pup joint china manufacturer quotation

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OCTG Pup Joints is one kind of common accessories for connection with casing and tubing. Threaded pup joints are divided into male threaded ends, single male threaded and Female threaded. The size and material is the same as the casing or tubing.

China N80 Pup Joint Manufacturer Derbo Supplies N80 Pup Joint, Hot Rolled, 1.66 Inch, EUE 2.40lb/ft, Oiled, Painting Finish, for Oil & Gas Industries.

ADFO manufactures Pup Joints with Integral Hammer Union end connections.These Pup Joints are used on high pressure discharge lines, choke and kill lines, auxiliary flow and other applications.

Windlass manufactures Pup Joints with integral hammer lug union end connections. This enables faster, easier make-up and break-out of temporary flow lines.

Prithviraj Industries manufactures Pup Joints up to 20, 000 psi cold working pressure in sizes: 1, 11 /2, 2, 3, and 4-inch bore sizes, lengths to 20 feet.

[1] On July 22, 2011, the Canada Border Services Agency (CBSA) received a written complaint from Alberta Oil Tool (AOT), a division of Dover Corporation (Canada) Limited of Edmonton, Alberta, (hereafter, "the Complainant") alleging that imports of certain pup joints originating in or exported from the People"s Republic of China (China) are being dumped and subsidized and causing injury to the Canadian industry.

[2] On August 12, 2011, pursuant to paragraph 32(1)(a) of the Special Import Measures Act (SIMA), the CBSA informed the Complainant that the complaint was properly documented. The CBSA also notified the government of China (GOC) that a properly documented complaint had been received and provided the GOC with the non-confidential version of the subsidy portion of the complaint, which excluded sections dealing with normal value, export price and margin of dumping.

[3] On September 9, 2011 consultations were held with the GOC in Ottawa pursuant to Article 13.1 of the Agreement on Subsidies and Countervailing Measures. During these consultations, China made representations with respect to its views on the evidence presented in the non-confidential version of the subsidy portion of the complaint.

[4] On September 12, 2011, pursuant to subsection 31(1) of SIMA, the President of the CBSA (President) initiated investigations respecting the dumping and subsidizing of certain pup joints from China.

[5] On September 13, 2011, the Canadian International Trade Tribunal (Tribunal) commenced a preliminary injury inquiry, pursuant to subsection 34(2) of SIMA, into whether the evidence discloses a reasonable indication that the alleged dumping and subsidizing of certain pup joints from China have caused injury or retardation or are threatening to cause injury to the Canadian industry producing the goods. On November 14, 2011, pursuant to subsection 37.1(1) of SIMA, the Tribunal determined that there is evidence that discloses a reasonable indication that the alleged dumping and subsidizing of certain pup joints have caused injury or retardation or are threatening to cause injury to the domestic industry.

[6] On December 12, 2011, the CBSA made preliminary determinations of dumping and subsidizing with respect to certain pup joints originating in or exported from China pursuant to subsection 38(1) of SIMA, and began imposing provisional duties on imports of the subject goods pursuant to subsection 8(1) of SIMA.

[8] The CBSA continued its investigations and, on the basis of the evidence, the President is satisfied that certain pup joints originating in or exported from China have been dumped and subsidized and that the margins of dumping and the amounts of subsidy are not insignificant. Consequently, on March 12, 2012, the President made final determinations of dumping and subsidizing pursuant to paragraph 41(1)(a) of SIMA.

[10] Each of the two investigations has its own separate Period of Investigation (POI). The dumping POI includes shipments of subject pup joints released into Canada from July 1, 2010 to June 30, 2011, while the subsidy POI includes shipments of subject pup joints released into Canada from January 1, 2010 to June 30, 2011.

