U.S. market
since January 1, 2017, and 5 expect additional entrants. Purchasers were generally uncertain
regarding expectations of new TCCSS suppliers entering the U.S. market.12
Supply constraints
*** U.S. producers reported that they had experienced supply constraints since January
1, 2017.13 U.S. producer *** reported that it was forced to put customers on allocation relative
to the volume of tin mill black plate (black plate) that could be purchased from other sources
because its largest supplier of black plate, ***, refused to continue supplying it beginning
January 2022, as well as the section 232 measures make it difficult to source black plate from
offshore suppliers. U.S. producer *** reported that there was a temporary tightness of supply
in 2021 as the economy began to recover from the COVID-19 pandemic, but it has had ample
supply available for at least the last 20 months. U.S. producer *** reported that it largely met
its contractual commitments for TCCSS during the period of review. It has not declined or
refused to continue supplying any existing customers, although it transitioned to supplying
certain customers via spot sales rather than annual contracts and has not declined new
customers at any point during the review period. It listed the following supply constraints:
• 	***
• 	***
12 *** cited rumors that SDI may enter the market and *** reported that an unnamed producer in
Vietnam has shown interest in the U.S. market.
13 Producer questionnaire responses, section IV-21.

II-10
• 	***
Eleven of 21 importers reported that they had experienced supply constraints since
January 1, 2017. Several importers cited import restrictions as causes for supply constraints:14
• 	*** noted that its imports are limited due to various import tariffs, duties, and
regulations.
• 	*** reported that its supply was stopped after the preliminary determination in
the Tin Mill Products AD/CVD investigation on Canada, China, Germany, and
South Korea.
• 	*** reported it is limited to a small quota of around 12 metric tons per year.
• 	*** reported that there was a 10-month period of uncertainty which no orders
were placed by its customers for TCCSS produced in ***; and,
• 	*** reported that imposed tariffs limit the supply base and is the largest
constraint.
• 	Importer *** reported that contracts are negotiated annually, and sometimes
demand has exceeded available capacity for specific products. It stated that
changes in demand from customers under contracts cannot always be
accommodated due to production capacity having already been committed to
other customers during the contract negotiation process for that year.
• 	Importer *** was unable to meet increased demand on occasion due to
production reliability issues.
• 	Importer *** reported that demand of all its customers was higher than installed
capacity.
14 Importer questionnaire responses, section III-19.

II-11
• 	Importer *** reported that during the second half of 2020 and parts of 2021, it
declined orders for preexisting customers due to the lack of container availability
and/or inconsistent vessel schedules, declined new/additional orders due to
uncertainties surrounding its ability to deliver on a normal schedule and with its
usual delivered pricing terms, and was unable to deliver certain arriving
shipments due to issues unrelated to the countervailing duty and antidumping
investigations.
Importer and purchaser *** reported that Cleveland-Cliffs, Duferco, and Ohio Coatings
did not accept orders in 2020 and 2021. Importer *** reported monthly and reduced annual
allocations as domestic mills would limit volume(s) and specifications they would produce, as
well as reduced next year’s contract volume from prior years contractual volume and or actual
shipped tons. It also reported that production orders were often called complete short by more
than contractual leeway on a majority of the orders. Lastly, it stated that orders would not be
available for shipment as confirmed on the producing mills order acknowledgements, often
being several months late, requiring alternate supply chains to be sought in order to meet
customer requirements.
Seventeen of 22 purchasers reported that they experienced supply constraints by
suppliers of TCCSS since January 1, 2017. Nine of these purchasers reported that domestic firms
have frequently had supply constraints and five reported occasional instances of being unable
to obtain domestically produced TCCSS. Purchasers reported domestic supply issues in 2020,
2021, and 2022, including being put on allocation (***), refusal to accept orders or provide
quotes (***), and an inability to meet contractual obligations for volume (***). *** reported an
inability of U.S. Steel and Cleveland-Cliffs to supply volumes in excess of their contracted
amounts. With respect to Japan, there were no purchasers that reported frequent or occasional
supply constraints, and four purchasers reported rarely or never experiencing supply
constraints. Most responding purchasers (11) reported rarely or never experiencing such supply
constraints with nonsubject sources.
Contracted delivery refusal
Two U.S. producers reported that their customers declined to accept contractually
obligated TCCSS since January 1, 2017. U.S. producer *** reported that customers always have
the option to refuse to buy and will exercise that option if they can get a better price
elsewhere. For example, it stated that many customers refused to take the full amount for
which they had contracted in 2022, which is why its end-of-period inventories increased so

II-12
much from 2021 to 2022. U.S. producer *** reported that despite continued strong demand in
2022, multiple contract customers refused to accept delivery of TCCSS, resulting in a shortfall of
more than *** short tons compared to their minimum contractual commitments for the year.
Forecasted high pricing and demand signals in the second half of 2021 allowed the producer to
secure higher prices in its annual TCCSS contracts for 2022. The producer alleges that
customers' failure to purchase contractually obligated volumes in 2022 was, in general, driven
by preference for lower-priced imported TCCSS. In contrast, when the producer’s contractual
prices were generally lower than market prices in 2021, customers sought out additional
volumes from it beyond the contracted volumes to stockpile products prior to 2022 contract
prices going into effect. For 2023 contracts, the producer attempted to secure "take or pay"
contracts from key customers so that a shortfall like what occurred in 2022 would not recur.
Customers largely rejected this, and the producer was only able to secure lower volumes when
it tried to otherwise maintain higher contract prices.
Purchasers were also asked if they had declined acceptance of contractually obligated
TCCSS since 2017. Most purchasers (18 of 22) reported that they had not declined acceptance
and 4 reported that they did. When asked how frequently they declined domestic product
deliveries, three of the four firms that reported declining acceptance of product reported
declining delivery of domestic product “occasionally” since 2017. *** reported that it is
committed to fulfilling supply agreement obligations with domestic and foreign steel mills, but
there have been instances of volatility in the market since 2017 where the rise and fall of
demand has prompted it to purchase less (or oftentimes more) than originally negotiated
through the annual supply negotiation process. *** reported a post-COVID-19 demand decline
in mid-2022 and into 2023, and that it was forced to cut volumes with all suppliers during this
time. *** reported that it refused delivery of TCCSS that was delivered more than 6 months
later than promised.
Impact of production facility closures
Two U.S. producers, ten importers, and nine purchasers reported that there were
changes in the availability of U.S.-produced TCCSS between 2017 and 2020. Domestic producer
U.S. Steel indefinitely idled two of its mills: East Chicago Tin (in December 2019) and Gary
Works (in August 2022). It also idled a line at UPI in Pittsburg, California in late 2023. Firms cited
declining U.S. production and reduced capacity due to the idlings, particularly U.S. Steel’s East
Chicago plant in late 2019, which led to a narrowing of product offerings.
Three U.S. producers, 15 importers, and 17 purchasers reported that there were
changes in the availability of U.S.-produced TCCSS between 2021 and 2023. For this time

II-13
period, firms again cited declining U.S. production and reduced capacity due to the idling of
multiple domestic mills, particularly U.S. Steel’s Gary Works plant in 2022 and UPI’s closure in
late 2023.15 Purchaser *** stated that U.S. producers shifted their investments and available
production capacity away from TCCSS to higher margin, rolled products for much of 2021 and
the first half of 2022. This shift occurred despite increases in TCCSS demand and significantly
reduced practical U.S. tinplate production capacity in recent years, which includes permanent
reduction in U.S. capacity caused by the complete removal of assets from tin mill steel
production, the indefinite idling of other assets, and the planned closure of other capacity. It
also stated that Cleveland-Cliffs has taken capacity out of service despite strong demand,
including the indefinite idling of its Indiana Harbor #3 and #4 blast furnaces. Lastly, it stated
that Ohio Coatings was not able to use much of its available tin mill steel production capacity
because it was completely unable to obtain the black plate substrate from Cleveland-Cliffs or
U.S. Steel.
One U.S. producer, eight importers, and eight purchasers reported that they anticipate
changes to the availability of U.S.-produced TCCSS. Several firms, including U.S. producer ***,
expect additional declines in U.S. production. Firms indicated concern about the long-term
viability of Cleveland-Cliffs’ Weirton facility. Firms cited the planned acquisition of U.S. Steel by
Nippon Steel, which alternatively could bring idled facilities back online.
When asked whether they had been impacted by the closure of domestic TCCSS
production facilities since 2017, purchasers were relatively split. Nine purchasers reported they
had been impacted by the closure of production facilities and six reported they had not. Seven
of the nine purchasers that reported they had been impacted by a closure specifically cited
closures at U.S. Steel facilities. Silgan stated the reduction in domestic suppliers to two mills has
impacted back-up plans to address situations with late deliveries.16 Purchasers were asked the
same question with respect to closures of Japanese TCCSS production facilities. Eight
purchasers reported they were not impacted, and 14 reported they did not know.
Additionally, purchasers were asked what effects the reduction in production of TCCSS
facilities at East Chicago and Gary Works have had on purchasers and the TCCSS products
market in the United States. Several purchasers reported limited or no impact on their
purchases (***). Some reported that U.S. Steel is able to produce the same specifications at its
15 Silgan has stated that they are seeking 175,000 tons of product to replace the lost West Coast
supply resulting from UPI’s closure. Hearing transcript, p. 194 (Arena).
16 Hearing transcript, p. 176 (Arena).

II-14
remaining facilities (***), while others reported needing to turn to foreign sources to fill the
gap (***). Firms noted the lead time and capacity concerns, price uncertainty, and reduced
availability as general effects on the TCCSS market in the United States. Several firms anticipate
the need to rely on imports with domestic supply declining and increased costs. Among the 15
responding purchasers that purchased TCCSS from East Chicago and Gary Works, 9 purchasers
reported that U.S. Steel did not offer TCCSS from alternative sources to meet contractual
commitments or secure incremental volumes and 6 reported that U.S. Steel did. All six
purchasers noted that U.S. Steel filled orders from its Midwest plant. *** elaborated that
before and after the COVID-19 pandemic, U.S. Steel did work to supply material from
alternative TCCSS plants but that during the pandemic, TFS production was “sold out” and no
TFS availability was offered from its Midwest plant.
On-time, in-full delivery rates
Fourteen of the 22 purchasers provided on-time in-full delivery rates by source in 2023.
They generally reported a lower rate for domestic sources than import sources. ***. The
average rate reported for domestic sources overall was 64.4 percent (based on responses of
nine purchasers).17 The average rate reported for nonsubject sources overall was 73.9 percent
(based on the responses of 11 purchasers). Seven purchasers reported on-time in-full delivery
rates from U.S. Steel; rates ranged from 30 to 68 percent, with six purchasers reporting rates of
50 percent or below. Four purchasers reported rates for Cleveland-Cliffs, ranging from 12 to 84
percent. Two purchasers reported rates for Ohio Coatings, ranging from 76 to 84 percent.
U.S. demand
Based on available information, the overall demand for TCCSS is likely to experience
moderate changes in response to changes in price. The main contributing factors are the
availability of substitute products and the moderate-to-high-cost share of TCCSS in its end-use
products. This responsiveness is somewhat mitigated by the investment required for
purchasers to change from use of cans to containers made from other materials.
17 Purchasers’ responses for domestic suppliers included the three U.S. producers as well as other
domestic suppliers.

II-15
End uses and cost share
U.S. demand for TCCSS largely depends on the demand for U.S.-produced downstream
products. Reported end uses include aerosol cans, automotive products, can bodies and
bottoms, food cans, filter components, general line cans, kitchen goods, metal packaging,
mounting cups, and paint cans and trays. No responding U.S. producer, importer, or purchaser
reported changes in end uses.
Most reported cost shares for cans and other downstream products were 40 to 80
percent, with reported shares ranging from 41 percent (popcorn tins) to 100 percent (bakeware
and mounting cups). With respect to food cans, firms noted that TCCSS comprises 50 to 85
percent of the cost of manufacturing the can.
Business cycles
Most firms (all 3 U.S. producers, 13 of 22 importers, and 16 of 21 purchasers) indicated
that the TCCSS market was subject to business cycles. Many firms reported seasonality in
demand, with higher demand in the summer when food and produce are packaged and slightly
lower demand in winter, although firms noted that demand timing can vary throughout the
year based on the specific product being packaged. Firms reported that some TCCSS
specifications are seasonal while others have more consistent use throughout the year and that
weather and other conditions affecting harvests can affect demand. Firms also noted seasonal
demand for items like bakeware or other holiday products. Other downstream uses of a cyclical
nature reported by purchasers may also affect demand for TCCSS, such as automotive
production, home canning, or manufacturing building products.
Firms also reported increased demand in 2020 during the COVID-19 pandemic because
of concerns regarding food availability and security and higher demand for aerosol cleaning
products such as Lysol disinfectant sprays. Purchaser *** noted that food container demand,
which can drive demand for TCCSS, can be counter-cyclical to observed trends in GDP.
Demand trends
Most U.S. producers and purchasers reported that U.S. demand for TCCSS fluctuated
upward or steadily increased between January 1, 2017, and December 31, 2020, while
importers responses were mixed but generally indicate that demand fluctuated (table II-5).
Most firms indicated that increases in demand were due to the COVID-19 pandemic while
decreases in demand were due to demand for alternate or substitute packaging.
Most firms reported that U.S. demand fluctuated downward or steadily decreased for
TCCSS between January 1, 2021, and December 31, 2023 (table II-6). Firms reported that U.S.

II-16
demand remained high in 2021 due the COVID-19 pandemic, but demand has decreased since
2021 due to abatement of COVID-19 related demand, inflation, reduced can shipments,
inventory overhang/backlogs, and increased use of substitutes. Some firms noted that the
market returned to pre-pandemic levels.
Table II-5
TCCSS: Count of firms’ responses overall domestic and foreign demand in 2017-20, by firm type
Market 	Firm type
Steadily
increased
Fluctuated
up
No
change
Fluctuated
down
Steadily
decreased
U.S. demand 	U.S. producers 	0 	2 	0 	1 	0
U.S. demand 	Importers 	2 	7 	3 	7 	1
U.S. demand 	Purchasers 	2 	12 	2 	3 	0
U.S. demand 	Foreign producers 	0 	1 	1 	0 	0
Foreign demand 	U.S. producers 	0 	1 	0 	0 	0
Foreign demand 	Importers 	2 	3 	1 	3 	2
Foreign demand 	Purchasers 	1 	7 	2 	1 	1
Demand in Japan 	Foreign producers 	0 	0 	0 	2 	1
Demand in other
export markets 	Foreign producers 	0 	3 	0 	0 	0
Demand for end use
products 	Purchasers 	1 	1 	1 	10 	2
Source: Compiled from data submitted in response to Commission questionnaires.
Table II-6
TCCSS: Count of firms’ responses overall domestic and foreign demand in 2021-23, by firm type
Market 	Firm type
Steadily
increased
Fluctuated
up
No
change
Fluctuated
down
Steadily
decreased
U.S. demand 	U.S. producers 	0 	0 	0 	3 	0
U.S. demand 	Importers 	3 	3 	3 	9 	3
U.S. demand 	Purchasers 	0 	3 	2 	12 	2
U.S. demand 	Foreign producers 	0 	0 	1 	1 	0
Foreign demand 	U.S. producers 	0 	0 	1 	0 	0
Foreign demand 	Importers 	3 	3 	1 	3 	3
Foreign demand 	Purchasers 	0 	2 	3 	4 	2
Demand in Japan 	Foreign producers 	0 	0 	0 	3 	0
Demand in other
export markets 	Foreign producers 	0 	0 	1 	2 	0
Source: Compiled from data submitted in response to Commission questionnaires.

II-17
A majority of purchasers reported that demand for their final products incorporating
TCCSS fluctuated downward (10 of 15 firms) or steadily decreased (2) since January 1, 2017.
Fourteen of these firms reported that the change in demand for their final products effected
their demand for TCCSS. Several firms reported a direct effect of changing demand from their
customers on their demand for TCCSS. Others noted that demand for food cans and aerosol
products substantially increased during the COVID-19 pandemic and subsequent decline in
demand post-COVID.
Firms expect demand to remain stable or decline over the next two years (table II-7).
Table II-7
TCCSS: Count of firms’ responses regarding anticipated overall domestic and foreign demand, by
firm type
Market 	Firm type
Steadily
increase
Fluctuate
up
No
change
Fluctuate
down
Steadily
decrease
U.S. demand 	U.S. producers 	0 	1 	1 	1 	1
U.S. demand 	Importers 	0 	1 	8 	8 	8
U.S. demand 	Purchasers 	0 	1 	8 	7 	7
U.S. demand 	Foreign producers 	0 	0 	2 	0 	0
Foreign demand 	U.S. producers 	0 	0 	1 	0 	0
Foreign demand 	Importers 	0 	2 	5 	3 	3
Foreign demand 	Purchasers 	1 	3 	4 	1 	1
Demand in Japan 	Foreign producers 	0 	0 	0 	3 	3
Demand in other
export markets 	Foreign producers 	0 	2 	1 	0 	0
Source: Compiled from data submitted in response to Commission questionnaires.
Substitute products
Substitutes for TCCSS include aluminum, plastic, glass, foil pouches, flexible packaging,
and PET, for food packaging or aerosol cans.18 Most firms report no change in the types of
substitutes since January 1, 2017, however seven importers and seven purchasers reported
changes. These firms cited increased demand for BPA-free coatings and coating products, such
as TFS laminate products; pouches, cardboard, and plastic use increased due to the cost of
steel; and cold roll (light gauge) for painted end uses like oil filters.
18 Tin- and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Third Review), USITC
Publication 4795, June 2018, p. II-8.

II-18
Substitutability issues
This section assesses the degree to which U.S.-produced TCCSS and imports of TCCSS
from subject countries can be substituted for one another by examining the importance of
certain purchasing factors and the comparability of TCCSS from domestic and imported sources
based on those factors. Based on available data, staff believes that there is at least a moderate
degree of substitutability between domestically produced TCCSS and TCCSS imported from
Japan.19 The main factors limiting substitutability were availability/available capacity to
produce domestic tin mill products, rejection rates and lack of qualification for certain types of
domestic tin mill products, and certain types of tin mill products only being available only from
certain sources. For tin mill products of the same type, substitutability is higher, as there is
reportedly general interchangeability among tin mill products of similar quality and usage.
Factors affecting purchasing decisions20
Purchaser decisions based on source
As shown in table II-8, most purchasers reported that they at least sometimes make
purchasing decisions based on the producer and the country of origin. Of the 8 purchasers that
reported that they always make decisions based on the manufacturer, 4 firms cited
qualification status; other reasons cited include quality, availability, and avoiding potential
trade issues. ***.
19 The degree of substitution between domestic and imported TCCSS depends upon the extent of
product differentiation between the domestic and imported products and reflects how easily purchasers
can switch from domestically produced TCCSS to the TCCSS imported from subject countries (or vice
versa) when prices change. The degree of substitution may include such factors as relative prices
(discounts/rebates), quality differences (e.g., grade standards, defect rates, etc.), and differences in
sales conditions (e.g., lead times between order and delivery dates, reliability of supply, product
services, etc.).
20 Eighteen purchasers indicated they had marketing/pricing knowledge of domestic TCCSS, 5 of
Japanese TCCSS, and 19 of TCCSS from nonsubject countries.

II-19
Table II-8
TCCSS: Count of purchasers’ responses regarding frequency of purchasing decisions based on
producer and country of origin
Firm making decision 	Decision based on 	Always 	Usually 	Sometimes 	Never
Purchaser 	Producer 	8 	0 	8 	7
Customer 	Producer 	2 	3 	6 	9
Purchaser 	Country 	6 	2 	6 	8
Customer 	Country 	1 	3 	8 	8
Source: Compiled from data submitted in response to Commission questionnaires.
Importance of purchasing domestic product
Responding purchasers reported that domestic product was not required for nearly all
their total purchases (approximately 96 percent in 2023). Twenty of 22 purchasers reported
that most or all of their purchases did not require purchasing U.S.-produced product. Two
purchasers reported that domestic product was required by law (for 2 to 3 percent of their
purchases), 8 reported it was required by their customers (for 2 to 100 percent of their
purchases), and 2 reported other preferences for domestic product. Reasons cited for
preferring domestic product included promoting goods “Made in USA,” contingency of supply,
and lead times.
Most important purchase factors
The most often cited top three factors firms consider in their purchasing decisions for
TCCSS were quality (20 firms), price or cost (14 firms), and availability or supply (13 firms) as
shown in table II-9. Quality was the most frequently cited first-most important factor (cited by 9
firms), followed by availability or supply (5 firms); quality was the most frequently reported
second-most important factor (6 firms); and price or cost was the most frequently reported
third-most important factor (7 firms).
Table II-9
TCCSS: Count of ranking of factors used in purchasing decisions as reported by purchasers, by
factor
Factor 	First 	Second 	Third 	Total
Quality 	9 	6 	5 	20
Price or cost 	3 	4 	7 	14
Availability or supply 	5 	4 	4 	13
Delivery 	0 	3 	2 	5
Ability to produce desired specifications 	2 	1 	0 	3
All other factors 	3 	3 	3 	NA
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Other factors include traditional supplier of other products, credit, service, and trust.

II-20
The majority of purchasers (12 of 22) reported that they sometimes purchase the
lowest-priced product. Six reported usually, two reported always, and three reported never
purchasing the lowest-priced product.
Importance of specified purchase factors
Purchasers were asked to rate the importance of 18 factors in their purchasing decisions
(table II-10). The factors rated as very important by more than half of responding purchasers
were reliability of supply (22 firms), availability and quality meets industry standards (21 firms
each), product consistency (20), delivery time (19), availability of TCCSS less than or equal to 41
inches wide (15), delivery terms and price (14 each), payment terms and technical
support/service (13 each), and quality exceeding industry standards (11). A majority of
responding purchasers identified availability of TCCSS greater than 41 inches in width (11) and
availability of drawn and ironed TCCSS (12) as “not important.”
Table II-10
TCCSS: Count of purchasers’ responses regarding importance of purchase factors, by factor
Factor 	Very important
Somewhat
important 	Not important
Availability 	21 	1 	0
Availability – product ≥41 inches 	7 	3 	11
Availability – product <41 inches 	15 	5 	2
Availability – drawn & ironed product 	6 	3 	12
Delivery terms 	14 	7 	1
Delivery time 	19 	3 	0
Discounts offered 	8 	11 	3
Minimum quantity requirements 	2 	15 	4
Packaging 	9 	11 	2
Payment terms 	13 	7 	1
Price 	14 	8 	0
Product consistency 	20 	2 	0
Product range 	9 	11 	2
Quality meets industry standards 	21 	1 	0
Quality exceeds industry standards 	11 	9 	1
Reliability of supply 	22 	0 	0
Technical support/service 	13 	9 	0
U.S. transportation costs 	10 	10 	2
Source: Compiled from data submitted in response to Commission questionnaires.

II-21
Lead times
TCCSS is primarily produced-to-order. U.S. producers reported that *** percent of their
U.S. shipments were produced-to-order in 2023, with lead times averaging *** days for
deferred shipment and *** days for shipment upon completion.21 The sole importer of
Japanese TCCSS reported that *** percent of its U.S. shipments were produced-to-order, with
lead times averaging *** days.
Supplier certification
Eighteen of 22 responding purchasers require their suppliers to become certified or
qualified to sell TCCSS to their firm. Sixteen purchasers reported the time to qualify a new
supplier; responses ranged from 30 to 540 days.22 There are currently no qualified suppliers in
Japan for any specification of TCCSS for U.S. purchasers.23
Purchasers were requested to report the share of their total purchases in 2023 that
involved TCCSS specifications for which at least one supplier from each source (United States,
Japan, and nonsubject countries) was qualified. Fourteen purchasers reported that at least one
U.S. producer was qualified to produce a portion of the TCCSS they purchased in 2023, with
shares reported ranging from 4 to 100 percent.24 Fifteen purchasers reported that nonsubject
sources were qualified, with shares reported ranging from 12 to 100 percent. ***.
21 Firms were asked to report separately for shipments that were produced-to-order with deferred
shipment (including sales the firm produced for a specific customer that were held in their inventories
for delivery at a later date) and those that were produced-to-order for shipment upon completion. ***.
22 Five of the 16 firms reported 90 days or fewer and the remaining 11 firms reported 180 days or
longer.
23 Hearing transcript, p. 171 (Stringer).
24 ***.

II-22
Twelve purchasers reported that a domestic or foreign supplier had failed in its attempt
to qualify TCCSS or had lost its approved status since January 1, 2017. Seven of these
purchasers reported that a U.S. producer, specifically Cleveland-Cliffs or U.S. Steel, failed to
qualify on certain specifications or at certain times. Eight purchasers reported that one or more
foreign mills in nonsubject countries failed qualification. There were no reports of mills in Japan
failing qualification.
Minimum quality specifications
As shown in table II-11, most responding purchasers reported that domestically
produced TCCSS always (5 firms) or usually (8 firms) met minimum quality specifications,
although 5 firms responded that domestic product sometimes met minimum quality
specifications. Most purchasers did not know whether Japanese TCCSS product met minimum
quality specifications; among those with knowledge, three responded that it usually did, and
one responded that it always did. Purchasers reported that TCCSS from nonsubject sources
always (11 firms) or usually (7 firms) met minimum quality specifications. All 22 responding
purchasers reported factors that determined the quality of TCCSS. Generally, purchasers will
order a trial or small batch of product from suppliers and test for performance in purchasers’
manufacturing process, adherence to requested specifications, while also reviewing suppliers’
delivery performance and technical support.
Table II-11
TCCSS: Count of purchasers’ responses regarding suppliers’ ability to meet minimum quality
specifications, by source
Source of purchases 	Always 	Usually 	Sometimes
Rarely or
never
Don't
Know
United States 	5 	8 	5 	0 	4
Japan 	1 	3 	0 	0 	18
Nonsubject sources 	11 	7 	0 	0 	3
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Purchasers were asked how often domestically produced or imported TCCSS meets minimum
quality specifications for their own or their customers’ uses.
Rejection rates
Purchasers were asked to provide the proportion of the TCCSS products that were
delivered to them by their top five suppliers of TCCSS in 2023 that ended up being rejected
(e.g., returned or scrapped). Fourteen purchasers provided information on rejections for
deliveries received in 2023 (see appendix F). For deliveries from domestic suppliers, rejection
rates varied from 0.1 percent to 50 percent and averaged 7.3 percent. Corresponding rejection

II-23
quantities ranged from 1 short ton to 853 short tons, totaling 5,677 short tons of rejected
TCCSS. Twelve purchasers provided information on rejections for deliveries received in 2023
from non-U.S. sources.25 Rejection rates for these deliveries varied from 0.04 percent to 9
percent and averaged 1.5 percent. Corresponding rejection quantities ranged from 2 short tons
to 1,116 short tons, totaling 4,672 short tons. Reasons for rejecting deliveries were similar
across sources and included rust, visual defects, shape defects, and damage.
Changes in purchasing patterns
Eight purchasers reported that they had changed suppliers since January 1, 2017, while
14 reported that they had not. Specifically, firms dropped or reduced purchases from China
because of antidumping cases, ***. Firms added purchases from ***.
Purchasers were also asked about changes in their purchasing patterns from different
countries since January 1, 2017 (table II-12). Purchasers reported decreased purchases of U.S.-
produced product because of lack of domestic availability and product, inability to validate
domestic sources, and reduced customer demand. Purchasers reported they did not purchase
product from Japan. Purchasers reported fluctuating purchases of product from nonsubject
countries because of reduced domestic availability and changing demand trends.
Table II-12
TCCSS: Count of purchasers’ responses regarding changes in purchase patterns from U.S.,
subject, and nonsubject countries
Source of purchases 	Decreased 	Increased 	Constant 	Fluctuated
Did not
purchase
United States 	7 	0 	0 	14 	3
Japan 	0 	0 	0 	0 	18
Nonsubject sources 	2 	2 	1 	14 	1
Sources unknown 	0 	0 	1 	1 	11
Source: Compiled from data submitted in response to Commission questionnaires.
Purchase factor comparisons of domestic products, subject imports, and
nonsubject imports
Purchasers were asked a number of questions comparing TCCSS produced in the United
States, Japan, and nonsubject countries. First, purchasers were asked for a country-by-country
25 No information on rejections of deliveries from Japan was received.

II-24
comparison on the same 18 factors (table II-13) for which they were asked to rate the
importance.
Purchaser responses comparing domestically produced TCCSS and TCCSS imported from
Japan were few and mixed across most factors. Most purchasers reported that U.S. and
nonsubject TCCSS were comparable on availability of TCCSS less than 41 inches wide, delivery
terms, discounts, minimum quantity requirements, packaging, payment terms, price, and
quality meeting industry standards. All responding purchasers noted that domestic availability
of product greater than or equal to 41 inches were inferior to the TCCSS from Japan. A majority
of purchasers also noted that U.S. product range and availability (in general) are inferior to that
for TCCSS from Japan. A majority of respondents reported that delivery time was superior for
TCCSS produced in the United States. Factors that the majority of respondents indicated were
very important in their purchasing decisions (table II-10) and described as comparable when
comparing the domestic and nonsubject country supply were: availability of TCCSS under 41
inches wide, delivery terms, payment terms, price, and quality meeting industry standards.
Table II-13
TCCSS: Count of purchasers’ responses comparing U.S.-produced and imported product, by
factor and country pair
Factor 	Country pair 	Superior 	Comparable 	Inferior
Availability 	U.S. v. Japan 	2 	0 	3
Availability – product ≥41 inches 	U.S. v. Japan 	0 	0 	3
Availability – product <41 inches 	U.S. v. Japan 	1 	2 	1
Availability – drawn & ironed product 	U.S. v. Japan 	0 	2 	2
Delivery terms 	U.S. v. Japan 	2 	2 	0
Delivery time 	U.S. v. Japan 	3 	1 	0
Discounts offered 	U.S. v. Japan 	1 	3 	0
Minimum quantity requirements 	U.S. v. Japan 	2 	1 	1
Packaging 	U.S. v. Japan 	1 	3 	0
Payment terms 	U.S. v. Japan 	1 	3 	0
Price 	U.S. v. Japan 	2 	2 	0
Product consistency 	U.S. v. Japan 	1 	1 	2
Product range 	U.S. v. Japan 	1 	1 	3
Quality meets industry standards 	U.S. v. Japan 	1 	2 	1
Quality exceeds industry standards 	U.S. v. Japan 	1 	2 	1
Reliability of supply 	U.S. v. Japan 	2 	0 	2
Technical support/service 	U.S. v. Japan 	2 	0 	2
U.S. transportation costs 	U.S. v. Japan 	2 	2 	0
Table continued.

II-25
Table II-13 Continued
TCCSS: Count of purchasers’ responses comparing U.S.-produced and imported product, by
factor and country pair
Factor 	Country pair 	Superior 	Comparable 	Inferior
Availability 	U.S. v. Nonsubject 	2 	6 	10
Availability – product >=41 inches 	U.S. v. Nonsubject 	0 	0 	11
Availability – product <41 inches 	U.S. v. Nonsubject 	0 	10 	6
Availability – drawn & ironed product 	U.S. v. Nonsubject 	0 	4 	5
Delivery terms 	U.S. v. Nonsubject 	2 	11 	3
Delivery time 	U.S. v. Nonsubject 	7 	6 	3
Discounts offered 	U.S. v. Nonsubject 	0 	14 	1
Minimum quantity requirements 	U.S. v. Nonsubject 	3 	9 	4
Packaging 	U.S. v. Nonsubject 	0 	12 	4
Payment terms 	U.S. v. Nonsubject 	1 	11 	4
Price 	U.S. v. Nonsubject 	0 	11 	5
Product consistency 	U.S. v. Nonsubject 	0 	6 	10
Product range 	U.S. v. Nonsubject 	0 	7 	10
Quality meets industry standards 	U.S. v. Nonsubject 	0 	10 	6
Quality exceeds industry standards 	U.S. v. Nonsubject 	0 	6 	10
Reliability of supply 	U.S. v. Nonsubject 	2 	3 	11
Technical support/service 	U.S. v. Nonsubject 	3 	7 	6
U.S. transportation costs 	U.S. v. Nonsubject 	7 	7 	2
Source: Compiled from data submitted in response to Commission questionnaires.
Note: A rating of superior means that price/U.S. transportation cost is generally lower. For example, if a
firm reported “U.S. superior,” it meant that the U.S. product was generally priced lower than the imported
product.
Comparison of U.S.-produced and imported TCCSS
In order to determine whether U.S.-produced TCCSS can generally be used in the same
applications as imports from Japan, U.S. producers, importers, and purchasers were asked
whether the products can always, frequently, sometimes, or never be used interchangeably. As
shown in table II-14, *** U.S. producers reported that TCCSS produced in the United States,
Japan, and nonsubject countries was always interchangeable. In contrast, the majority of
responding importers and purchasers reported that domestically produced TCCSS and TCCSS
imported from Japan and nonsubject countries were frequently or sometimes interchangeable.
One purchaser, two purchaser/importers, and two importers reported limited to no availability
of U.S. production capacity for specifications they required as the reason for limited
interchangeability between U.S.- and foreign-produced TCCSS.

