# Large Diameter Graphite Electrodes From the People's Republic of China and India: Initiation of Less-Than-Fair-Value Investigations
**AGENCY:**
Enforcement and Compliance, International Trade Administration, Department of Commerce.
**DATES:**
Applicable March 16, 2026.
**FOR FURTHER INFORMATION CONTACT:**
Deborah Cohen at (202) 482-4521 (the People's Republic of China (China)) and Hannah Lee at (202) 482-1216 (India), AD/CVD Operations, Enforcement and Compliance, International Trade Administration, U.S. Department of Commerce, 1401 Constitution Avenue NW, Washington, DC 20230.
**SUPPLEMENTARY INFORMATION:**
**The Petitions**
On February 24, 2026, the U.S. Department of Commerce (Commerce) received antidumping duty (AD) petitions concerning imports of large diameter graphite electrodes (large graphite electrodes) from China and India, filed in proper form on behalf of the LDGE Fair Trade Coalition and its individual members (the petitioners). [^1] The AD Petitions were accompanied by countervailing duty (CVD) petitions concerning imports of large graphite electrodes from China and India. [^2]
[^1]*See* Petitioners' Letter, “Petition for the Imposition of Antidumping and Countervailing Duties,” dated February 24, 2026 (Petitions). The individual members of the LDGE Fair Trade Coalition are Resonac Graphite America Inc. and Tokai Carbon GE LLC. *Id.*
[^2]*Id.*
Between February 27 and March 10, 2026, Commerce requested supplemental information pertaining to certain aspects of the Petitions in supplemental questionnaires. [^3] Between March 3 and 11, 2026, the petitioners filed timely responses to these requests for additional information. [^4]
[^3]*See* Commerce's Letters, “Supplemental Questions,” dated February 27, 2026 (First General Issues Supplemental Questionnaire); First Country-Specific AD Questionnaires: India AD Questionnaire and China AD Supplemental Questionnaire, dated February 27 and March 2, 2026, respectively; and Second Country-Specific AD Questionnaires: Second India AD Questionnaire and Second China AD Questionnaire, dated March 4 and 10, 2026; *see also* Memorandum, “Teleconference with Counsel to the Petitioners,” dated March 10, 2026 (March 10, 2026, Memorandum).
[^4]*See* Petitioners' Letters, “Response to Supplemental Questions,” dated March 4, 2026 (First General Issues Supplement); Country-Specific AD Supplemental Responses: India AD Supplement and China AD Supplement, dated March 3 and 5, 2026; Second Country-Specific AD Supplemental Responses: India AD Supplement and China AD Supplement, dated March 6 and 11, 2026; and “Petitioners' Second Supplement to Volume I of the Petition for the Imposition of Antidumping and Countervailing Duties on Imports from China and India,” dated March 11, 2026 (Second General Issues Supplement).
In accordance with section 732(b) of the Tariff Act of 1930, as amended (the Act), the petitioners allege that imports of large graphite electrodes from China and India are being, or are likely to be, sold in the United States at less than fair value (LTFV) within the meaning of section 731 of the Act, and that imports of such products are materially injuring, or threatening material injury to, the large graphite electrodes industry in the United States. Consistent with section 732(b)(1) of the Act, the Petitions were accompanied by information reasonably available to the petitioners supporting their allegations.
Commerce finds that the petitioners filed the Petitions on behalf of the domestic industry, because the petitioners are interested parties, as defined in sections 771(9)(C) and (F) of the Act. Commerce also finds that the petitioners demonstrated sufficient industry support for the initiation of the requested LTFV investigations. [^5]
[^5]*See* section on “Determination of Industry Support for the Petitions,” *infra.*
**Periods of Investigations (POI)**
Because the Petitions were filed on February 24, 2026, pursuant to 19 CFR 351.204(b)(1), the POI for the India LTFV investigation is January 1, 2025, through December 31, 2025. Because China is a non-market economy (NME) country, pursuant to 19 CFR 351.204(b)(1), the POI for the China LTFV investigation is July 1, 2025, through December 31, 2025.
**Scope of the Investigations**
The products covered by these investigations are large graphite electrodes from China and India. For a full description of the scope of these investigations, *see* the appendix to this notice.