[13] Of the other producers certified to produce the like goods in Canada, only Tenaris Canada (Tenaris), of Sault Ste. Marie, Ontario, confirmed that they are manufacturing them. Tenaris produces like goods which are premium pup joints in relatively small quantities and provided a letter supporting the complaint.[1]

[14] At the initiation of the investigations, the CBSA identified 109 potential exporters and producers of the goods under investigation. The CBSA sent a Dumping Request for Information (RFI) to each potential exporter and section 20 and subsidy RFIs to each potential exporter and producer in China.

[18] For the purpose of these investigations, “Government of China” refers to all levels of government, i.e. federal, central, provincial/state, regional, municipal, city, township, village, local, legislative, administrative or judicial, singular, collective, elected or appointed. It also includes any person, agency, enterprise, or institution acting for, on behalf of, or under the authority of, or under the authority of any law passed by, the government of that country or that provincial, state or municipal or other local or regional government.

[22] As part of the section 20 inquiry, RFIs were sent to all known producers of pup joints in other countries (excluding China). This list of certified producers was obtained directly from the American Petroleum Institute (API). Although seven producers indicated their intention to provide a response, no complete response to the Surrogate RFI was ever received.

“Oil country tubular goods pup joints, made of carbon or alloy steel, welded or seamless, heat-treated or not heat-treated, regardless of end finish, having an outside diameter from 2 3/8 inches to 4 1/2 inches (60.3 mm to 114.3 mm), in all grades, in lengths from 2 feet to 12 feet (61 cm to 366 cm) originating in or exported from the People"s Republic of China.”

[24] Pup joints are oil country tubular goods (OCTG) made from carbon or alloy steel pipes used for the exploration and exploitation of oil and natural gas. These pipes may be made by the electric resistance welded (ERW) or seamless production method, and are supplied to meet API specification 5CT or equivalent standard.[6]

[25] Pup joints are primarily used for the purpose of adjusting the depth of strings or down hole tools, particularly where exact depth readings in a well are required for any given purpose, such as setting valves, packers, nipples or circulating sleeves. Pup joints are also used with down hole pumps. The number and lengths of pup joints may vary widely from well to well, depending on the various equipment and performance requirements established by engineers of the purchasing end users.

[26] Pup joints may range from 2 feet to 12 feet in length with a permitted tolerance of plus or minus three inches. The sizes are generally 2, 4, 6, 8, 10 and 12 feet in length.

[27] The pup joints subject to these investigations are, by virtue of the characteristics such as the outside diameter range, essentially short lengths of OCTG tubing.

[28] Pup joints are manufactured in Canada by the Complainant using plain end tube as an input. For J55 grade pup joints, a length of J55 OCTG tubing is employed. For L80 grade pup joints, the input is an A-519 mechanical tube with the appropriate steel chemistry for L80 OCTG. The L80 input tube does not qualify for the API 5CT designation until it has been tested in accordance with API requirements. The Complainant performs the testing required.

[30] The production process of the input pipe itself is virtually identical to that employed for OCTG tubing and casing. There are, however, significant subsequent costs associated with transforming the input tubing into pup joints including: cutting to length, end finishing, threading, and testing to meet the certification required.

[31] For J55 grade pup joints, the Complainant produces an upset end by heating (upset forging) and butting to thicken the end of the pipe diameter for threading. J55 tubing is cut 8 inches longer than the required pup joint length to accommodate this process. In the case of L80 grade pup joints, the production process uses profiling rather than upset ends, and accordingly only 1/4 inch of additional length is needed to accommodate finishing. Profiling refers to machining the pipe towards the ends of the pipe so it is thicker at the far ends. This process is used instead of upsetting because upsetting a pipe with steel chemistry for an L80 grade would require the producer to heat-treat the pipe again.

[32] Testing includes drift testing which is an assessment of the straightness within the hollow part of the tube, to ensure no bends or kinks exist after the pup joint was forged, and hydrostatic testing which assesses the pup joint’s ability to withstand internal pressure.

[40] Regarding the dumping investigation, information was requested from known and potential exporters, vendors and importers, concerning shipments of subject pup joints released into Canada during the dumping POI of July 1, 2010 to June 30, 2011.