II-26
Table II-14
TCCSS: Count of firms reporting the interchangeability between product produced in the United
States and in other countries, by country pair and firm type
Country pair 	Firm type 	Always 	Frequently 	Sometimes 	Never
United States vs. Japan U.S. producers 	3 	0 	0 	0
United States vs. Other 	U.S. producers 	3 	0 	0 	0
Japan vs. Other 	U.S. producers 	2 	0 	0 	0
United States vs. Japan Importers 	0 	4 	2 	1
United States vs. Other 	Importers 	0 	7 	10 	0
Japan vs. Other 	Importers 	0 	5 	4 	0
United States vs. Japan Purchasers 	0 	3 	1 	1
United States vs. Other 	Purchasers 	3 	6 	8 	1
Japan vs. Other 	Purchasers 	0 	3 	2 	0
Source: Compiled from data submitted in response to Commission questionnaires.
Note: ***.
In addition, U.S. producers, importers, and purchasers were asked to assess how often
differences other than price were significant in sales of TCCSS from the United States, Japan, or
nonsubject countries. As seen in table II-15, U.S. producers reported that factors other than
price are sometimes or never significant regarding the sales of their TCCSS, regardless of
country-pair. Importers generally reported non-price factors as frequently or sometimes
significant across all country-pairs, whereas a majority of purchasers reported them to be
always or frequently significant for all country-pairs. Importers reported supply constraints in
U.S. production, quality differences, and product range differences as significant factors other
than price which affect their sales. Purchasers also included the same or similar explanations in
their responses, namely rejection rates and the availability of product widths.
Table II-15
TCCSS: Count of U.S. producers reporting the significance of differences other than price
between product produced in the United States and in other countries, by country pair
Country pair 	Firm type 	Always 	Frequently 	Sometimes 	Never
United States vs. Japan 	U.S. producers 	0 	0 	2 	1
United States vs. Other 	U.S. producers 	0 	0 	2 	1
Japan vs. Other 	U.S. producers 	0 	0 	0 	1
United States vs. Japan 	Importers 	1 	4 	1 	1
United States vs. Other 	Importers 	4 	8 	7 	0
Japan vs. Other 	Importers 	1 	2 	4 	0
United States vs. Japan 	Purchasers 	2 	2 	1 	0
United States vs. Other 	Purchasers 	10 	4 	3 	1
Japan vs. Other 	Purchasers 	2 	2 	1 	0
Source: Compiled from data submitted in response to Commission questionnaires.

II-27
Elasticity estimates
This section discusses elasticity estimates; parties did not provide alternative elasticity
estimates in their prehearing or posthearing briefs.
U.S. supply elasticity
The domestic supply elasticity for TCCSS measures the sensitivity of the quantity
supplied by U.S. producers to changes in the U.S. market price of TCCSS. The elasticity of
domestic supply depends on several factors including the level of excess capacity, the ease with
which producers can alter capacity, producers’ ability to shift to production of other products,
the existence of inventories, and the availability of alternate markets for U.S.-produced TCCSS.
Analysis of these factors above indicates that the U.S. industry has the ability to somewhat
increase or decrease shipments to the U.S. market; an estimate in the range of 4 to 6 is
suggested. U.S. producer Cleveland-Cliffs indefinitely idled its facility in Weirton, West Virginia
as of April 20, 2024.26 This production location was responsible for *** percent of domestic
production in 2023 (table I-8). Without a corresponding increase in capacity from other
domestic producers to offset lost capacity from this event, there will likely be a decrease in the
level of excess capacity and the ease with which producers can alter capacity, decreasing
domestic producers’ ability to respond to changes in the U.S. market price of TCCSS.
U.S. demand elasticity
The U.S. demand elasticity for TCCSS measures the sensitivity of the overall quantity
demanded to a change in the U.S. market price of TCCSS. This estimate depends on factors
discussed above such as the existence, availability, and commercial viability of substitute
products, as well as the component share of the TCCSS in the production of any downstream
products. Based on the available information, the aggregate demand for TCCSS is likely to be
slightly inelastic; a range of -0.75 to -1.0 is suggested.
26 Cleveland Cliffs in Weirton Idled, https://www.mariettatimes.com/news/local-
news/2024/04/cleveland-cliffs-in-weirton-idled/, retrieved April 22, 2024.

II-28
Substitution elasticity
The elasticity of substitution depends upon the extent of product differentiation
between the domestic and imported products.27 Product differentiation, in turn, depends upon
such factors as quality (e.g., chemistry, appearance, etc.) and conditions of sale (e.g.,
availability, sales terms/discounts/promotions, etc.). Based on available information, the
elasticity of substitution between U.S.-produced and imported TCCSS is likely to be in the range
of 2 to 4. The main factors limiting substitutability are available domestic capacity, and certain
types of TCCSS only being available only from certain sources. For TCCSS products of the same
type, substitutability is higher, as there is reportedly general interchangeability among TCCSS of
similar quality and usage.
27 The substitution elasticity measures the responsiveness of the relative U.S. consumption levels of
the subject imports and the domestic like products to changes in their relative prices. This reflects how
easily purchasers switch from the U.S. product to the subject products (or vice versa) when prices
change.

III-1
Part III: Condition of the U.S. industry
Overview
The information in this section of the report was compiled from responses to the
Commission’s questionnaires. The Commission received a questionnaire response from three
firms, Cleveland-Cliffs, Ohio Coatings, and U.S. Steel, which accounted for all known U.S.
production of TCCSS in 2023. Of these three producers, Cleveland-Cliffs and U.S. Steel
accounted for approximately *** percent of U.S. production in 2023.
Industry events since the last five-year review
Table III-1 presents events in the U.S. industry since the last five-year review. As of April
20, 2024, there are only two operating TCCSS production facilities in the United States: Ohio
Coatings’ plant in Yorkville, Ohio1 and U.S. Steels’ Midwest plant in Portage, Indiana. Previously,
U.S. Steel produced TCCSS at four different facilities: East Chicago Tin (East Chicago, Indiana),
Gary Works (Gary, Indiana), Midwest (Portage, Indiana), and USS-UPI (Pittsburg, California). U.S.
Steel’s East Chicago plant was idled in 2019 and permanently closed in 2022. U.S. Steel’s Gary
Works and USS-UPI plants were indefinitely idled in late-2022 and late-2023, respectively. At
present, U.S. Steel operates only two TCCSS production lines at its Midwest facility.2 3 On April
20, 2024, Cleveland-Cliffs indefinitely idled its TCCSS plant in Weirton, West Virginia.4
1 Ohio Coatings is not a producer of tin mill black plate (“TMBP”), the steel substrate used in the
manufacturing of TCCSS; rather the firm purchases the input from various sources to produce TCCSS at
its Yorkville plant. Ohio Coatings reported that during the review period ***. Ohio Coatings’ producer
questionnaire at II-2c. U.S. Steel reported that ***. U.S. Steel’s posthearing brief, exh. 1, pp 7–8, and
exh. 11-A. Cleveland-Cliffs reported that ***. Cleveland-Cliffs’ posthearing brief, exh. 1.
2 Hearing transcript, p. 18 (Kopf); U.S. Steel’s prehearing brief, pp. 11-12; U.S. Steel’s posthearing
brief, April 16, 2024, pp. 5 and 14, and exh.1, pp. 1-2.
3 U.S. Steel noted that its Gary Works plant could be restarted quickly if market conditions and
demand for U.S.-made TCCSS improves and reaches a ‘critical mass’. Hearing transcript, pp. 19 and 42
(Kopf); U.S. Steel’s posthearing brief, April 16, 2024, p. 6; exh. 1, pp. 1-2; and exh. 2 p. 1.
4 Cleveland-Cliffs noted that it will preserve the assets of its Weirton facility in the hopes of an
eventual restart. Hearing transcript, pp. 23-27 (Smith) and 44-45 (Smith); Cleveland-Cliffs’ posthearing
brief, April 16, 2024, p. 2 and exh. 1.

III-2
Table III-1
TCCSS: Developments in the U.S. industry since January 1, 2017
Item 	Firm 	Event
Resumed
operations
U.S. Steel 	April 2017— Completion of re-start at the Midwest facility in Portage,
Indiana, after concluding repairs and extensive air and water testing in
response to a process release of hexavalent chromium three days prior.
Expansion 	U.S. Steel 	August 2018— Announcement of $750 million in capital upgrades over
five years to revitalize the Gary Works facility through installation of
new, state-of-the-art production equipment and modernizing technology
to boost the facility’s corporate competitiveness, environmental
compliance, and service to industrial customers (including container
manufacturing industries).
Plant idling 	U.S. Steel 	June 2019— Announcement of the temporarily idling of one of four
blast furnaces at the Gary Works facility to better align production to
corporate order books, with current-quarter earnings forecasted below
Wall Street estimates due to lower steel prices and softening market
demand.
Layoffs 	ArcelorMittal 	August 2019— Announcement of layoffs of 100 employees at the
ArcelorMittal Weirton tin mill facility in Weirton, West Virginia (“Weirton
facility”). Demand for tin mill products unexpectedly declined over the
prior six weeks, attributed by a local union leader to foreign currency
manipulation, some foreign tinplate producers evading the section 232
steel tariffs, and lower demand by food canners due to poorer seasonal
vegetable harvests afflicted by either flooding or droughts.
Plant idling
and layoffs
U.S. Steel 	August 2019— Announcement of an “indefinite” idling of the East
Chicago, Indiana, tin mill operations by mid-November 2019, days after
major food processor and distributor Del Monte Foods Inc. (“Del
Monte”) announced the closure of two tin canning facilities with layoffs
of more than 800 workers. About one-half of the 297 employees will be
offered positions at the other two U.S. Steel facilities, while the others
will be laid off. U.S. Steel cited low tin mill capacity utilization due to
continued high levels of low-priced imports which have captured about
one-half of the domestic tin mill products market for its decision to
consolidate tin mill production down from three to two facilities. Del
Monte cited both the higher priced tin mill products attributable to the
section 232 steel tariffs and the ongoing decline of canned food sales
as younger consumers shift more toward fresh foods.
Acquisition 	U.S. Steel 	February 2020— U.S. Steel acquires sole ownership of the USS-
POSCO Industries (“UPI”) joint-venture rolling facility, located in
Pittsburg, California, upon completing the buy-out of POSCO California
Corp’s. 50-percent ownership share.
Acquisition 	Cleveland-
Cliffs
December 2020— Completion of a $1.4 billion acquisition of the
steelmaking and finishing facilities of ArcelorMittal, including the
Weirton facility.
Table continued.

III-3
Table III-1 Continued
TCCSS: Developments in the U.S. industry since January 1, 2017
Item 	Firm 	Event
Environmental
protection
violations
UPI 	August 2021— Four-million dollars civil settlement with the Contra
Costa County District Attorney’s Office to resolve allegations that UPI
firm violated state and environmental regulations by improperly storing
and illegally disposing of hazardous materials and wastes, dating back
to 2017.
Closure 	UPI 	January 2022— Reported plans to close UPI by December 2023, with
the shuttered facility to be sold in 2023 or 2024.
Plant closing 	U.S. Steel 	March 2022— U.S. Steel permanently closed its East Chicago Tin
facility. The mill had been idled on an indefinite basis since fourth-
quarter 2019. Tin mill operations shifted to the Midwest and Gary Works
facilities.
Plant idling 	U.S. Steel 	August 2022— U.S. Steel idles Tin Line No. 5 at its Gary Works facility
in response to current market conditions.
Plant closing 	UPI 	August 2022— Reported announcement that UPI will cease production
in 2023 and sale of the property for warehouse space to Amazon.com
Inc.
Plant idling 	U.S. Steel 	October 2022— Announcement of the idling of all tin mill products
operations at the Gary Works facility, with former tin-mill workers shifted
to other positions within the Gary Works facility.
New labor
agreement
Cleveland-
Cliffs
October 2022— USW membership overwhelmingly approves a new
four-year labor contract (through September 2026) covering 12,000
members at 13 Cleveland-Cliffs facilities, including the Weirton facility.
The new contract raises base wages by 20 percent, improves insurance
benefits for both active and retired employees, raises pensions,
improves vacation provisions, includes an additional holiday, and
includes new provisions for parental paid leave and for employees who
are victims of domestic violence.
New labor
agreement
U.S. Steel 	December 2022— Announcement of the ratification of a new successor
four-year collective bargaining agreement by the approximately 11,000
USW-represented employees at the firm’s domestic flat-rolled steel
facilities, iron ore mining facilities, and tubular steel operations. The
new contract provides a lump sum bonus, raises wages by more than
20 percent over its term, raises pensions, includes an additional
holiday, improves healthcare benefits for both active and retired
employees. This agreement is effective retroactively to September 1,
2022, through September 1, 2026.
Table continued.

III-4
Table III-1 Continued
TCCSS: Developments in the U.S. industry since January 1, 2017
Item 	Firm 	Event
Layoffs 	U.S. Steel 	December 2022— Indefinite idling of most tin mill operations at its Gary
Works facility. The idling included tin line No. 5, which was previously
temporarily idled in third-quarter 2022, and tin line No. 6.
U.S. Steel also provided advanced notice of plans to lay off 244 tin-mill
workers at its Gary Works facility by February 2023. In its Worker
Adjustment and Retraining Notification (“WARN”) to the Indiana
Department of Workforce Development, U.S. Steel stated that the Tin
Mill Division will be shut down due to “market conditions which were
out of the company’s control, including the continuing reduced demand
for the company’s tin products and significantly increased tin mill
imports.” Although U.S. Steel is coordinating with the United
Steelworkers (“USW”) local union to identify available placement
opportunities for impacted employees in open jobs across the firm,
additional layoffs could be forthcoming if these market conditions
continue.
Layoffs 	Cleveland-
Cliffs
May 2023— Announcement of layoffs of approximately 300 employees
that manufacture tinplate for packaging products at the Weirton facility,
citing unfair import competition. According to Lourenco Goncalves,
Chairman, President, and Chief Executive Officer, “{O}nce again, unfair
trade practices are harming good paying, union jobs.”
Acquisition
offers
U.S. Steel,
Cleveland-
Cliffs, Esmark
August 2023— U.S. Steel receives two unsolicited purchase offers
from Cleveland-Cliffs for $7.3 billion and from Esmark Steel Group
(“Esmark”) for $7.8 billion.
Acquisition
offer rejected
U.S. Steel,
Cleveland-
Cliffs
August 2023— U.S. Steel turns down Cleveland-Cliffs’ $7.3 billion offer
after the latter “…refused to engage in the necessary and customary
process to assess valuation and certainty unless U.S. Steel agreed to
the economic terms of the proposal in advance.” The former will also
conduct a strategic corporate planning review of the “multiple
unsolicited proposals” received.
Acquisition
offer withdrawn
Esmark 	August 2023— Esmark withdraws its $7.8 billion offer to purchase U.S.
Steel, citing its partnership with the USW in acquiring Wheeling
Pittsburgh Steel (in November 2007) and acknowledging the USW’s
support for Cleveland-Cliffs’ purchase offer.
Acquisition
offer
evaluation
U.S. Steel 	August 2023— Announcement to shareholders that the firm is signing
non-disclosure agreements with potential buyers ahead of sharing due
diligence information with them, while it reviews its options for
evaluating the multiple unsolicited offers for either selected or all of
U.S. Steel’s facilities and other assets.
Acquisition
offer reported
ArcelorMittal,
U.S. Steel
August 2023— ArcelorMittal SA (Luxembourg) reportedly confers with
its investment bankers to finance a potential purchase offer for U.S.
Steel. However, the USW reportedly will not endorse any buyers other
than Cleveland-Cliffs.
Acquisition
process
disagreement
Cleveland-
Cliffs, U.S.
Steel
September 2023— Cleveland-Cliffs locked out from the ongoing due
diligence and acquisition process after declining to sign U.S. Steel’s
non-disclosure agreement. The former also refused to sign a six-month
standstill agreement that would prevent it from challenging the latter’s
board of directors, reportedly to keep its options open.
Table continued.

III-5
Table III-1 Continued
TCCSS: Developments in the U.S. industry since January 1, 2017
Item 	Firm 	Event
Acquisition
offer
Stelco 	September 2023— Canadian steelmaker Stelco Holdings Co. (“Stelco”)
reportedly considered, with the backing of unnamed partners, a
purchase offer for selected iron ore mine and steel facilities of U.S.
Steel (not confirmed officially by either Stelco or any of its potential
partners).
Acquisition
offer
Nippon Steel 	September 2023— Nippon Steel reportedly expressed willingness to
offer $9.5 billion for U.S. Steel, including its integrated steelmaking
facilities. (According to regulatory filings, Nippon Steel valued U.S.
Steel’s modern electric-arc furnace steelmaking facilities in Arkansas
and its iron ore mines in Minnesota at a combined $9.2 billion).
Acquisition
offer
U.S. Steel,
Nippon Steel
December 2023— U.S. Steel announces its agreement to be acquired
by Japan’s largest steelmaker, Nippon Steel, in an all-cash transaction
valued at $14.1 billion, plus assumption of U.S. Steel’s ($800 million)
debt for a total equivalent buyout offer of $14.9 billion. Under this
acquisition agreement, Nippon Steel will honor current U.S. Steel labor
agreements and U.S. Steel will retain its current corporate name for its
operations going forward. The acquisition offer was approved by the
Boards of Directors of both firms but still needs U.S. Steel shareholder
and official regulatory approvals. Both firms anticipate completing this
transaction by second- or third-quarter 2024. None of Nippon Steel’s
U.S. steel facilities currently produce tin mill products.
Acquisition
offer
USW 	December 2023— In opposition to Nippon Steel’s acquisition offer for
U.S. Steel, USW International President David McCall states that:
“{N}either U.S. Steel nor Nippon reached out to our union regarding the
deal, which is in itself a violation of our partnership agreement that
requires U.S. Steel to notify us of a change in control or business
conditions. Based on this alone, the USW does not believe that Nippon
understands the full breadth of the obligations of all our agreements,
and we do not know whether it has the capacity to live up to our
existing contract. This includes not just the day-to-day commitments of
our labor agreement, but also significant obligations to fund pension
and retiree insurance benefits that are the most extensive in the
domestic steel industry.”
Plant idling 	UPI 	November 2023— Reported official idling announcement for UPI.
Production operations conclude in December 2023 with remaining
shipping operations anticipated to conclude by March 2024.
Labor
grievance filing
USW 	January 2024— The USW International and five locals representing
U.S. Steel employees file grievances against the acquisition. They
contend that provisions of the basic labor agreement were violated
during the acquisition review process and request dispute resolution.
According to the USW, information was not shared about the sale
process and the union was neither consulted nor reassured that its
collective bargaining agreements will be upheld after completion of the
acquisition.
Acquisition
financing
Nippon Steel 	January 2024— Announcement of securing $16 billion in bridge loans
from three major Japanese banks, to finance its acquisition of U.S.
Steel, consisting of $6.5 billion from Sumitomo Mitsui Financial Group,
$5.5 billion from Mitsubishi UFJ Financial Group, and $4 billion from
Mizuho Financial Group.
Table continued.

III-6
Table III-1 Continued
TCCSS: Developments in the U.S. industry since January 1, 2017
Item 	Firm 	Event
Acquisition
offer rescinded
Cleveland-
Cliffs
February 2024— Announcement that the firm’s offer of $54 per share in
cash and stock is no longer available as a fallback option for U.S. Steel
if Nippon Steel’s $55 per share all-cash offer is not concluded.
Acquisition
follow-up
Nippon Steel 	February 2024— Announcement that Nippon Steel is on schedule to
conclude its acquisition of U.S. Steel by September. Corporate
representatives met with U.S. Congressional Members in January and
plan to reach out to USW representatives.
Plant idling,
layoffs
Cleveland-
Cliffs
February 2024— Announcement of indefinite idling of the Weirton
facility by April 2024 and issuance of a WARN to approximately 900
employees, who will be provided with either relocation opportunities to
other Cleveland-Cliffs facilities or severance packages. The
announcement cites the Commission’s negative determinations on tin
mill products originating in Canada, China, Germany, and terminated
investigation on subject products originating in South Korea.
Labor contract
negotiations
Nippon
Steel, USW
February 2024— Nippon Steel and USW sign a nondisclosure
agreement ahead of negotiating acceptance of existing labor
agreements with U.S. Steel.
Labor contract
negotiations
Nippon
Steel, USW
March 2024— First negotiating meeting. Although Nippon Steel
representatives reportedly reiterated their firm’s intentions to abide by
the existing collective labor agreements, the USW leaders characterized
the meeting as failing to address specific union concerns about
corporate financial transparency and agreement enforcement with the
Nippon Steel North America subsidiary and the foreign parent firm.
Shareholders
acquisition
approval
U.S. Steel 	April 2024— U.S. Steel’s shareholders overwhelmingly voted to
approve Nippon Steel’s acquisition offer. After this special shareholders’
meeting held on April 12, 2024, Takahiro Mori, Vice Chairman pledged
his firm’s commitments:
(1) As a wholly owned subsidiary, U.S. steel will have access to Nippon
Steel’s products, operational and production technologies, and
decarbonization technologies;
(2) Retention of the U.S. Steel name and Pittsburgh headquarters, no
transfers of jobs or production overseas, and continued existing
relationships with suppliers, customers, and communities;
(3) Recognition of the USW as the bargaining representative for
represented employees, honoring all commitments under the Basic
Labor Agreement (“BLA”), and accepting all agreements between
U.S. Steel and the USW; and
(4) Reiteration of prior commitments to no layoffs or plant closures, job
and pension security, and new capital investments totaling at least
$1.4 billion during 2024–26 at facilities covered by the BLA.
Plant idling,
layoffs
Cleveland-
Cliffs
April 2024— The USW will continue its opposition to Nippon Steel’s
acquisition of U.S. Steel after the shareholders vote, according to
District 7 Director, Michael Millsap, and International President, David
McCall, as the transaction is still subject to pending antitrust and
national security reviews.
Table continued.

III-7
Table III-1 Continued
TCCSS: Developments in the U.S. industry since January 1, 2017
Item 	Firm 	Event
Plant idling,
layoffs
Cleveland-
Cliffs
April 2024— Cleveland-Cliffs and USW representatives clarified that the
Weirton facility is not being shut down, but rather, operations for
TCCSS, black plate, and other steel products are being indefinitely
idled. The facility is not for sale, many employees chose to remain in the
area, and the production equipment is being preserved for any eventual
restarting of operations. The scheduled cessation of operations was
moved back from April 15 to April 20 to resolve the remaining aspects of
the employees’ union contracts. All production operations ceased with
this facility in an indefinitely idled status as of April 20, 2024.
Source: U.S. Steel, “U.S. Steel Issues Statement On Midwest Plant Restart,” News release, April 18,
2017, https://www.ussteel.com/newsroom/-/blogs/u-s-steel-issues-statement-on-midwest-plant-restart;
U.S. Steel, “U.S. Steel Issues New Update On April 11 Midwest Plant Incident,” News release, April 14,
2017, https://www.ussteel.com/newsroom/-/blogs/u-s-steel-issues-new-update-on-april-11-midwest-plant-
incident;
U.S. Steel, “U.S. Steel Issues Update On April 11 Midwest Plant Incident,” News release, April 13, 2017,
https://www.ussteel.com/newsroom/-/blogs/u-s-steel-issues-update-on-april-11-midwest-plant-incident;
Ohio Coatings, “ISO 9001:2015 Certification,” News, November 21, 2017,
https://ohiocoatingscompany.com/news/;
Business Facilities, “U.S. Steel To Invest $750M In Indiana,” August 16, 2018,
https://businessfacilities.com/u-s-steel-invest-750m-gary-indiana/;
CNBC, “US Steel to Idle Three Blast Furnaces, Hurt by Lower Prices and Soft Demand,” June 19, 2019,
https://www.cnbc.com/2019/06/19/us-steel-to-idle-three-blast-furnaces-hurt-by-lower-prices-and-soft-
demand.html;
Christopher Lawrence, “Poor Crops Result in Layoffs in Weirton,” Metro News (Charleston, West
Virginia), August 21, 2019, https://wvmetronews.com/2019/08/21/poor-crops-result-in-layoffs-in-weirton/;
Summer Wilkinson, “Weirton Business to Lay Off 100 Employees,” WTOV-9, August 20, 2019,
https://wtov9.com/news/local/weirton-business-to-lay-off-100-employees;
Justine Coyne, “US Steel to Idle East Chicago Tin Mill in Indiana,” S&P Global Commodity Insights,
August 23, 2019, https://www.spglobal.com/commodityinsights/en/market-insights/latest-
news/metals/082319-us-steel-to-idle-east-chicago-tin-mill-in-indiana;
Joseph S. Pete, “U.S. Steel to Idle East Chicago Tin, Lay Off Around 150 Workers; ArcelorMittal Laying
Off Tin Workers in West Virginia,” Indiana Economic Digest, August 26, 2019,
https://indianaeconomicdigest.net/Content/Most-Recent/Quality-of-Life/Article/U-S-Steel-to-idle-East-
Chicago-Tin-lay-off-around-150-workers-ArcelorMittal-laying-off-tin-workers-in-West-
Virginia/31/352/97175;
Katherine Cox, “U.S. Steel Closing East Chicago Tin Plant Indefinitely, Up To 300 Workers Impacted,”
WRTV Indianapolis, September 2019, https://www.wrtv.com/u-s-steel-closing-east-chicago-tin-plant-
indefinitely-up-to-300-workers-impacted;
Wesley Mills, “U.S. Steel Updates Layoff Notice to State,” Inside Indiana Business, October 30, 2019,
https://www.insideindianabusiness.com/articles/us-steel-updates-layoff-notice-to-state;
U.S. Steel, “U.S. Steel Acquires Remaining 50 Percent Ownership Interest in USS-POSCO Industries
(UPI) from POSCO-California Corporation,” March 1, 2020, https://investors.ussteel.com/news/news-
details/2020/U.-S.-Steel-Acquires-Remaining-50-Percent-Ownership-Interest-in-USS-POSCO-Industries-
UPI-From-POSCO-California-Corporation/default.aspx;
Table continued.

III-8
Table III-1 Continued
TCCSS: Developments in the U.S. industry since January 1, 2017
Source: Globe Newswire, “U.S. Steel Acquires Remaining 50 Percent Ownership Interest in USS-POSCO
Industries (UPI) From POSCO-California Corporation,” News release, March 1, 2020,
https://www.globenewswire.com/en/news-release/2020/03/01/1993067/0/en/U-S-Steel-Acquires-
Remaining-50-Percent-Ownership-Interest-in-USS-POSCO-Industries-UPI-From-POSCO-California-
Corporation.html;
UPI, “Tinplate” web page,©2023, https://www.ussupi.com/products/tinplate/, retrieved June 21, 2023;
IW Staff, “Cleveland-Cliffs Completes ArcelorMittal USA Purchase,” Industry Week, December 10, 2020,
https://www.industryweek.com/leadership/growth-strategies/article/21149986/clevelandcliffs-completes-
arcelormittal-usa-purchase;
Weirton Daily Times Staff, “Cleveland Cliffs Takes Over ArcelorMittal’s United States Assets, Including
Weirton Tin Mill,” December 10, 2020, https://www.weirtondailytimes.com/news/local-
news/2020/12/cleveland-cliffs-takes-over-arcelormittals-united-states-assets-including-weirton-tin-mill/;
Cleveland-Cliffs, “Cleveland-Cliffs Inc. Completes Acquisition of ArcelorMittal USA,” News release,
December 9, 2020, https://www.clevelandcliffs.com/news/news-releases/detail/8/cleveland-cliffs-inc-
completes-acquisition;
BusinessWire, “Cleveland-Cliffs Inc. to Acquire ArcelorMittal USA,” September 28, 2020,
https://www.businesswire.com/news/home/20200927005083/en/Cleveland-Cliffs-Inc.-to-Acquire-
ArcelorMittal-USA;
Richard Hurd, “Pittsburg-based Steel Company Reaches $4 Million Settlement After Violating
Environmental Regulations,” The East Bay Times (Livermore, California), August 18, 2021,
https://www.eastbaytimes.com/2021/08/18/pittsburg-based-steel-company-reaches-4-million-settlement-
after-violating-environmental-regulations/;
Abby Verret, “US Steel to Close UPI, Sell Property in 2023,” Fastmarkets, January 18, 2022,
https://www.fastmarkets.com/insights/us-steel-to-close-upi-sell-property-in-
2023#:~:text=US%20Steel%20Corp%20has%20informed,2023%2C%20several%20market%20participan
ts%20said;
U.S. Steel, “About Us, Locations, East Chicago Tin,” ©2023, https://www.ussteel.com/about-
us/locations#:~:text=East%20Chicago%20Tin, retrieved April 12, 2024;
U.S. Steel, “U.S. Steel 2022 Form 10-K Report,” February 3, 2023, pp. 9, 49 (as filed),
https://investors.ussteel.com/sec-filings/all-sec-filings?page=10##document-3683-0001163302-23-
000016-2;
U.S. Steel, “U.S. Steel’s 2019 Form 10-K Report,” February 14, 2020, pp. 34, 74 (as filed),
https://investors.ussteel.com/sec-filings/all-sec-filings?page=41##document-1638-0001163302-20-
000012-2;
Nichole Bastin, “UPI Closure to Have Limited Impact on Steel Prices,” Metal Miner, August 22, 2022,
https://agmetalminer.com/2022/08/22/upi-closure-to-have-limited-impact-on-steel-prices/;
Wesley Mills, “U.S. Steel Tin Mill Future Remains Uncertain,” Inside Indiana Business, October 13, 2022,
https://www.insideindianabusiness.com/articles/u-s-steel-tin-mill-future-remains-uncertain;
Cleveland-Cliffs, “Cleveland-Cliffs and the United Steelworkers Reach Tentative Labor Agreement,” News
release, August 27, 2022, https://www.clevelandcliffs.com/news/news-releases/detail/555/cleveland-cliffs-
and-the-united-steelworkers-reach;
Cleveland-Cliffs, “Cleveland-Cliffs Announces Ratification of New Labor Agreement with the USW
Covering 12,000 Union Members” News release, October 12, 2022,
https://www.clevelandcliffs.com/news/news-releases/detail/559/cleveland-cliffs-announces-ratification-of-
new-labor;
Table continued.

III-9
Table III-1 Continued
TCCSS: Developments in the U.S. industry since January 1, 2017
Source: Reuters, “Union, Cleveland-Cliffs Ratify New Labor Agreement,” October 12, 2022,
https://www.reuters.com/world/us/usw-union-cleveland-cliffs-ratify-new-labor-agreement-2022-10-12/;
U.S. Steel, “U. S. Steel Announces Ratification of New Collective Bargaining Agreements by United
Steelworkers,” News release, December 20, 2022, https://investors.ussteel.com/news-events/news-
releases/detail/7/u-s-steel-announces-ratification-of-new-collective;
USW, “Steelworkers Ratify Historic Agreement with Cleveland-Cliffs Steel,” News release, October 12,
2022, https://m.usw.org/news/media-center/releases/2022/steelworkers-ratify-historic-agreement-with-
cleveland-cliffs-steel;
USW, “Steelworkers Ratify Four-Year Contract with U.S. Steel,” News release, December 20, 2022,
https://m.usw.org/news/media-center/releases/2022/steelworkers-ratify-four-year-contract-with-u-s-steel;
Joseph S. Pete, “U.S. Steel to Lay Off 244 Workers When It Idles Tin Operations at Gary Works,” The
Times of Northwest Indiana (Muncie, Indiana), December 29, 2022,
https://www.nwitimes.com/news/local/u-s-steel-to-lay-off-244-workers-when-it-idles-tin-operations-at-
gary/article_697b1039-c566-5cd4-b2f8-e07800784625.html;
Heather Pfundstein, “U.S. Steel to Lay Off 244 Employees at Gary Works,” Northwest Indiana Business
Magazine, December 31, 2022, https://nwindianabusiness.com/community/business-news/u-s-steel-to-
lay-off-244-employees-at-gary-works/52912/;
Alexander Brown, “U.S. Steel Details Layoffs at Gary Works,” Inside Indiana Business, December 29,
2022, https://www.insideindianabusiness.com/articles/u-s-steel-details-layoffs-at-gary-works;
Weirton Daily Times Staff, “Layoffs Coming to Cleveland-Cliffs in Weirton,” May 13, 2023,
https://www.weirtondailytimes.com/news/local-news/2023/05/layoffs-coming-to-cleveland-cliffs-in-weirton/;
William Steinbacht, “300 Steelworkers in Weirton to be Laid Off in June,” WTOV-9, May 9, 2023,
https://wtov9.com/news/local/300-steelworkers-in-weirton-to-be-laid-off-in-june-usw-weirton-mark-glyptis;
Edward DiorioSun, “Officials Meet Following Steel Plant Layoff to Alert Those in Need of Possible
Benefits,” WTOV-9, May 21, 2023, https://wtov9.com/news/local/officials-meet-following-steel-plant-layoff-
to-alert-those-in-need-of-possible-benefits;
Association for Iron & Steel Technology (“AIST”), “Multiple Offers on Table: for U.S. Steel,” Steel News,
August 17, 2023, https://www.aist.org/news/steel-news/2023/august/14-18-august/multiple-offers-on-
table-for-u-s-steel;
U.S. Steel, “U.S. Steel Confirms Receipt of Unsolicited Proposals from Cleveland-Cliffs and Multiple
Other Parties; Reaffirms Competitive Strategic Review Process to Maximize Stockholder Value,” News
release, August 13, 2023, https://investors.ussteel.com/news-events/news-releases/detail/641/u-s-steel-
confirms-receipt-of-unsolicited-proposals-from;
AIST, “Esmark Ends Effort to Acquire U.S. Steel,” Steel News, August 23, 2023,
https://www.aist.org/news/steel-news/2023/august/21-25-august/esmark-ends-effort-to-acquire-u-s-steel;
Katie Reagan, “Esmark Inc. Respects History, Working Relationship and Position of USW. Therefore, Will
Not Make a Bid for U.S. Steel,” BusinessWire, August 23, 2023,
https://www.businesswire.com/news/home/20230823390935/en/Esmark-Inc.-Respects-History-Working-
Relationship-and-Position-of-USW.-Therefore-Will-Not-Make-a-Bid-for-U.S.-Steel;
David B. Burritt (President), David S. Sutherland (Chairman), “Stockholder Update Letter,” U.S. Steel,
August 29, 2023,
https://d1io3yog0oux5.cloudfront.net/_60f25a8c4f072661bb0ee8d88891f612/ussteel/db/3199/30186/pdf/
U.+S.+Steel+-+Stockholder+Update+Letter+8.29.23.pdf;
Gregory Roumeliotis and Emma-Victoria Farr, “ArcelorMittal Weighs Possible Bid for US Steel,” Reuters,
August 16, 2023, https://www.reuters.com/markets/deals/arcelormittal-weighs-possible-bid-us-steel-
sources-2023-08-16/;
Bianca Flowers, “Steel Union Head Calls ArcelorMittal Bid for US Steel 'Foolish,'” Reuters, August 16,
2023, https://www.reuters.com/markets/deals/steel-union-head-calls-arcelormittal-bid-us-steel-foolish-
2023-08-16/;
Table continued.