**Comments on the Scope of the Investigations**
Between February 27 and March 10, 2026, Commerce requested information and clarification from the petitioners regarding the proposed scope to ensure that the scope language in the Petitions is an accurate reflection of the products for which the domestic industry is seeking relief. [^6] Between March 4 and 11, 2026, the petitioners provided clarifications and revised the scope. [^7] The description of merchandise covered by these investigations, as described in the appendix to this notice, reflects these clarifications.
[^6]*See* First General Issues Supplemental Questionnaire; *see also* March 10, 2026, Memorandum.
[^7]*See* First General Issues Supplement at 5-17 and Exhibits GEN-SUPP-4 and GEN-SUPP-5; *see also* Second General Issues Supplement at 2-7 and Exhibit GEN-SUPP2-1.
As discussed in the *Preamble* to Commerce's regulations, we are setting aside a period for interested parties to raise issues regarding product coverage ( *i.e.,* scope). [^8] Commerce will consider all scope comments received from interested parties and, if necessary, will consult with interested parties prior to the issuance of the preliminary determinations. If scope comments include factual information, all such factual information should be limited to public information. [^9] Commerce requests that interested parties provide at the beginning of their scope comments a public executive summary for each comment or issue raised in their submission. Commerce further requests that interested parties limit their public executive summary of each comment or issue to no more than 450 words, not including citations. Commerce intends to use the public executive summaries as the basis of the comment summaries included in the analysis of scope comments. To facilitate preparation of its questionnaires, Commerce requests that scope comments be submitted by 5:00 p.m. Eastern Time (ET) on April 6, 2026, which is the next business day after 20 calendar days from the signature date of this notice. [^10] Any rebuttal comments, which may include factual information, and should also be limited to public information, must be filed by 5:00 p.m. ET on April 16, 2026, which is 10 calendar days from the initial comment deadline.
[^8]*See Antidumping Duties; Countervailing Duties, Final Rule,* 62 FR 27296, 27323 (May 19, 1997) ( *Preamble* ); *see also* 19 CFR 351.312.
[^9]*See* 19 CFR 351.102(b)(21) (defining “factual information”).
[^10] The deadline for scope comments falls on April 5, 2026, which is a Sunday. Commerce's practice dictates that where a deadline falls on a weekend or federal holiday, the appropriate deadline is the next business day (in this instance, April 6, 2026). *See* 19 CFR 351.303(b)(1) (“For both electronically filed and manually filed documents, if the applicable due date falls on a non-business day, the Secretary will accept documents that are filed on the next business day.”).
Commerce requests that any factual information that parties consider relevant to the scope of these investigations be submitted during that period. However, if a party subsequently finds that additional factual information pertaining to the scope of the investigations may be relevant, the party must contact Commerce and request permission to submit the additional information. All scope comments must be filed simultaneously on the records of the concurrent LTFV and CVD investigations.
**Filing Requirements**
All submissions to Commerce must be filed electronically via Enforcement and Compliance's Antidumping Duty and Countervailing Duty Centralized Electronic Service System (ACCESS), unless an exception applies. [^11] An electronically filed document must be received successfully in its entirety by the time and date it is due.
[^11]*See Antidumping and Countervailing Duty Proceedings: Electronic Filing Procedures; Administrative Protective Order Procedures,* 76 FR 39263 (July 6, 2011); *see also Enforcement and Compliance; Change of Electronic Filing System Name,* 79 FR 69046 (November 20, 2014), for details of Commerce's electronic filing requirements, effective August 5, 2011. Information on using ACCESS can be found at *https://access.trade.gov/help.aspx* and a handbook can be found at *https://access.trade.gov/help/Handbook_on_Electronic_Filing_Procedures.pdf.*
**Comments on Product Characteristics**
Commerce is providing interested parties an opportunity to comment on the appropriate physical characteristics of large graphite electrodes to be reported in response to Commerce's AD questionnaires. This information will be used to identify the key physical characteristics of the subject merchandise in order to report the relevant factors of production (FOP) or cost of production (COP) accurately, as well as to develop appropriate product comparison criteria.