[41] Regarding the subsidy investigation, information related to potential actionable subsidies was requested from known and potential exporters and the GOC concerning financial contributions made to exporters or producers of subject pup joints released into Canada during the subsidy POI of January 1, 2010 to June 30, 2011.

[42] In addition, known and possible exporters and producers of pup joints, along with the GOC, were requested to respond to the section 20 RFI for the purposes of the section 20 Inquiry.

[55] The Complainant requested that section 20 be applied in the determination of normal values due to the alleged existence of the conditions set forth in paragraph 20(1)(a) of SIMA. In their complaint, the Complainant provided information to support these allegations concerning the steel industry in China including the OCTG sector, which includes pup joints.[15]

[56] At the initiation of the dumping investigation, the CBSA had sufficient information from the Complainant, the CBSA’s own research and previous CBSA section 20 opinions to support the initiation of a section 20 inquiry to examine the extent of GOC involvement in pricing in the OCTG sector, which includes pup joints. The information indicated that domestic prices in China have been influenced by various GOC industrial policies concerning the Chinese steel industry including the OCTG sector, which includes pup joints.

[60] As part of the CBSA’s examination of the OCTG sector in China, which includes pup joints, the GOC was requested to provide information concerning the Chinese manufacturers of OCTG by region, the type of products produced (i.e. welded versus seamless) and their respective steel production capacities. In addition, the GOC was requested to indicate the ownership structure of each manufacturer along with information pertaining to OCTG manufacturers that are State-Owned Enterprises (SOE).

[61] In response, the GOC provided OCTG sector information that was limited to the sole cooperating exporter in China, Hengshui Weijia. The GOC provided no further details on the other producers in the Chinese OCTG sector. In its response, the GOC indicated that:

[63] Furthermore, according to recent legislation passed by the GOC, through the Criterion for the Production and Operation of Steel Industry – GY [2010] No. 105,[17] there is an application process that requests this information from producers along with additional detailed information concerning output value, sales revenue, profits etc. At minimum, the GOC has the information available from its SOEs, which comprise a substantial proportion of the top OCTG producers in the sector. This indicates that the information requested by the CBSA is available to the GOC and current information from the GOC regarding the OCTG sector in China, which includes pup joints, would have been useful to the CBSA in its analysis.

[64] This is the same sector that was examined in the CBSA’s investigations of certain Seamless Steel Casing (2008) and certain OCTG (2010). Each of those section 20 inquiries concluded that domestic prices in the OCTG sector in China are substantially determined by the GOC and that there is sufficient reason to believe that the domestic prices are not substantially the same as they would be in a competitive market.

[65] The following is the CBSA’s analysis of the relevant factors that prevail in the Chinese steel industry, which subsequently affect the OCTG sector, which includes pup joints.

[70] The 2009 Steel Revitalization/Rescue Plan also applies to the OCTG sector in China, which includes pup joints. There is evidence on the record confirming that the GOC specifically directed one of the cooperating exporters in the OCTG (2010) investigation, which was one of the largest SOE producers, and possibly the largest seamless OCTG manufacturer, to reorganize with another company.[20]

[73] Also included in this plan are minimum requirements for steel production in order to eliminate smaller players in the market. Through this plan, the GOC is continuing its reform and restructuring of the Chinese steel industry. The GOC’s target is that by 2015, China’s top 10 steel producers will represent 60% of the country’s total steel output. According to the NSP (2005), the long-range GOC target for mergers and acquisitions is to have the top 10 Chinese steel producers account for 70% of total national steel production by 2020.[23] This plan is the next development stage of GOC directives aimed at achieving this long-range 2020 target.