III-10
Table III-1 Continued
TCCSS: Developments in the U.S. industry since January 1, 2017
Source: Gregory Roumeliotis, Anirban Sen, David Carnevali, “Cleveland-Cliffs Clashes with U.S. Steel as
Sale Process Gets Underway— Sources,” Reuters, September 20, 2023,
https://finance.yahoo.com/news/cleveland-cliffs-clashes-u-steel-
214504560.html?guccounter=1&guce_referrer=aHR0cHM6Ly93d3cuZ29vZ2xlLmNvbS8&guce_referrer_
sig=AQAAAF30GAZbe6-C2vk40ajrjTv9WjJdfeTb886tFZAuTCq-e6G5TIwqw5-
TO_Cpf4CYT2xdpTjT2tTbxAA7ZD4pTO5qNArWp7NRSmMbjgzURq0w6uiVbTZgy92qrWN3t0OffZ1tby8w
o6cjdA3aBDIHg4xCqrnj5xnKlf7WyojqSKOA;
Andrew Willis, “Stelco Wants All, or Some, of U.S. Steel. But It’s Complicated,” The Globe and Mail
(Toronto, Ontario), September 22, 2023, https://www.theglobeandmail.com/business/article-stelco-wants-
all-or-some-of-us-steel-but-its-complicated/;
Evan Robinson-Johnson, “U.S. Steel's Dealmaking Horse Race—and the Surprise Ending,” Pittsburgh
Post-Gazette, January 27, 2024, https://www.post-gazette.com/business/powersource/2024/01/26/us-
steel-nippon-sale-bid/stories/202401250108;
CBS News Bay Area, “East Bay Lawmakers Push to Keep USS-Posco Steel Mill in Pittsburg Open,”
November 10, 2023, https://www.cbsnews.com/sanfrancisco/news/pittsburg-members-of-congress-push-
to-keep-uss-posco-industries-steel-mill-open/;
U.S. Steel, “Nippon Steel Corporation (NSC) to Acquire U.S. Steel, Moving Forward Together as the ‘Best
Steelmaker with World-Leading Capabilities,’” News release, December 18, 2023,
https://www.businesswire.com/news/home/20231218603022/en/;
U.S. Steel, “Acquisition of United States Steel Corp. by Nippon Steel Corp.,” Schedule 14A Proxy
Statement, Final Transcript of Joint Call and Webcast, December 18, 2023,
https://www.nipponsteel.com/common/secure/en/ir/library/pdf/20231218_500.pdf;
Nippon Steel and U.S. Steel, “Nippon Steel Corporation to Acquire U.S. Steel, Moving Forward Together
as the 'Best Steelmaker with World-Leading Capabilities,’” Nippon Steel-U.S. Steel transaction investor
presentation, December 18, 2023, https://assets-global.website-
files.com/657e2ba174351fdd7e22a128/65803f14dd25c3dcb0eb0dd1_USS%20-
%20NSC%20Investor%20Presentation.pdf;
Nippon Steel, “Acquisition of United States Steel Corporation,” Press release, December 18, 2023
(English translation), https://www.nipponsteel.com/common/secure/en/ir/library/pdf/20231218_100.pdf;
Nippon Steel, “Acquisition of U.S. Steel,” Nippon Steel Investor and Shareholder Presentation, December
18, 2023, https://www.nipponsteel.com/common/secure/en/ir/library/pdf/20231218_200.pdf;
Robert Tita and River Davis, “Nippon Steel to Acquire U.S. Steel for $14.1 Billion,” Wall Street Journal,
December 18, 2023, https://www.wsj.com/business/deals/nippon-steel-to-acquire-u-s-steel-for-55-shr-
854c6f73;
Yuka Obayashi, “Nippon Steel Confident of Completing US Steel Acquisition,” Reuters, January 5, 2024,
https://www.reuters.com/markets/deals/nippon-steel-confident-completing-us-steel-acquisition-2024-01-
05/;
USW, “USW Slams Nippon Plan to Acquire USS,” News release, December 18, 2023,
https://www.usw.org/news/media-center/releases/2023/usw-slams-nippon-plan-to-acquire-us;
Anya Litvak, “'Talk is Cheap,' Says Union After Filing Grievances Against U.S. Steel Over Its Sale to
Nippon,” Pittsburgh Post-Gazette, January 13, 2024, https://www.post-gazette.com/business/pittsburgh-
company-news/2024/01/13/us-steel-nippon-steel-corp-united-steel-workers/stories/202401130068;
Strategic Research Institute (“SRI”), “Decline in Steel: USS-UPI Shutdown Looms,” Steel Guru Business
News, November 1, 2023, https://www.steelguru.com/steel/decline-in-steel-uss-upi-shutdown-looms;
Judith Prieve, “End of a Bay Area Era? Pittsburg’s Steel Mill Idles Amid Sale to Japanese Company,” The
Mercury News (San Jose, CA), January 20, 2024, https://www.mercurynews.com/2024/01/20/end-of-a-
bay-area-era-pittsburgs-steel-mill-idles-amid-sale-to-japanese-company/;
Table continued.

III-11
Table III-1 Continued
TCCSS: Developments in the U.S. industry since January 1, 2017
Source: AIST, “Goncalves: Cleveland-Cliffs Won’t Backstop U.S. Steel Sale,” Steel News, January 5,
2024, https://www.aist.org/news/steel-news/2024/february/5-9-february-2024/goncalves-cleveland-cliffs-
won%e2%80%99t-backstop-u-s-stee;
Joseph Deaux, “Cliffs CEO Says His US Steel Bid Is ‘Absolutely Gone,’” Yahoo Finance, February 1,
2024, https://finance.yahoo.com/news/cliffs-ceo-says-us-steel-202650531.html;
Reuters, “Nippon Steel Says Japan's 3 Megabanks Plan $16 Bln Loan for U.S. Steel Acquisition,”
January 30, 2024, https://www.reuters.com/markets/deals/japans-3-megabanks-loan-nippon-steel-16-bln-
us-steel-acquisition-bloomberg-2024-01-30/;
Aaron J. Brown, “The Steelworkers Strike Back; Cleveland-Cliffs Stands to Gain,” Minnesota Reformer
(St. Paul, Minnesota), February 6, 2024, https://minnesotareformer.com/2024/02/06/the-steelworkers-
strike-back-cleveland-cliffs-stands-to-gain/;
Yuka Obayashi and Katya Golubkova, “Nippon Steel Says on Track to Close U.S. Steel Deal by
September,” Japan Times, February 7, 2024,
https://www.japantimes.co.jp/business/2024/02/07/companies/nippon-steel-deal-september/;
Cleveland-Cliffs, “Cleveland-Cliffs to Idle Weirton Tinplate Facility Following Unfavorable ITC Ruling,”
News release, February 15, 2024, https://www.clevelandcliffs.com/news/news-
releases/detail/622/cleveland-cliffs-to-idle-weirton-tinplate-facility;
USITC, “Tin Mill Products from Canada, China, and Germany Do Not Injure U.S. Industry, Says USITC,”
News release 24-013, February 6, 2024,
https://www.usitc.gov/press_room/news_release/2024/er0206_64836.htm;
Joseph Deaux, “United Steelworkers Union Signs NDA With Nippon Steel to Advance Talks,” Yahoo!
Finance, February 26, 2024, https://finance.yahoo.com/news/united-steelworkers-union-signs-nda-
210556615.html;
Shuhei Ochiai, “Nippon Steel Executive to Negotiate with Union on U.S. Steel Deal,” Nikkei Asia, March
5, 2024, https://asia.nikkei.com/Business/Business-deals/Nippon-Steel-executive-to-negotiate-with-union-
on-U.S.-Steel-deal;
Michael Millsap and David McCall, “Meeting with Nippon Yields No Progress,” March 7, 2024,
https://m.usw.org/union/mission/industries/metals/resources/bargaining-with-uss/meeting-with-nippon-
yields-no-progress;
Michael Millsap and David McCall, “Smoke and Mirrors USS/Nippon Style,” February 26, 2024,
https://m.usw.org/union/mission/industries/metals/resources/bargaining-with-uss/smoke-and-mirrors-uss-
nippon-style;
U.S. Steel, “U.S. Steel Stockholders Approve Transaction with Nippon Steel Corporation (NSC),” News
release, April 12, 2024, https://investors.ussteel.com/news-events/news-releases/detail/673/u-s-steel-
stockholders-approve-transaction-with-nippon;
Nippon Steel, “Nippon Steel’s Acquisition of U.S. Steel Approved by U.S. Steel Stockholders,” News
release, April 13, 2024, https://www.nipponsteel.com/common/secure/en/news/20240413_100.pdf;
Craig Howell, “Cleveland Cliffs in Weirton idled,” The Marietta Times (Marietta, Ohio), April 22, 2024,
https://www.mariettatimes.com/news/local-news/2024/04/cleveland-cliffs-in-weirton-idled/;
Joseph S. Pete, “USW Says U.S. Steel Board Vote for Nippon Acquisition ‘Isn’t End of Story,’” The Times
of Northwest Indiana, April 15, 2024, https://www.nwitimes.com/news/local/usw-says-u-s-steel-board-
vote-for-nippon-acqusition-isnt-end-of-story/article_76c74e74-fb45-11ee-8533-875ffd877136.html;
Mark Glyptis, “Weirton Tin Mill Has a Future,” Letter to the Editor, The Intelligencer/Wheeling News-
Register, April 13, 2024, https://www.theintelligencer.net/opinion/letters-to-the-editor/2024/03/weirton-tin-
mill-has-a-future/;
Craig Howell, “Weirton Plant Won’t be Dismantled as Part of Idling,” Weirton Daily Times, April 5, 2024,
https://www.weirtondailytimes.com/news/local-news/2024/04/weirton-plant-wont-be-dismantled-as-part-of-
idling/;
Table continued.

III-12
Table III-1 Continued
TCCSS: Developments in the U.S. industry since January 1, 2017
Source: Cleveland-Cliffs, response to NOI, July 3, 2023, p. 1, exh. 2;
U.S. Steel, response to NOI, July 3, 2023, pp. 17–18, 21, exhs. 7, 8, 9;
*** questionnaire response, Attachment A;
Cleveland-Cliffs, prehearing brief, March 28, 2024, pp. 1–2, exh. 1, 4;
U.S. Steel, prehearing brief, March 28, 2024, pp, 11–12, exh. 1;
Japanese respondents’ prehearing brief, March 28, 2024, p. 9, exh. 6;
Hearing transcript, April 9, 2024, pp. 18–19 (Kopf), 23, 25–27, 44–45 (Smith), 36 (Glyptis);
Cleveland-Cliffs’ posthearing brief, April 16, 2024, exh. 1: Declaration of Gordon O'Neill, paras. 5, 10, 11;
U.S. Steel’s posthearing brief, April 16, 2024, pp. 5–6, 14; exh. 1, pp. 18–19.
Changes experienced by the industry
In this proceeding, U.S. producers were asked to report any change in the character of
their operations or organization relating to the production of TCCSS since the last five-year
review in 2017. Table III-2 presents reported changes identified by the domestic producers.
Since the last review, there have been new entrants into the U.S. TCCSS market (Cleveland-
Cliff’s acquisition of ArcelorMittal’s tin mill production facility in Weirton, West Virginia) but
also industry consolidation (U.S. Steel’s acquisition of USS-UPI). U.S. producers also reported
idling and closures (at U.S. Steel’s plants in East Chicago, Gary Works, and USS-UPI), production
curtailments (***), and planned layoffs (at Cleveland-Cliffs’ plant in Weirton).

III-13
Table III-2
TCCSS: U.S. producers’ reported changes in operations since January 1, 2017, by type of change
and firm
Type of
change 	Firm name and narrative on changes in operations
Plant
closings
***
Prolonged
shutdowns
***
Prolonged
shutdowns
***
Production
curtailments
***
Acquisitions 	***
Table continued.

III-14
Table III-2 Continued
TCCSS: U.S. producers’ reported changes in operations since January 1, 2017, by type of change
and firm
Type of
change 	Firm name and narrative on changes in operations
Acquisitions 	***
Other 	***
Other 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Anticipated changes in operations
In this proceeding, the Commission asked U.S. producers if the COVID-19 pandemic had
an impact on their operations relating to TCCSS. Two firms, ***, responded to the question by
stating that the TCCSS industry was deemed a critical industry at the beginning of the pandemic
and that TCCSS producers/workers were considered essential. The firms noted that demand for
tin products actually increased at the onset of the COVID-19 pandemic due to food availability
and security concerns. However, starting in late 2022, U.S. producers reported a decrease in
demand for domestically produced TCCSS and, ***, a shift towards imports of TCCSS.
In December 2023, U.S. Steel announced its agreement to be acquired by Japan’s largest
steelmaker, Nippon Steel, in an all-cash transaction valued at $14.1 billion. The sale is currently
pending U.S. regulatory approval. In February 2024, Cleveland-Cliffs announced that it will
indefinitely idle its Weirton, West Virginia plant in April 2024.

III-15
U.S. production, capacity, and capacity utilization
Table III-3 presents U.S. producers’ installed and practical capacity and production on
the same equipment. Consistent with the closure and idling of several TCCSS production plants
since 2017 (as noted above), capacity and production decreased across all metrics during 2021
through 2023. Practical overall capacity and practical TCCSS capacity were the same in each
period, as U.S. producers noted that they do not produce alternative products on the
equipment used to produce TCCSS. Practical overall capacity declined year-over-year,
decreasing by *** percent from *** short tons in 2021 to *** short tons in 2023. Practical
overall production also declined year-over-year, decreasing by *** percent from *** short tons
in 2021 to *** short tons in 2023.
Table III-3
TCCSS: U.S. producers’ installed and practical capacity, production, and utilization on the same
equipment as in-scope production, by measure and period
Capacity and production in short tons; utilization in percent
Item 	Measure 	2021 	2022 	2023
Installed overall 	Capacity 	*** 	*** 	***
Installed overall 	Production 	*** 	*** 	***
Installed overall 	Utilization 	*** 	*** 	***
Practical overall 	Capacity 	*** 	*** 	***
Practical overall 	Production 	*** 	*** 	***
Practical overall 	Utilization 	*** 	*** 	***
Practical TCCSS 	Capacity 	*** 	*** 	***
Practical TCCSS 	Production 	*** 	*** 	***
Practical TCCSS 	Utilization 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

III-16
Constraints on capacity
Table III-4 presents U.S. producers’ reported narratives regarding practical capacity
constraints. U.S. producers list material inputs and labor as production constraints. In terms of
“other constraints,” U.S. producers identified a combination of production bottlenecks,
available labor force, raw material supplies, and demand/order volume as TCCSS capacity
constraints.
Table III-4
TCCSS: U.S. producers’ reported capacity constraints, by type of constraint and firm
Type of
constraint 	Firm name and narrative on constraints to practical overall capacity
Production
bottlenecks
***
Existing labor
force
***
Supply of
material inputs
***
Other constraints 	***
Other constraints 	***
Other constraints 	***
Source: Compiled from data submitted in response to Commission questionnaires.

III-17
Operations data
Table III-5 and figure III-1 present U.S. producers’ capacity, production, and capacity
utilization. Practical TCCSS capacity, production, and capacity utilization declined in each year
during 2021-23. Practical TCCSS capacity decreased by *** percent from *** short tons in 2021
to *** short tons in 2023. Production decreased by *** percent from *** short tons in 2021 to
*** short tons in 2023.5 Capacity utilization decreased by *** percentage points from ***
percent in 2021 to *** percent in 2023.
Table III-5
TCCSS: U.S. producers’ output, by firm and period
Practical capacity
Capacity in short tons
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table III-5 Continued
TCCSS: U.S. producers’ output, by firm and period
Production
Production in short tons
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
5 ***. The firm’s production increased by *** percent during 2021-22 but then decreased by ***
percent during 2022-23, reflecting a total decrease of *** percent during 2021-23. *** noted that ***.
*** U.S. producer questionnaire at II-2b.

III-18
Table III-5 Continued
TCCSS: U.S. producers’ output, by firm and period
Capacity utilization
Capacity utilization in percent
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table III-5 Continued
TCCSS: U.S. producers’ output, by firm and period
Share of production
Share in percent
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

III-19
Figure III-1
TCCSS: U.S. producers’ capacity, production, and capacity utilization, by period
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires.
Alternative products
None of the U.S. producers reported production of out-of-scope products on the same
equipment and machinery used to produce TCCSS.

III-20
U.S. producers’ U.S. shipments and exports
Table III-6 presents U.S. producers’ U.S. shipments, export shipments, and total
shipments. The vast majority of U.S. producers’ shipments were U.S. commercial shipments.6
Producers’ U.S. shipments, by quantity, declined in each period, decreasing by *** percent
from *** short tons in 2021 to *** short tons in 2023. Exports, by quantity, accounted for a
small share of total shipments (only *** percent in each year during 2021-23).7 Total
shipments, consequently, followed the trend of U.S. producers’ U.S. shipments and declined
year-over-year during 2021-23.
Table III-6
TCCSS: U.S. producers’ total shipments, by destination and period
Quantity in short tons; value in 1,000 dollars; unit value in dollars per short ton; shares in percent
Item 	Measure 	2021 	2022 	2023
U.S. shipments 	Quantity 	*** 	*** 	***
Export shipments 	Quantity 	*** 	*** 	***
Total shipments 	Quantity 	*** 	*** 	***
U.S. shipments 	Value 	*** 	*** 	***
Export shipments 	Value 	*** 	*** 	***
Total shipments 	Value 	*** 	*** 	***
U.S. shipments 	Unit value 	*** 	*** 	***
Export shipments 	Unit value 	*** 	*** 	***
Total shipments 	Unit value 	*** 	*** 	***
U.S. shipments 	Share of quantity 	*** 	*** 	***
Export shipments 	Share of quantity 	*** 	*** 	***
Total shipments 	Share of quantity 	*** 	*** 	***
U.S. shipments 	Share of value 	*** 	*** 	***
Export shipments 	Share of value 	*** 	*** 	***
Total shipments 	Share of value 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.
6 *** reported internal consumption. *** reported transfers to related firms.
7 *** reported exports. These exports were to ***.

III-21
U.S. producers’ inventories
Table III-7 presents U.S. producers’ end-of-period inventories and the ratio of these
inventories to U.S. producers’ production, U.S. shipments, and total shipments. End-of-period
inventories increased irregularly by *** percent during 2021-23. In 2021, inventories were ***
short tons, then increased to *** short tons in 2022,8 before decreasing to *** short tons in
2023. As a result of increased inventories, but declining production and shipments (as noted
above), the ratio of inventories to production, to U.S. shipments, and to total shipments
increased from 2021 to 2023.9
Table III-7
TCCSS: U.S. producers’ inventories and their ratio to select items, by period
Quantity in short tons; ratio in percent
Item 	Measure 	2021 	2022 	2023
End-of-period inventory 	Quantity 	*** 	*** 	***
Inventory to U.S. production 	Ratio 	*** 	*** 	***
Inventory to U.S. shipments 	Ratio 	*** 	*** 	***
Inventory to total shipments 	Ratio 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.
8 End-of-period inventories increased by *** percent during 2021-22. *** accounted for the vast
majority of end-of-period inventories in 2022. The firm reported that ***. Additionally, *** reported
that ***.
9 As reported above, U.S. Steel permanently idled its USS-UPI plant in Pittsburg, California at the end
of 2023. U.S. Steel reports that “***.” U.S. Steel’s posthearing brief, April 16, 2024, exh. 13, pp. 1-2.
In addition, in December 2023, U.S. Steel announced its agreement to be acquired by Japan’s largest
steelmaker, Nippon Steel, in an all-cash transaction valued at $14.1 billion. The sale is currently pending
U.S. regulatory approval.

III-22
U.S. producers’ imports from Japan
In this proceeding, ***.10 Table III-8 presents *** during 2021-23.
Table III-8
TCCSS: ***'s U.S. production, imports from ***, and ratio of imports to production, by source and
by period
Quantity in short tons; ratios in percent
Item 	Measure 	2021 	2022 	2023
U.S. production 	Quantity 	*** 	*** 	***
Imports from Japan 	Quantity 	*** 	*** 	***
Imports from Japan to U.S. production 	Ratio 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.
10 ***. Emails from *** on February 29, 2024 and April 15, 2024.

III-23
U.S. employment, wages, and productivity
In 2022, as previously noted, Cleveland-Cliffs and U.S. Steel ratified new labor
agreements with the United Steelworkers union. These agreements raised employees’ wages,
provided bonuses, and increased retirement/pension contributions. However, plant closures
and idling starting in 2022 into 2023 are reflected in the U.S. producers’ employment-related
data (table III-9).11 Production and related workers’ (PRWs’) hourly wages increased from 2021
to 2022 and further into 2023, increasing by *** percent during 2021-23. However, production
and total hours worked decreased during 2021-23. In addition, productivity declined sharply
after 2021. The combination of higher wage rates and lower productivity are reflected in the
rising unit labor costs to produce TCCSS between 2021 and 2023.
Table III-9
TCCSS: U.S. producers’ employment related information, by period
Item 	2021 	2022 	2023
Production and related workers (PRWs) (number) 	*** 	*** 	***
Total hours worked (1,000 hours) 	*** 	*** 	***
Hours worked per PRW (hours) 	*** 	*** 	***
Wages paid ($1,000) 	*** 	*** 	***
Hourly wages (dollars per hour) 	*** 	*** 	***
Productivity (short tons per 1,000 hours) 	*** 	*** 	***
Unit labor costs (dollars per short ton) 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.
11 On April 20, 2024, Cleveland-Cliff’s permanently idled its TCCSS plant in Weirton, West Virginia.
Cleveland-Cliffs reported that its 900 employees at the plant will be laid off starting April 2024.
However, some employees have been offered and taken positions at other Cleveland-Cliffs facilities.
Cleveland-Cliff’s witness testimony brief, April 9, 2024, pp. 7-8 (Glyptis); Hearing transcript, pp. 33-37
(Glyptis).

III-24
Part III: FINANCIAL E XPERIE NCE OF U.S. PROD UCERS
Financial experience of U.S. producers
Background12
Three U.S. producers (Cleveland-Cliffs, Ohio Coatings, and U.S. Steel) reported financial
results and related information on their U.S. TCCSS operations. The reported financial results
are based on information from accounting systems designed to generate/report overall
financial results on a U.S. GAAP basis and were reported for calendar-year periods.
With respect to their overall operations, publicly traded Cleveland-Cliffs and U.S. Steel
are both vertically integrated,13 while Ohio Coatings, a privately held company, is not. In
addition to the level of integration and underlying production operations, U.S. producers differ
to some extent in terms of product mix.14
In 2020, Cleveland-Cliffs and U.S. Steel both engaged in acquisition-related activity
involving TCCSS operations. Cleveland-Cliffs purchased the assets of ArcelorMittal USA
(December 2020), inclusive of the Weirton facility, and U.S. Steel acquired the remaining equity
interest in USS-UPI (March 2020).15 After the purchase of ArcelorMittal USA and as a result of
what Cleveland-Cliffs characterized as sustained underinvestment by the predecessor company,
Cleveland-Cliffs made capital expenditures and upgrades to the Weirton facility, as well as
12 The following abbreviations are used in the tables and/or text of this section: generally accepted
accounting principles (“GAAP”), fiscal year (“FY”), net sales (“NS”), cost of goods sold (“COGS”), selling,
general, and administrative expenses (“SG&A expenses”), average unit values (“AUVs”), research and
development (“R&D”), and return on assets (“ROA”).
13 TCCSS operations take place within the Steelmaking segment of Cleveland-Cliffs and the North
American Flat-Rolled segment of U.S. Steel. Cleveland-Cliffs 2023 10-K, p. 6., and U.S. Steel 2023 10-K, p.
4. Note: Steelmaking is Cleveland-Cliffs’ reportable segment and reflects all primary operations. As it
relates to the level of integration in general, Cleveland-Cliffs states “We have a vertically integrated
portfolio, which begins at the mining stage and goes all the way through the manufacturing of steel
products, including stamping, tooling and tubing. We have the unique advantage as a steel producer of
being fully or partially self-sufficient with our production of raw materials for steel manufacturing, which
includes iron ore pellets, HBI, scrap and coking coal.” Cleveland-Cliffs 2023 10-K, p. 6. Referencing its
non-mini mill steelmaking operations, U.S. Steel states “As a predominately integrated producer . . .
primary raw materials are iron units in the form of iron ore pellets and sinter ore, carbon units in the
form of coal and coke (which is produced from coking coal) and steel scrap”. U.S. Steel 2023 10-K, p. 16.
14 Tin-and-Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Third Review), USITC
Publication 4795, June 2018, p. III-13. Tin Mill Products from Canada, China, Germany, and South Korea,
Inv. Nos. 701-TA-685 and 731-TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, p.
VI-1.
15 Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-685 and 731-
TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, p. VI-2.

III-25
increased employment.16 Since 2020 U.S. Steel idled various operations related to its TCCSS
operations.17 Changes in operations noted by Ohio Coatings were the ***.18
Figure III-2 presents each responding firm’s share of the total reported net sales
quantity in 2023.
Figure III-2
TCCSS: U.S. producers’ share of net sales quantity in 2023, by firm
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires.
16 Ibid.
17 Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-685 and 731-
TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, p. VI-2. U.S. Steel reported that
USS-UPI was indefinitely idled in December 2023. U.S. Steel 2023 10-K, p. 14.
18 *** U.S. producer questionnaires response, section II-2a. ***. Ibid. ***. *** U.S. producer
questionnaires response, section III-9d. With respect to Weirton’s sale of black plate, Cleveland-Cliffs’
CEO stated “When we have fewer orders of tin plate for our tinning facility at Weirton, we will always
give priority to our own facilities. So, instead of having surplus of tin mill black plate that I can sell to
others, I have a shortage of orders of tin mill products out of Weirton. So I was using all my tin mill black
plate to supply the fewer orders that I had to Weirton and to also force the clients to put orders with us
and not with Ohio Coatings.” Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos.
701-TA-685 and 731-TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, p. VI-2, fn.
10.

III-26
Operations on TCCSS
Table III-10 and table III-11 present income-and-loss data for the U.S. producers’ TCCSS
operations and corresponding changes in AUVs, respectively. Table III-12 presents a variance
analysis of the financial results.19 Appendix E presents selected company-specific financial
information.
Table III-10
TCCSS: U.S. producers’ results of operations, by item and period
Quantity in short tons; Value in 1,000 dollars
Item 	Measure 	2021 	2022 	2023
Total net sales 	Quantity 	*** 	*** 	***
Total net sales 	Value 	*** 	*** 	***
COGS: Raw materials 	Value 	*** 	*** 	***
COGS: Direct labor 	Value 	*** 	*** 	***
COGS: Other factory costs 	Value 	*** 	*** 	***
COGS: Total 	Value 	*** 	*** 	***
Gross profit or (loss) 	Value 	*** 	*** 	***
SG&A expenses 	Value 	*** 	*** 	***
Operating income or (loss) 	Value 	*** 	*** 	***
Interest expense 	Value 	*** 	*** 	***
All other expenses 	Value 	*** 	*** 	***
All other income 	Value 	*** 	*** 	***
Net income or (loss) 	Value 	*** 	*** 	***
Depreciation/amortization included
above 	Value 	*** 	*** 	***
Estimated cash flow from operations 	Value 	*** 	*** 	***
Table continued.
19 The Commission’s variance analysis is calculated in three parts: sales variance, COGS variance, and
SG&A expenses variance. Each part consists of a price variance (in the case of the sales variance) or a
cost or expense variance (in the case of the COGS and SG&A expenses variance), and a volume variance.
The sales or cost/expense variance is calculated as the change in unit price or per-unit cost/expense
times the new volume, while the volume variance is calculated as the change in volume times the old
unit price or per-unit cost/expense. As summarized at the bottom of the variance analysis, the price
variance is from sales, the cost/expense variance is the sum of those items from COGS and SG&A
variances, respectively, and the volume variance is the sum of the volume components of the net sales,
COGS, and SG&A expenses variances. The Commission’s variance analysis is more meaningful when
product mix remains the same throughout the period. In general, U.S. producers indicated that changes
in product mix were not an important factor in terms of explaining the pattern of average sales value
during the period. As indicated below, however, ***, reported that its average sales value was impacted
by changes in product mix and market conditions/demand.

III-27
Table III-10 Continued
TCCSS: U.S. producers’ results of operations, by item and period
Ratios in percent; Shares in percent; Unit values in dollars per short ton; Count in number of firms
reporting
Item 	Measure 	2021 	2022 	2023
COGS: Raw materials 	Ratio to NS 	*** 	*** 	***
COGS: Direct labor 	Ratio to NS 	*** 	*** 	***
COGS: Other factory costs 	Ratio to NS 	*** 	*** 	***
COGS: Total 	Ratio to NS 	*** 	*** 	***
Gross profit or (loss) 	Ratio to NS 	*** 	*** 	***
SG&A expenses 	Ratio to NS 	*** 	*** 	***
Operating income or (loss) 	Ratio to NS 	*** 	*** 	***
Net income or (loss) 	Ratio to NS 	*** 	*** 	***
COGS: Raw materials 	Share 	*** 	*** 	***
COGS: Direct labor 	Share 	*** 	*** 	***
COGS: Other factory costs 	Share 	*** 	*** 	***
COGS: Total 	Share 	*** 	*** 	***
Total net sales 	Unit value 	*** 	*** 	***
COGS: Raw materials 	Unit value 	*** 	*** 	***
COGS: Direct labor 	Unit value 	*** 	*** 	***
COGS: Other factory costs 	Unit value 	*** 	*** 	***
COGS: Total 	Unit value 	*** 	*** 	***
Gross profit or (loss) 	Unit value 	*** 	*** 	***
SG&A expenses 	Unit value 	*** 	*** 	***
Operating income or (loss) 	Unit value 	*** 	*** 	***
Net income or (loss) 	Unit value 	*** 	*** 	***
Operating losses 	Count 	*** 	*** 	***
Net losses 	Count 	*** 	*** 	***
Data 	Count 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Ratios represent the ratio to net sales value and shares represent the share of COGS.
Table III-11
TCCSS: Changes in AUVs between comparison periods
Changes in percent
Item 	2021-23 	2021-22 	2022-23
Total net sales 	*** 	*** 	***
COGS: Raw materials 	*** 	*** 	***
COGS: Direct labor 	*** 	*** 	***
COGS: Other factory costs 	*** 	*** 	***
COGS: Total 	*** 	*** 	***
Table continued.

III-28
Table III-11 Continued
TCCSS: Changes in AUVs between comparison periods
Changes in dollars per short ton
Item 	2021-23 	2021-22 	2022-23
Total net sales 	*** 	*** 	***
COGS: Raw materials 	*** 	*** 	***
COGS: Direct labor 	*** 	*** 	***
COGS: Other factory costs 	*** 	*** 	***
COGS: Total 	*** 	*** 	***
Gross profit or (loss) 	*** 	*** 	***
SG&A expenses 	*** 	*** 	***
Operating income or (loss) 	*** 	*** 	***
Net income or (loss) 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Period changes preceded by a “▲” represent an increase, while period changes preceded by a “▼”
represent a decrease.
Table III-12
TCCSS: Variance analysis on the operations of the U.S. producers between comparison periods
Value in 1,000 dollars
Item 	2021-23 	2021-22 	2022-23
Net sales price variance 	*** 	*** 	***
Net sales volume variance 	*** 	*** 	***
Net sales total variance 	*** 	*** 	***
COGS cost variance 	*** 	*** 	***
COGS volume variance 	*** 	*** 	***
COGS total variance 	*** 	*** 	***
Gross profit variance 	*** 	*** 	***
SG&A cost variance 	*** 	*** 	***
SG&A volume variance 	*** 	*** 	***
SG&A total variance 	*** 	*** 	***
Operating income price variance 	*** 	*** 	***
Operating income cost variance 	*** 	*** 	***
Operating income volume variance 	*** 	*** 	***
Operating income total variance 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.

III-29
Net sales
Commercial sales, primarily reflecting U.S. commercial shipments, was the *** category
of TCCSS sales reported. Given the ***, a single line item for sales is presented in the relevant
tables above.20
Quantity
On a company-specific basis, U.S. producers reported a mixed directional pattern in
2022: *** reporting modestly higher sales quantity, while *** reported lower sales quantities
(see table E-1). As noted previously, ***.21 In 2023, U.S. producers were directionally uniform
with all reporting lower sales quantity.
Value
A large share of TCCSS sales reflects fixed prices agreed to in annual sales contracts
negotiated during the fall of the preceding year.22 While average sales value and raw material
cost were directionally the same, TCCSS sales value does not include a direct or formulaic pass
through of primary raw material costs.23
The U.S. industry’s total TCCSS sales value increased to its highest level in 2022 and then
declined to its lowest level in 2023. The sales section of the variance analysis (table III-12)
20 ***. Email with attachment from ***, February 20, 2024.
21 ***. Ibid.
22 Tin-and-Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Third Review), USITC
Publication 4795, June 2018, p. IV-14, p. V-1. Tin Mill Products from Canada, China, Germany, and South
Korea, Inv. Nos. 701-TA-685 and 731-TA-1599-1601 and 1603 (Final), USITC Publication 5492, February
2024, p. VI-8.
23 Ibid.

III-30
shows that the increase in total sales value in 2022 reflects an overall positive price variance
that more than offset the corresponding negative sales volume variance. In contrast, the
decline in total sales value in 2023 reflects a negative sales volume variance, the primary factor,
as well as a somewhat smaller negative price variance.
*** U.S. producers reported increasing average sales values in 2022 but diverged
somewhat in 2023: *** reported declines in average sales value; *** reported a modest
increase. *** attributed the pattern of average sales value to changes in demand and
underlying sales value, as opposed to changes in product mix.24 In contrast, *** indicated that
the pattern of its average sales value reflects a combination of changes in product mix, ***, as
well as demand and market conditions.25 While *** alternated in terms of which reported the
highest company-specific average sales value, *** reported the lowest average sales value in
2021, 2022, and 2023 (see table E-1).
Cost of goods sold and gross profit or loss
Raw materials
In addition to tin and/or chromium coating materials, which would be reported by all
U.S. producers, the total raw material costs reported in table III-10 reflect a combination of
primary steel-making inputs, as well as purchased black plate. TCCSS sales, as noted previously,
24 ***. Email with attachment from ***, February 27, 2024. ***. Email with attachment from ***,
February 20, 2024.
25 Email with attachment from ***, February 20, 2024.