Interested parties may provide any information or comments that they feel are relevant to the development of an accurate list of physical characteristics. Specifically, they may provide comments as to which characteristics are appropriate to use as: (1) general product characteristics; and (2) product comparison criteria. We note that it is not always appropriate to use all product characteristics as product comparison criteria. We base product comparison criteria on meaningful commercial differences among products. In other words, although there may be some physical product characteristics utilized by manufacturers to describe large graphite electrodes, it may be that only a select few product characteristics take into account commercially meaningful physical characteristics. In addition, interested parties may comment on the order in which the physical characteristics should be used in matching products. Generally, Commerce attempts to list the most important physical characteristics first and the least important characteristics last.
In order to consider the suggestions of interested parties in developing and issuing the AD questionnaires, all product characteristics comments must be filed by 5:00 p.m. ET on April 6, 2026, which is the next business day after 20 calendar days from the signature date of this notice. [^12] Any rebuttal comments must be filed by 5:00 p.m. ET on April 16, 2026, which is 10 calendar days from the initial comment deadline. All comments and submissions to Commerce must be filed electronically using ACCESS, as explained above, on the record of both of the LTFV investigations.
[^12] The deadline for product characteristics falls on April 5, 2026, which is a Sunday. Commerce's practice dictates that where a deadline falls on a weekend or federal holiday, the appropriate deadline is the next business day (in this instance, April 6, 2026). *See* 19 CFR 351.303(b)(1) (“For both electronically filed and manually filed documents, if the applicable due date falls on a non-business day, the Secretary will accept documents that are filed on the next business day.”).
**Determination of Industry Support for the Petitions**
Section 732(b)(1) of the Act requires that a petition be filed on behalf of the domestic industry. Section 732(c)(4)(A) of the Act provides that a petition meets this requirement if the domestic producers or workers who support the petition account for: (i) at least 25 percent of the total production of the domestic like product; and (ii) more than 50 percent of the production of the domestic like product produced by that portion of the industry expressing support for, or opposition to, the petition. Moreover, section 732(c)(4)(D) of the Act provides that, if the petition does not establish support of domestic producers or workers accounting for more than 50 percent of the total production of the domestic like product, Commerce shall: (i) poll the industry or rely on other information in order to determine if there is support for the petition, as required by subparagraph (A); or (ii) determine industry support using a statistically valid sampling method to poll the “industry.”
Section 771(4)(A) of the Act defines the “industry” as the producers as a whole of a domestic like product. Thus, to determine whether a petition has the requisite industry support, the statute directs Commerce to look to producers and workers who produce the domestic like product. The U.S. International Trade Commission (ITC), which is responsible for determining whether “the domestic industry” has been injured, must also determine what constitutes a domestic like product in order to define the industry. While both Commerce and the ITC apply the same statutory definition regarding the domestic like product, [^13] they do so for different purposes and pursuant to a separate and distinct authority. In addition, Commerce's determination is subject to limitations of time and information. Although this may result in different definitions of the like product, such differences do not render the decision of either agency contrary to law. [^14]
[^13]*See* section 771(10) of the Act.
[^14]*See USEC, Inc.* v. *United States,* 132 F.Supp.2d 1, 8 (CIT 2001) (citing *Algoma Steel Corp., Ltd.* v. *United States,* 688 F. Supp. 639, 644 (CIT 1988), *aff'd Algoma Steel Corp., Ltd.* v. *United States,* 865 F.2d 240 (Fed. Cir. 1989)).
Section 771(10) of the Act defines the 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 title.” Thus, the reference point from which the domestic like product analysis begins is “the article subject to an investigation” ( *i.e.,* the class or kind of merchandise to be investigated, which normally will be the scope as defined in the petition).
With regard to the domestic like product, the petitioner does not offer a definition of the domestic like product distinct from the scope of the investigations. [^15] Based on our analysis of the information submitted on the record, we have determined that large graphite electrodes, as defined in the scope, constitute a single domestic like product, and we have analyzed industry support in terms of that domestic like product. [^16]
[^15] For a discussion of the domestic like product analysis as applied to these cases and information regarding industry support, see Checklists, “Antidumping Duty Investigation Initiation Checklists: Large Graphite Electrodes from the People's Republic of China and India,” dated concurrently with, and hereby adopted by, this notice (Country-Specific AD Initiation Checklists), at Attachment II, Analysis of Industry Support for the Antidumping and Countervailing Duty Petitions Covering Large Diameter Graphite Electrodes from the People's Republic of China and India (Attachment II). These checklists are on file electronically via ACCESS.