[75] According to the plan, the more highly concentrated steel industry will reduce overcapacity, decrease pollution and will improve Chinese steel producers’ bargaining power when negotiating prices on iron ore imports. In addition, through the 12th Five-Year Development Plan for the Steel Industry, the GOC is progressing with its initiative in the 2009 Steel Revitalization/Rescue Plan to move Chinese steel production facilities to China’s coast. By the end of this GOC directed plan in 2015, 40% of China’s steel production will be relocated to the coast.[25]

Improve planning by regional authorities of industries to develop the steel industry, combine the regional mergers and reconstruction and eliminate obsolete construction. Related enterprises should put forward the planning scheme corresponding to the foregoing plan. The China Iron and Steel Industry should assist and put forward advice on the policy.

[80] Together with the GOC’s recent legislation: Criterion for the Production and Operation of Steel Industry – GY [2010] No. 105[28] and Several Observations of the General Office of the State Council on Further Strengthening Energy-saving and Emission Reduction Efforts, as well as the Accelerating of Restructuring of Steel Industry – GBF (1010) No. 34,[29] these plans set out the detailed requirements for existing production and operations of steel enterprises in China. For construction and renovation projects in the steel industry, the GOC’s development policies for the steel industry apply (i.e. the 12th Five-Year Plan: Iron and Steel and 2009 Steel Revitalization/Rescue Plan).

[82] The above GOC statement that the Five-Year Plans are merely instructive and guiding are inconsistent with the reality of the GOC’s macro-economic policies/measures that support the GOC’s stated objectives. The GOC’s measures, notices and observations as addressed in this section 20 inquiry serve to illustrate the fact that the GOC is closely administering the steel industry in China.

[83] Based on the information on the record, the scope of the GOC’s macro-economic policies/measures provide a compelling factual basis that the GOC is influencing the Chinese steel industry including the OCTG sector, which includes the pup joints under investigation.

[86] The intent of this legislation is to further support and carry out the 2009 Steel Revitalization/Rescue Plan, to achieve the energy-saving and emission targets, in addition to the restructuring of the steel industry in China as approved by the State Council. One main objective of the State Council is to “resolutely suppress the excessive growth of steel production capacity” and “strictly implement the approval and review process of steel projects.”[32]

[88] Information on the record further illustrates that GOC macro-economic policies/measures are compulsory and followed by local governments, with substantive impacts on the commercial decisions of producers of pup joints.[33]

[89] The “China Steel Pipe Industry 12th Five-Year Plan” was released by the Steel Pipe Branch of the China Steel Construction Society.[34] In its response to the section 20 RFI, the China Iron and Steel Association (CISA) stated that the Steel Pipe Branch is one of its member institutions.[35] The CBSA considers CISA to be “Government” as it is under the administration of SASAC as per its Articles of Association. This plan directs that the output of steel pipe should be controlled at 67-75 million metric tonnes (mmt). The scope of the GOC’s reform of the Chinese steel industry thus extends to the Chinese pipe sector, with the industry concentration targets through mergers and acquisitions to be attained by the end of 2015. Additional details of the China Steel Pipe Industry 12th Five-Plan were addressed in the Statement of Reasons for the preliminary determination.

[91] Wuxi Forest Petroleum Technology Co., Ltd. (Wuxi Forest) had provided a response to the CBSA’s dumping RFI which had Chinese domestic sales of pup joints.[37] Wuxi Forest is a Chinese trading company and is not a manufacturer of pup joints. The company’s exports to Canada were subsequently found to be non-subject to the investigation. Wuxi Forest had purchased pup joints in China for re-sale during the POI. The acquisition cost of these pup joints represent actual Chinese domestic sales of pup joints. These Chinese domestic sales are all grade P110 pup joints which is a high-end API 5CT specification.[38] The CBSA used these Chinese domestic selling prices of pup joints for the following analysis.