III-31
do not include a direct or formulaic passthrough of raw material costs. As it relates to input
costs in general, U.S. producers enter into various contracts to limit volatility.26
On an overall basis total raw material costs ranged from a low of *** percent of total
COGS (2023) to a high of *** percent (2022).27 With regard to the steel component specifically,
non-integrated producer Ohio Coatings reported that it *** consumed ***, accounting for ***
percent of its total 2023 raw material cost,28 while the two integrated producers, in addition to
tin and chromium coating materials, consumed either hot-rolled steel only (***)29 or a
combination of hot-rolled steel and black plate (***).30 While the form of steel ultimately
consumed to produce TCCSS by Cleveland-Cliffs and U.S. Steel is black plate, the reported total
raw material costs in table III-10, in addition to tin
26 Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-685 and 731-
TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, p. VI-12. Cleveland-Cliffs 2022
10-K, pp. 52-53. Email with attachment from ***, February 20, 2024. U.S. Steel 2023 10-K, p. 93. U.S.
Steel 2023 10-K, p. 17.
27 *** was the *** U.S. producer to separately report inputs purchased from related suppliers.
According to the company, related supplier inputs were reported when the entities supplying material
inputs were legally distinct from the consuming entities. Email with attachment from ***, February 27,
2024. The related supplier inputs reported by *** were ***, generally recorded at the related supplier’s
cost. Ibid. *** U.S. producer questionnaire response, sections III-5-III-7b. *** considered all entities
supplying and consuming material inputs to be legally the same and therefore did not separately report
purchases from related suppliers. Email with attachment from ***, February 20, 2024.
28 *** U.S. producer questionnaire responses, section III-9c. ***. *** U.S. producer questionnaire
responses, section III-9d.
29 ***. *** U.S. producer questionnaire responses, section III-9d. ***. USITC auditor notes
(prehearing).
30 ***. *** U.S. producer questionnaire responses, section III-16. ***. *** U.S. producer
questionnaire responses, section III-9d. ***. USITC auditor notes (prehearing).

III-32
and chromium coating materials, reflect underlying steelmaking inputs; i.e., not the discrete
cost of consumed black plate.
The U.S. industry’s average per short ton raw material cost increased notably in 2022
and then declined somewhat in 2023. Like average sales value, changes in average raw material
cost were generally attributed to underlying input prices/costs, as opposed to changes in
product mix.31 *** consistently reported the lowest company-specific average raw material
cost. ***, whose average raw material cost primarily reflects ***, reported the highest average
raw material cost (see table E-1).
Direct labor cost and other factory costs
The U.S. industry’s direct labor cost, the smallest primary component of total COGS,
declined irregularly as a share of total COGS, ranging from a low of *** percent of total COGS
(2023) to a high of *** percent (2021). Other factory costs, the second largest primary
component of COGS, increased irregularly as a share of total COGS, ranging from *** percent
(2022) to *** percent (2023). Consistent with the manner in which material cost was reported,
the direct labor and other factory costs reported by *** reflect ***.32
31 *** indicated that the pattern of average raw material cost reflects increases in underlying costs,
as opposed to changes in product mix. Email with attachment from ***, February 27, 2024. With regard
to the pattern of its average raw material cost, *** stated ***. Email with attachment from ***,
February 20, 2024. In contrast, *** indicated that average raw material cost reflect changes in both
product mix (***) and underlying input costs. ***. Email with attachment from ***, February 20, 2024.
32 ***. *** U.S. producer questionnaire, section III-8. Email with attachment from ***, February 27,
2024. *** U.S. producer questionnaire, section III-8. Email with attachment from ***, February 20,
2024.

III-33
On a company-specific basis average per short ton direct labor cost and other factory
costs reflect relatively wide ranges (see table E-1): *** reporting the lowest average direct labor
cost and lowest average other factory costs; *** reporting the highest average direct labor cost
and, for most part, the highest average other factory costs; *** reporting average direct labor
cost and average other factory costs between those of ***.
Given the capital intensive nature of manufacturing TCCSS, the level of capacity
utilization and corresponding fixed cost absorption are important determinants of average
COGS, in particular the other factory costs component.33 ***.34 *** also emphasized the
importance of capacity utilization with regard to COGS and financial results in general.35
33 Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-685 and 731-
TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, p. VI-13.
34 Email with attachment from ***, February 20, 2024. ***. *** U.S. producer questionnaire, section
III-11. U.S. Steel presents asset impairment charges, ***, as a separate line item in the operating
expenses section of its consolidated income statement. U.S. Steel 2023 10-K, p. 67.
35 ***. Email with attachment from ***, February 27, 2024. ***. Email with attachment from ***,
February 20, 2024.

III-34
As a group, U.S. producers reported progressively higher average COGS with *** and
*** reporting the lowest and highest company-specific average COGS, respectively (see table E-
1).36
Gross profit or loss
The U.S. industry reported gross profit in 2021, reflecting a gross profit ratio (total gross
profit or loss divided by total net sales value) that was somewhat above breakeven. In 2022,
notwithstanding a decline in total sales quantity, the U.S. industry reported substantially higher
total gross profit and corresponding gross profit ratio. To the extent that all U.S. producers
reported higher average COGS in 2022, the notable improvement in gross results in that year
was generally a function of higher average sales value; the expansion in gross profit ratio
reflecting a percentage increase in average sales value that was somewhat less than twice the
corresponding percentage increase in average COGS (see table III-11).
As noted previously, fixed prices for TCCSS are negotiated with customers in the fall of
each year and subsequently recognized in the following year’s sales values. With regard to
prospective average sales value and profitability in 2022, Cleveland-Cliffs’ CEO stated during the
company’s third quarter 2021 earnings call that “Our tinplate business, for example, which we
have already renegotiated with all the clients, they are increasing between 2021, 2022 price-
wise, 100%. In other words, we are doubling the price of our tinplate. So because the costs are
not increased, not even marginally close, it's a fraction of that, so we're going to have a
meaningful bigger contribution from tinplate.”37
While still positive in 2023, the U.S. industry’s total gross profit was lower compared
with 2022. In conjunction with a continued decline in sales quantity, the reduction in gross
36 ***. Email with attachment from ***, February 27, 2024. *** higher average direct labor and other
factory costs generally explains why its average COGS was highest on a company-specific basis; i.e., the
other component of COGS, raw material costs, was the lowest on a company-specific basis (see table E-
1). ***. USITC auditor notes (prehearing).
37 Transcript of Cleveland-Cliffs Q3 2021 earnings call, p. 17.

III-35
profit in 2023 reflects the combined negative impact of lower average sales value and higher
average COGS. As noted previously, the increase in average COGS, in part, reflects lower
throughput and a reduction in corresponding fixed cost absorption. While company-specific
directional patterns were mixed, *** U.S. producers reported lower gross results in 2023
compared with 2022 (see table E-1).
SG&A expenses and operating income or loss
The U.S. industry’s total SG&A expenses were at their highest level in 2021 and declined
in 2022 and 2023.38 On a company-specific basis SG&A expense ratios (total SG&A expenses
divided by total net sales value) varied and generally occupied distinct ranges: *** SG&A
expense ratio exhibiting the least amount of variability; *** at its highest level in 2021 and then
declining; *** remaining at relatively lows in 2021, 2022, and 2023 (see table E-1).
While the U.S. industry’s gross results were positive in 2021, they did not exceed
corresponding SG&A expenses in that year, yielding an overall operating loss. In 2022, the
expansion in gross profit (on an absolute basis and as a ratio to net sales), combined with a
modest decline in total SG&A expenses, yielded operating income. The subsequent contraction
in total gross profit in 2023, offset partially by a continued decline in SG&A expenses, yielded
lower but still positive total operating results.
On a company-specific basis, U.S. producers were directionally uniform in terms of
reporting relative improvements in their operating results in 2022, followed by declines in
2023. While magnitudes varied, *** reported operating income throughout the period. In
contrast, *** reported operating losses of varying magnitudes.
38 *** accounted for the substantial majority of the U.S. industry’s reported SG&A expenses and
therefore largely determined the overall pattern (see table E-1). ***. Email with attachment from ***,
February 20, 2024.

III-36
All other expenses and net income or loss
The absolute differences between the U.S. industry’s operating and net results are
generally explained by the presence of interest expense (2021 and 2022) and the combination
of interest expense and other income (2023) (see table III-10). Other expenses, while present,
generally had a limited impact.39 40
Overall operating and net results were directionally the same (both improving in 2022
and then lower in 2023). Reflecting a relatively large increase in other income in that year, 2023
was the only year when the U.S. industry’s net results exceeded corresponding operating
results.
Capital expenditures and research and development expenses
Table III-13 and table III-15 present U.S. producers’ capital expenditures and R&D
expenses related to their TCCSS operations, respectively, by firm. Table III-14 and table III-16
present corresponding narrative descriptions.
Table III-13
TCCSS: U.S. producers’ capital expenditures, by firm and period
Value in 1,000 dollars
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
39 With the exception of 2021, *** of the U.S. industry’s total other income. USITC auditor notes
(prehearing). As presented in table III-12 and in contrast with the amounts presented for the years
overlapping the Commission’s recently-completed TCCSS investigations (2021 and 2022), the sign
convention for *** other income is positive and therefore additive, as opposed to negative and
subtractive, to net results. Ibid.
40 *** reported no non-recurring items during the period. *** U.S. producer questionnaire, sections
III-10a-b. *** other income was reported as a non-recurring item. According to ***, items that it would
routinely consider non-recurring are recorded at a higher reporting level and therefore not included in
its TCCSS financial results. *** U.S. producer questionnaire, section III-11. See footnote 34.

III-37
Table III-14
TCCSS: U.S. producers’ narrative descriptions of their capital expenditures, by firm
Firm 	Narrative on capital expenditures
Cleveland-Cliffs 	***
Ohio Coatings 	***
U.S. Steel 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Table III-15
TCCSS: U.S. producers’ R&D expenses, by firm and period
1,000 dollars
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.

III-38
Table III-16
TCCSS: U.S. producers’ narrative descriptions of their R&D expenses, by firm
Firm 	Narrative on R&D expenses
Cleveland-Cliffs 	***
Ohio Coatings 	***
U.S. Steel 	***
Source: Compiled from data submitted in response to Commission questionnaires.
*** accounted for *** percent of the U.S. industry’s total capital expenditures, followed
by *** (*** percent), and *** (*** percent). As shown in table III-13, the directional pattern of
capital expenditures varied by company: *** capital expenditures were at their highest level in
2022; *** capital expenditures were at their highest level in 2021 and subsequently declined;
*** capital expenditures were relatively low and limited to 2021 and 2023.
In 2017 U.S. Steel initiated large capital investment projects related to its tin mill
operations, which were largely completed prior to 2021.41 Capital expenditure projects
undertaken by Cleveland-Cliffs, initiated in the fall of 2020 and largely completed by the end of
2022, reportedly impacted, to some extent, ongoing operations at the Weirton facility.42 43
41 Tin-and-Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Third Review), USITC
Publication 4795, June 2018, p. III-18. Tin Mill Products from Canada, China, Germany, and South Korea,
Inv. Nos. 701-TA-685 and 731-TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024,
pp. VI-19-20.
42 Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-685 and 731-
TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, p. VI-19.
43 As described by the CEO of Cleveland-Cliffs, “. . . Weirton had been subject to systematic
disinvestment by ArcelorMittal for years. In the three years leading up to our acquisition {in December
2020}, ArcelorMittal had invested an average of only $6 million of annual CAPEX in Weirton. For a facility
producing tin mill products to serve the discerning and specification-sensitive packaging market, that
level of capital investment is insufficient. In sharp contrast to the way that ArcelorMittal had been
operating Weirton, Cleveland-Cliffs immediately began an aggressive capital investment campaign to
optimize Weirton's production and quality capabilities, investing more than $50 million over the course
of 2021 and 2022.” Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-
(continued...)

III-39
Assets and return on assets
Table III-17 presents data on the U.S. producers’ total assets and table III-18 presents
corresponding ROA.44 Table III-19 presents U.S. producers’ narrative information regarding
aspects of reported asset information.
Table III-17
TCCSS: U.S. producers’ total net assets, by firm and period
Value in 1,000 dollars
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Table III-18
TCCSS: U.S. producers’ ROA, by firm and period
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
685 and 731-TA-1599-1601 and 1603 (Final), USITC Publication 5492, February 2024, pp. VI-19-20, fn.
46. Regarding specific capital expenditures, the CEO of Cleveland-Cliffs also stated “We installed a
tension leveler on the No. 4 line at Weirton to improve the shape of the products we make. We spent 10
million dollars to rebuild the No. 6 line at Weirton. We also hired approximately 200 additional workers
needed to operate Weirton efficiently and safely.” Ibid.
44 ROA is calculated here as operating results divided by total assets. With regard to a company’s
overall operations, staff notes that a total asset value (i.e., the bottom line value on the asset side of a
company’s balance sheet) reflects an aggregation of a number of current and non-current assets, which,
in many instances, are not product specific. The ability of U.S. producers to assign total asset values to
discrete product lines affects the meaningfulness of calculated operating return on net assets.

III-40
Table III-19
TCCSS: U.S. producers’ narrative descriptions of their total net assets, by firm
Firm 	Narrative on total assets
Cleveland-Cliffs 	***
Ohio Coatings 	***
U.S. Steel 	***
Source: Compiled from data submitted in response to Commission questionnaires.
As shown in table III-17, U.S. producers’ total net assets increased to their highest level
in 2022 and then declined to their lowest level in 2023. In contrast with ***, *** total net
assets ended the period somewhat higher compared with 2021. As indicated in table III-19, ***
attributed this pattern to higher levels of ***.

IV-1
Part IV: U.S. imports and the foreign industries
U.S. imports
Overview
The Commission issued an importer questionnaire to 29 firms believed to be U.S.
importers of TCCSS.1 The Commission received 21 questionnaire responses from firms which
import TCCSS into the United States, as well as five questionnaire responses from firms which
import excluded tin mill products.2 The responding firms’ imports accounted for the vast
majority of TCCSS imports from Japan and all other sources in 2023.3 4 In light of the data
coverage by the Commission questionnaires, import data in this report are based on
questionnaire responses.
1 TCCSS is currently imported under HTS statistical reporting numbers 7210.11.0000, 7210.12.0000,
7210.50.0000, 7210.50.0020, 7210.50.0090, 7212.10.0000, 7212.50.0000, 7225.99.0090, and
7226.99.0180. However, HTS statistical numbers 7212.50.0000, 7225.99.0090, and 7226.99.0180 are
believed to include only limited amounts of subject merchandise.
2 For more information on the U.S. importers, the location of their headquarters, and the share of
their reported imports in 2023, firm-by-firm, see the “U.S. importers” section in Part I of this report.
3 According to official Commerce statistics for HTS statistical reporting numbers 7210.11.0000,
7210.12.0000, 7210.50.0000, 7210.50.0020, 7210.50.0090, and 7212.10.0000, the primary HTS numbers
for TCCSS, U.S. imports of TCCSS from Japan equaled 66,493 short tons in 2023. The volume of TCCSS
imports from Japan presented in official Commerce statistics is likely overstated and reflects mostly
imports of out-of-scope excluded tin mill products (see “The subject merchandise” section of Part I for
information on excluded merchandise). Data from subject foreign producer/exporter questionnaires
show that *** short tons of TCCSS was exported from Japan to the United States in 2023. *** reported
importing *** short tons of TCCSS from Japan in 2023. Accordingly, *** imports accounted for ***
percent of U.S. imports of TCCSS from Japan in 2023.
4 According to official Commerce statistics for HTS statistical reporting numbers 7210.11.0000,
7210.12.0000, 7210.50.0000, 7210.50.0020, 7210.50.0090, and 7212.10.0000, the primary HTS numbers
for TCCSS, U.S. imports of TCCSS from all other sources equaled 990,604 short tons in 2023. Importers
responding to the Commission’s questionnaire reported importing *** short tons TCCSS from all other
sources in 2023. Accordingly, these importers accounted for *** percent of TCCSS imports from all other
sources in 2023. Staff believe that questionnaire responses account for the vast majority of TCCSS
imports from subject and all other sources in 2023.

IV-2
Imports from subject and nonsubject countries
Table IV-1 and figure IV-1 present information on U.S. imports of TCCSS from Japan and
all other sources during 2021 through 2023 and table IV-2 presents data on the changes in
import quantity, value, and unit value between comparison periods.
As a share of imports, imports from Japan accounted a fraction of total imports during
2021-23.5 There were *** imports of TCCSS from Japan in 2021, *** short tons in 2022, and ***
short tons in 2023. Imports from all other sources accounted for the vast majority of U.S. TCCSS
imports during 2021-23.6 Imports from all other sources decreased irregularly by *** percent
during 2021-23. They increased by *** percent during 2021-22 from *** short tons in 2021 to
*** short tons in 2022.7 They decreased, however, by *** percent during 2022-23 from ***
short tons in 2022 to *** short tons in 2023.8
The average unit value of TCCSS imports from Japan as compared with the average unit
value of TCCSS imports from all other sources was *** in 2021 and lower in both 2022 and
2023. However, the average unit value of U.S. importers’ U.S shipments of imports from Japan
compared with the average unit value of U.S. importers’ U.S. shipments of imports from all
sources was *** in 2021 and higher in both 2022 and 2023.
5 *** reported imports of TCCSS from Japan. *** reported that ***. *** noted that ***.
6 *** accounted for the vast majority of TCCSS imports from all other sources during 2021-23. In
2023, they accounted for *** percent of TCCSS imports from all other sources. The importers report
importing TCCSS ***.
7 *** reported that in 2021 and 2022 there was an increase in demand for TCCSS to produce canned
foods and aerosols due to health and safety concerns following the onset of the COVID-19 pandemic.
Importers also reported that U.S. can manufacturers ***.
8 As discussed in Part I of this report, U.S. imports of TCCSS from Canada, China, Germany, the
Netherlands, South Korea, Taiwan, Turkey, and the United Kingdom were subject to antidumping duty
(and in the case of China, countervailing duty) investigations throughout 2023.

IV-3
Table IV-1
TCCSS: U.S. imports by source and by period
Quantity in short tons; value in 1,000 dollars; unit value in dollars per short; share and ratio in percent
Source 	Measure 	2021 	2022 	2023
Japan 	Quantity 	*** 	*** 	***
Nonsubject sources 	Quantity 	*** 	*** 	***
All import sources 	Quantity 	*** 	*** 	***
Japan 	Value 	*** 	*** 	***
Nonsubject sources 	Value 	*** 	*** 	***
All import sources 	Value 	*** 	*** 	***
Japan 	Unit value 	*** 	*** 	***
Nonsubject sources 	Unit value 	*** 	*** 	***
All import sources 	Unit value 	*** 	*** 	***
Japan 	Share of quantity 	*** 	*** 	***
Nonsubject sources 	Share of quantity 	*** 	*** 	***
All import sources 	Share of quantity 	*** 	*** 	***
Japan 	Share of value 	*** 	*** 	***
Nonsubject sources 	Share of value 	*** 	*** 	***
All import sources 	Share of value 	*** 	*** 	***
Japan 	Ratio 	*** 	*** 	***
Nonsubject sources 	Ratio 	*** 	*** 	***
All import sources 	Ratio 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Ratios represent U.S. imports to U.S. producers’ production.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.
Table IV-2
TCCSS: Changes in import quantity and values between comparison periods
Changes in percent
Source 	Measure 	2021-23 	2021-22 	2022-23
Japan 	%Δ Quantity 	▲*** 	▲*** 	▲***
Nonsubject sources 	%Δ Quantity 	▼*** 	▲*** 	▼***
All import sources 	%Δ Quantity 	▼*** 	▲*** 	▼***
Japan 	%Δ Value 	▲*** 	▲*** 	▲***
Nonsubject sources 	%Δ Value 	▲*** 	▲*** 	▼***
All import sources 	%Δ Value 	▲*** 	▲*** 	▼***
Japan 	%Δ Unit value 	▲*** 	▲*** 	▼***
Nonsubject sources 	%Δ Unit value 	▲*** 	▲*** 	▼***
All import sources 	%Δ Unit value 	▲*** 	▲*** 	▼***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

IV-4
Figure IV-1
TCCSS: U.S. import quantities and average unit values, by source and by period
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires.

IV-5
U.S. shipments by coating type and width
In this proceeding, U.S. producers and importers were asked to report on their U.S.
shipments, and subject foreign producers were asked to report on their total shipments, of
TCCSS by coating type (i.e., D&I tin plate vs other tin plate vs tin-free plate) and width (i.e., less
than 41 inches wide vs greater than or equal to 41 inches wide) during 2023. Table IV-3 and
figure IV-2 present firms’ shipments by coating type and table IV-4 and figure IV-3 present
firms’ shipments by width.
U.S. importers’ U.S. shipments of TCCSS from Japan and all other sources consisted
primarily of D&I tin plate, accounting for *** percent and *** percent, respectively, of their
total U.S. shipments in 2023. Conversely, U.S. producers’ U.S. shipments consist primarily of
other tin plate, which accounted for *** percent of their total U.S. shipments in 2023. Similarly,
foreign producers primarily shipped other tin plate. In 2023, other tin plate accounted for ***
percent of subject foreign producers’ total shipments.
In terms of width, U.S. producers’ U.S. shipments and U.S. importers’ U.S. shipments
from both Japan and all other sources consisted primarily of TCCSS which had a length of less
than 41 inches. Subject foreign producers also shipped primarily TCCSS which had a length of
less than 41 inches. In 2023, TCCSS of less than 41 inches wide accounted for *** percent of
subject foreign producers’ total shipments.

IV-6
Table IV-3
TCCSS: U.S. producers’ and U.S. importers’ U.S. shipments and subject foreign producers’ total
shipments, by source and coating type, 2023
Quantity in short tons
Source
Tin plate:
D&I
Tin plate:
Other
Tin-free
plate
All coating
types
U.S. market: U.S. producers 	*** 	*** 	*** 	***
U.S. market: Japan 	*** 	*** 	*** 	***
U.S. market: nonsubject sources 	*** 	*** 	*** 	***
U.S. market: all import sources 	*** 	*** 	*** 	***
U.S. market: all sources 	*** 	*** 	*** 	***
Foreign industry: Japan 	*** 	*** 	*** 	***
Table continued.
Table IV-3 Continued
TCCSS: U.S. producers’ and U.S. importers’ U.S. shipments and subject foreign producers’ total
shipments, by source and coating type, 2023
Share across in percent
Source
Tin plate:
D&I
Tin plate:
Other
Tin-free
plate
All coating
types
U.S. market: U.S. producers 	*** 	*** 	*** 	100.0
U.S. market: Japan 	*** 	*** 	*** 	100.0
U.S. market: nonsubject sources 	*** 	*** 	*** 	100.0
U.S. market: all import sources 	*** 	*** 	*** 	100.0
U.S. market: all sources 	*** 	*** 	*** 	100.0
Foreign industry: Japan 	*** 	*** 	*** 	100.0
Table continued.
Table IV-3 Continued
TCCSS: U.S. producers’ and U.S. importers’ U.S. shipments and subject foreign producers’ total
shipments, by source and coating type, 2023
Share down in percent
Source
Tin plate:
D&I
Tin plate:
Other
Tin-free
plate
All coating
types
U.S. market: U.S. producers 	*** 	*** 	*** 	***
U.S. market: Japan 	*** 	*** 	*** 	***
U.S. market: nonsubject sources 	*** 	*** 	*** 	***
U.S. market: all import sources 	*** 	*** 	*** 	***
U.S. market: all sources 	100.0 	100.0 	100.0 	100.0
Source: Compiled from data submitted in response to Commission questionnaires. U.S. market data is
from U.S. shipments, and foreign industry data is based on total shipments.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

IV-7
Figure IV-2
TCCSS: U.S. producers’ and U.S. importers’ U.S. shipments and subject foreign producers’ total
shipments, by source and coating type, 2023
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires. U.S. market data is
from U.S. shipments, and foreign industry data is based on total shipments.

IV-8
Table IV-4
TCCSS: U.S. producers’ and U.S. importers’ U.S. shipments and subject foreign producers’ total
shipments, by source and width, 2023
Quantity in short ton
Source 	<41 inches 	≥41 inches 	All widths
U.S. market: U.S. producers 	*** 	*** 	***
U.S. market: Japan 	*** 	*** 	***
U.S. market: nonsubject sources 	*** 	*** 	***
U.S. market: all import sources 	*** 	*** 	***
U.S. market: all sources 	*** 	*** 	***
Foreign industry: Japan 	*** 	*** 	***
Table continued.
Table IV-4 Continued
TCCSS: U.S. producers’ and U.S. importers’ U.S. shipments and subject foreign producers’ total
shipments, by source and width, 2023
Share across in percent
Source 	<41 inches 	≥41 inches 	All widths
U.S. market: U.S. producers 	*** 	*** 	100.0
U.S. market: Japan 	*** 	*** 	100.0
U.S. market: nonsubject sources 	*** 	*** 	100.0
U.S. market: all import sources 	*** 	*** 	100.0
U.S. market: all sources 	*** 	*** 	100.0
Foreign industry: Japan 	*** 	*** 	100.0
Table continued.
Table IV-4 Continued
TCCSS: U.S. producers’ and U.S. importers’ U.S. shipments and subject foreign producers’ total
shipments, by source and width, 2023
Share down in percent
Source 	<41 inches 	≥41 inches 	All widths
U.S. market: U.S. producers 	*** 	*** 	***
U.S. market: Japan 	*** 	*** 	***
U.S. market: nonsubject sources 	*** 	*** 	***
U.S. market: all import sources 	*** 	*** 	***
U.S. market: all sources 	100.0 	100.0 	100.0
Source: Compiled from data submitted in response to Commission questionnaires. U.S. market data is
from U.S. shipments, and foreign industry data is based on total shipments.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

IV-9
Figure IV-3
TCCSS: U.S. producers’ and U.S. importers’ U.S. shipments and subject foreign producers’ total
shipments, by source and width, 2023
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires. U.S. market data is
from U.S. shipments, and foreign industry data is based on total shipments.

IV-10
U.S. inventories of imported merchandise
Table IV-5 presents data on the inventories held by U.S. importers of TCCSS from Japan
and all other sources. U.S. importers’ inventories of TCCSS from Japan *** during 2021-23.9
Importers’ inventories of TCCSS from all other sources increased irregularly by *** percent
during 2021-23, increasing from *** short tons in 2021 to *** short tons in 2022 and then
decreasing to *** short tons in 2023.10 Similarly, the ratio of inventories from all other sources
to total U.S. shipments increased irregularly by *** percentage points during 2021-23,
increasing from *** percent in 2021 to *** percent in 2022 and then decreasing to *** percent
in 2023.
Table IV-5
TCCSS: U.S. importers’ end-of-period inventories of imports, by source and period
Quantity in short tons; ratios in percent
Measure 	Source 	2021 	2022 	2023
Inventories quantity 	Japan 	*** 	*** 	***
Ratio to imports 	Japan 	*** 	*** 	***
Ratio to U.S. shipments of imports 	Japan 	*** 	*** 	***
Ratio to total shipments of imports 	Japan 	*** 	*** 	***
Inventories quantity 	Nonsubject 	*** 	*** 	***
Ratio to imports 	Nonsubject 	*** 	*** 	***
Ratio to U.S. shipments of imports 	Nonsubject 	*** 	*** 	***
Ratio to total shipments of imports 	Nonsubject 	*** 	*** 	***
Inventories quantity 	All 	*** 	*** 	***
Ratio to imports 	All 	*** 	*** 	***
Ratio to U.S. shipments of imports 	All 	*** 	*** 	***
Ratio to total shipments of imports 	All 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.
9 *** reported that ***.
10 *** accounted for the majority of held imports from all other sources during 2021-23. In 2023, ***
accounted for *** percent of inventories from all other sources. *** reported that ***.

IV-11
U.S. importers’ imports subsequent to December 31, 2023
The Commission requested importers to indicate whether they had imported or
arranged for the importation of TCCSS for delivery after December 31, 2023; such imports are
presented in table IV-6. *** reported that it had arranged for the importation of *** short tons
of TCCSS from Japan ***, accounting for all arranged imports of subject merchandise for
delivery after December 31, 2023.
Fourteen firms reported arranged imports of TCCSS from all other sources for delivery
after December 31, 2023. The leading importer of arranged imports from all other sources, ***,
accounted for *** percent of all arranged imports. *** reported that it imports TCCSS from
***.
Table IV-6
TCCSS: Arranged imports, by source and projected quarter
Quantity in short tons
Source 	Jan-Mar 2024 	Apr-Jun 2024 	Jul-Sep 2024 	Oct-Dec 2024 	Total
Japan 	*** 	*** 	*** 	*** 	***
Nonsubject sources 	*** 	*** 	*** 	*** 	***
All import sources 	*** 	*** 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.
U.S. imports of excluded tin mill products
As previously noted, the HTSUS numbers under which TCCSS is imported contain out-of-
scope tin mill products. As a result, in this proceeding, importers were asked to report their
imports and arranged imports of excluded tin mill products (table IV-7 and table IV-8,
respectively).11 Imports of excluded tin mill products from Japan accounted for the majority of
all imports of excluded tin mill products. The share of these imports was *** in each year
during 2021-23. Arranged imports of excluded tin mill products from Japan for delivery after
December 31, 2023 equaled *** shorts, accounting for *** percent of all arranged imports of
excluded tin mill products.
11 Nine firms reported imports and/or arranged imports of excluded tin mill products. ***.

IV-12
Table IV-7
Excluded tin mill products: U.S. importers’ imports of out-of-scope excluded tin mill products
under the primary HTS, by source and period
Quantity in short tons; value in 1,000 dollars, unit values in dollars per short ton; shares in percent
Source 	Measure 	2021 	2022 	2023
Japan 	Quantity 	*** 	*** 	***
All other sources 	Quantity 	*** 	*** 	***
All import sources 	Quantity 	*** 	*** 	***
Japan 	Value 	*** 	*** 	***
All other sources 	Value 	*** 	*** 	***
All import sources 	Value 	*** 	*** 	***
Japan 	Unit value 	*** 	*** 	***
All other sources 	Unit value 	*** 	*** 	***
All import sources 	Unit value 	*** 	*** 	***
Japan 	Share of quantity 	*** 	*** 	***
All other sources 	Share of quantity 	*** 	*** 	***
All import sources 	Share of quantity 	*** 	*** 	***
Japan 	Share of value 	*** 	*** 	***
All other sources 	Share of value 	*** 	*** 	***
All import sources 	Share of value 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.
Table IV-8
Excluded tin mill products: Arranged imports, by source and projected quarter
Quantity in short tons
Source
Jan-Mar
2024
Apr-Jun
2024
Jul-Sep
2024
Oct-Dec
2024 	Total
Japan 	*** 	*** 	*** 	*** 	***
Nonsubect sources 	*** 	*** 	*** 	*** 	***
All import sources 	*** 	*** 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

IV-13
The industry in Japan
Overview
During the final phase of the original investigation, the Commission received foreign
producer/exporter questionnaires from four firms, which accounted for approximately 100
percent of production of TCCSS in Japan during 1999.12 13 During the first, second, and third
five-year reviews, the Commission received foreign producer/exporter questionnaires from
three firms, which accounted for all production of TCCSS in Japan during 2005, 2011, and 2016,
respectively.14
In this current five-year review, the Commission issued a foreign producers/exporters
questionnaire to three firms believed to produce and/or export TCCSS in Japan. The
Commission received a response from all three firms: JFE Steel Corporation (“JFE Steel”);
Nippon Steel Corporation (“Nippon Steel”); and Toyo Kohan Co., Ltd. (“Toyo Kohan”). These
three firms accounted for all production of TCCSS in Japan during 2023 and all exports of TCCSS
from Japan to the United States in 2023. Table IV-9 presents information on the TCCSS
operations of these responding producers and exporters in Japan.
Table IV-9
TCCSS: Summary data for producers in Japan, 2023
Quantity in short tons
Firm
Production
(short tons)
Share of
reported
production
(percent)
Exports to
the United
States
(short tons)
Share of
reported
exports to
the United
States
(percent)
Total
shipments
(short tons)
Share of
firm's total
shipments
exported to
the United
States
(percent)
JFE Steel 	*** 	*** 	*** 	*** 	*** 	***
Nippon Steel 	*** 	*** 	*** 	*** 	*** 	***
Toyo Kohan 	*** 	*** 	*** 	*** 	*** 	***
All firms 	*** 	*** 	*** 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
12 Original publication, p. VII-1.
13 In 1999, four firms produced TCCSS in Japan, specifically Kawasaki Steel Corp., Nippon Steel Corp.,
NKK Corp., and Toyo Kohan Co., Ltd. In 2002, Kawasaki Steel Corp. and NKK Corp. merged to establish
JFE Holdings Co. and in 2003 JFE Holding Co. established JFE Steel Corp., a producer of TCCSS in Japan.
First review publication, p. IV-6; second review publication, p. I-13; third review publication, p. I-14.
14 First review publication, p. IV-6; second review publication, pp. I-12 and IV-6; and third review
publication, pp. I-12 and IV-5.