[^16] For further discussion, *see* Attachment II of the Country-Specific AD Initiation Checklists.
In determining whether the petitioners have standing under section 732(c)(4)(A) of the Act, we considered the industry support data contained in the Petitions with reference to the domestic like product as defined in the “Scope of the Investigations,” in the appendix to this notice. To establish industry support, the petitioners provided their own production of the domestic like product in 2025. The petitioners identified themselves as the only two producers of large graphite electrodes in the United States; therefore, the Petitions are supported by 100 percent of the U.S. industry. [^17] We relied on data provided by the petitioners for purposes of measuring industry support. [^18]
[^17]*Id.*
[^18]*Id.*
Our review of the data provided in the Petitions, the First General Issues Supplement, and other information readily available to Commerce indicates that the petitioners have established industry support for the Petitions. [^19] First, the Petitions established support from domestic producers (or workers) accounting for more than 50 percent of the total production of the domestic like product and, as such, Commerce is not required to take further action in order to evaluate industry support ( *e.g.,* polling). [^20] Second, the domestic producers (or workers) have met the statutory criteria for industry support under section 732(c)(4)(A)(i) of the Act because the domestic producers (or workers) who support the Petitions account for at least 25 percent of the total production of the domestic like product. [^21] Finally, the domestic producers (or workers) have met the statutory criteria for industry support under section 732(c)(4)(A)(ii) of the Act because the domestic producers (or workers) who support the Petitions account for more than 50 percent of the production of the domestic like product produced by that portion of the industry expressing support for, or opposition to, the Petitions. [^22] Accordingly, Commerce determines that the Petitions were filed on behalf of the domestic industry within the meaning of section 732(b)(1) of the Act. [^23]
[^19]*Id.*
[^20]*Id.; see also* section 732(c)(4)(D) of the Act.
[^21]*See* Attachment II of the Country-Specific AD Initiation Checklists.
[^22]*Id.*
[^23]*Id.*
**Allegations and Evidence of Material Injury and Causation**
The petitioners allege that the U.S. industry producing the domestic like product is being materially injured, or is threatened with material injury, by reason of the imports of the subject merchandise sold at LTFV. In addition, the petitioners allege that subject imports exceed the negligibility threshold provided for under section 771(24)(A) of the Act. [^24]
[^24] For further discussion, *see* Country-Specific AD Initiation Checklists at Attachment III, Analysis of Allegations and Evidence of Material Injury and Causation for the Antidumping and Countervailing Duty Petitions Covering Large Diameter Graphite Electrodes from the People's Republic of China and India.
The petitioners contend that the industry's injured condition is illustrated by a significant increase in the volume of subject imports; reduced market share; underselling and price depression; lost sales and revenues; declines in production, capacity utilization, and U.S. shipments; and negative impact on financial performance. [^25] We assessed the allegations and supporting evidence regarding material injury, threat of material injury, causation, cumulation, as well as negligibility, and we have determined that these allegations are properly supported by adequate evidence, and meet the statutory requirements for initiation. [^26]
[^25]*Id.*
[^26]*Id.*
**Allegations of Sales at LTFV**
The following is a description of the allegations of sales at LTFV upon which Commerce based its decision to initiate LTFV investigations of imports of large graphite electrodes from China and India. The sources of data for the deductions and adjustments relating to U.S. price and normal value (NV) are discussed in greater detail in the Country-Specific AD Initiation Checklists.
**U.S. Price**
For India, the petitioners based export price (EP) based on pricing information for large graphite electrodes produced in India and sold or offered for sale in the U.S. market. [^27] For China, the petitioners based EP on: (1) pricing information for large graphite electrodes produced in China and sold or offered for sale in the U.S. market; and (2) the POI average unit value (AUV) derived from official import statistics for imports of large graphite electrodes from China. [^28] The petitioners made certain adjustments to U.S. price to calculate a net ex-factory U.S. price, where applicable. [^29]
[^27]*See* India AD Initiation Checklist.
[^28]*See* China AD Initiation Checklist.
[^29]*See* Country-Specific AD Initiation Checklists.
**Normal Value
30**
[^30] In accordance with section 773(b)(2) of the Act, for the India investigation, Commerce will request information necessary to calculate the constructed value (CV) and COP to determine whether there are reasonable grounds to believe or suspect that sales of the foreign like product have been made at prices that represent less than the COP of the product.