[92] Firstly, the CBSA compared the overall average selling price of these P110 goods sold in China, with U.S. selling prices of High Collapse P110 (HCP) as reported by Pipe Logix during the POI.[39] Pipe Logix does not report U.S. domestic selling prices for ordinary P110 grade product, as it is not normally sold in the US domestic market. However, P110 is required for some applications in the Canadian oilfield where there are sour gas environments. HCP pipe is not an equivalent grade but a very comparable specification to the P110. A comparison of the HCP to the P110 grades based on like outside diameters (OD) and nominal weights of 11.6 pounds per foot (lbs/ft) for the Chinese and U.S. products indicates that the selling price of Chinese P110 pup joints was less than the selling prices of standard length HCP casing in the U.S. (likely about a 30 foot length), on a metric tonne basis.

[93] To put this in perspective, if the Chinese domestic pup joints were all of 10 foot lengths, there would be approximately 19 pup joints in a metric tonne with each end piece finished and tested according to the API 5CT specification. [40] In contrast, the reported U.S. Pipe Logix selling price, on a metric tonne basis, is comprised of average standard lengths of about 30 feet, meaning each tonne would comprise roughly six 30 foot lengths with finished and tested ends according to the API 5CT specification.[41] With the same OD and 11.6 lbs/ft nominal weight in each example, the Chinese domestic prices do not reflect the additional cost and resulting incremental value in selling price for the additional 13 finished end pieces of pup joints. This is a conservative example in respect of the Chinese selling price. One metric tonne of the Chinese goods could alternatively be comprised of 63 three foot pup joints, each with finished and tested ends according to the API 5CT specification.[42] This would illustrate an even greater cost and a substantial selling price differential.

United States to Canada during the POI.[43] In this comparison, the CBSA did not have sales of P110 in the same OD and lbs/ft as the Chinese goods but both were similar. The OD and nominal weight for the US selling prices were 3.5 inches and 9.3 lbs/ft compared to the Chinese product of 4.5 inches and 11.6 lbs/ft, which are sufficiently similar for comparison purposes. The lengths of the pup joints were the same at six feet. This comparison of selling prices indicates that the Chinese pup joints were 86% below that of the U.S. selling price. Consequently, in this comparison, the Chinese pup joint price is markedly lower than competitive market pricing for the same grade and same length of pup joint.

[95] In a third comparison, the CBSA compared the overall average domestic Chinese P110 pup joint selling price with the lowest U.S. selling prices of the lowest grade of API 5CT specification, J55, as per the Pipe Logix report over the POI.[44] The Chinese selling price was 34% lower than the U.S. J55 selling price.

[96] Each of the CBSA’s comparisons indicates that Chinese domestic pup joint selling prices are substantially below corresponding competitive market prices. Based on the CBSA’s price analysis, the evidence indicates that Chinese domestic OCTG pup joint prices are not substantially the same as they would be if they were determined in a competitive market.

[97] The wide range and material nature of the GOC measures have resulted in significant influence on the Chinese steel industry including the OCTG sector, which includes pup joints. The conditions described in paragraph 20(1)(a) of SIMA exist in this sector. Domestic prices are substantially determined by the GOC, and there is sufficient reason to believe that the domestic prices of pup joints are not substantially the same as they would be in a competitive market.

[98] Based on the above analysis, for the purposes of the final determination, the President affirmed the opinion rendered at the preliminary determination that the conditions described in paragraph 20(1)(a)apply in the OCTG sector in China, which includes pup joints.[45]

[100] For purposes of the preliminary determination, normal values could not be calculated on the basis of domestic selling prices in China or on the full cost of goods plus profit, as the President formed the opinion that the conditions described in section 20 exist in the OCTG sector, which includes pup joints.

[105] While the CBSA does not have sufficient pricing, costing or import data available relating to a surrogate country, it does have pricing information for pup joints imported into Canada from, and originating in, the United States. This information was acquired from internal import data and from brokers representing the importers of these goods.[46] For the purposes of the final determination, normal values were determined on the basis of these prices.