IV-14
Comparative data
Table IV-10 presents a comparative summary of operational data for producers of TCCSS
in Japan during the original investigation, subsequent full five-year reviews, and the current
proceeding. Foreign producers’ capacity and production decreased by *** percent and ***
percent, respectively, from 1999 to 2023. Despite decreasing capacity and production, capacity
utilization remained above *** percent during each period examined. Foreign producers’
exports of TCCSS to the United States decreased from 331,161 short tons in 1999 to zero in
2005, remained at zero in 2011 and 2016, and were *** short tons in 2023.
Table IV-10
TCCSS: Comparative data on Japan producers’ TCCSS operations from the original investigation
and subsequent reviews, by period
Quantity in short tons; value in 1,000 dollars; ratio in percent: NA is not applicable
Item 	Measure 	1999 	2005 	2011 	2016 	2023
Capacity 	Quantity 	3,244,873 	1,933,348 	1,821,137 	1,735,539 	***
Production 	Quantity 	2,870,629 	1,513,084 	1,511,188 	1,583,677 	***
Capacity utilization 	Ratio 	88.5 	78.3 	83.0 	91.2 	***
Exports to the United States 	Quantity 	331,161 	--- 	--- 	--- 	***
Exports to the United States 	Value 	NA 	--- 	--- 	--- 	***
Source: For the years 1999, 2005, 2011, and 2016 data are compiled using data submitted in the
Commission’s original investigation and subsequent five-year reviews. For the year 2023, data are
compiled from data submitted in response to Commission questionnaires.
Note: TCCSS capacity in 1999 may be overstated as responding Japanese producers included excluded
tin mill products in their capacity calculations during the original investigation. Original publication, p. VII-
1, fn. 2.
Note: Shares and ratios shown as “0.0” percent represent non-zero values less than “0.05” percent.
Zeros, null values, and undefined calculations are suppressed and shown as “---“.

IV-15
Developments in the Japanese industry since the previous review
Table IV-11 presents events in the Japanese TCCSS industry since the last five-year
review.
Table IV-11
TCCSS: Developments in the Japanese industry since 2017
Item 	Firm 	Event
Corporate
name
change
Nippon
Steel
May 2018— Announcement of a corporate name change from former Nippon
Steel & Sumitomo Metal Corp. (“NSSMC”) to “Nippon Steel Corp., effective April
1, 2019.
Closure 	Nippon
Steel
November 2019— Announcement of business lines reorganization with the
closure of the tin mill products line at its Setouchi Works facility in Hirohata by
the end of Fiscal Year (“FY”) 2020, which will reduce the firm’s annual TCCSS
capacity by 140,000 metric tons (154,000 short tons), to the 1,060,000 metric
tons (1,168,000 short tons) of existing annual TCCSS production capacity at its
Yawata Works and Nagoya Works facilities. TCCSS production capabilities will
be further constrained by closure of several integrated facilities, which will
reduce the firm’s annual steelmaking capacity by approximately 10 million short
tons, that produce flat-rolled steel.
Expansion 	Nippon
Steel
February 2020— Announcement of ¥49-billion (approximately $391-million)
capital investments to reline the No. 3 blast furnace followed by installation of
advanced information and production control technologies to stabilize
production and achieve higher productivity levels at its Nagoya integrated
facility. The relining and upgrades are anticipated to expand the blast furnace
capacity by 4,414 cubic feet to 156,267 cubic feet, to be completed by first-half
2022. The Nagoya facility is also the main integrated production base to provide
high-grade steel sheet to other Nippon Steel facilities producing downstream
steel mill products, including tin mill steel products.
Closure 	JFE
Steel
March 2020— Announcement that an electrolytic tin line will be shut down at
the Chiba facility, with additional tinplate lines to be shuttered starting in
FY2022, to consolidate tin mill products operations at the Fukuyama facility in
response to weak market demand conditions and rising raw materials costs to
enhance corporate competitiveness.
Closure 	JFE
Steel
March 2020— Announcement of plans to shut down the upstream production
processes and hot-rolling equipment at its East Japan Works facility in Keihin by
the end of FY2023 (ending March 2024). This closure, representing 4 million
tons (13 percent) of the firm’s annual crude steel production capacity, will also
reduce the amount of steel sheet available for producing TCCSS.
Table continued.

IV-16
Table IV-11 Continued
TCCSS: Developments in the Japanese industry since 2017
Item 	Firm 	Event
Closure 	JFE
Steel
November 2020— Rescheduling of the planned shutdown of the upstream
production processes and hot-rolling equipment at its East Japan Works facility
in Keihin from March 2024 to September 2023.
Upgrade 	JFE
Steel
November 2020— Announcement of earlier than planned ¥43-billion (about
$412-million) revamping of the No. 6 blast furnace at the East Japan Works
facility in Chiba from FY2023 to fourth-quarter 2022. The anticipated gains from
an earlier “blow-in” (restart) date of December 2022 is accelerating profitability
improvements from the ongoing corporate structural reforms.
New
products
Nippon
Steel
October 2021— Announcement of initial commercial production of its newly
developed EZP™ chromate-free tinplate that substitutes a zirconium treatment
process for the existing hexavalent-chromate treatment process. This readily
recyclable tinplate offers corrosion resistance, lacquer adhesion, weldability, an
attractive outer appearance, and contents safety as an environmentally benign
material for food containers. Nippon Steel’s news release further mentioned that
it “…has been developing, manufacturing, and supplying various types of
tinplate in accordance with environmental regulations around the world.” The
European Union (“EU”) will ban hexavalent chromium in the chromate treatment
process for tinplate under its Registration, Evaluation, Authorisation, and
Restriction of Chemicals (“REACH”) Regulations that will enter into force in April
2024. EZP™ chromate-free tinplate received official certification as a Food
Contact Substance by the U.S. Food and Drug Administration (“FDA”) and the
EU, and approval is pending by the South American members of the Common
Market of the Southern Cone (“MERCOSOR”).
Closure 	Toyo
Kohan
April 2022— Reduction of annual production capacity to *** short tons after
shutting down one tin mill products line with annual production capacity of ***
short tons at its Kudamatsu facility.
Restart 	Nippon
Steel
August 2022— Announcement that the No. 3 blast furnace at the Nagoya
facility, that was relined, upgraded, and expanded during January–June 2022,
will be restarted by late-August 2022. The Nagoya facility provides high-grade
steel sheet to other Nippon Steel facilities producing downstream steel mill
products, including tin mill steel products.
Closure 	JFE
Steel
Third-quarter 2022— Shut down of the tin mill products lines at the Chiba facility
to consolidate tinplate production at the Fukuyama facility in FY2023 onward.
Restart 	JFE
Steel
January 2023— After completing the planned revamping, begun in September
2022, restart of the No. 6 blast furnace at the East Japan Works facility (Chiba
Area). Although not expanding the furnace’s capacity, the revamping process
also installed data-science technology to improve the accuracy of positioning
material charging and controlling furnace heat to stabilize furnace operations.
Adjacent equipment was also updated to improve workability and extend the
operating life of the furnace body. TCCSS are produced at the East Japan
Works facility (Chiba Area) and the West Japan Works (Fukuyama Area).
Table continued.

IV-17
Table IV-11 Continued
TCCSS: Developments in the Japanese industry since 2017
Item 	Firm 	Event
Acquisition
offer
Nippon
Steel
September 2023— Nippon Steel reportedly expressed willingness to offer
$9.5 billion for U.S. Steel, including its integrated steelmaking facilities.
(According to regulatory filings, Nippon Steel valued U.S. Steel’s modern
electric-arc furnace steelmaking facilities in Arkansas and its iron ore mines in
Minnesota at a combined $9.2 billion).
Acquisition
offer
U.S.
Steel,
Nippon
Steel
December 2023— U.S. Steel announces its agreement to be acquired by
Japan’s largest steelmaker, Nippon Steel, in an all-cash transaction valued at
$14.1 billion, plus assumption of U.S. Steel’s debts ($800 million) for a total
equivalent buyout offer of $14.9 billion. Under this acquisition agreement,
Nippon Steel will honor current U.S. Steel labor agreements and U.S. Steel
will retain its current corporate name for its operations going forward. The
acquisition offer was approved by the Boards of Directors of both firms but still
needs U.S. Steel shareholder and official regulatory approvals. Both firms
anticipate completing this transaction by second- or third-quarter 2024. None
of Nippon Steel’s U.S. steel facilities currently produce tin mill products.
Acquisition
financing
Nippon
Steel
January 2024— Announcement of securing $16 billion in bridge loans from
three major Japanese banks, to finance its acquisition of U.S. Steel,
consisting of $6.5 billion from Sumitomo Mitsui Financial Group, $5.5 billion
from Mitsubishi UFJ Financial Group, and $4 billion from Mizuho Financial
Group.
Acquisition
follow-up
Nippon
Steel
February 2024— Announcement that Nippon Steel is on schedule to conclude
its acquisition of U.S. Steel by September. Corporate representatives met with
U.S. Congressional Members last month and plan to reach out to USW
representatives.
Labor
contract
negotiations
Nippon
Steel,
USW
February 2024— Nippon Steel and USW sign a nondisclosure agreement
ahead of negotiating acceptance of existing labor agreements with U.S. Steel.
Labor
contract
negotiations
Nippon
Steel,
USW
March 2024— First negotiating meeting. Although Nippon Steel
representatives reportedly reiterated their firm’s intentions to abide by the
existing collective labor agreements, the USW leaders characterized the
meeting as failing to address specific union concerns about corporate
financial transparency and agreement enforcement with the Nippon Steel
North America subsidiary and the foreign parent firm.
Shareholders
acquisition
approval
U.S.
Steel
April 2024— After U.S. Steel’s shareholders overwhelmingly voted to approve
Nippon Steel’s acquisition offer (on April 12, 2024), Takahiro Mori, Vice
Chairman pledged his firm’s commitments:
(1) As a wholly owned subsidiary, U.S. steel will have access to Nippon
Steel’s products, operational and production technologies, and
decarbonization technologies;
(2) Retention of the U.S. Steel name and Pittsburgh headquarters, no
transfers of jobs or production overseas, and continued existing
relationships with suppliers, customers, and communities; and
(3) Recognition of the USW as the bargaining representative for represented
employees, honoring all commitments under the Basic Labor Agreement
(“BLA”), and accepting all agreements between U. S. Steel and the USW.
Reiteration of prior commitments to no layoffs or plant closures, job and
pension security, and new capital investments totaling at least $1.4 billion
during 2024–26 at facilities covered by the BLA.
Table continued.

IV-18
Table IV-11 Continued
TCCSS: Developments in the Japanese industry since 2017
Source: NSSMC, “Notice Regarding Changes of the Trade Names of Nippon Steel & Sumitomo Metal
Corporation (“NSSMC”) and Consolidated Subsidiaries, and an Amendment to the Articles of
Incorporation of NSSMC,” May 16, 2018,
https://www.nipponsteel.com/common/secure/en/news/20180516_200.pdf;
Nippon Steel, “Nippon Steel to Integrate and Reorganize Steelworks,” News release, November 1, 2019,
https://www.nipponsteel.com/common/secure/en/news/20191101_100.pdf;
Nippon Steel, Nippon Steel Group Medium- to Long-Term Management Plan, March 5, 2021, pp. 7–8, 16,
17–19, 43, https://www.nipponsteel.com/en/ir/library/pdf/20210305_200.pdf;
Nippon Steel, Nippon Steel Second Quarter FY2019 Earnings Summary, November 1, 2019, pp. 12, 15,
17, 18, https://www.nipponsteel.com/en/ir/library/pdf/20191101_400.pdf;
Nippon Steel, “Nippon Steel Decides to Line the No. 3 Blast Furnace of Its Nagoya Works,” News
release, June 5, 2020, https://www.nipponsteel.com/en/news/20200605_100.html;
JFE Steel, “JFE Steel to Optimize Domestic Production Operations Through Structural Reforms,” News
release, March 27, 2020, https://www.jfe-steel.co.jp/en/release/2020/200327.pdf;
JFE Steel, “JFE Group Revision of Financial Results Forecasts in FY2019 Ended March 31, 2020 Etc.,”
March 27, 2020, https://www.jfe-holdings.co.jp/en/investor/zaimu/g-data/2019/March2020-200327-
release04.pdf;
International Tin Association (“ITA”), “JFE Steel to Consolidate Tinplate Lines,” February 17, 2020,
https://www.internationaltin.org/jfe-steel-to-consolidate-tinplate-lines/;
Azusa Kawakami and Tsukasa Morikuni, “Japan's JFE Shuts Blast Furnace as Outlook Dims,” Nikkei
Asia, March 28, 2020, https://asia.nikkei.com/Business/Business-trends/Japan-s-JFE-shuts-blast-furnace-
as-outlook-dims;
Shanghai Metals Market (“SMM”), “Japanese Steelmaker JFE to Shut a Blast Furnace to Optimise
Domestic Operations,” March 29, 2020, https://news.metal.com/newscontent/101050722/japanese-
steelmaker-jfe-to-shut-a-blast-furnace-to-optimise-domestic-operations;
JFE Steel, “JFE Steel to Shutter Keihin’s Upstream Processes and Hot Rolling by Sept. 2023,” News
release, November 9, 2020, https://www.jfe-steel.co.jp/en/release/2020/201109_01.html;
JFE Steel, “No. 6 Blast Furnace at East Japan Works (Chiba) to be Revamped,” News release,
November 9, 2020, https://www.jfe-steel.co.jp/en/release/2020/201109_02.html;
U.S. Federal Reserve Board (FRB), “Foreign Exchange Rates - G.5 Monthly,” release date: December 1,
2020, https://www.federalreserve.gov/releases/g5/20201201/.
Nippon Steel, “Nippon Steel Has Begun the Full Commercial Production of Chromate-free Tinplate
(EZP™),” News release, October 20, 2021, https://www.nipponsteel.com/en/news/20211020_200.html;
Toyo Kohan, “Kudamatsu Plant” web page, no date, https://www.toyokohan.co.jp/en/profile/factory.html,
retrieved July 7, 2023;
Nippon Steel, “Resume Operations of the No. 3 Blast Furnace at Nagoya Works,” News release, August
16, 2022, https://www.nipponsteel.com/common/secure/en/news/20220816_100.pdf;
Susan Ni, “Japan's JFE to Permanently Close East Japan Works' Tin Plate Production Line in 2022,” Yieh
Corp., Steel News, May 27, 2020, https://www.yieh.com/en/NewsItem/117131;
JFE Steel, “JFE Steel Resumes Operating No. 6 Blast Furnace at East Japan Works (Chiba),” News
release, January 16, 2023, https://www.jfe-steel.co.jp/en/release/2023/230116.html;
Katsumi Kojima, “Typical Products and Manufacturing Processes of Can Materials in JFE Steel,” JFE
Steel Technical Report No. 23, March 2018, p. 2, https://www.jfe-
steel.co.jp/en/research/report/023/pdf/023-02.pdf;
Table continued.

IV-19
Table IV-11 Continued
TCCSS: Developments in the Japanese industry since 2017
Source: Evan Robinson-Johnson, “U.S. Steel's Dealmaking Horse Race—and the Surprise Ending,”
Pittsburgh Post-Gazette, January 27, 2024, https://www.post-
gazette.com/business/powersource/2024/01/26/us-steel-nippon-sale-bid/stories/202401250108;
U.S. Steel, “Nippon Steel Corporation (NSC) to Acquire U. S. Steel, Moving Forward Together as the
‘Best Steelmaker with World-Leading Capabilities,’” News release, December 18, 2023,
https://www.businesswire.com/news/home/20231218603022/en/;
U.S. Steel, “Acquisition of United States Steel Corp. by Nippon Steel Corp.,” Schedule 14A Proxy
Statement, Final Transcript of Joint Call and Webcast, December 18, 2023,
https://www.nipponsteel.com/common/secure/en/ir/library/pdf/20231218_500.pdf;
Nippon Steel and U.S. Steel, “Nippon Steel Corporation to Acquire U. S. Steel, Moving Forward Together
as the 'Best Steelmaker with World-Leading Capabilities,’” Nippon Steel-U.S. Steel transaction investor
presentation, December 18, 2023, https://assets-global.website-
files.com/657e2ba174351fdd7e22a128/65803f14dd25c3dcb0eb0dd1_USS%20-
%20NSC%20Investor%20Presentation.pdf;
Nippon Steel, “Acquisition of United States Steel Corporation,” Press release, December 18, 2023
(English translation), https://www.nipponsteel.com/common/secure/en/ir/library/pdf/20231218_100.pdf;
Nippon Steel, “Acquisition of U.S. Steel,” Nippon Steel investor and shareholder presentation, December
18, 2023, https://www.nipponsteel.com/common/secure/en/ir/library/pdf/20231218_200.pdf;
Robert Tita and River Davis, “Nippon Steel to Acquire U.S. Steel for $14.1 Billion,” Wall Street Journal,
December 18, 2023, https://www.wsj.com/business/deals/nippon-steel-to-acquire-u-s-steel-for-55-shr-
854c6f73;
Yuka Obayashi, “Nippon Steel Confident of Completing US Steel Acquisition,” Reuters, January 5, 2024,
https://www.reuters.com/markets/deals/nippon-steel-confident-completing-us-steel-acquisition-2024-01-
05/;
Reuters, “Nippon Steel Says Japan's 3 Megabanks Plan $16 Bln Loan for U.S. Steel Acquisition,”
January 30, 2024, https://www.reuters.com/markets/deals/japans-3-megabanks-loan-nippon-steel-16-bln-
us-steel-acquisition-bloomberg-2024-01-30/;
Yuka Obayashi and Katya Golubkova, “Nippon Steel Says on Track to Close U.S. Steel Deal by
September,” Japan Times, February 7, 2024,
https://www.japantimes.co.jp/business/2024/02/07/companies/nippon-steel-deal-september/;
Nippon Steel, “Nippon Steel’s Acquisition of U. S. Steel Approved by U. S. Steel Stockholders,” News
release, April 13, 2024, https://www.nipponsteel.com/common/secure/en/news/20240413_100.pdf;
Cleveland-Cliffs’ response to the notice of institution, July 3, 2023, pp. 22–23, exh. 5;
U.S. Steel’s response to the notice of institution, July 5, 2023, pp. 9–10, exhs. 3, 4;
JFE Steel’s response to the notice of institution, June 30, 2023, pp. 2, 6;
Nippon Steel’s response to the notice of institution, July 3, 2023, pp. 4–5, exhs. 2, 3, 4, 5; and
Toyo Kohan’s response to the notice of institution, July 3, 2023, p. 2.
Japanese respondents’ prehearing brief, March 28, 2024, pp. 6–7, exhs. 1, 3, 4.
Note: U.S. dollar values were calculated by USITC staff from the U.S. Federal Reserve Board’s (“FRB”)
monthly average yen per dollar rate for the date of the Japanese producer’s capital-investment
announcement. FRB, “Foreign Exchange Rates - G.5 Monthly,” release date: March 2, 2020,
https://www.federalreserve.gov/releases/g5/20200302/.
Note: More information about Nippon Steel’s acquisition offer for U.S. Steel in December 2023 is included
in table III-1.

IV-20
Changes in operations
Producers in Japan were asked to report any change in the character of their operations
or organization relating to the production of TCCSS since January 1, 2017. Table IV-12 presents
the changes identified by the producers.
Table IV-12
TCCSS: Reported changes in operations in Japan, since January 1, 2017, by firm
Item 	Firm name and narrative on changes in operations
Plant closings 	***
Plant closings 	***
Production curtailments 	***
Other 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Nippon Steel reported that ***.15 Nippon Steel further reported that ***.16
JFE Steel reported that ***.17 JFE Steel further reported that ***.18
Toyo Kohan reported ***.19
15 Nippon Steel’s foreign producer questionnaire at I-2, II-3a and II-3c.
16 Nippon Steel’s foreign producer questionnaire at III-4.
17 JFE Steel’s foreign producer questionnaire at II-3f.
18 JFE Steel’s foreign producer questionnaire at II-4b.
19 Toyo Kohan’s foreign producer questionnaire at II-2a and II-3c.

IV-21
Operations on TCCSS
Table IV-13 presents data on subject foreign producers’ capacity and production on the
same equipment and machinery used to produce TCCSS. Following the closure of several TCCSS
production lines since 2017, capacity and production decreased across all metrics during 2021-
23. Practical overall capacity, which closely mirrored practical TCCSS capacity during the periods
examined, decreased by *** percent from *** short tons in 2021 to *** short tons in 2023.
Practical overall production decreased by *** percent from *** short tons in 2021 to *** short
tons in 2023.
Table IV-13
TCCSS: Producers' in Japan installed and practical capacity, production, and utilization, by
measure and period
Capacity and production in short tons; utilization in percent
Item 	Measure 	2021 	2022 	2023
Installed overall 	Capacity 	*** 	*** 	***
Installed overall 	Production 	*** 	*** 	***
Installed overall 	Utilization 	*** 	*** 	***
Practical overall 	Capacity 	*** 	*** 	***
Practical overall 	Production 	*** 	*** 	***
Practical overall 	Utilization 	*** 	*** 	***
Practical TCCSS 	Capacity 	*** 	*** 	***
Practical TCCSS 	Production 	*** 	*** 	***
Practical TCCSS 	Utilization 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

IV-22
Table IV-14 presents subject foreign producers’ reported narratives regarding practical
capacity constraints.
Table IV-14
TCCSS: Producers’ in Japan reported capacity constraints
Item 	Firm name and narrative on constraints to practical overall capacity
Production
bottlenecks
***
Production
bottlenecks
***
Production
bottlenecks
***
Other constraints 	***
Source: Compiled from data submitted in response to Commission questionnaires.

IV-23
Table IV-15 presents data on the TCCSS industry in Japan. As previously noted, ***
reported the closure of multiple TCCSS production lines during 2021-23. TCCSS capacity
consequently declined by *** percent from *** short tons in 2021 to *** short tons in 2023.
Similarly, production declined by *** percent from *** short tons in 2021 to *** short tons in
2023. Even though capacity and production decreased during 2021-23, capacity utilization was
higher in 2023 (*** percent) and 2022 (*** percent) as comparted with 2021 (*** percent).
Japanese producers’ total shipments decreased by *** percent during 2021-23, from
*** short tons in 2021 to *** short tons in 2023.20 21 Japanese producers’ exports accounted
for the largest share of total shipments in each year,22 whereas their home market shipments
ranged between *** percent (in 2021) and *** percent (in 2022).23
End-of-period inventories decreased by *** percent during 2021-23. However, the
inventories to production ratio, as well as the inventories to total shipments ratio, were both
higher in 2023 than in 2021 or 2022.
20 *** reported internal consumption. *** reported transfers to a related firm.
21 *** notes that demand for TCCSS peaked in 2021 during the height of the COVID-19 pandemic but
has weakened in 2022 and 2023 as the marked is returning to pre-pandemic levels. *** foreign producer
questionnaire at II-2b. Moreover, subject foreign producers note that the TCCSS market has shrunk as
customers shift to alternative products. See the “Alternative products” section below for more
information.
22 See the “Reported exports” section below for more information on export shipments.
23 *** reports that home market shipments of TCCSS generally ship to beverage can manufacturers,
whereas TCCSS exports ship to food can manufacturers. *** foreign producer questionnaire at III-11 and
III-13.

IV-24
Table IV-15
TCCSS: Data on industry in Japan, by period
Quantity in short tons; value in 1,000 dollars; unit value in dollars per short ton; ratio and share in percent
Item 	Measure 	2021 	2022 	2023
Capacity 	Quantity 	*** 	*** 	***
Production 	Quantity 	*** 	*** 	***
End-of-period inventories 	Quantity 	*** 	*** 	***
Internal consumption and transfers 	Quantity 	*** 	*** 	***
Commercial home market shipments 	Quantity 	*** 	*** 	***
Home market shipments 	Quantity 	*** 	*** 	***
Export shipments 	Quantity 	*** 	*** 	***
Total shipments 	Quantity 	*** 	*** 	***
Internal consumption and transfers 	Value 	*** 	*** 	***
Commercial home market shipments 	Value 	*** 	*** 	***
Home market shipments 	Value 	*** 	*** 	***
Export shipments 	Value 	*** 	*** 	***
Total shipments 	Value 	*** 	*** 	***
Internal consumption and transfers 	Unit value 	*** 	*** 	***
Commercial home market shipments 	Unit value 	*** 	*** 	***
Home market shipments 	Unit value 	*** 	*** 	***
Export shipments 	Unit value 	*** 	*** 	***
Total shipments 	Unit value 	*** 	*** 	***
Capacity utilization ratio 	Ratio 	*** 	*** 	***
Inventory ratio to production 	Ratio 	*** 	*** 	***
Inventory ratio to total shipments 	Ratio 	*** 	*** 	***
Internal consumption and transfers 	Share 	*** 	*** 	***
Commercial home market shipments 	Share 	*** 	*** 	***
Home market shipments 	Share 	*** 	*** 	***
Export shipments 	Share 	*** 	*** 	***
Total shipments 	Share 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.

IV-25
Reported exports
Table IV-16 presents subject foreign producers reported exports of TCCSS. Subject
foreign producers’ exports to the United States were *** short tons in 2021, *** short tons in
2022, and *** short tons in 2023.24 *** reported that its exports of TCCSS to the United States
were ***.25
Foreign producers’ exports to all destination markets decreased by *** percent during
2021-23 from *** short tons in 2021 to *** short tons in 2023.26 During 2021-23, the majority
of foreign producers’ exports were to *** and “other” export destinations.27
24 During 2021-23, Nippon Steel reported that ***, JFE Steel reported that ***, and Toyo Kohan
reported that ***.
25 *** reported that since the imposition of the antidumping duty order on TCCSS from Japan in
2000, it has shifted its TCCSS exports to ***. *** reported that Section 232 duties and tariff rate quotas
on tin plate and tin-free plate ***. *** foreign producer questionnaire at I-7, II-11, and III-17.
26 Nippon Steel and Toyo Kohan reported *** and JFE Steel reported ***. Nippon Steel’s, Toyo
Kohan’s, and JFE Steel’s foreign producer questionnaires at II-10, respectively. Subject foreign producers
also noted that trade actions such as safeguards and quotas on TCCSS in the European Union and the
United Kingdom ***. Nippon Steel’s, Toyo Kohan’s, and JFE Steel’s foreign producer questionnaires at II-
9, respectively.
27 Foreign producers listed “other” destination markets as: ***.

IV-26
Table IV-16
TCCSS: Producers' reported exports from Japan, by destination market and period
Quantity in short tons; value in 1,000 dollars
Destination market 	Measure 	2021 	2022 	2023
United States 	Quantity 	*** 	*** 	***
Canada 	Quantity 	*** 	*** 	***
Mexico 	Quantity 	*** 	*** 	***
European Union 	Quantity 	*** 	*** 	***
Asia 	Quantity 	*** 	*** 	***
All other destination markets 	Quantity 	*** 	*** 	***
Non-U.S. destination markets 	Quantity 	*** 	*** 	***
All destination markets 	Quantity 	*** 	*** 	***
United States 	Value 	*** 	*** 	***
Canada 	Value 	*** 	*** 	***
Mexico 	Value 	*** 	*** 	***
European Union 	Value 	*** 	*** 	***
Asia 	Value 	*** 	*** 	***
All other destination markets 	Value 	*** 	*** 	***
Non-U.S. destination markets 	Value 	*** 	*** 	***
All destination markets 	Value 	*** 	*** 	***
Table continued.

IV-27
Table IV-16 Continued
TCCSS: Producers' exports from Japan, by destination market and period
Unit values in dollars per short ton; shares and ratios in percent
Destination market 	Measure 	2021 	2022 	2023
United States 	Unit value 	*** 	*** 	***
Canada 	Unit value 	*** 	*** 	***
Mexico 	Unit value 	*** 	*** 	***
European Union 	Unit value 	*** 	*** 	***
Asia 	Unit value 	*** 	*** 	***
All other destination markets 	Unit value 	*** 	*** 	***
Non-U.S. destination markets 	Unit value 	*** 	*** 	***
All destination markets 	Unit value 	*** 	*** 	***
United States 	Share of quantity 	*** 	*** 	***
Canada 	Share of quantity 	*** 	*** 	***
Mexico 	Share of quantity 	*** 	*** 	***
European Union 	Share of quantity 	*** 	*** 	***
Asia 	Share of quantity 	*** 	*** 	***
All other destination markets 	Share of quantity 	*** 	*** 	***
Non-U.S. destination markets 	Share of quantity 	*** 	*** 	***
All destination markets 	Share of quantity 	*** 	*** 	***
United States 	Ratio 	*** 	*** 	***
Canada 	Ratio 	*** 	*** 	***
Mexico 	Ratio 	*** 	*** 	***
European Union 	Ratio 	*** 	*** 	***
Asia 	Ratio 	*** 	*** 	***
All other destination markets 	Ratio 	*** 	*** 	***
Non-U.S. destination markets 	Ratio 	*** 	*** 	***
All destination markets 	Ratio 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“. Ratios represent the
portion of the foreign producers' total shipments.

IV-28
Alternative products
*** reported production of excluded tin mill products and/or other out-of-scope
merchandise on the same equipment and machinery used to produce TCCSS (table IV-17).28 In
terms of excluded tin mill products, *** reported production of laminated tin-free steel.29 ***
reported production of other products. ***.
During 2021-23, production of all out-of-scope products declined by *** percent.
However, as TCCSS production also declined, the share of all out-of-scope production to total
production remained stable, ranging between *** percent (in 2023) and *** percent (in 2022).
Table IV-17
TCCSS: Producers’ in Japan overall production on the same equipment as in-scope production,
by period
Quantity in short tons; share in percent
Product type 	Measure 	2021 	2022 	2023
TCCSS 	Quantity 	*** 	*** 	***
Excluded tin mill products 	Quantity 	*** 	*** 	***
Other products 	Quantity 	*** 	*** 	***
All out-of-scope products 	Quantity 	*** 	*** 	***
All products 	Quantity 	*** 	*** 	***
TCCSS 	Share 	*** 	*** 	***
Excluded tin mill products 	Share 	*** 	*** 	***
Other products 	Share 	*** 	*** 	***
All out-of-scope products 	Share 	*** 	*** 	***
All products 	Share 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
Zeroes, null values, and undefined calculations are suppressed and shown as “---“.
28 For more information and a definition of excluded tin mill products, see the “The subject
merchandise” section of Part I of this report.
29 *** reported prioritizing production of laminated tin-free steel. *** foreign producer
questionnaire at II-3d and II-11; *** foreign producer questionnaire at I-7 and II-4. *** notes that can
manufacturers have started to shift towards use of laminated steel as it is considered a safer and more
environmentally friendly alternative to TCCSS. *** foreign producer questionnaire at II-18.

IV-29
Foreign producers’ operations on excluded tin mill products
As noted above, *** produce excluded tin mill products on the same equipment and
machinery used to produce TCCSS. Table IV-18 presents data on their excluded tin mill products
operations. During 2021-23, capacity and production of excluded tin mill products deceased by
*** percent and *** percent, respectively. Capacity utilization also decreased from *** percent
in 2021 to *** percent in 2023.
Exports accounted for the largest share of total shipments of excluded tin mill products,
ranging between *** percent (in 2023) and *** percent (in 2021). Exports of tin mill products
to the United States ranged between *** percent (in 2023) and *** percent (in 2022). During
2021-23, exports of excluded tin mill products to the United States decreased by *** percent
from *** short tons in 2021 to *** short tons in 2023.
Table IV-18
Excluded tin mill products: Foreign producers' production and shipments of out-of-scope
excluded tin mill products, by source and period
Quantity in short tons; share in percent
Item 	Measure 	2021 	2022 	2023
Capacity 	Quantity 	*** 	*** 	***
Production 	Quantity 	*** 	*** 	***
Internal consumption or transfers 	Quantity 	*** 	*** 	***
Commercial shipments in home market 	Quantity 	*** 	*** 	***
Exports to the U.S. 	Quantity 	*** 	*** 	***
Exports to all markets except the U.S. 	Quantity 	*** 	*** 	***
Export shipments 	Quantity 	*** 	*** 	***
Total shipments 	Quantity 	*** 	*** 	***
Capacity utilization 	Share of quantity 	*** 	*** 	***
Internal consumption or transfers 	Share of quantity 	*** 	*** 	***
Commercial shipments in home market 	Share of quantity 	*** 	*** 	***
Exports to the U.S. 	Share of quantity 	*** 	*** 	***
Exports to all markets except the U.S. 	Share of quantity 	*** 	*** 	***
Export shipments 	Share of quantity 	*** 	*** 	***
Total shipments 	Share of quantity 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.

IV-30
Exports
According to the Global Trade Atlas (“GTA”), the leading export market destinations for
TCCSS from Japan are Mexico and the Philippines (table IV-19). In 2023, Mexico was the top
export market destination for TCCSS from Japan, accounting for 30.9 percent of exports by
quantity, followed by the Philippines, accounting for 16.0 percent. During 2021–23, Japan
exports to the United States did not exceed 3,222 short tons; they were 213 short tons in 2023,
representing less than 0.05 percent of Japan’s total exports.
Table IV-19
TCCSS: Exports from Japan, by destination market and period
Quantity in short tons; value in 1,000 dollars
Destination market 	Measure 	2021 	2022 	2023
United States 	Quantity 	3,222 	276 	213
Mexico 	Quantity 	188,121 	179,044 	179,520
Philippines 	Quantity 	131,189 	141,462 	92,764
Peru 	Quantity 	51,321 	42,802 	40,049
Indonesia 	Quantity 	32,912 	21,925 	34,129
Brazil 	Quantity 	37,981 	30,525 	33,640
India 	Quantity 	26,221 	28,081 	30,393
Saudi Arabia 	Quantity 	29,381 	19,028 	18,751
United Arab Emirates 	Quantity 	17,395 	18,706 	18,405
All other destination markets 	Quantity 	247,949 	174,956 	132,659
All destination markets 	Quantity 	765,692 	656,805 	580,523
United States 	Value 	5,051 	654 	374
Mexico 	Value 	177,703 	251,189 	189,706
Philippines 	Value 	149,577 	207,579 	112,725
Peru 	Value 	48,911 	69,938 	50,218
Indonesia 	Value 	35,824 	30,788 	35,058
Brazil 	Value 	34,770 	41,610 	36,238
India 	Value 	18,946 	21,654 	18,502
Saudi Arabia 	Value 	29,683 	30,599 	17,148
United Arab Emirates 	Value 	20,225 	28,054 	17,623
All other destination markets 	Value 	251,278 	251,746 	138,429
All destination markets 	Value 	771,966 	933,811 	616,020
Table continued.