For India, the petitioners calculated NV on home market pricing information they obtained for large graphite electrodes produced in and sold, or offered for sale, in India during the POI. [^31]
[^31]*See* India AD Initiation Checklist.
Commerce considers China to be an NME country. [^32] In accordance with section 771(18)(C)(i) of the Act, any determination that a foreign country is an NME country shall remain in effect until revoked by Commerce. Therefore, we continue to treat China as an NME country for purposes of the initiation of the LTFV investigation. Accordingly, we base NV on FOPs valued in a surrogate market economy country in accordance with section 773(C) of the Act.
[^32]*See, e.g., Certain Freight Rail Couplers and Parts Thereof from the People's Republic of China: Preliminary Affirmative Determination of Sales at Less Than Fair Value and Preliminary Affirmative Determination of Critical Circumstances,* 88 FR 15372 (March 13, 2023), and accompanying Preliminary Decision Memorandum at 5, unchanged in *Certain Freight Rail Couplers and Parts Thereof from the People's Republic of China: Final Affirmative Determination of Sales at Less-Than-Fair Value and Final Affirmative Determination of Critical Circumstances,* 88 FR 34485 (May 30, 2023).
The petitioners claim that Brazil, Malaysia, and the Republic of Türkiye (Türkiye) are appropriate surrogate countries for China because they are market economy countries that are at a level of economic development comparable to that of China and are significant producers of comparable merchandise. [^33] The petitioners provided publicly available information from Brazil, Malaysia, and Türkiye to value all FOPs. [^34] Based on the information provided by the petitioners, we believe it is appropriate to use Brazil, Malaysia, and Türkiye as surrogate countries for China to value all FOPs for initiation purposes.
[^33]*See* China AD Initiation Checklist.
[^34]*Id.*
Interested parties will have the opportunity to submit comments regarding surrogate country selection and, pursuant to 19 CFR 351.301(c)(3)(i), will be provided an opportunity to submit publicly available information to value FOPs within 30 days before the scheduled date of the preliminary determination.
**Factors of Production**
Because information regarding the volume of inputs consumed by Chinese producers/exporters was not reasonably available, the petitioners used the production experience and product-specific consumptions rates of U.S. producers of large graphite electrodes as a surrogate to value Chinese manufacturers' FOPs. [^35] Additionally, for China, the petitioners calculated factory overhead, SG&A, and profit based on the experience of Brazilian, Malaysian, and Turkish producers of comparable merchandise. [^36]
[^35]*See* China AD Initiation Checklist.
[^36]*Id.*
**Fair Value Comparisons**
Based on the data provided by the petitioners, there is reason to believe that imports of large graphite electrodes from Chian and India are being, or are likely to be, sold in the United States at LTFV. Based on comparisons of EP to NV in accordance with sections 772 and 773 of the Act, the estimated dumping margins for large graphite electrodes for each of the countries covered by the initiation are as follows: (1) China (Brazil surrogate)—44.71 to 116.64 percent; (2) China (Malaysia surrogate) 38.33 to 98.79 percent; (3) China (Türkiye surrogate) 77.59 to 146.72 percent; and (4) India—42.59 to 73.40 percent. [^37]
[^37]*See* Country-Specific AD Initiation Checklists.
**Initiation of LTFV Investigations**
Based upon the examination of the Petitions and supplemental responses, we find that they meet the requirements of section 732 of the Act. Therefore, we are initiating LTFV investigations to determine whether imports of large graphite electrodes from China and India are being, or are likely to be, sold in the United States at LTFV. In accordance with section 733(b)(1)(A) of the Act and 19 CFR 351.205(b)(1), unless postponed, we will make our preliminary determinations no later than 140 days after the date of this initiation.
**Respondent Selection**
**China**
In the Petitions, the petitioners identified 28 companies in China as producers and/or exporters of large graphite electrodes. [^38] Our standard practice for respondent selection in AD investigations involving NME countries is to select respondents based on quantity and value (Q&V) questionnaires in cases where Commerce has determined that the number of companies is large, and it cannot individually examine each company based upon its resources. Therefore, considering the number of producers and/or exporters identified in the Petitions, Commerce will solicit Q&V information that can serve as a basis for selecting exporters for individual examination in the event that Commerce determines that the number is large and decides to limit the number of respondents individually examined pursuant to section 777A(c)(2) of the Act. Because there are 28 Chinese producers and/or exporters identified in the Petitions, Commerce has determined that it will issue Q&V questionnaires to the largest producers and/or exporters in China that are identified in the U.S. Customs and Border Protection POI entry data for which there is complete address information on the record. [^39]
[^38]*See* Petitions at Volume I (pages 13-14 and Exhibit GEN-4); *see also* First General Issues Supplement at 2-4 and Exhibit GEN-SUPP-1.