[106] The normal values for each subject good exported to Canada by Hengshui Weijia over the period of investigation was based on the price of imported pup joints from the United States which matched the major characteristics used to identify these goods. Where such a match was not possible on a given transaction, the difference between the total normal value and the total export price for all other transactions for which matches were made, expressed as a percentage of this total export price, was used to establish the normal value.

[113] Based on the preceding, 100% of the subject goods from China were dumped by a weighted average margin of dumping of 144%, expressed as a percentage of the export price.

[114] Under paragraph 41(1)(a) of SIMA, the President shall make a final determination of dumping when he is satisfied that the goods have been dumped and that the margin of dumping of the goods of a country is not insignificant. Pursuant to subsection 2(1) of SIMA, a margin of dumping of less than 2% is defined as insignificant. The margin of dumping of certain pup joints from China is not less than 2% and is, therefore, not insignificant.

[119] A review of the information submitted by Hengshui Weijia revealed that the company had no domestic sales during the POI. All Hengshui Weijia production is for export and all products are pup joints.

[120] Normal values for Hengshui Weijia were determined pursuant to a ministerial specification under subsection 29(1) of SIMA. The normal values for each subject good exported to Canada by Hengshui Weijia over the period of investigation was based on the price of imported pup joints from the United States which matched the major characteristics used to identify these goods. Where such a match was not possible on a given transaction, the difference between the total normal value and the total export price for all other transactions for which matches were made, expressed as a percentage of this total export price, was used to establish the normal value.

[164] SIMA does not define or provide any guidance regarding the determination of a “developing country” for purposes of Article 27.10 of the WTO Agreement on Subsidies and Countervailing Measures. As an administrative alternative, the CBSA refers to the Development Assistance Committee List of Official Development Assistance Recipients (DAC List of ODA Recipients) for guidance.[57] As China is included in the listing, the CBSA will extend developing country status to China for purposes of this investigation. As the preceding table illustrates, the amount of subsidy found during this investigation is not insignificant.

[168] On the basis of the results of the investigation, the President is satisfied that certain pup joints originating in or exported from the People’s Republic China, have been dumped and that the margin of dumping is not insignificant. Consequently, on March 12, 2012, the President made a final determination of dumping pursuant to paragraph 41(1)(a) of SIMA respecting the subject goods.

[169] Similarly, on the basis of the results of the investigation, the President is satisfied that certain pup joints originating in or exported from the People’s Republic of China have been subsidized and that the amount of subsidy is not insignificant. As a result, the President also made a final determination of subsidizing pursuant to paragraph 41(1)(a) of SIMA respecting the subject goods on this same date.

Counsel for the GOC stated that the “CBSA’s denial of an extension of the deadline to file RFIs past October 19, 2011 was unreasonable.” [60] Counsel further suggested that “any information deemed as insufficient or limited by the CBSA could have been addressed or cured by providing sufficient time to respond or by issuing supplemental questionnaires.”[61] Counsel for the GOC concluded by stating that “Canada’s refusal to grant an extension of the deadlines to file RFI responses denied China the opportunity to meaningfully participate in this proceeding.[62]

“More specifically, in regards to operations or production capacity of companies in the OCTG sector, the GOC has stated unequivocally that there is no approval required concerning additional capacity and/or joint venture and that modifications on additions of capacity and/or joint ventures concerning OCTG are ultimately decided by the producers themselves.”[84]

“According to the Company law of China, the SASAC director is a representative of the shareholder. SASAC guides and pushes the reform and restructuring of state-owned enterprises, as well as supervises the maintenance and appreciation of state assets value for those state-invested enterprises.”[92]

Counsel for Hengshui Weijia also contested the CBSA’s estimated subsidy amount at the preliminary determination for Program 1: Preferential Tax Policies for Enterprises with Foreign Investment (FIEs). Counsel challenged both the calculation and the basis for the calculation, stating that the CBSA lacked the specificity component required to consider a subsidy program actionable, as the rules under the “Income Tax Circular automatically apply to all enterprises in China and the criteria and conditions are strictly adhered to.”[97]