IV-31
Table IV-19 Continued
TCCSS: Exports from Japan, by destination market and period
Unit value in dollars per short ton; share in percent
Destination market 	Measure 	2021 	2022 	2023
United States 	Unit value 	1,568 	2,370 	1,756
Mexico 	Unit value 	945 	1,403 	1,057
Philippines 	Unit value 	1,140 	1,467 	1,215
Peru 	Unit value 	953 	1,634 	1,254
Indonesia 	Unit value 	1,088 	1,404 	1,027
Brazil 	Unit value 	915 	1,363 	1,077
India 	Unit value 	723 	771 	609
Saudi Arabia 	Unit value 	1,010 	1,608 	915
United Arab Emirates 	Unit value 	1,163 	1,500 	957
All other destination markets 	Unit value 	1,013 	1,439 	1,043
All destination markets 	Unit value 	1,008 	1,422 	1,061
United States 	Share of quantity 	0.4 	0.0 	0.0
Mexico 	Share of quantity 	24.6 	27.3 	30.9
Philippines 	Share of quantity 	17.1 	21.5 	16.0
Peru 	Share of quantity 	6.7 	6.5 	6.9
Indonesia 	Share of quantity 	4.3 	3.3 	5.9
Brazil 	Share of quantity 	5.0 	4.6 	5.8
India 	Share of quantity 	3.4 	4.3 	5.2
Saudi Arabia 	Share of quantity 	3.8 	2.9 	3.2
United Arab Emirates 	Share of quantity 	2.3 	2.8 	3.2
All other destination markets 	Share of quantity 	32.4 	26.6 	22.9
All destination markets 	Share of quantity 	100.0 	100.0 	100.0
Source: Official exports statistics under HS subheadings 7210.11, 7210.12, 7210.50, and 7212.10 as
reported by the Japan Ministry of Finance in the Global Trade Atlas Suite database, accessed April 17,
2024.
Note: Data presented in the table may be overstated as HS subheadings 7210.11, 7210.12, 7210.50, and
7212.10 contain excluded tin mill products.
Note: These data do not include HS subheadings 7212.50, 7225.99, and 7226.99 as they are believed to
contain a large share of products outside the scope of this proceeding.
Note: Because of rounding, figures may not add to total shown.
Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
United States is shown at the top, all remaining top export destinations shown in descending order of
2023 data.

IV-32
Third-country trade actions
There have been several safeguard and antidumping duty (“AD”) actions in third-
country markets on tin mill products, including TCCSS, originating in Japan. These proceedings
are summarized table IV-20.
Table IV-20
Tin mill products: Third-country trade actions
Authority 	Subject products 	Actions and effective dates
European
Union
(“EU”)
Certain steel mill products,
including TCCSS, from
certain trade partners
including Japan.
February 2, 2019— The European Commission (“EC”)
imposed safeguard measures on EU steel imports from
37 trade partners, including Japan, for three years,
effective July 19, 2018, through June 30, 2021. Steel
imports classifiable in 26 product categories were
subject to annual tariff rate quotas (“TRQs”) based on
historical import levels for each product category. For
each category, import volumes within the TRQ levels
entered free of additional duty but further imports were
subject to an additional duty of 25 percent ad valorem.
EU 	Certain steel mill products,
including TCCSS, from
certain trade partners
including Japan.
June 10, 2021— After completing the scheduled
reviews, the EC extended the safeguard measures on
EU steel imports for another three years, effective July
1, 2021, through June 30, 2024.
EU 	Certain steel mill products,
including TCCSS, from
certain trade partners
including Japan.
June 2, 2023— After completing a review to determine
whether, based on the circumstances at that time, the
EC reached a determination not to terminate the
extended safeguard measures on EU steel imports a
year earlier than scheduled, by June 30, 2023.
India 	Coated or plated tin mill flat-
rolled steel products,
including TCCSS, from the
EU, Japan, South Korea,
and the United States.
June 17, 2020— AD duties recommended for publication
in the Gazette of India Extraordinary, with final rates of
“nil” per metric ton for Nippon Steel and $222 per metric
ton ($201 per short ton) for all other Japanese
producers, for five years.
India 	Coated or plated tin mill flat-
rolled steel products,
including TCCSS, from the
EU, Japan, South Korea,
and the United States.
November 20, 2020— AD investigation terminated
without imposition of duties.
United
Kingdom
(“UK”)
Certain steel mill products,
including TCCSS, from
certain trade partners
including Japan.
May 21, 2021— The UK Trade Remedies Investigations
Directorate (“TRID”) reached a preliminary determination
finding of “…serious injury or threat thereof caused by
increased imports to the domestic industry producing
certain steel products” for the UK Secretary of State for
International Trade to reach a final determination
whether to extend the safeguard measures on UK steel
imports.
UK 	Certain steel mill products,
including TCCSS, from
certain trade partners
including Japan.
June 30, 2022— The UK Secretary of State for
International Trade announced extension of safeguard
measures on UK imports of five categories of steel mill
products, including tin mill products, for two more years,
effective July 1, 2022, through June 30, 2024.
Table continued.

IV-33
Table IV-20 Continued
Tin mill products: Third-country trade actions
Source: Global Trade Alert, “EU: Extension of Definitive Safeguard Measure on Imports of Steel
Products,” Intervention 61213, June 19, 2018,
https://www.globaltradealert.org/intervention/61213/safeguard/eu-extension-of-definitive-safeguard-
measure-on-imports-of-steel-products, retrieved July 14, 2023;
EC, “Case No. Safe009: Commission Implementing Regulation (EU) 2019/159 of 31 January 2019,”
Official Journal of the European Union, February 1, 2019, pp. L 31/27–L 31/74, https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019R0159&from=EN;
EC, “Commission Implementing Regulation 2021/1029 of 24 June 2021, Amending Commission
Implementing Regulation (EU) 2019/159 to Prolong the Safeguard Measure on Imports of Certain Steel
Products,” Official Journal of the European Union, June 25, 2021, pp. L 225 1/1–L 225 1/42, https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021R1029&from=EN;
EC, “Commission Implementing Regulation (EU) 2022/978 of 23 June 2022, Amending Implementing
Regulation (EU) 2019/159 Imposing a Definitive Safeguard Measure on Imports of Certain Steel
Products,” C/2022/4172, EUR-Lex document No. 32022R0978, Official Journal of the European Union,
June 24, 2022, pp. L 167/58–L 167/87, https://eur-lex.europa.eu/legal-
content/EN/TXT/HTML/?uri=CELEX:32022R0978&qid=1691166158703;
World Trade Organization (“WTO”), Committee on Safeguards, “Notification Under Article 12.1(B) of the
WTO Agreement on Safeguards: European Union,”
G/SG/N/8/EU/1/Suppl.2#G/SG/N/10/EU/1/Suppl.11#G/SG/N/11/EU/1/Suppl.8, June 11, 2021,
https://docs.wto.org/dol2fe/Pages/FE_Search/FE_S_S009-
DP.aspx?language=E&CatalogueIdList=274749,274694,271405,269335,267942,265019,264887,264057
,262911,260639&CurrentCatalogueIdIndex=1&FullTextHash=&HasEnglishRecord=True&HasFrenchRec
ord=True&HasSpanishRecord=True;
WTO, Committee on Safeguards, “Notification Under Article 12.1(B) of the WTO Agreement on
Safeguards: European Union,”
G/SG/N/8/EU/1/Suppl.3#G/SG/N/10/EU/1/Suppl.17#G/SG/N/11/EU/1/Suppl.11, June 2, 2023,
https://docs.wto.org/dol2fe/Pages/FE_Search/FE_S_S009-
DP.aspx?language=E&CatalogueIdList=294981,294799,291265,290125,290075,284953,283593,283230
,283175,279712&CurrentCatalogueIdIndex=1&FullTextHash=&HasEnglishRecord=True&HasFrenchRec
ord=True&HasSpanishRecord=True;
Global Trade Alert, “India: Initiation of Antidumping Investigation on Imports of Certain Tin Mill Flat-rolled
Steel Products from the European Union, Japan, the United States and the Republic of Korea,”
Intervention 37715, June 28, 2019, https://www.globaltradealert.org/state-act/37715/india-initiation-of-
antidumping-investigation-on-imports-of-certain-tin-mill-flat-rolled-steel-products-from-the-european-
union-japan-the-united-states-and-the-republic-of-korea;
Government of India, Ministry of Commerce and Industry, Department of Commerce, Directorate General
of Trade Remedies, “Final Findings in Anti-dumping Investigation Concerning Imports of Coated/Plated
Tin Mill Flat Rolled Steel Products originating in or exported from the European Union, Japan, USA
and Korea RP,” File No. 6/9/2019-DGTR, June 17, 2020,
https://www.dgtr.gov.in/sites/default/files/NCV%20Final%20Findings.pdf;
Government of India, Ministry of Commerce and Industry, Department of Commerce, Directorate General
of Trade Remedies, “Coated/Plated Tin Mill Flat Rolled Steel Products originating in or exported from the
European Union, Japan, USA and Korea RP,” November 27, 2020, https://www.dgtr.gov.in/anti-dumping-
cases/coatedplated-tin-mill-flat-rolled-steel-products-originating-or-exported-european;
WTO, Committee on Anti-Dumping Practices, “Semi-Annual Report Under Article l6.4 of the WTO
Antidumping Agreement: India,” G/ADP/N/350/IND/Rev.1, April 26, 2021,
https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=q:/G/ADP/N350INDR1.pdf&Open=True;
Table continued.

IV-34
Table IV-20 Continued
Tin mill products: Third-country trade actions
Source: WTO, Committee on Safeguards, “Notification Under Article 12.1(B) of the WTO Agreement on
Safeguards: Great Britain,” G/SG/N/8/GBR/1/Suppl.1#G/SG/N/10/GBR/1#G/SG/N/11/GBR/1, June 11,
2021, https://docs.wto.org/dol2fe/Pages/FE_Search/FE_S_S009-
DP.aspx?language=E&CatalogueIdList=275202,274695,274155,267168,265761,261849,261850,260999
,260998,260997&CurrentCatalogueIdIndex=1&FullTextHash=&HasEnglishRecord=True&HasFrenchRec
ord=True&HasSpanishRecord=True;
Steel Orbis, “UK Extends Safeguard Measures, Suspends Measure on Ukraine Imports,” June 30, 2022,
https://www.steelorbis.com/steel-news/latest-news/uk-extends-steel-safeguard-measures-suspends-
measure-on-ukrainian-imports-1250630.htm.
Note: The United Kingdom (“UK”) officially withdrew its membership from the EU on January 31, 2020.
Under the Withdrawal Agreement, the UK remained a member of the EU Single Market and the EU
Customs Union, and EU law continued to apply in the UK until the end of the transition period, January
31, 2021. EC, “Agreement on the Withdrawal of the United Kingdom of Great Britain and Northern Ireland
from the European Union and the European Atomic Energy Community,” Official Journal of the European
Union, January 31, 2020, L 29/7–L 29/187, https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:12020W/TXT; EC, “The EU-UK Withdrawal Agreement,” no date,
https://commission.europa.eu/strategy-and-policy/relations-non-eu-countries/relations-united-kingdom/eu-
uk-withdrawal-agreement_en, retrieved August 3, 2023; EC, “Questions and Answers on the United
Kingdom's withdrawal from the European Union on 31 January 2020,” press release, January 24, 2020,
https://ec.europa.eu/commission/presscorner/detail/en/qanda_20_104.

IV-35
Global market
Global exports
Table IV-21 presents global export data for TCCSS by source in descending order of
quantity for 2023. China is the world’s largest exporter, accounting for 29.8 percent, followed
by Germany at 14.5 percent of the total for 2023. As the third largest exporter, Japan
accounted for 8.9 percent of the global total. By contrast, the United States accounted for 1.7
percent in that year.
Table IV-21
TCCSS: Quantity of global exports by country and period
Quantity in short tons; value in 1,000 dollars
Exporting country 	Measure 	2021 	2022 	2023
United States 	Quantity 	102,727 	116,915 	113,584
Japan 	Quantity 	765,692 	656,805 	580,522
China 	Quantity 	1,864,448 	2,362,215 	1,932,944
Germany 	Quantity 	980,023 	919,995 	939,884
Netherlands 	Quantity 	714,184 	655,748 	529,127
South Korea 	Quantity 	467,967 	457,936 	495,121
Slovakia 	Quantity 	459,758 	421,832 	308,291
Canada 	Quantity 	255,649 	294,239 	234,484
France 	Quantity 	387,816 	359,914 	191,318
Belgium 	Quantity 	171,712 	175,335 	190,956
Taiwan 	Quantity 	197,162 	177,676 	147,038
Spain 	Quantity 	263,355 	210,234 	135,937
All other exporters 	Quantity 	997,653 	946,851 	696,265
All reporting exporters 	Quantity 	7,628,145 	7,755,694 	6,495,474
United States 	Value 	92,168 	129,056 	107,861
Japan 	Value 	771,966 	933,811 	616,020
China 	Value 	2,040,241 	2,979,438 	1,831,494
Germany 	Value 	944,041 	1,471,228 	1,368,586
Netherlands 	Value 	759,660 	1,053,511 	820,748
South Korea 	Value 	538,161 	694,446 	573,126
Slovakia 	Value 	482,891 	641,951 	426,215
Canada 	Value 	289,309 	474,807 	418,269
France 	Value 	391,020 	526,667 	269,360
Belgium 	Value 	169,552 	236,659 	233,522
Taiwan 	Value 	220,558 	252,933 	154,636
Spain 	Value 	261,898 	307,873 	198,729
All other exporters 	Value 	1,133,422 	1,375,494 	844,748
All reporting exporters 	Value 	8,094,887 	11,077,872 	7,863,314
Table continued.

IV-36
Table IV-21 Continued
TCCSS: Quantity of global exports by country and period
Unit value in dollars per short ton; share in percent
Exporting country 	Measure 	2021 	2022 	2023
United States 	Unit value 	897 	1,104 	950
Japan 	Unit value 	1,008 	1,422 	1,061
China 	Unit value 	1,094 	1,261 	948
Germany 	Unit value 	963 	1,599 	1,456
Netherlands 	Unit value 	1,064 	1,607 	1,551
South Korea 	Unit value 	1,150 	1,516 	1,158
Slovakia 	Unit value 	1,050 	1,522 	1,383
Canada 	Unit value 	1,132 	1,614 	1,784
France 	Unit value 	1,008 	1,463 	1,408
Belgium 	Unit value 	987 	1,350 	1,223
Taiwan 	Unit value 	1,119 	1,424 	1,052
Spain 	Unit value 	994 	1,464 	1,462
All other exporters 	Unit value 	1,136 	1,453 	1,213
All reporting exporters 	Unit value 	1,061 	1,428 	1,211
United States 	Share of quantity 	1.3 	1.5 	1.7
Japan 	Share of quantity 	10.0 	8.5 	8.9
China 	Share of quantity 	24.4 	30.5 	29.8
Germany 	Share of quantity 	12.8 	11.9 	14.5
Netherlands 	Share of quantity 	9.4 	8.5 	8.1
South Korea 	Share of quantity 	6.1 	5.9 	7.6
Slovakia 	Share of quantity 	6.0 	5.4 	4.7
Canada 	Share of quantity 	3.4 	3.8 	3.6
France 	Share of quantity 	5.1 	4.6 	2.9
Belgium 	Share of quantity 	2.3 	2.3 	2.9
Taiwan 	Share of quantity 	2.6 	2.3 	2.3
Spain 	Share of quantity 	3.5 	2.7 	2.1
All other exporters 	Share of quantity 	13.1 	12.2 	10.7
All reporting exporters 	Share of quantity 	100.0 	100.0 	100.0
Source: Official exports statistics under HS subheadings 7210.11, 7210.12, 7210.50, 7212.10 as reported
by various national statistical authorities in the Global Trade Atlas Suite database, accessed April 17,
2024.
Note: Data presented in the table may be overstated as HS subheadings 7210.11, 7210.12, 7210.50, and
7212.10 contain excluded tin mill products.
Note: These data do not include HS subheadings 7212.50, 7225.99, and 7226.99 as they are believed to
contain a large share of products outside the scope of this proceeding.
Note: Because of rounding, figures may not add to total shown.
Note: Chile reported its data in kilograms, and this was converted to short tons. United States is shown at
the top followed by Japan, all remaining top exporting countries in descending order of 2023 data.

IV-37
Global imports
Table IV-22 presents global import data for TCCSS by market in descending order of
quantity for 2023. The United States is the world’s largest importer, accounting for 17.9
percent, followed by Italy for 13.1 percent and Mexico for 5.0 percent of the total that year.30
Table IV-22
Tin and chromium-coated steel sheet: Global imports, by reporting country and by period
Quantity in short tons; value in 1,000 dollars
Importing country 	Measure 	2021 	2022 	2023
United States 	Quantity 	1,207,718 	1,466,361 	1,066,794
Japan 	Quantity 	25,675 	22,347 	25,527
Italy 	Quantity 	825,508 	968,030 	778,380
Mexico 	Quantity 	322,549 	409,908 	299,999
Spain 	Quantity 	193,908 	195,137 	261,119
Philippines 	Quantity 	292,424 	312,423 	232,687
Thailand 	Quantity 	310,590 	244,808 	232,429
Belgium 	Quantity 	135,059 	199,094 	231,982
France 	Quantity 	209,605 	204,790 	214,523
Netherlands 	Quantity 	213,951 	204,862 	178,757
Germany 	Quantity 	204,623 	234,234 	177,065
Indonesia 	Quantity 	193,932 	203,675 	173,276
All other importers 	Quantity 	3,406,729 	2,937,132 	2,076,593
All reporting importers 	Quantity 	7,542,270 	7,602,801 	5,949,130
Table continued.
30 Mexico’s imports of TCCSS in 2023 declined by 109,908 short tons or by 26.8 percent from the
prior year’s level, despite the closure of the Altos Hornos de México S.A. (“AMHSA”) flat-rolled steel
facility located in Monclova, Coahuila, since late-November 2022. Rye Druzin, “Ahmsa Closure in Mexico
Squeezes US Steel Market,” Argus Media, January 19, 2023, https://www.argusmedia.com/en/news-
and-insights/latest-market-news/2411196-ahmsa-closure-in-mexico-squeezes-us-steel-market; Global
Energy Monitor (“GEM”) Wiki, “Altos Hornos de Mexico S.A. (AHMSA) Steel Plant,” April 11, 2024,
https://www.gem.wiki/Altos_Hornos_De_Mexico_S.A._(AHMSA)_steel_plant.

IV-38
Table IV-22 Continued
Tin and chromium-coated steel sheet: Global imports, by reporting country and by period
Quantity in short tons; value in 1,000 dollars
Importing country 	Measure 	2021 	2022 	2023
United States 	Value 	1,217,718 	2,398,415 	1,693,886
Japan 	Value 	23,151 	21,819 	27,726
Italy 	Value 	836,326 	1,401,187 	1,012,763
Mexico 	Value 	359,422 	653,586 	371,145
Spain 	Value 	204,933 	291,223 	350,271
Philippines 	Value 	297,806 	412,901 	241,856
Thailand 	Value 	333,343 	325,257 	243,109
Belgium 	Value 	118,792 	252,483 	239,299
France 	Value 	225,433 	332,505 	323,889
Netherlands 	Value 	233,892 	275,885 	241,859
Germany 	Value 	213,559 	338,978 	246,403
Indonesia 	Value 	221,331 	292,501 	175,483
All other importers 	Value 	3,727,417 	4,439,293 	2,698,931
All reporting importers 	Value 	8,013,123 	11,436,033 	7,866,621
United States 	Unit value 	1,008 	1,636 	1,588
Japan 	Unit value 	902 	976 	1,086
Italy 	Unit value 	1,013 	1,447 	1,301
Mexico 	Unit value 	1,114 	1,594 	1,237
Spain 	Unit value 	1,057 	1,492 	1,341
Philippines 	Unit value 	1,018 	1,322 	1,039
Thailand 	Unit value 	1,073 	1,329 	1,046
Belgium 	Unit value 	880 	1,268 	1,032
France 	Unit value 	1,076 	1,624 	1,510
Netherlands 	Unit value 	1,093 	1,347 	1,353
Germany 	Unit value 	1,044 	1,447 	1,392
Indonesia 	Unit value 	1,141 	1,436 	1,013
All other importers 	Unit value 	1,094 	1,511 	1,300
All reporting importers 	Unit value 	1,062 	1,504 	1,322
Table continued.

IV-39
Table IV-22 Continued
Tin and chromium-coated steel sheet: Global imports, by reporting country and by period
Unit values in dollars per short ton; shares in percent
Importing country 	Measure 	2021 	2022 	2023
United States 	Share of quantity 	16.0 	19.3 	17.9
Japan 	Share of quantity 	0.3 	0.3 	0.4
Italy 	Share of quantity 	10.9 	12.7 	13.1
Mexico 	Share of quantity 	4.3 	5.4 	5.0
Spain 	Share of quantity 	2.6 	2.6 	4.4
Philippines 	Share of quantity 	3.9 	4.1 	3.9
Thailand 	Share of quantity 	4.1 	3.2 	3.9
Belgium 	Share of quantity 	1.8 	2.6 	3.9
France 	Share of quantity 	2.8 	2.7 	3.6
Netherlands 	Share of quantity 	2.8 	2.7 	3.0
Germany 	Share of quantity 	2.7 	3.1 	3.0
Indonesia 	Share of quantity 	2.6 	2.7 	2.9
All other importers 	Share of quantity 	45.2 	38.6 	34.9
All reporting importers 	Share of quantity 	100.0 	100.0 	100.0
Source: Official exports statistics under HS subheadings 7210.11, 7210.12, 7210.50, 7212.10 as reported
by various national statistical authorities in the Global Trade Atlas Suite database, accessed April 22,
2024.
Note: Data presented in the table may be overstated as HS subheadings 7210.11, 7210.12, 7210.50, and
7212.10 contain excluded tin mill products.
Note: These data do not include HS subheadings 7212.50, 7225.99, and 7226.99 as they are believed to
contain a large share of products outside the scope of this proceeding.
Note: Because of rounding, figures may not add to total shown.
Note: Chile reported its data in kilograms, and this was converted to short tons. United States is shown at
the top followed by Japan, all remaining top exporting countries in descending order of 2023 data.

IV-40
Prices in the U.S. market compared to non-U.S. markets
Two U.S. producers and five importers reported that they were aware of TCCSS prices in
non-U.S. markets. Firms that were aware of pricing in other markets were asked to compare
such prices to those in the U.S. market. All responding firms reported that TCCSS prices in the
United States were higher than prices in other markets. U.S. producer *** stated that prices for
flat-rolled products, including TCCSS, tend to be higher in the United States than in other
markets. Importer *** reported that U.S. market prices are 25 to 40 percent higher than prices
in other markets. Importer *** reported that U.S. market prices for TCCSS have been 10 to 30
percent above prices in Europe since at least 2018. Purchasers providing testimony at the
Commission hearing also reported that U.S. tin plate price is 30 percent higher than the
European price and that the United States has the highest price for tin plate.31
Foreign producers were also asked to compare market prices of TCCSS in the Japanese
home market, the United States, and third-country markets. Responding firms reported that
they did not have enough information on TCCSS prices in the U.S. market to provide a
comparison. Two foreign producers reported that TCCSS prices in Japan tend to be relatively
high because of quality requirements by customers in Japan and small order sizes.
31 Hearing transcript, pp. 163-164 (Arena), 164 (Dietrich), and 165 (Hughes).

V-1
Part V: Pricing data
Factors affecting prices
Raw material costs
U.S. producers’ raw material costs increased as a share of cost of goods sold from ***
percent in 2021 to *** percent in 2022 before decreasing to *** percent in 2023. The cost of
steel, rather than tin or chromium, is the single largest raw material cost in producing TCCSS.
Prices for cold-rolled coil (in particular, tin mill black plate) and hot-rolled coil (used to produce
tin mill black plate) increased rapidly from January 2021 through September 2021, declined
irregularly through the end of 2022, then fluctuated and partially recovered over the course of
2023 (figure V-1 and table V-1). Hot-rolled coil prices were modestly lower in December 2023
than in January 2021 and cold-rolled coil prices were modestly higher.
Figure V-1
Raw materials: Hot-rolled and cold-rolled coil, monthly average prices, 2021-23
* 	* 	* 	* 	* 	* 	*
Source: ***, retrieved February 20, 2024.

V-2
Table V-1
Raw materials: Hot-rolled and cold-rolled coil, monthly average prices, 2021-23
Prices in dollars per short ton
Period 	Hot-rolled coil 	Cold-rolled coil
January 2021 	*** 	***
February 2021 	*** 	***
March 2021 	*** 	***
April 2021 	*** 	***
May 2021 	*** 	***
June 2021 	*** 	***
July 2021 	*** 	***
August 2021 	*** 	***
September 2021 	*** 	***
October 2021 	*** 	***
November 2021 	*** 	***
December 2021 	*** 	***
January 2022 	*** 	***
February 2022 	*** 	***
March 2022 	*** 	***
April 2022 	*** 	***
May 2022 	*** 	***
June 2022 	*** 	***
July 2022 	*** 	***
August 2022 	*** 	***
September 2022 	*** 	***
October 2022 	*** 	***
November 2022 	*** 	***
December 2022 	*** 	***
January 2023 	*** 	***
February 2023 	*** 	***
March 2023 	*** 	***
April 2023 	*** 	***
May 2023 	*** 	***
June 2023 	*** 	***
July 2023 	*** 	***
August 2023 	*** 	***
September 2023 	*** 	***
October 2023 	*** 	***
November 2023 	*** 	***
December 2023 	*** 	***
Source: ***, retrieved February 20, 2024.

V-3
All three U.S. producers and most responding importers reported that raw material
prices increased from 2017 to 2020. Most importers and one U.S. producer reported that raw
material prices increased from 2021 to 2023 but the other two U.S. producers reported that
raw material prices decreased from 2021 to 2023.1 Responses were mixed regarding
anticipated prices of raw materials. Two U.S. producers anticipated an increase and one
anticipated a decrease in raw material prices. Importers’ responses were nearly evenly divided
between increase, no change, and decrease. U.S. producer *** reported that since annual
contracts for TCCSS do not have an adjustment for raw materials costs, changes in raw material
prices did not directly impact its sales prices for TCCSS.
Fourteen of 22 purchasers reported being familiar with TCCSS’s raw material costs and
10 of 18 purchasers reported that raw materials affect contract prices. Purchasers reported that
raw material prices are one factor in determining TCCSS prices but other factors such as other
input costs and supply and demand for TCCSS also influence pricing. Purchaser *** reported,
“Tinplate is a unique product that often does not correlate well with upstream inputs.”
Purchasers *** and *** reported that TCCSS price increases during periods when hot-rolled
steel prices increased were not matched by commensurate TCCSS price decreases when hot-
rolled steel prices decreased. Purchaser *** stated that price increases for TCCSS have been
much higher than price increases for raw materials.
Transportation costs to the U.S. market
Transportation costs for TCCSS shipped from Japan to the United States averaged 9.7
percent during 2023. These estimates were derived from official Commerce import data and
represent the transportation and other charges on imports.2
U.S. inland transportation costs
All three responding U.S. producers and 15 of 18 importers reported that they typically
arrange transportation to their customers. U.S. producers reported that their U.S. inland
transportation costs ranged from 2 to 3 percent while responding importers reported costs of 4
to 10 percent.
1 Most firms reported that raw material prices fluctuated up or down rather than steadily increasing
or decreasing.
2 The estimated transportation costs were obtained by subtracting the customs value from the c.i.f.
value of the imports for 2023 and then dividing by the customs value based on the HTS statistical
reporting numbers 7210.11.0000, 7210.12.0000, 7210.50.0000, 7210.50.0020, 7210.50.0090, and
7212.10.0000.

V-4
Pricing practices
Pricing methods
U.S. producers and importers reported setting prices using both transaction-by-
transaction negotiations and contracts, although most U.S. producers’ sales were on a contract
basis (table V-2).
Table V-2
TCCSS: Count of U.S. producers’ and importers’ reported price setting methods
Method 	U.S. producers 	Importers
Transaction-by-transaction 	2 	10
Contract 	3 	12
Set price list 	0 	2
Other 	0 	1
Responding firms 	3 	18
Source: Compiled from data submitted in response to Commission questionnaires.
Note: The sum of responses down may not add up to the total number of responding firms as each firm
was instructed to check all applicable price setting methods employed.
U.S. producers reported selling most of their TCCSS under annual contracts (table V-3).3
***.4 Twenty-one of 22 purchasers reported that their purchases involve negotiations.
Purchaser *** reported that its negotiations of annual contracts occur during the fourth
quarter for the following year. Similarly, purchaser *** reported that it issues an annual
Request for Pricing (RFP) based on the expected products and demand forecasted for the
following year, and that negotiations begin in September and are finalized by December/early
January. All three U.S. producers reported that their annual contracts fix prices, specify a range
for quantities, are not indexed to raw material prices, and that prices are not re-negotiable
during the contract period; however,
3 ***.
4 TCCSS imports in general tend to be sold via annual contracts. In the recent tin mill products final
investigations, more than three quarter of sales of imports from subject countries were on an annual
contract basis. Tin Mill Products from Canada, China, Germany, and South Korea, Inv. Nos. 701-TA-685
and 731-TA-1599-1601, 1603 (Final), USITC Publication 5492, February 2024, p. V-6.

V-5
U.S. producer *** reported that prices are subject to renegotiation during the course of the
contract “whe{nev}er foreign offers are aggressively low.”5
Table V-3
TCCSS: U.S. producers’ and subject importers’ shares of commercial U.S. shipments by type of
sale, 2023
Share in percent
Type of sale 	U.S. producers 	Subject importers
Long-term contracts 	*** 	***
Annual contracts 	*** 	***
Short-term contracts 	*** 	***
Spot sales 	*** 	***
Total 	100.0 	100.0
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Because of rounding, figures may not add to the totals shown.
Responding Japanese producers reported that most of their TCCSS sales were on a spot
or short-term contract basis. Spot sales comprised *** percent of their sales to the U.S. market
in 2023. For sales to other export markets, *** percent were on a short-term contract basis and
*** percent were spot sales, with the remainder annual contracts. Sales to the Japanese home
market were more evenly split among long-term contracts (***), spot sales (*** percent), and
short-term contracts (*** percent).
Eight of 22 purchasers reported that they purchase TCCSS monthly, five purchase
weekly, two purchase daily, two purchase quarterly, two purchase annually; and six reported
other purchasing frequencies. Most purchasers contact between 1 and 5 suppliers before
making a purchase, although four purchasers reported contacting a range that contained 10 or
more suppliers.
5 U.S. Steel stated contract “negotiations generally begin in the third quarter of the year prior to the
calendar year contract period. We rely on the annual contracts to establish an Annual Operating Plan, or
AOP, for our tin mill production equipment and to secure raw materials, such as tin coating metal.”
Hearing transcript, p. 20 (Kopf).

V-6
Sales terms and discounts
All three U.S. producers typically quote prices on an f.o.b. basis. Four importers reported
quoting prices on a delivered basis and two reported quoting prices on an f.o.b. basis.
*** reported not offering discounts, and *** discounts. Seventeen of 18 responding
importers reported having no discount policy. One importer reported offering loyalty discounts
and one reported no discount policy except payment terms discounts.
Price leadership
Half of the responding purchasers (11 of 22) named one or more firms as price leaders
in the U.S. TCCSS market. All 11 purchasers reported that U.S. Steel was a price leader, three
purchasers reported that Cleveland-Cliffs was a price leader, and one purchaser reported that
ThyssenKrup Steel was a price leader. Several purchasers reported that U.S. Steel was the first
supplier to establish a price for upcoming contracts. For example, *** reported, “Typically,
negotiations with other potential suppliers do not even begin until after U.S. Steel indicates
which products, at what volume and at what prices they will supply for the upcoming year.”
One purchaser, ***, reported that U.S. Steel provides pricing in the fall during annual contract
negotiations. One purchaser, ***, reported that Cleveland-Cliffs became the price leader in
2022 *** a take-it or leave-it offer, while another purchaser, ***, reported that Cleveland-Cliffs
recently offered prices independent of U.S. Steel.

V-7
Price data
The Commission requested U.S. producers6 and importers to provide quarterly data for
the total quantity and f.o.b. value of the following TCCSS products shipped to unrelated U.S.
customers during January 2021–December 2023.7
Product 1.-- Single reduced, electrolytic tinplate with base box weights of 75–95 lbs.
inclusive and less than 41 inches in width, in coils.
Product 2.-- Double reduced, electrolytic tinplate with base box weights of 55–65 lbs.
inclusive and less than 41 inches in width, in coils.
Product 3.-- Single reduced, electrolytic chromium-coated steel with base box weights
of 65–80 lbs. inclusive and less than 41 inches in width, in coils.
Product 4.-- Double reduced, electrolytic chromium-coated steel with base box weights
of 55–65 lbs. inclusive and less than 41 inches in width, in coils.
All three U.S. producers and one importer (***) provided usable pricing data for sales of
four requested products, although not all firms reported pricing for all products for all
quarters.8 Pricing data reported by these firms accounted for *** percent of U.S. producers’
U.S. shipments of TCCSS and *** percent of U.S. shipments of subject imports from Japan in
2023.9
Price data for products 1-4 are presented in tables V-4 to V-7 and figures V-2 to V-5.
6 As a part of its analysis, staff used data from *** questionnaire response on February 9, 2024,
which covered both "prime" and "second" commercial shipments. On February 20, 2024, the producer
provided an unsolicited revision to pricing data that comprised only "prime" commercial shipments.
However, because the questionnaires in this proceeding make no such distinction, staff has continued to
rely on the data from the initial submission to maintain consistency in reporting.
7 The definitions for the four pricing products differ from those in the third review. Tin- and
Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860 (Third Review), USITC Publication 4795,
June 2018 (“Third review publication”), pp. V-3-4. The price items in the fourth review have been
modified by the phrase "less than 41 inches in width" consistent with the price items included in the
final phase of the Commission's investigation. Tin Mill Products from Canada, China, Germany, and
South Korea, Investigation Nos. 701-TA-685 and 731-TA-1599-1601 and 1603 (Final).
8 Per-unit pricing data are calculated from total quantity and total value data provided by U.S.
producers and importers. The precision and variation of these figures may be affected by rounding,
limited quantities, and producer or importer estimates.
9 Pricing coverage is based on U.S. shipments reported in questionnaires.