[^39] See Memorandum, “Release of U.S. Customs and Border Protection Entry Data {China},” dated March 13, 2026.
Commerce will post the Q&V questionnaires along with filing instructions on Commerce's website at *https://www.trade.gov/ec-adcvd-qv-questionnaire.* Producers/exporters of large graphite electrodes from China that do not receive Q&V questionnaires may still submit a response to the Q&V questionnaire and can obtain a copy of the Q&V questionnaire from Commerce's website. Responses to the Q&V questionnaire must be submitted by the relevant Chinese producers/exporters no later than 5:00 p.m. ET on March 30, 2026, which is two weeks from the signature date of this notice. All Q&V questionnaire responses must be filed electronically via ACCESS. An electronically filed document must be received successfully, in its entirety, by ACCESS no later than 5:00 p.m. ET on the deadline noted above.
Interested parties must submit applications for disclosure under administrative protective order (APO) in accordance with 19 CFR 351.305(b). Instructions for filing such applications may be found on Commerce's website at *https://www.trade.gov/administrative-protective-orders.*
**India**
In the Petitions, the petitioners identified three companies in India. [^40] Following standard practice in LTFV investigations involving market economy countries, in the event Commerce determines that the number of companies is large, and it cannot individually examine each company based upon Commerce's resource, where appropriate, Commerce intends to select mandatory respondents based on CBP data for imports under the appropriate Harmonized Tariff Schedule of the United States (HTSUS) subheading(s) listed in the “Scope of the Investigations,” in the appendix.
[^40]*See* Petitions at Volume I (pages 13-14 and Exhibit GEN-4).
On March 13, 2026, Commerce released CBP data on imports of large graphite electrodes from India under APO to all parties with access to information protected by APO and indicated that interested parties wishing to comment on CBP data and/or respondent selection must do so within three business days of the publication date of the notice of initiation of these investigations. [^41] Comments must be filed electronically using ACCESS. An electronically filed document must be received successfully in its entirety via ACCESS by 5:00 p.m. ET on the specified deadline. Commerce will not accept rebuttal comments regarding the CBP data or respondent selection.
[^41]*See* Memorandum, “Release of U.S. Customs and Border Protection Entry Data {India},” dated March 13, 2026.
Interested parties must submit applications for disclosure under APO in accordance with 19 CFR 351.305(b). As stated above, instructions for filing such applications may be found on Commerce's website at *https://www.trade.gov/administrative-protective-orders.*
**Separate Rates**
In order to obtain separate rate status in an NME investigation, exporters and producers must submit a separate rate application. The specific requirements for submitting a separate rate application in an NME investigation are outlined in detail in the application itself, which is available on Commerce's website at *https://access.trade.gov/Resources/nme/nme-sep-rate.html.* Note that Commerce recently promulgated new regulations pertaining to separate rates, including the separate rate application deadline and eligibility for separate rate status, in 19 CFR 351.108. [^42] Pursuant to 19 CFR 351.108(d)(1), the separate rate application will be due 21 days after publication of this initiation notice. [^43] Exporters and producers must file a timely separate rate application if they want to be considered for individual examination. In addition, pursuant to 19 CFR 351.108(e), exporters and producers who submit a separate rate application and have been selected as mandatory respondents will be eligible for consideration for separate rate status only if they fully respond to all parts of Commerce's AD questionnaire and participate in the LTFV proceeding as mandatory respondents. [^44] Commerce requires that companies from China submit a response both to the Q&V questionnaire and to the separate rate application by the respective deadlines to receive consideration for separate rate status. Companies not filing a timely Q&V questionnaire response will not receive separate rate consideration.
[^42]* See Regulations Enhancing the Administration of the Antidumping and Countervailing Duty Trade Remedy Laws, * 89 FR 101694, 101759-60 (December 16, 2024).