With regards to the subsidy calculation for Preferential Tax Policies, the CBSA found that Hengshui Weijia had not sufficiently responded to the question as to why their income tax rate was substantially below the standard rate for corporations in China. The company actually responded that for the CBSA to “assume that Hengshui Weijia should be aware of why its tax rate was [x%] instead of 10% or 15% is ludicrous.”[100]

Counsel for the GOC stated that the CBSA’s reliance on section 20 is “misplaced.”[101] In making these comments, the GOC cited China’s Accession Protocol to the WTO as support to its position that Chinese prices and costs should be used as the primary methodology in making the necessary “pricing or costing comparisons involved in investigating dumping claims.”[102]

As part of the preliminary determination of dumping, the President formed the opinion that the conditions of section 20 exist in the Chinese OCTG sector, which includes pup joints.

The CBSA has undertaken extensive research into the GOC’s involvement in the steel industry, including the Chinese OCTG sector, which includes pup joints. The CBSA has formed the section 20 opinion on the OCTG sector in China in two previous investigations – Seamless Steel Casing (2008) and Oil Country Tubular Goods (2010). The full details of this research are available on the CBSA’s listing of exhibits.

Counsel for the GOC objected to the CBSA using any methodology for calculating normal values that was not based upon the “timely filed, verifiable and accurate information governing the pup joints sector in China.”[110] The GOC also claimed that the “GOC and its producers have clearly established that market economy conditions prevail in the OCTG industry.”[111]

At the time of the preliminary determination, the President formed the opinion that the conditions of section 20 exist in the OCTG sector, which includes pup joints. Where section 20 conditions exist, the CBSA may determine normal values using the selling price, or the total cost and profit, of like goods sold by producers in a surrogate country designated by the President pursuant to paragraph 20(1)(c) of SIMA or, failing that, paragraph 20(1)(d) of SIMA provides for calculating normal values using re-sales in Canada of goods imported from a third country. The CBSA was unable to obtain sufficient information for either of these two approaches and accordingly used an alternative method to estimate normal values for purposes of the preliminary determination.

For the purposes of the final determination, a more comprehensive analysis using actual imports of goods matching the subject good characteristics from the United States were used as basis for normal values. These normal values were compared with the exported goods from the cooperative exporter. The CBSA considers this to be the best available information, given the lack of pricing information on the record, in spite of the CBSA’s efforts to obtain it from other producers of pup joints.

Furthermore, although counsel for the GOC suggested the use of Brazil as a more appropriate surrogate alternative to, for example, domestic selling prices in the United States, the CBSA notes that counsel provided no evidence of such prices for the CBSA’s consideration. In fact, all statements made in relation to Brazil in case arguments, regarding its production capability for both oil and OCTG etc. were without any reference to evidence on the record. Had counsel for the GOC or any other interested party submitted documentation to support these statements, the CBSA would have considered it as part of its surrogate country analysis. As such, the CBSA had very little information in regards to domestic selling prices in other countries for OCTG in general, let alone pup joints.

It is also worthy to note that at the initiation of the investigation, the CBSA did contact producers of pup joints in Brazil, requesting that they respond to the RFI provided to them for the purposes of a surrogate country analysis.[115] As stated earlier, no responses to the surrogate RFI were received.

The following programs were also included in the current investigation. Questions concerning these programs were included in the RFI sent to the GOC and to all known exporters of the goods in China. None of the cooperative exporters reported using these programs during the subsidy POI. Without a complete response to the subsidy RFI from the GOC and all known exporters, the CBSA does not have detailed descriptions of these programs; nor does it have sufficient information to determine that any of these programs do not constitute actionable subsidies. In other words, the CBSA does not have sufficient information to determine that any of these programs should be removed from the investigation for the purposes of the final determination.