V-8
Table V-4
TCCSS: Weighted-average f.o.b. prices and quantities of domestic and imported product 1 and
margins of underselling/(overselling), by source and quarter
Price in dollars per short ton, quantity in short tons, margin in percent.
Period 	U.S. price 	U.S. quantity 	Japan price 	Japan quantity 	Japan margin
2021 Q1 	*** 	*** 	*** 	*** 	***
2021 Q2 	*** 	*** 	*** 	*** 	***
2021 Q3 	*** 	*** 	*** 	*** 	***
2021 Q4 	*** 	*** 	*** 	*** 	***
2022 Q1 	*** 	*** 	*** 	*** 	***
2022 Q2 	*** 	*** 	*** 	*** 	***
2022 Q3 	*** 	*** 	*** 	*** 	***
2022 Q4 	*** 	*** 	*** 	*** 	***
2023 Q1 	*** 	*** 	*** 	*** 	***
2023 Q2 	*** 	*** 	*** 	*** 	***
2023 Q3 	*** 	*** 	*** 	*** 	***
2023 Q4 	*** 	*** 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Product 1: Single reduced, electrolytic tinplate with base box weights of 75–95 lbs. inclusive and
less than 41 inches in width, in coils.
Table V-5
TCCSS: Weighted-average f.o.b. prices and quantities of domestic and imported product 2 and
margins of underselling/(overselling), by source and quarter
Price in dollars per short ton, quantity in short tons, margin in percent.
Period 	U.S. price 	U.S. quantity 	Japan price 	Japan quantity 	Japan margin
2021 Q1 	*** 	*** 	*** 	*** 	***
2021 Q2 	*** 	*** 	*** 	*** 	***
2021 Q3 	*** 	*** 	*** 	*** 	***
2021 Q4 	*** 	*** 	*** 	*** 	***
2022 Q1 	*** 	*** 	*** 	*** 	***
2022 Q2 	*** 	*** 	*** 	*** 	***
2022 Q3 	*** 	*** 	*** 	*** 	***
2022 Q4 	*** 	*** 	*** 	*** 	***
2023 Q1 	*** 	*** 	*** 	*** 	***
2023 Q2 	*** 	*** 	*** 	*** 	***
2023 Q3 	*** 	*** 	*** 	*** 	***
2023 Q4 	*** 	*** 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Product 2: Double reduced, electrolytic tinplate with base box weights of 55–65 lbs. inclusive and
less than 41 inches in width, in coils.

V-9
Table V-6
TCCSS: Weighted-average f.o.b. prices and quantities of domestic and imported product 3 and
margins of underselling/(overselling), by source and quarter
Price in dollars per short ton, quantity in short tons, margin in percent.
Period 	U.S. price 	U.S. quantity 	Japan price 	Japan quantity 	Japan margin
2021 Q1 	*** 	*** 	*** 	*** 	***
2021 Q2 	*** 	*** 	*** 	*** 	***
2021 Q3 	*** 	*** 	*** 	*** 	***
2021 Q4 	*** 	*** 	*** 	*** 	***
2022 Q1 	*** 	*** 	*** 	*** 	***
2022 Q2 	*** 	*** 	*** 	*** 	***
2022 Q3 	*** 	*** 	*** 	*** 	***
2022 Q4 	*** 	*** 	*** 	*** 	***
2023 Q1 	*** 	*** 	*** 	*** 	***
2023 Q2 	*** 	*** 	*** 	*** 	***
2023 Q3 	*** 	*** 	*** 	*** 	***
2023 Q4 	*** 	*** 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Product 3: Single reduced, electrolytic chromium-coated steel with base box weights of 65–80 lbs.
inclusive and less than 41 inches in width, in coils. ***.
Table V-7
TCCSS: Weighted-average f.o.b. prices and quantities of domestic and imported product 4 and
margins of underselling/(overselling), by source and quarter
Price in dollars per short ton, quantity in short tons, margin in percent.
Period 	U.S. price 	U.S. quantity 	Japan price 	Japan quantity 	Japan margin
2021 Q1 	*** 	*** 	*** 	*** 	***
2021 Q2 	*** 	*** 	*** 	*** 	***
2021 Q3 	*** 	*** 	*** 	*** 	***
2021 Q4 	*** 	*** 	*** 	*** 	***
2022 Q1 	*** 	*** 	*** 	*** 	***
2022 Q2 	*** 	*** 	*** 	*** 	***
2022 Q3 	*** 	*** 	*** 	*** 	***
2022 Q4 	*** 	*** 	*** 	*** 	***
2023 Q1 	*** 	*** 	*** 	*** 	***
2023 Q2 	*** 	*** 	*** 	*** 	***
2023 Q3 	*** 	*** 	*** 	*** 	***
2023 Q4 	*** 	*** 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Product 4: Double reduced, electrolytic chromium-coated steel with base box weights of 55–65 lbs.
inclusive and less than 41 inches in width, in coils. ***.

V-10
Figure V-2
TCCSS: Weighted-average prices and quantities of domestic and imported product 1, by source
and quarter
Price of product 1
* 	* 	* 	* 	* 	* 	*
Volume of product 1
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Product 1: Single reduced, electrolytic tinplate with base box weights of 75–95 lbs. inclusive and
less than 41 inches in width, in coils.

V-11
Figure V-3
TCCSS: Weighted-average prices and quantities of domestic and imported product 2, by source
and quarter
Price of product 2
* 	* 	* 	* 	* 	* 	*
Volume of product 2
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Product 2: Double reduced, electrolytic tinplate with base box weights of 55–65 lbs. inclusive and
less than 41 inches in width, in coils.

V-12
Figure V-4
TCCSS: Weighted-average prices and quantities of domestic and imported product 3, by source
and quarter
Price of product 3
* 	* 	* 	* 	* 	* 	*
Volume of product 3
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Product 3: Single reduced, electrolytic chromium-coated steel with base box weights of 65–80 lbs.
inclusive and less than 41 inches in width, in coils. ***.

V-13
Figure V-5
TCCSS: Weighted-average prices and quantities of domestic and imported product 4, by source
and quarter
Price of product 4
* 	* 	* 	* 	* 	* 	*
Volume of product 4
* 	* 	* 	* 	* 	* 	*
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Product 4: Double reduced, electrolytic chromium-coated steel with base box weights of 55–65 lbs.
inclusive and less than 41 inches in width, in coils. ***.

V-14
Price trends
Domestic prices increased overall during 2021 to 2023. Prices experienced large
increases in 2022, with pricing products 1 to 3 reaching period highs in the third quarter of 2022
and product 4 reaching a period high in the fourth quarter of 2022. Prices declined somewhat in
2023 but remained well above 2021 prices. Table V-8 summarizes the price trends, by country
and by product. As shown in the table, domestic price increases exceeded 50 percent for each
of the pricing products during 2021-23.
Table V-8
TCCSS: Summary of price data, by product and source
Quantity in short tons, price in dollars per short ton
Product 	Source
Number
of
quarters 	Quantity
Low
price
High
price
First
quarter
price
Last
quarter
price
Change
over period
Product 1 	United States 	12 	*** 	*** 	*** 	*** 	*** 	***
Product 1 	Japan 	2 	*** 	*** 	*** 	*** 	*** 	***
Product 2 	United States 	12 	*** 	*** 	*** 	*** 	*** 	***
Product 2 	Japan 	2 	*** 	*** 	*** 	*** 	*** 	***
Product 3 	United States 	12 	*** 	*** 	*** 	*** 	*** 	***
Product 3 	Japan 	0 	0 	0 	0 	0 	0 	0
Product 4 	United States 	12 	*** 	*** 	*** 	*** 	*** 	***
Product 4 	Japan 	0 	0 	0 	0 	0 	0 	0
Source: Compiled from data submitted in response to Commission questionnaires.
Note: Percent change column is percentage change from the first quarter in 2021 to the last quarter in
2023.

V-15
Price comparisons10
As shown in table V-9, prices for TCCSS imported from Japan were higher than those for
U.S.-produced product in the four instances for which data were reported. As discussed above,
subject imports of TCCSS from Japan were available in very limited quantities sold on a spot
basis.
Table V-9
TCCSS: Instances of underselling and overselling and the range and average of margins, by
product
Quantity in short tons; margin in percent
Item 	Type
Number of
quarters 	Quantity
Average
margin
Minimum
margin
Maximum
margin
Product 1 	Underselling 	*** 	*** 	*** 	*** 	***
Product 2 	Underselling 	*** 	*** 	*** 	*** 	***
Product 3 	Underselling 	*** 	*** 	*** 	*** 	***
Product 4 	Underselling 	*** 	*** 	*** 	*** 	***
All products 	Underselling 	--- 	*** 	*** 	*** 	***
Product 1 	Overselling 	*** 	*** 	*** 	*** 	***
Product 2 	Overselling 	*** 	*** 	*** 	*** 	***
Product 3 	Overselling 	*** 	*** 	*** 	*** 	***
Product 4 	Overselling 	*** 	*** 	*** 	*** 	***
All products 	Overselling 	4 	*** 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: These data include only quarters in which there is a comparison between the U.S. and subject
product.
10 In the original investigations prices were collected based on bid data. One or more of the final
Japanese bids were below all U.S. bids in 45 instances; Japanese bids were within the range of all U.S.
bids in 21 instances; and Japanese bids were above U.S. bids in 6 instances. In 9 instances there were no
comparable U.S. final bids and in 10 instances there were initial Japanese bids but no final Japanese
bids. In the second remand, the Commission looked at 51 bid comparisons. In these it reported 21
instances in which the Japanese bids were below all the U.S. bids. In 16 instances, the Japanese bids
were within the range of all U.S. bids. In no instances were Japanese prices above all U.S. bids. In six
instances, there were Japanese bids but no comparable U.S. bids, and in eight instances, there were
initial Japanese bids but no final Japanese bids. Tin- and Chromium-Coated Steel Sheet from Japan, Inv.
No. 731-TA-860 (Third Review), USITC Publication 4795, June 2018 (“Third review publication”), p. V-6.
In the first review, there were seven instances where subject price data could be compared to
domestic data; in all seven instances subject import prices were above comparable domestic prices, and
margins of overselling ranged from 6.6 to 28.4 percent. In the second and third reviews, there were no
price comparisons available. Tin- and Chromium-Coated Steel Sheet from Japan, Inv. No. 731-TA-860
(Third Review), USITC Publication 4795, June 2018 (“Third review publication”), p. V-6.

APPENDIX A FEDERAL REGISTER NOTICES
A-1

A-3
The Commission makes available notices relevant to its investigations and reviews on its
website, www.usitc.gov. In addition, the following tabulation presents, in chronological order,
Federal Register notices issued by the Commission and Commerce during the current
proceeding.
Citation 	Title 	Link
88 FR 35832,
June 1, 2023
Initiation of Five-Year
(Sunset) Reviews
https://www.govinfo.gov/content/pkg/FR-
2023-06-01/pdf/2023-11680.pdf
88 FR 35920,
June 1, 2023
Tin- and Chromium-
Coated Steel Sheet From
Japan; Institution of a
Five-Year Review
https://www.govinfo.gov/content/pkg/FR-
2023-06-01/pdf/2023-11465.pdf
88 FR 64464,
September 19, 2023
Tin- and Chromium-
Coated Steel Sheet From
Japan; Notice of
Commission
Determination To
Conduct a Full Five-Year
Review
https://www.govinfo.gov/content/pkg/FR-
2023-09-19/pdf/2023-20183.pdf
88 FR 69133,
October 5, 2023
Certain Tin Mill Products
From Japan: Final Results
of the Expedited Fourth
Sunset Review of the
Antidumping Duty Order
https://www.govinfo.gov/content/pkg/FR-
2023-10-05/pdf/2023-22127.pdf
88 FR 74209,
October 30, 2023
Tin- and Chromium-
Coated Steel Sheet From
Japan; Scheduling of a
Full Five-Year Review
https://www.govinfo.gov/content/pkg/FR-
2023-10-30/pdf/2023-23887.pdf

APPENDIX B

LIST OF HEARING WITNESSES

B-1

B-3
CALENDAR OF PUBLIC HEARING
Those listed below appeared in the United States International Trade Commission’s hearing:
Subject: 	Tin- and Chromium-Coated Steel Sheet from Japan
Inv. No.: 	731-TA-860 (Fourth Review)
Date and Time: 	April 9, 2024 - 9:30 a.m.
Sessions were held in connection with this review in the Main Hearing Room (Room
101), 500 E Street, SW., Washington, DC.
OPENING REMARKS:
In Support of the Continuation (Nicole Brunda, Cassidy Levy Kent (USA) LLP)
In Opposition to the Continuation (Yujin K. McNamara, Akin Gump Strauss Hauer & Feld LLP)
In Support of the Continuation of the
Antidumping Duty Order:
King & Spalding LLP
Washington, DC
on behalf of
Cleveland-Cliffs Inc. (“Cleveland-Cliffs”)
Clifford T. Smith, Executive Vice President & President, Cleveland-Cliffs Steel,
Cleveland-Cliffs
Gordon O’Neill, Senior Director, Demand Management & Commercial Strategy,
Cleveland-Cliffs
Stephen P. Vaughn 	) – OF COUNSEL

B-4
In Support of the Continuation of the
Antidumping Duty Order (continued):
Cassidy Levy Kent (USA) LLP
Washington, DC
on behalf of
United States Steel Corporation (“U. S. Steel”)
Robert Y. Kopf, Vice President – Sales and Marketing, U. S. Steel
Thomas M. Beline 	)
Mary Jane Alves 	)
) – OF CONSEL
Nicole Brunda 	)
Margaret E. Monday 	)
NON-PARTY IN SUPPORT OF CONTINUATION:
Schagrin Associates
Washington, DC
on behalf of
United Steel, Paper and Forestry, Rubber, Manufacturing, Energy,
Allied Industrial and Service Workers International Union (“USW”)
Mark Glyptis, President, United Steelworkers Local 2911
Elizabeth J. Drake 	) – OF COUNSEL

B-5
In Opposition to the Continuation of the
Antidumping Duty Order:
Akin Gump Strauss Hauer & Feld LLP
Washington, DC
on behalf of
JFE Steel Corporation
Nippon Steel Corporation
Toyo Kohan Co., Ltd.
(“Japanese Respondents”)
Daniel Dietrich, Vice President of Procurement & Supply Chain,
Trivium Packaging USA Inc.
Thomas Hughes, Director of Metal Sourcing, Crown Cork and Seal USA Inc.
Tom Madrecki, Vice President of Campaigns and Special Projects,
Consumer Brands Association
Yujin K. McNamara 	)
Julia K. Eppard 	) – OF COUNSEL
Sydney L. Stringer 	)
Curtis, Mallet-Prevost, Colt & Mosle LLP
Washington, DC
on behalf of
Silgan Containers Manufacturing Corporation (“Silgan”)
Mike Arena, Vice President of Logistics and Operational Support, Silgan
Daniel L. Porter 	)
) – OF COUNSEL
James C. Beaty 	)
REBUTTAL/CLOSING REMARKS:
In Support of the Continuation (Thomas M. Beline, Cassidy Levy Kent (USA) LLP)
In Opposition to the Continuation (Yujin K. McNamara, Akin Gump Strauss Hauer & Feld LLP)

APPENDIX C
SUMMARY DATA
C-1

C-2
Contents 	Page
Table C-1: TCCSS: Summary data concerning the U.S. market, by item and period ................... C-3
Historical summary data from the original investigation and subsequent
full five-year reviews .................................................................................................................... C-5
Table C-1: TCCSS: Summary data concerning the U.S. market, 1997-99,
January-March 1999, and January-March 2000
(i.e., original investsigation) .................................................................................................... C-7
Table C-1: TCCSS: Summary data concerning the US. market, 2000-05
(i.e., the first full review) ......................................................................................................... C-9
Table C-1: TCCSS: Summary data concerning the U.S. market, 2006-11
(i.e., the second full reivew) .................................................................................................. C-11
Table C-1: TCCSS: Summary data concerning the U.S. market, 2014-16,
January to September 2016, and January to September 2017
(i.e., third full review) ............................................................................................................ C-13

Table C-1
TCCSS: Summary data concerning the U.S. market, by item and period
Item 	2021 	2022 	2023 	2021-23 	2021-22 	2022-23
U.S. consumption quantity:
Amount........................................................ 	2,494,413 	2,322,143 	1,889,860 	▼(24.2) 	▼(6.9) 	▼(18.6)
Producers' share (fn1).................................. 	*** 	*** 	*** 	▼*** 	▼*** 	▼***
Importers' share (fn1):
Japan........................................................ 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
Nonsubject sources.................................. 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
All import sources................................. 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
U.S. consumption value:
Amount........................................................ 	2,907,642 	4,705,717 	3,478,681 	▲19.6 	▲61.8 	▼(26.1)
Producers' share (fn1).................................. 	*** 	*** 	*** 	▼*** 	▼*** 	▼***
Importers' share (fn1):
Japan........................................................ 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
Nonsubject sources.................................. 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
All import sources................................. 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
U.S. importers' U.S. shipments of imports from:
Japan:
Quantity.................................................... 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
Value........................................................ 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
Unit value................................................. 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Ending inventory quantity.......................... 	*** 	*** 	*** 	*** 	*** 	***
Nonsubject sources:
Quantity.................................................... 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
Value........................................................ 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Unit value................................................. 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Ending inventory quantity.......................... 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
All import sources:
Quantity.................................................... 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
Value........................................................ 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Unit value................................................. 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Ending inventory quantity.......................... 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
U.S. producers':
Practical capacity quantity............................ 	*** 	*** 	*** 	▼*** 	▼*** 	▼***
Production quantity...................................... 	*** 	*** 	*** 	▼*** 	▼*** 	▼***
Capacity utilization (fn1)............................... 	*** 	*** 	*** 	▼*** 	▼*** 	▼***
U.S. shipments:
Quantity.................................................... 	*** 	*** 	*** 	▼*** 	▼*** 	▼***
Value........................................................ 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
Unit value................................................. 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Export shipments:
Quantity.................................................... 	*** 	*** 	*** 	▼*** 	▼*** 	▼***
Value........................................................ 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
Unit value................................................. 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
Table continued.
C-3
Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period
changes=percent--exceptions noted
Reported data 	Period changes
Calendar year 	Calendar year

Table C-1 Continued
TCCSS: Summary data concerning the U.S. market, by item and period
Item 	2021 	2022 	2023 	2021-23 	2021-22 	2022-23
U.S. producers': Continued
Ending inventory quantity............................. 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Inventories/total shipments (fn1).................. 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Production workers...................................... 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
Hours worked (1,000s)................................. 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
Wages paid ($1,000).................................... 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
Hourly wages (dollars per hour)................... 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
Productivity (short tons per 1,000 hours)...... 	*** 	*** 	*** 	▼*** 	▼*** 	▼***
Unit labor costs............................................ 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
Net sales:
Quantity.................................................... 	*** 	*** 	*** 	▼*** 	▼*** 	▼***
Value........................................................ 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
Unit value................................................. 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Cost of goods sold (COGS)......................... 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
Gross profit or (loss) (fn2)............................ 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
SG&A expenses........................................... 	*** 	*** 	*** 	▼*** 	▼*** 	▼***
Operating income or (loss) (fn2)................... 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Net income or (loss) (fn2)............................. 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Unit COGS................................................... 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
Unit SG&A expenses................................... 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
Unit operating income or (loss) (fn2)............ 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Unit net income or (loss) (fn2)...................... 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
COGS/sales (fn1)......................................... 	*** 	*** 	*** 	▼*** 	▼*** 	▲***
Operating income or (loss)/sales (fn1)......... 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Net income or (loss)/sales (fn1)................... 	*** 	*** 	*** 	▲*** 	▲*** 	▼***
Capital expenditures.................................... 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
Research and development expenses......... 	*** 	*** 	*** 	▲*** 	▲*** 	▲***
Total assets................................................. 	*** 	*** 	*** 	▼*** 	▲*** 	▼***
fn1.--Reported data are in percent and period changes are in percentage points.
Source: Compiled from data submitted in response to Commission questionnaires. 508 compliant tables containing these data are
contained in Parts I, III, and IV of this report.
Note.--Shares and ratios shown as “0.0” percent represent non-zero values less than “0.05” percent (if positive) and greater than
“(0.05)” percent (if negative). Zeroes, null values, and undefined calculations are suppressed and shown as “---“. Period changes
preceded by a “▲” represent an increase, while period changes preceded by a “▼” represent a decrease.
fn2.--Percent changes only calculated when both comparison values represent profits; The directional change in profitability provided
when one or both comparison values represent a loss.
C-4
Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period
changes=percent--exceptions noted
Reported data 	Period changes
Calendar year 	Calendar year

C-5
HISTORICAL SUMMARY DATA
FROM THE ORIGINAL INVESTIGATION AND SUBSEQUENT FULL FIVE-YEAR REVIEWS

Table C-1 TCCSS: Sunvnary data concerning the U.S. market, 1897-119, January-March 1189, and January-March 2000
(Quantlty=ahort tons, value=1,000 dollars, unit values, unit labor costs, and unit expenses are per short ton; period changes•percent, except where noted)
Item
U. S. consumption quantity:
Amount . . ... . ........... .... .
Producers' share (1), .......... .
Importers' share(1):
Japan ... .................. .
Other sources .... . ... .... ... .
Totallmporta . . . .... ... .....
U.S. consumption value:
Amount.. .... .. . . .......... ..
Producers' share (1)............
Importers' share (1):
Japan... ....... ..... .. . ....
Other sources.. ..... . .......
Total Imports.... ... . . ... ...
U.S. shlpmeru of Imports from:
Japan:
Quantity ..... , . . ... .... . ....
Value . ... . .. , ...... , .. . . . ..
Unit value .. .. . . .. ..... . .... .
Ending IIMlllloly quantity.... .. .
Other soun:es:
Quantity, ... ..... ..... .. ....
Value ........ ...... ... .... .
Unit value ......... ........ . .
Ending Inventory quantity ... .. . .
All sources:
Quantity .. ... .. . . ....... .. ..
Value .. .... ...... . . . . . .....
Unit value . ........... . .. ... .
Ending ll'Na1tory quantity , . . .. ..
U.S. producers':
Average capacity quantity.. ....
Production quantity ............ .
Capacity utlllzallan (1) ........ . .
U. S. shipments:
Quantity .. . .. ............ . . .
Value ............ . .... .....
Unit value .......... ...... . ..
Export shipments:
Quantity .. . .... .... ... .. ....
Value... ......... ....... . ..
Unit value ................. . .
Ending Inventory quantity .. ... .. .
lnventorl8lltalal shipments (1) . . ..
Producllon workers . ............
Hours worked (1,000s) .. . . ......
Wages paid ($1,0008) .. ... . ...
Howly wages ............... ..
Productivity(tons per 1,000 hours).
Unit labor COits.. .... ......... .
Net sales:
Quantity ........... .... ... ..
Value ... . ..... .. . ......... .
Unit value ........ ......... . .
Coat of goods sold(COGS) .....
Gron profit or (loss) .... . . .... . .
SG&A expenses .. . .... . .. . .. ..
Op-Ung income or (loss)..... ..
Capltal expenditures . . .... . .....
Unit COGS .... .... . .. ... ... . .
Unit SG&A expenses. .... . ... ..
Unit operating income or (loss) ...
COGS/sales(1) ........ . . .. .. .
Operating income or(loss)/
sales(1).... . . . ...... . . .... .
1997
182,157
120,997
$664.25
634
4,855,145
3,728,44 1
76.8
3,554 ,768
2,192,180
$616.68
1B6,510
115,979
$621.84
360,768
9.8
6,922
15,287
380,470
$24.89
243.9
$102.05
3,742,829
2,308,486
$616.7B
2,224,570
83,916
104,893
(20,977)
91,501
$594.36
$28.03
($5.80)
98.4
(0.9)
1998
• •
• •• •
242,081
154,488
$838.25
4,425
• •
• •
• •
4,889,145
3,425,572
70.4
3,283,424
2,003,321
$610.13
194,999
117,585
$803.00
354,047
10.2
8,224
13,654
348,345
$25.37
250.9
$101.11
3,47 6,048
2,120,928
$610.15
2,075,245
45,681
109,806
(84,125)
71,747
$597.01
$31.59
($18.45)
97.8
(3.0)
Reported data Parlod changes
· January-March
1999 1991 2000 1997-99 1997-98 199B-99
• •• •
• •
329,84 5
196,185
$595.14
1 1,741
•
•
4,807,145
3,433,592
74.5
3,227,134
1,898,063
$588.16
247,485
140,563
$567.97
346,375
10.0
6,004
13,297
344,320
$25.89
258.2
$100.28
3,472,054
2,034,967
$586.10
•
•
•
2,061,471
(28,504)
105,980
(132,484)
105,068
$593.73
$30.52
($38.18)
101.3
(6.5)
•
•
•
84,737
51,185
$803.81
11,114
•
•
•
1,148,438
854,8'18
74.4
805,995
476,447
$591.13
45,372
27,247
$600.52
368,838
10.8
5,880
3,235
77,828
$24.00
284.2
$90.81
849,241
501,805
$590.89
505,980
•
•
•
(4,175)
27,773
(31,948)
24,069
$595.80
$32.70
($37.62)
100.8
(6.4)
•
•
•
•
•
•
98,783
57,153
$590.53
13,812
•
•
•
1,040,444
849,382
81.6
778,793
459,860
$592.00
64,498
38,339
$594.42
358,343
10.8
5,877
3,152
81,988
$28.01
289.5
$98.53
838,184
495,968
$591.71
483,880
12,088
21,726
(9,840)
14,579
$577.30
$25.92
($11.50)
97.8
(1.9)
-2.1
-3.5
3.9
2.8
6.5
-7.0
-3.1
3.6
2.5
6.1
81.0
82.1
-10.4
1751.9
35.7
2 7.8
-5.9
-7.1
54.0
42.3
-7.6
78.1
-5.1
-7.9
-2.3
-S.2
-13.4
-4.6
32.7
21.2
-8.7
-4.0
0.3
-13.3
-13.0
-S .5
4.0
5.9
-1.7
-7.2
-11.8
-5.0
•7.3
-131.8
1.0
-531 .8
14.8
-<J.1
8.9
580.8
4.9
-5.6
-5.1
-2.3
1.8
0.5
2.3
-3.1
-2.4
1.8
0.7
2.4
32.9
27.7
-3.9
517,9
2.3
3.2
0.8
•27.5
14.7
13.5
-1.0
2. 1
0.3
-8.1
-8.4
-7.8
-8.8
-1.1
4.6
1.4
-3.0
-1.9
0.5
-10.1
-10.7
-9.0
1.9
2.9
-<J.9
-7.1
-8.1
-1.1
-3.7
-45.6
4.7
-205.7
-21.8
0.4
12.7
229.2
1.5
-2.1
3.2
-4.1
2.0
2.1
4.1
-1.0
-3.7
1.9
1.8
3.7
36.2
27.0
-3.8
165.3
32.7
23.8
-8.7
2B.1
34.3
25.3
-3.7
72.5
-5.4
0.2
4.2
-1.7
-5.3
-3.6
26.9
19.5
-5.8
-2.2
.(J.2
-3.5
-2.6
--0.6
2.1
2.9
--0.8
--0.1
-4.1
-3.9
--0.7
-158.0
-3.5
·108.8
48.4
-<J.5
-3.4
108.8
3.5
-3.5
(1) "Reported data• are in percent and "period changes• are in percentage points.
Jan.-Mar.
1999--00
-<J.4
-2.7
1.3
1.4
2.7
-<J.5
-2.5
1.1
1.4
2.5
14.2
11.7
-2 .2
24.3
18.7
17.2
0.4
-2.3
15.4
14.3
-1.0
10.9
-9.4
-<J.8
7.2
-3.8
-3.5
0.1
42.2
40.7
-1.0
-3.4
-<J.2
-3.1
-2.8
5.8
8.4
2.0
8.3
-1 .3
-1.2
0.1
-4.4
-389.5
-21.8
-3 9.8
-39.5
-3.1
-20.7
-69.4
-3.3
4.4
Note.-Financial data are reported on a fiscal year basis and may not necessarily be comparable to data reported on a calendar year basis. Because of rounding, figures may not add
to the totals shown. Unit values and shares are calculated from the unrounded figures.
Source: Compiled from data submitted In response to Commission questionnaires.
C-7