[^43]*See* 19 CFR 351.108(d)(1).
[^44]*See* 19 CFR 351.108(e).
**Use of Combination Rates**
Commerce will calculate combination rates for certain respondents that are eligible for a separate rate in an NME investigation. The Separate Rates and Combination Rates Bulletin states:
{w}hile continuing the practice of assigning separate rates only to exporters, all separate rates that {Commerce} will now assign in its NME investigation will be specific to those producers that supplied the exporter during the period of investigation. Note, however, that one rate is calculated for the exporter and all of the producers which supplied subject merchandise to it during the period of investigation. This practice applies both to mandatory respondents receiving an individually calculated separate rate as well as the pool of non-investigated firms receiving the {weighted average} of the individually calculated rates. This practice is referred to as the application of “combination rates” because such rates apply to specific combinations of exporters and one or more producers. The cash-deposit rate assigned to an exporter will apply only to merchandise both exported by the firm in question and produced by a firm that supplied the exporter during the period of investigation. [^45]
[^45]*See* Enforcement and Compliance's Policy Bulletin No. 05.1, regarding, “Separate-Rates Practice and Application of Combination Rates in Antidumping Investigation involving NME Countries,” (April 5, 2005), at 6 (emphasis added), available on Commerce's website at *https://access.trade.gov/Resources/policy/bull05-1.pdf.*
**Distribution of Copies of the Petitions**
In accordance with section 732(b)(3)(A) of the Act and 19 CFR 351.202(f), copies of the public version of the Petitions have been provided to the Governments of China and India via ACCESS. To the extent practicable, we will attempt to provide a copy of the public version of the Petitions to each exporter named in the Petitions, as provided under 19 CFR 351.203(c)(2).
**ITC Notification**
Commerce will notify the ITC of our initiation, as required by section 732(d) of the Act.
**Preliminary Determinations by the ITC**
The ITC will preliminarily determine, within 45 days after the date on which the Petitions were filed, whether there is a reasonable indication that imports of large graphite electrodes from China and/or India are materially injuring, or threatening material injury to, a U.S. industry. [^46] Negative ITC determinations for either country will result in the investigation being terminated with respect to that country. [^47] Otherwise, these LTFV investigations will proceed according to statutory and regulatory time limits.
[^46]*See* section 733(a) of the Act.
[^47]*Id.*
**Submission of Factual Information**
Factual information is defined in 19 CFR 351.102(b)(21) as: (i) evidence submitted in response to questionnaires; (ii) evidence submitted in support of allegations; (iii) publicly available information to value factors under 19 CFR 351.408(c) or to measure the adequacy of remuneration under 19 CFR 351.511(a)(2); (iv) evidence placed on the record by Commerce; and (v) evidence other than factual information described in (i)-(iv). Section 351.301(b) of Commerce's regulations requires any party, when submitting factual information, to specify under which subsection of 19 CFR 351.102(b)(21) the information is being submitted [^48] and, if the information is submitted to rebut, clarify, or correct factual information already on the record, to provide an explanation identifying the information already on the record that the factual information seeks to rebut, clarify, or correct. [^49] Time limits for the submission of factual information are addressed in 19 CFR 351.301, which provides specific time limits based on the type of factual information being submitted. Interested parties should review the regulations prior to submitting factual information in these investigations.
[^48]*See* 19 CFR 351.301(b).
[^49]*See* 19 CFR 351.301(b)(2).
**Particular Market Situation Allegation**
Section 773(e) of the Act addresses the concept of particular market situation (PMS) for purposes of CV, stating that “if a particular market situation exists such that the cost of materials and fabrication or other processing of any kind does not accurately reflect the cost of production in the ordinary course of trade, the administering authority may use another calculation methodology under this subtitle or any other calculation methodology.” When an interested party submits a PMS allegation pursuant to section 773(e) of the Act ( *i.e.,* a cost-based PMS allegation), the submission must be filed in accordance with the requirements of 19 CFR 351.416(b), and Commerce will respond to such a submission consistent with 19 CFR 351.301(c)(2)(v). If Commerce finds that a cost-based PMS exists under section 773(e) of the Act, then it will modify its dumping calculations appropriately.