Program 67: Preferential Tax Policies for FIEs and Foreign Enterprises Which Have Establishments or Places in China and are Engaged in Production or Business Operations Purchasing Domestically Produced Equipments

[2] Dumping Exhibit 67 (PRO). Wuxi Forest Petroleum Technology Co., Ltd. is an exporter and not a manufacturer. The reported goods were Seamless Carbon or Alloy Steel Oil and Gas Well Casing products subject to Tribunal Inquiry No. NQ-2007-001 Finding issued by the Tribunal on March 10, 2008.

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One is a short Drill Pipe used to adjust the length of the Drill String; The other one OCTG Pup Joint is a pipe of non-standard length, which is used to adjust the length of tubular strings to its exact requirement.

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API Spec 5CT – This Standard specifies the technical delivery conditions for steel pipes (casing, tubing and pup joints), coupling stock, coupling material and accessory material and establishes requirements for three Product Specification Levels (PSL-1, PSL-2, PSL-3). The requirements for PSL-1 are the basis of this Standard. The requirements that define different levels of standard technical requirements for PSL-2 and PSL-3, for all Grades except H-40, L-80 9Cr and C110, are contained in Annex H.

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Adjustable Pup Joint Tubing API 5CT 4-1/2" P110 NUE End Type Pup Joints are used to adjust the height of full length tubing or casing strings. They are also used to adjust the depth of downhole tools. TUBING ... Read More

L80 Pup Joint Tubing 4-1/2" , Oil Drilling Pipe Cold Rolled Processed Pup Joints are used to adjust the height of full length tubing or casing strings. They are also used to adjust the depth of downhole tools. ... Read More

Seamless Pup Joint Tubing N80 Phosphoating Surface Treatment Pup Joints are used to adjust the height of full length tubing or casing strings. They are also used to adjust the depth of downhole tools. TUBING ... Read More

Oil Field Perforated Pup Joint Red Green Color Paint K55 For Oil Transport Pup Joints are used to adjust the height of full length tubing or casing strings. They are also used to adjust the depth of downhole ... Read More

J55 Pup Joint Tubing Round Shape Thick Wall Non Secondary Condition Pup Joints are used to adjust the height of full length tubing or casing strings. They are also used to adjust the depth of downhole tools. ... Read More

Plain End Integral Pup Joint Galvanized Treatment , P110 Oil Line Pipe Pup Joints are used to adjust the height of full length tubing or casing strings. They are also used to adjust the depth of downhole tools. ... Read More

L80 Pup Joint Tubing Convenient Connection Durable Anti Rust Pup Joints are used to adjust the height of full length tubing or casing strings. They are also used to adjust the depth of downhole tools. TUBING ... Read More

Customizable Npst Pup Joint Hot Rolled N80 Grade Low Carbon Steel Pup Joints are used to adjust the height of full length tubing or casing strings. They are also used to adjust the depth of downhole tools. ... Read More

Threaded Pup Joint Tubing K55 , Oil Supply Pipe For Well Drilling Pup Joints are used to adjust the height of full length tubing or casing strings. They are also used to adjust the depth of downhole tools. ... Read More

Industrial Crossover Pup Joints Anti Corrosion Petroleum Machinery Pup Joints are used to adjust the height of full length tubing or casing strings. They are also used to adjust the depth of downhole tools. ... Read More

Site: www.pmeindustrial.com; Cell: +8613818990736 PME take great pride in supplying API Standard products & solutions to our professional customers and contractors worldwide, API 7K Vibrator Rotary Hoses, API 16C Choke and Kill Lines, API 16D BOP Control Hoses, Weco Type Hammer Unions, Anti-slip Mat, API 6A Flowline Products, FMC SPM SJ Type Fluid Control, Plug Valves, Swivel Joints, Integral Fittings, Crossover Adapters, Pup Joints, and Cementing & Circulating Lines, etc. As the most reputable and experienced team for drilling, completion and production, PME can do your job faster and more efficiently at a lower cost.