Table C-1
TCCSS: Summary data concerning the U.S. market, 2000-05
(Quantity=short tons, value=1,000 dollars, unit values, unit labor costs, and unit expenses are per short ton; period changes=percent except where noted)
Reported data 	Period changes
Item 	2000 	2001 	2002 	2003 	2004 	2005 	2000-05 	2000-01 	2001-02 	2002-03 	2003-04 	2004-05
U.S. consumption quantity:
Amount . . . . . . . . . . . . . . . . . . . 	3,721,766 	3,246,151 	3,362,793 	3,217,877 	3,422,955 	3,150,528 	-15.3 	-12.8 	3.6 	-4.3 	6.4 	-8.0
Producers' share (1) . . . . . . . . . 	86.0 	87.4 	89.8 	88.1 	85.4 	82.1 	-3.9 	1.4 	2.4 	-1.7 	-2.7 	-3.3
Importers' share (1):
Japan . . . . . . . . . . . . . . . . . . . . 	2.6 	0.0 	0.0 	0.0 	0.0 	0.0 	-2.6 	-2.6 	0.0 	0.0 	0.0 	0.0
All other sources . . . . . . . . . . . 	11.4 	12.6 	10.2 	11.9 	14.6 	17.9 	6.5 	1.2 	-2.4 	1.7 	2.7 	3.3
Total imports . . . . . . . . . . . . . 	14.0 	12.6 	10.2 	11.9 	14.6 	17.9 	3.9 	-1.4 	-2.4 	1.7 	2.7 	3.3
U.S. consumption value:
Amount . . . . . . . . . . . . . . . . . . . 	2,199,070 	1,936,374 	2,018,250 	1,963,398 	2,281,267 	2,382,943 	8.4 	-11.9 	4.2 	-2.7 	16.2 	4.5
Producers' share (1) . . . . . . . . . 	85.3 	86.9 	89.9 	87.8 	85.2 	81.1 	-4.2 	1.6 	3.0 	-2.1 	-2.6 	-4.1
Importers' share (1):
Japan . . . . . . . . . . . . . . . . . . . . 	2.7 	0.0 	0.0 	0.0 	0.0 	0.0 	-2.7 	-2.7 	0.0 	0.0 	0.0 	0.0
All other sources . . . . . . . . . . . 	12.0 	13.1 	10.1 	12.2 	14.8 	18.9 	6.9 	1.0 	-3.0 	2.1 	2.6 	4.1
Total imports . . . . . . . . . . . . . 	14.7 	13.1 	10.1 	12.2 	14.8 	18.9 	4.2 	-1.6 	-3.0 	2.1 	2.6 	4.1
U.S. shipments of imports from:
Japan:
Quantity . . . . . . . . . . . . . . . . . . 	95,533 	0 	0 	0 	0 	0 	-100.0 	-100.0 	(2) 	(2) 	(2) 	(2)
Value . . . . . . . . . . . . . . . . . . . . 	58,990 	0 	0 	0 	0 	0 	-100.0 	-100.0 	(2) 	(2) 	(2) 	(2)
Unit value . . . . . . . . . . . . . . . . . 	$617.48 	(2) 	(2) 	(2) 	(2) 	(2) 	-100.0 	-100.0 	(2) 	(2) 	(2) 	(2)
Ending inventory quantity . . . . . 	*** 	0 	0 	0 	0 	0 	*** 	*** 	(2) 	(2) 	(2) 	(2)
All other sources:
Quantity . . . . . . . . . . . . . . . . . . 	424,800 	408,543 	342,006 	382,321 	499,523 	563,173 	32.6 	-3.8 	-16.3 	11.8 	30.7 	12.7
Value . . . . . . . . . . . . . . . . . . . . 	264,629 	253,260 	204,206 	239,326 	337,928 	450,765 	70.3 	-4.3 	-19.4 	17.2 	41.2 	33.4
Unit value . . . . . . . . . . . . . . . . . 	$622.95 	$619.91 	$597.08 	$625.98 	$676.50 	$800.40 	28.5 	-0.5 	-3.7 	4.8 	8.1 	18.3
Ending inventory quantity . . . . . 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
All sources:
Quantity . . . . . . . . . . . . . . . . . . 	520,333 	408,543 	342,006 	382,321 	499,523 	563,173 	8.2 	-21.5 	-16.3 	11.8 	30.7 	12.7
Value . . . . . . . . . . . . . . . . . . . . 	323,619 	253,260 	204,206 	239,326 	337,928 	450,765 	39.3 	-21.7 	-19.4 	17.2 	41.2 	33.4
Unit value . . . . . . . . . . . . . . . . . 	$621.95 	$619.91 	$597.08 	$625.98 	$676.50 	$800.40 	28.7 	-0.3 	-3.7 	4.8 	8.1 	18.3
Ending inventory quantity . . . . . 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
U.S. producers':
Average capacity quantity . . . . . 	4,591,145 	3,777,878 	3,629,045 	3,670,240 	3,670,240 	3,670,240 	-20.1 	-17.7 	-3.9 	1.1 	0.0 	0.0
Production quantity . . . . . . . . . . 	3,333,869 	2,916,110 	3,125,623 	2,934,465 	2,946,392 	2,738,382 	-17.9 	-12.5 	7.2 	-6.1 	0.4 	-7.1
Capacity utilization (1) . . . . . . . . 	72.6 	77.2 	86.1 	80.0 	80.3 	74.6 	2.0 	4.6 	8.9 	-6.2 	0.3 	-5.7
U.S. shipments:
Quantity . . . . . . . . . . . . . . . . . . 	3,201,433 	2,837,608 	3,020,787 	2,835,556 	2,923,432 	2,587,355 	-19.2 	-11.4 	6.5 	-6.1 	3.1 	-11.5
Value . . . . . . . . . . . . . . . . . . . . 	1,875,451 	1,683,114 	1,814,044 	1,724,072 	1,943,339 	1,932,178 	3.0 	-10.3 	7.8 	-5.0 	12.7 	-0.6
Unit value . . . . . . . . . . . . . . . . . 	$585.82 	$593.15 	$600.52 	$608.02 	$664.75 	$746.78 	27.5 	1.3 	1.2 	1.2 	9.3 	12.3
Export shipments:
Quantity . . . . . . . . . . . . . . . . . . 	194,443 	105,341 	110,525 	101,589 	123,459 	105,963 	-45.5 	-45.8 	4.9 	-8.1 	21.5 	-14.2
Value . . . . . . . . . . . . . . . . . . . . 	108,274 	61,367 	65,880 	56,774 	72,304 	81,455 	-24.8 	-43.3 	7.4 	-13.8 	27.4 	12.7
Unit value . . . . . . . . . . . . . . . . . 	$556.84 	$582.56 	$596.06 	$558.86 	$585.65 	$768.71 	38.0 	4.6 	2.3 	-6.2 	4.8 	31.3
Ending inventory quantity . . . . . . 	349,202 	331,964 	324,275 	363,429 	262,974 	307,218 	-12.0 	-4.9 	-2.3 	12.1 	-27.6 	16.8
Inventories/total shipments (1) . . 	10.3 	11.3 	10.4 	12.4 	8.6 	11.4 	1.1 	1.0 	-0.9 	2.0 	-3.7 	2.8
Production workers . . . . . . . . . . 	5,794 	5,256 	4,637 	4,331 	3,857 	3,769 	-34.9 	-9.3 	-11.8 	-6.6 	-10.9 	-2.3
Hours worked (1,000s) . . . . . . . . 	15,399 	10,918 	9,874 	8,609 	8,136 	7,665 	-50.2 	-29.1 	-9.6 	-12.8 	-5.5 	-5.8
Wages paid ($1,000s) . . . . . . . . 	334,330 	287,189 	265,145 	222,495 	223,492 	232,355 	-30.5 	-14.1 	-7.7 	-16.1 	0.4 	4.0
Hourly wages . . . . . . . . . . . . . . . 	$21.71 	$26.30 	$26.85 	$25.84 	$27.47 	$30.31 	39.6 	21.2 	2.1 	-3.8 	6.3 	10.4
Productivity (tons/1,000 hours) . 	216.5 	267.1 	316.6 	340.9 	362.1 	357.3 	65.0 	23.4 	18.5 	7.7 	6.2 	-1.3
Unit labor costs . . . . . . . . . . . . . 	$100.28 	$98.48 	$84.83 	$75.82 	$75.85 	$84.85 	-15.4 	-1.8 	-13.9 	-10.6 	0.0 	11.9
Net sales:
Quantity . . . . . . . . . . . . . . . . . . 	3,358,878 	2,940,949 	3,132,312 	2,936,145 	3,048,847 	2,695,138 	-19.8 	-12.4 	6.5 	-6.3 	3.8 	-11.6
Value . . . . . . . . . . . . . . . . . . . . 	1,975,725 	1,740,481 	1,872,924 	1,778,843 	2,016,042 	2,016,252 	2.1 	-11.9 	7.6 	-5.0 	13.3 	0.0
Unit value . . . . . . . . . . . . . . . . . 	$588.21 	$591.81 	$597.94 	$605.84 	$661.25 	$748.11 	27.2 	0.6 	1.0 	1.3 	9.1 	13.1
Cost of goods sold (COGS) . . . . 	1,958,057 	1,732,228 	1,805,419 	1,622,522 	1,923,537 	1,920,750 	-1.9 	-11.5 	4.2 	-10.1 	18.6 	-0.1
Gross profit or (loss) . . . . . . . . . 	17,668 	8,253 	67,505 	156,321 	92,505 	95,502 	440.5 	-53.3 	717.9 	131.6 	-40.8 	3.2
SG&A expenses . . . . . . . . . . . . 	97,321 	81,965 	79,271 	133,678 	110,965 	110,244 	13.3 	-15.8 	-3.3 	68.6 	-17.0 	-0.6
Operating income or (loss) . . . . . 	(79,653) 	(73,712) 	(11,766) 	22,643 	(18,460) 	(14,742) 	81.5 	7.5 	84.0 	292.4 	-181.5 	20.1
Capital expenditures . . . . . . . . . 	83,191 	35,529 	*** 	*** 	*** 	*** 	*** 	-57.3 	*** 	*** 	*** 	***
Unit COGS . . . . . . . . . . . . . . . . . 	$582.95 	$589.00 	$576.39 	$552.60 	$630.91 	$712.67 	22.3 	1.0 	-2.1 	-4.1 	14.2 	13.0
Unit SG&A expenses . . . . . . . . . 	$28.97 	$27.87 	$25.31 	$45.53 	$36.40 	$40.90 	41.2 	-3.8 	-9.2 	79.9 	-20.1 	12.4
Unit operating income or (loss) . 	($23.71) 	($25.06) 	($3.76) 	$7.71 	($6.05) 	($5.47) 	76.9 	-5.7 	85.0 	305.3 	-178.5 	9.7
COGS/sales (1) . . . . . . . . . . . . . 	99.1 	99.5 	96.4 	91.2 	95.4 	95.3 	-3.8 	0.4 	-3.1 	-5.2 	4.2 	-0.1
Operating income or (loss)/
sales (1) . . . . . . . . . . . . . . . . . . 	(4.0) 	(4.2) 	(0.6) 	1.3 	(0.9) 	(0.7) 	3.3 	-0.2 	3.6 	1.9 	-2.2 	0.2
(1) "Reported data" are in percent and "period changes" are in percentage points.
(2) Not applicable.
Note.--Financial data are reported on a fiscal year basis and may not necessarily be comparable to data reported on a calendar year basis. Because of rounding, figures may not add to the totals shown.
Unit values and shares are calculated from the unrounded figures.
Source: Compiled from data submitted in response to Commission questionnaires.
C-9

Table C-1
TCCSS: Summary data concerning the U.S. market, 2006-11
(Quantity=short tons, value=1,000 dollars, unit values, unit labor costs, and unit expenses are per short ton; period changes=percent except where noted)
Reported data 	Period changes
Item 	2006 	2007 	2008 	2009 	2010 	2011 	2006-11 	2006-07 	2007-08 	2008-09 	2009-10 	2010-11
U.S. consumption quantity:
Amount . . . . . . . . . . . . . . . . . . 3,283,229 	3,159,210 	3,139,040 	2,749,044 	3,212,052 	2,683,441 	-18.3 	-3.8 	-0.6 	-12.4 	16.8 	-16.5
Producers' share (1) . . . . . . . . 	80.5 	80.6 	87.4 	85.6 	80.2 	80.7 	0.1 	0.0 	6.8 	-1.7 	-5.5 	0.5
Importers' share (1):
Japan . . . . . . . . . . . . . . . . . . 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0
All other sources . . . . . . . . . . 	19.5 	19.4 	12.6 	14.4 	19.8 	19.3 	-0.1 	0.0 	-6.8 	1.7 	5.5 	-0.5
Total imports . . . . . . . . . . . . 	19.5 	19.4 	12.6 	14.4 	19.8 	19.3 	-0.1 	0.0 	-6.8 	1.7 	5.5 	-0.5
U.S. consumption value:
Amount . . . . . . . . . . . . . . . . . . 2,424,428 	2,400,865 	2,724,437 	3,026,986 	3,164,231 	2,778,297 	14.6 	-1.0 	13.5 	11.1 	4.5 	-12.2
Producers' share (1) . . . . . . . . 	80.6 	80.2 	86.7 	84.6 	78.8 	78.9 	-1.7 	-0.4 	6.5 	-2.1 	-5.9 	0.1
Importers' share (1):
Japan . . . . . . . . . . . . . . . . . . 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0 	0.0
All other sources . . . . . . . . . . 	19.4 	19.8 	13.3 	15.4 	21.2 	21.1 	1.7 	0.4 	-6.5 	2.1 	5.9 	-0.1
Total imports . . . . . . . . . . . . 	19.4 	19.8 	13.3 	15.4 	21.2 	21.1 	1.7 	0.4 	-6.5 	2.1 	5.9 	-0.1
U.S. imports from:
Japan:
Quantity . . . . . . . . . . . . . . . . 	0 	0 	0 	0 	0 	0 	(2) 	(2) 	(2) 	(2) 	(2) 	(2)
Value . . . . . . . . . . . . . . . . . . . 	0 	0 	0 	0 	0 	0 	(2) 	(2) 	(2) 	(2) 	(2) 	(2)
Unit value . . . . . . . . . . . . . . . 	(2) 	(2) 	(2) 	(2) 	(2) 	(2) 	(2) 	(2) 	(2) 	(2) 	(2) 	(2)
Ending inventory quantity . . . 	0 	0 	0 	0 	0 	0 	(2) 	(2) 	(2) 	(2) 	(2) 	(2)
All other sources:
Quantity . . . . . . . . . . . . . . . . 	639,023 	613,755 	396,448 	394,514 	636,373 	518,383 	-18.9 	-4.0 	-35.4 	-0.5 	61.3 	-18.5
Value . . . . . . . . . . . . . . . . . . . 	471,015 	475,101 	362,537 	465,472 	671,825 	586,977 	24.6 	0.9 	-23.7 	28.4 	44.3 	-12.6
Unit value . . . . . . . . . . . . . . . 	$737 	$774 	$914 	$1,180 	$1,056 	$1,132 	53.6 	5.0 	18.1 	29.0 	-10.5 	7.3
Ending inventory quantity . . . 	76,311 	41,709 	23,752 	32,771 	58,867 	70,261 	-7.9 	-45.3 	-43.1 	38.0 	79.6 	19.4
All sources:
Quantity . . . . . . . . . . . . . . . . 	639,023 	613,755 	396,448 	394,514 	636,373 	518,383 	-18.9 	-4.0 	-35.4 	-0.5 	61.3 	-18.5
Value . . . . . . . . . . . . . . . . . . . 	471,015 	475,101 	362,537 	465,472 	671,825 	586,977 	24.6 	0.9 	-23.7 	28.4 	44.3 	-12.6
Unit value . . . . . . . . . . . . . . . 	$737 	$774 	$914 	$1,180 	$1,056 	$1,132 	53.6 	5.0 	18.1 	29.0 	-10.5 	7.3
Ending inventory quantity . . . 	76,311 	41,709 	23,752 	32,771 	58,867 	70,261 	-7.9 	-45.3 	-43.1 	38.0 	79.6 	19.4
U.S. producers':
Average capacity quantity . . . . 3,653,000 	3,653,000 	3,627,720 	3,543,000 	3,543,000 	3,543,000 	-3.0 	0.0 	-0.7 	-2.3 	0.0 	0.0
Production quantity . . . . . . . . . 2,631,713 	2,546,797 	2,714,429 	2,442,402 	2,594,982 	2,168,240 	-17.6 	-3.2 	6.6 	-10.0 	6.2 	-16.4
Capacity utilization (1) . . . . . . . 	72.0 	69.7 	74.8 	68.9 	73.2 	61.2 	-10.8 	-2.3 	5.1 	-5.9 	4.3 	-12.0
U.S. shipments:
Quantity . . . . . . . . . . . . . . . . 	2,644,206 	2,545,455 	2,742,592 	2,354,530 	2,575,679 	2,165,058 	-18.1 	-3.7 	7.7 	-14.1 	9.4 	-15.9
Value . . . . . . . . . . . . . . . . . . . 1,953,413 	1,925,764 	2,361,900 	2,561,514 	2,492,406 	2,191,320 	12.2 	-1.4 	22.6 	8.5 	-2.7 	-12.1
Unit value . . . . . . . . . . . . . . . 	$739 	$757 	$861 	$1,088 	$968 	$1,012 	37.0 	2.4 	13.8 	26.3 	-11.1 	4.6
Export shipments:
Quantity . . . . . . . . . . . . . . . . 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Value . . . . . . . . . . . . . . . . . . . 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Unit value . . . . . . . . . . . . . . . 	$*** 	$*** 	$*** 	$*** 	$*** 	$*** 	*** 	*** 	*** 	*** 	*** 	***
Ending inventory quantity . . . . 	249,005 	234,647 	249,449 	341,928 	319,182 	297,562 	19.5 	-5.8 	6.3 	37.1 	-6.7 	-6.8
Inventories/total shipments (1) 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Production workers . . . . . . . . . 	*** 	*** 	3,648 	3,150 	3,200 	2,984 	-30.2 	-17.5 	3.5 	-13.7 	1.6 	-6.8
Hours worked (1,000s) . . . . . . 	*** 	*** 	7,013 	6,247 	6,455 	6,183 	-15.3 	-3.8 	-0.1 	-10.9 	3.3 	-4.2
Wages paid ($1,000s) . . . . . . 	*** 	*** 	197,843 	183,735 	199,460 	191,594 	1.7 	-2.9 	8.1 	-7.1 	8.6 	-3.9
Hourly wages . . . . . . . . . . . . . 	$*** 	$*** 	$28.21 	$29.41 	$30.90 	$30.99 	20.0 	1.0 	8.2 	4.3 	5.1 	0.3
Productivity (tons/1,000 hours) 	*** 	*** 	387.1 	391.0 	402.0 	350.7 	-2.8 	0.6 	6.6 	1.0 	2.8 	-12.8
Unit labor costs . . . . . . . . . . . . 	$*** 	$*** 	$72.89 	$75.23 	$76.86 	$88.36 	23.4 	0.4 	1.5 	3.2 	2.2 	15.0
Net sales:
Quantity . . . . . . . . . . . . . . . . 	2,678,947 	2,561,155 	2,763,295 	2,364,130 	2,590,379 	2,166,858 	-19.1 	-4.4 	7.9 	-14.4 	9.6 	-16.3
Value . . . . . . . . . . . . . . . . . . . 1,979,671 	1,937,407 	2,377,902 	2,571,572 	2,507,635 	2,193,349 	10.8 	-2.1 	22.7 	8.1 	-2.5 	-12.5
Unit value . . . . . . . . . . . . . . . 	$739 	$756 	$861 	$1,088 	$968 	$1,012 	37.0 	2.4 	13.8 	26.4 	-11.0 	4.6
Cost of goods sold (COGS) . . 	1,974,716 	1,984,764 	2,491,823 	2,337,536 	2,498,443 	2,283,740 	15.6 	0.5 	25.5 	-6.2 	6.9 	-8.6
Gross profit or (loss) . . . . . . . . 	4,955 	-47,357 	-113,921 	234,036 	9,192 	-90,391 	(2) 	(2) 	-140.6 	(2) 	-96.1 	(2)
SG&A expenses . . . . . . . . . . . 	111,433 	113,877 	115,281 	60,628 	87,422 	108,403 	-2.7 	2.2 	1.2 	-47.4 	44.2 	24.0
Operating income or (loss) . . . 	-106,478 	-161,234 	-229,202 	173,408 	-78,230 	-198,794 	-86.7 	-51.4 	-42.2 	(2) 	(2) 	-154.1
Capital expenditures . . . . . . . . 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Unit COGS . . . . . . . . . . . . . . . 	$737 	$775 	$902 	$989 	$965 	$1,054 	43.0 	5.1 	16.4 	9.6 	-2.5 	9.3
Unit SG&A expenses . . . . . . . 	$42 	$44 	$42 	$26 	$34 	$50 	20.3 	6.9 	-6.2 	-38.5 	31.6 	48.2
Unit operating income or (loss) 	-$40 	-$63 	-$83 	$73 	-$30 	-$92 	-130.8 	-58.4 	-31.8 	(2) 	(2) 	-203.8
COGS/sales (1) . . . . . . . . . . . 	99.7 	102.4 	104.8 	90.9 	99.6 	104.1 	4.4 	2.7 	2.3 	-13.9 	8.7 	4.5
Operating income or (loss)/
sales (1) . . . . . . . . . . . . . . . . 	-5.4 	-8.3 	-9.6 	6.7 	-3.1 	-9.1 	-3.7 	-2.9 	-1.3 	16.4 	-9.9 	-5.9
(1) "Reported data" are in percent and "period changes" are in percentage points.
(2) Not applicable.
Note.--Financial data are reported on a fiscal year basis and may not necessarily be comparable to data reported on a calendar year basis. Because of rounding, figures may not add to the totals s
Unit values and shares are calculated from the unrounded figures.
Source: Compiled from data submitted in response to Commission questionnaires and from official Commerce statistics.
C-11

Table C-1
TCCSS: Summary data concerning the U.S. market, 2014-16, January to September 2016, and January to September 2017
Jan-Sep
2014 	2015 	2016 	2016 	2017 	2014-16 	2014-15 	2015-16 	2016-17
U.S. consumption quantity:
Amount................................................................... 	2,661,145 	2,498,450 	2,454,209 	1,870,725 	1,799,976 	(7.8) 	(6.1) 	(1.8) 	(3.8)
Producers' share (fn1)............................................. 	68.3 	63.2 	56.9 	58.8 	53.9 	(11.4) 	(5.1) 	(6.3) 	(5.0)
Importers' share (fn1):
Japan................................................................... 	--- 	--- 	--- 	--- 	--- 	--- 	--- 	--- 	---
Netherlands......................................................... 	10.7 	10.9 	12.6 	11.8 	11.8 	2.0 	0.2 	1.7 	0.0
Canada................................................................ 	8.0 	8.7 	10.6 	10.5 	10.2 	2.6 	0.7 	1.9 	(0.3)
Germany.............................................................. 	4.1 	7.3 	7.7 	7.8 	9.1 	3.6 	3.2 	0.4 	1.3
Korea................................................................... 	3.8 	3.9 	5.2 	4.8 	5.0 	1.4 	0.1 	1.3 	0.2
China................................................................... 	3.7 	3.3 	4.4 	3.8 	5.8 	0.7 	(0.4) 	1.1 	2.0
All other sources.................................................. 	1.5 	2.8 	2.7 	2.4 	4.2 	1.2 	1.3 	(0.1) 	1.8
Nonsubject sources.......................................... 	31.7 	36.8 	43.1 	41.2 	46.1 	11.4 	5.1 	6.3 	5.0
All import sources.......................................... 	31.7 	36.8 	43.1 	41.2 	46.1 	11.4 	5.1 	6.3 	5.0
U.S. consumption value:
Amount................................................................... 	2,802,315 	2,561,810 	2,199,419 	1,673,430 	1,689,898 	(21.5) 	(8.6) 	(14.1) 	1.0
Producers' share (fn1)............................................. 	68.1 	63.9 	58.4 	60.2 	55.2 	(9.7) 	(4.2) 	(5.4) 	(4.9)
Importers' share (fn1):
Japan................................................................... 	--- 	--- 	--- 	--- 	--- 	--- 	--- 	--- 	---
Netherlands......................................................... 	10.3 	10.4 	12.1 	11.3 	11.3 	1.7 	0.1 	1.6 	0.0
Canada................................................................ 	8.9 	9.2 	10.9 	10.9 	10.6 	2.0 	0.3 	1.7 	(0.2)
Germany.............................................................. 	4.2 	7.1 	7.7 	7.8 	9.2 	3.5 	2.9 	0.7 	1.4
Korea................................................................... 	3.7 	3.8 	4.6 	4.3 	4.6 	0.9 	0.1 	0.8 	0.3
China................................................................... 	3.3 	2.9 	3.7 	3.3 	5.2 	0.4 	(0.3) 	0.8 	1.9
All other sources.................................................. 	1.5 	2.7 	2.6 	2.3 	3.9 	1.1 	1.2 	(0.2) 	1.6
Nonsubject sources.......................................... 	31.9 	36.1 	41.6 	39.8 	44.8 	9.7 	4.2 	5.4 	4.9
All import sources.......................................... 	31.9 	36.1 	41.6 	39.8 	44.8 	9.7 	4.2 	5.4 	4.9
U.S. imports from:
Japan:
Quantity............................................................... 	--- 	--- 	--- 	--- 	--- 	--- --- --- ---
Value................................................................... 	--- 	--- 	--- 	--- 	--- 	--- --- --- ---
Unit value............................................................. 	--- 	--- 	--- 	--- 	--- 	--- --- --- ---
Ending inventory quantity..................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Netherlands:
Quantity............................................................... 	283,946 	272,352 	309,996 	220,580 	212,922 	*** 	*** 	*** 	***
Value................................................................... 	290,009 	267,356 	265,444 	188,533 	190,629 	*** 	*** 	*** 	***
Unit value............................................................. 	$1,021 	$982 	$856 	$855 	$895 	*** 	*** 	*** 	***
Ending inventory quantity..................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Canada
Quantity............................................................... 	212,299 	216,295 	259,546 	196,883 	183,479 	*** 	*** 	*** 	***
Value................................................................... 	248,545 	234,808 	239,577 	181,788 	179,936 	*** 	*** 	*** 	***
Unit value............................................................. 	$1,171 	$1,086 	$923 	$923 	$981 	*** 	*** 	*** 	***
Ending inventory quantity..................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Germany
Quantity............................................................... 	109,478 	182,717 	188,800 	145,859 	163,723 	*** 	*** 	*** 	***
Value................................................................... 	117,128 	180,761 	169,658 	130,397 	154,823 	*** 	*** 	*** 	***
Unit value............................................................. 	$1,070 	$989 	$899 	$894 	$946 	*** 	*** 	*** 	***
Ending inventory quantity..................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Korea
Quantity............................................................... 	100,001 	96,200 	126,400 	90,449 	90,007 	*** 	*** 	*** 	***
Value................................................................... 	103,858 	97,421 	101,117 	72,486 	77,682 	*** 	*** 	*** 	***
Unit value............................................................. 	$1,039 	$1,013 	$800 	$801 	$863 	*** 	*** 	*** 	***
Ending inventory quantity..................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
China
Quantity............................................................... 	97,713 	82,669 	107,134 	71,458 	104,503 	*** 	*** 	*** 	***
Value................................................................... 	91,432 	74,865 	81,471 	54,699 	87,460 	*** 	*** 	*** 	***
Unit value............................................................. 	$936 	$906 	$760 	$765 	$837 	*** 	*** 	*** 	***
Ending inventory quantity..................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
All other sources:
Quantity............................................................... 	40,645 	70,231 	66,213 	45,019 	75,666 	*** 	*** 	*** 	***
Value................................................................... 	42,681 	70,404 	56,759 	38,783 	66,027 	*** 	*** 	*** 	***
Unit value............................................................. 	$1,050 	$1,002 	$857 	$861 	$873 	*** 	*** 	*** 	***
Ending inventory quantity..................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Nonsubject sources:
Quantity............................................................... 	844,082 	920,463 	1,058,090 	770,248 	830,300 	*** 	*** 	*** 	***
Value................................................................... 	893,654 	925,615 	914,025 	666,687 	756,556 	*** 	*** 	*** 	***
Unit value............................................................. 	$1,059 	$1,006 	$864 	$866 	$911 	*** 	*** 	*** 	***
Ending inventory quantity..................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
All import sources:
Quantity............................................................... 	844,082 	920,463 	1,058,090 	770,248 	830,300 	*** 	*** 	*** 	***
Value................................................................... 	893,654 	925,615 	914,025 	666,687 	756,556 	*** 	*** 	*** 	***
Unit value............................................................. 	$1,059 	$1,006 	$864 	$866 	$911 	*** 	*** 	*** 	***
Ending inventory quantity..................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Table continued on next page.
(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)
January-September
Reported data 	Period changes
Calendar year
C-13

Table C-1--Continued
TCCSS: Summary data concerning the U.S. market, 2014-16, January to September 2016, and January to September 2017
Jan-Sep
2014 	2015 	2016 	2016 	2017 	2014-16 	2014-15 	2015-16 	2016-17
U.S. producers':
Average capacity quantity....................................... 	3,068,000 	3,068,000 	3,068,000 	2,301,000 	2,301,000 	--- 	--- 	--- 	---
Production quantity................................................. 	1,835,936 	1,515,670 	1,374,409 	1,102,314 	997,687 	(25.1) 	(17.4) 	(9.3) 	(9.5)
Capacity utilization (fn1).......................................... 	59.8 	49.4 	44.8 	47.9 	43.4 	(15.0) 	(10.4) 	(4.6) 	(4.5)
U.S. shipments:
Quantity............................................................... 	1,817,063 	1,577,987 	1,396,119 	1,100,477 	969,676 	(23.2) 	(13.2) 	(11.5) 	(11.9)
Value................................................................... 	1,908,661 	1,636,195 	1,285,394 	1,006,743 	933,342 	(32.7) 	(14.3) 	(21.4) 	(7.3)
Unit value............................................................. 	$1,050 	$1,037 	$921 	$915 	$963 	(12.3) 	(1.3) 	(11.2) 	5.2
Export shipments:
Quantity............................................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Value................................................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Unit value............................................................. 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Ending inventory quantity........................................ 	253,038 	190,001 	167,428 	191,108 	191,931 	(33.8) 	(24.9) 	(11.9) 	0.4
Inventories/total shipments (fn1)............................. 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Production workers................................................. 	2,857 	2,670 	2,343 	2,349 	2,474 	(18.0) 	(6.5) 	(12.2) 	5.3
Hours worked (1,000s)............................................ 	5,564 	5,044 	4,537 	3,417 	3,665 	(18.5) 	(9.3) 	(10.1) 	7.3
Wages paid ($1,000)............................................... 	246,839 	207,385 	202,886 	154,431 	159,158 	(17.8) 	(16.0) 	(2.2) 	3.1
Hourly wages.......................................................... 	$44.36 	$41.12 	$44.72 	$45.19 	$43.43 	0.8 	(7.3) 	8.8 	(3.9)
Productivity (short tons per 1,000 hours) 	330.0 	300.5 	302.9 	322.6 	272.2 	(8.2) 	(8.9) 	0.8 	(15.6)
Unit labor costs....................................................... 	$134 	$137 	$148 	$140 	$160 	9.8 	1.8 	7.9 	13.9
Net sales:
Quantity............................................................... 	1,817,123 	1,578,707 	1,396,982 	1,101,207 	973,185 	(23.1) 	(13.1) 	(11.5) 	(11.6)
Value................................................................... 	1,908,724 	1,636,990 	1,286,257 	1,007,472 	936,494 	(32.6) 	(14.2) 	(21.4) 	(7.0)
Unit value............................................................. 	$1,050 	$1,037 	$921 	$915 	$962 	(12.3) 	(1.3) 	(11.2) 	5.2
Cost of goods sold (COGS).................................... 	1,865,877 	1,604,041 	1,279,130 	989,636 	962,322 	(31.4) 	(14.0) 	(20.3) 	(2.8)
Gross profit of (loss)................................................ 	42,847 	32,949 	7,127 	17,836 	(25,828) 	(83.4) 	(23.1) 	(78.4) 	fn2
SG&A expenses..................................................... 	55,228 	49,272 	34,180 	27,831 	23,809 	(38.1) 	(10.8) 	(30.6) 	(14.5)
Operating income or (loss)...................................... 	(12,381) 	(16,323) 	(27,053) 	(9,995) 	(49,637) 	118.5 	31.8 	65.7 	396.6
Capital expenditures............................................... 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	*** 	***
Unit COGS.............................................................. 	$1,027 	$1,016 	$916 	$899 	$989 	(10.8) 	(1.1) 	(9.9) 	10.0
Unit SG&A expenses.............................................. 	$30 	$31 	$24 	$25 	$24 	(19.5) 	2.7 	(21.6) 	(3.2)
Unit operating income or (loss)................................ 	($7) 	($10) 	($19) 	($9) 	($51) 	184.2 	51.7 	87.3 	461.9
COGS/sales (fn1)................................................... 	97.8 	98.0 	99.4 	98.2 	102.8 	1.7 	0.2 	1.5 	4.5
Operating income or (loss)/sales (fn1)..................... 	(0.6) 	(1.0) 	(2.1) 	(1.0) 	(5.3) 	(1.5) 	(0.3) 	(1.1) 	(4.3)
Note.--Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent.
fn1.--Reported data are in percent and period changes are in percentage points.
fn2.--Undefined.
fn3.--Not available.
(Quantity=short tons; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per short ton; Period changes=percent--exceptions noted)
Reported data 	Period changes
Calendar year 	January-September
Source: Compiled from data submitted in response to Commission questionnaires, and from official U.S. import statistics using HTS statistical reporting numbers 7210.11.0000, 7210.12.0000,
7210.50.0000, and 7212.10.0000, accessed February 1, 2018. 	.
C-14

APPENDIX D

IMPACT OF THE ORDER AND LIKELY EFFECTS OF REVOCATION

D-1

D-3
Table D-1
TCCSS: Firms’ narratives on the impact of the order and the likely impact of revocation
Response
type Firm type 	Firm name and narrative on impact or likely impact
Effect of order 	U.S. producers 	***
Effect of order 	U.S. producers 	***
Effect of order 	U.S. producers 	***
Likely impact
of revocation
U.S. producers 	***
Table continued.

D-4
Table D-1 Continued
TCCSS: Firms’ narratives on the impact of the order and the likely impact of revocation
Response
type Firm type 	Firm name and narrative on impact or likely impact
Likely impact
of revocation
U.S. producers 	***
Likely impact
of revocation
U.S. producers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Table continued.

D-5
Table D-1 Continued
TCCSS: Firms’ narratives on the impact of the order and the likely impact of revocation
Response
type Firm type 	Firm name and narrative on impact or likely impact
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Effect of order 	Importers 	***
Likely impact
of revocation
Importers 	***
Likely impact
of revocation
Importers 	***
Likely impact
of revocation
Importers 	***
Likely impact
of revocation
Importers 	***
Likely impact
of revocation
Importers 	***
Likely impact
of revocation
Importers 	***
Likely impact
of revocation
Importers 	***
Table continued.

D-6
Table D-1 Continued
TCCSS: Firms’ narratives on the impact of the order and the likely impact of revocation
Response
type Firm type 	Firm name and narrative on impact or likely impact
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Table continued.

D-7
Table D-1 Continued
TCCSS: Firms’ narratives on the impact of the order and the likely impact of revocation
Response
type Firm type 	Firm name and narrative on impact or likely impact
Effect of order 	Purchasers 	***
Effect of order 	Purchasers 	***
Likely impact
of revocation
Purchasers 	***
Likely impact
of revocation
Purchasers 	***
Likely impact
of revocation
Purchasers 	***
Likely impact
of revocation
Purchasers 	***
Likely impact
of revocation
Purchasers 	***
Likely impact
of revocation
Purchasers 	***
Likely impact
of revocation
Purchasers 	***
Likely impact
of revocation
Purchasers 	***
Likely impact
of revocation
Purchasers 	***
Table continued.

D-8
Table D-1 Continued
TCCSS: Firms’ narratives on the impact of the order and the likely impact of revocation
Response
type Firm type 	Firm name and narrative on impact or likely impact
Effect of order 	Foreign
producers
***
Effect of order 	Foreign
producers
***
Effect of order 	Foreign
producers
***
Likely impact
of revocation
Foreign
producers
***
Likely impact
of revocation
Foreign
producers
***
Source: Compiled from data submitted in response to Commission questionnaires.

APPENDIX E COMPANY-SPECIFIC FINANCIAL DATA
E-1

E-3
Table E-1
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Net sales quantity
Quantity in short tons
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Net sales value
Value in 1,000 dollars
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
COGS
Value in 1,000 dollars
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Gross profit or (loss)
Value in 1,000 dollars
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.

E-4
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
SG&A expenses
Value in 1,000 dollars
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Operating income or (loss)
Value in 1,000 dollars
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Net income or (loss)
Value in 1,000 dollars
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
COGS to net sales ratio
Ratio in percent
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.

E-5
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Gross profit or (loss) to net sales ratio
Ratio in percent
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
SG&A expenses to net sales ratio
Ratio in percent
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Operating income or (loss) to net sales ratio
Ratio in percent
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Net income or (loss) to net sales ratio
Ratio in percent
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.

E-6
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Unit net sales value
Unit value in dollars per short ton
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Unit total raw materials cost
Unit value in dollars per short ton
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Unit direct labor cost
Unit value in dollars per short ton
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Unit other factory costs
Unit value in dollars per short ton
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.

E-7
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Unit COGS
Unit value in dollars per short ton
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Unit gross profit or (loss)
Unit value in dollars per short ton
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Unit SG&A expenses
Unit value in dollars per short ton
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Unit operating income or (loss)
Unit value in dollars per short ton
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Table continued.

E-8
Table E-1 Continued
TCCSS: U.S. producers’ sales, costs/expenses, and profitability, by firm and period
Unit net income or (loss)
Unit value in dollars per short ton
Firm 	2021 	2022 	2023
Cleveland-Cliffs 	*** 	*** 	***
Ohio Coatings 	*** 	*** 	***
U.S. Steel 	*** 	*** 	***
All firms 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.

APPENDIX F

PURCHASER RESPONSES REGARDING REJECTION RATES

F-1

F-3
Table F-1
TCCSS: Purchaser responses regarding rejection rates
Proportion in percent; Quantity in short tons
Source 	Supplier name 	Purchaser
Proportion
rejected
Quantity
rejected 	Narrative on reason for rejection
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
Table continued.

F-4
Table F-1 Continued
TCCSS: Purchaser responses regarding rejection rates
Proportion in percent; Quantity in short tons
Source 	Supplier name 	Purchaser
Proportion
rejected
Quantity
rejected 	Narrative on reason for rejection
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
Table continued.

F-5
Table F-1 Continued
TCCSS: Purchaser responses regarding rejection rates
Proportion in percent; Quantity in short tons
Source 	Supplier name 	Purchaser
Proportion
rejected
Quantity
rejected 	Narrative on reason for rejection
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
Table continued.

F-6
Table F-1 Continued
TCCSS: Purchaser responses regarding rejection rates
Proportion in percent; Quantity in short tons
Source 	Supplier name 	Purchaser
Proportion
rejected
Quantity
rejected 	Narrative on reason for rejection
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
*** 	*** 	*** 	*** 	*** 	***
Source: Compiled from data submitted in response to Commission questionnaires.
Note: ***. Zeroes, null values, and undefined calculations are suppressed and shown as “---“.