Neither section 773(e) of the Act, nor 19 CFR 351.301(c)(2)(v), sets a deadline for the submission of cost-based PMS allegations and supporting factual information. However, in order to administer section 773(e) of the Act, Commerce must receive PMS allegations and supporting factual information with enough time to consider the submission. Thus, should an interested party wish to submit a cost-based PMS allegation and supporting new factual information pursuant to section 773(e) of the Act, it must do so no later than 20 days after submission of a respondent's initial section D questionnaire response
We note that a PMS allegation filed pursuant to sections 773(a)(1)(B)(ii)(III) or 773(a)(1)(C)(iii) of the Act ( *i.e.,* a sales-based PMS allegation) must be filed within 10 days of submission of a respondent's initial section B questionnaire response, in accordance with 19 CFR 351.301(c)(2)(i) and 19 CFR 351.404(c)(2).
**Extensions of Time Limits**
Parties may request an extension of time limits before the expiration of a time limit established under 19 CFR 351.301, or as otherwise specified by Commerce. In general, an extension request will be considered untimely if it is filed after the expiration of the time limit established under 19 CFR 351.301, or as otherwise specified by Commerce. [^50] For submissions that are due from multiple parties simultaneously, an extension request will be considered untimely if it is filed after 10:00 a.m. ET on the due date. Under certain circumstances, Commerce may elect to specify a different time limit by which extension requests will be considered untimely for submissions which are due from multiple parties simultaneously. In such a case, we will inform parties in a letter or memorandum of the deadline (including a specified time) by which extension requests must be filed to be considered timely. An extension request must be made in a separate, standalone submission; under limited circumstances we will grant untimely filed requests for the extension of time limits, where we determine, based on 19 CFR 351.302, that extraordinary circumstances exist. Parties should review Commerce's regulations concerning the extension of time limits and the *Time Limits Final Rule* prior to submitting factual information in these investigations. [^51]
[^50]*See* 19 CFR 351.301; *see also Extension of Time Limits; Final Rule,* 78 FR 57790 (September 20, 2013( *Time Limits Final Rule* ), available at *https://www.gpo.gov/fdsys/pkg/FR-2013-09-20/html/2013-22853.htm.*
[^51]*See* 19 CFR 351.302; *see also, e.g., Time Limits Final Rule.*
**Certification Requirements**
Any party submitting factual information in an AD or CVD proceeding must certify to the accuracy and completeness of that information. [^52] Parties must use the certification formats provided in 19 CFR 351.303(g). [^53] Commerce intends to reject factual submissions if the submitting party does not comply with the applicable certification requirements.
[^52]*See* section 782(b) of the Act.
[^53]*See Certification of Factual Information to Import Administration During Antidumping and Countervailing Duty Proceedings,* 78 FR 42678 (July 17, 2023) ( *Final Rule* ). Additional information regarding the *Final Rule* is available at *https://access.trade.gov/Resources/filing/index.html.*
**Notification to Interested Parties**
Interested parties must submit applications for disclosure under APO in accordance with 19 CFR 351.305. Parties wishing to participate in these investigations should ensure that they meet the requirements of 19 CFR 351.103(d) ( *e.g.,* by filing the required letter of appearance). Note that Commerce has amended certain of its requirements pertaining to the service of documents in 19 CFR 351.303(f). [^54]
[^54]*See Administrative Protective Order, Service, and Other Procedures in Antidumping and Countervailing Duty Proceedings,* 88 FR 67069 (September 29, 2023).
This notice is issued and published pursuant to sections 732(c)(2) and 777(i) of the Act, and 19 CFR 351.203(c).
*/S/Christopher Abbott*
Dated: March 16, 2026.
Christopher Abbott,
Deputy Assistant Secretary for Policy and Negotiations, performing the non-exclusive functions and duties of the Assistant Secretary for Enforcement and Compliance.
**Appendix**
**Scope of the Investigations**
The merchandise covered by these investigations includes all large diameter graphite electrodes of any length, whether or not finished, of a kind used in furnaces, with a nominal or actual diameter exceeding 425 millimeters (16.7 inches), and whether or not attached to a graphite pin joining system or any other type of joining system or hardware. The merchandise covered by these investigations also includes graphite pin joining systems (commonly referred to as pins or nipples) for large diameter graphite electrodes, of any length, and with a minimum diameter of 228.6 mm (9 inches) at its widest transverse cross-section, whether or not finished, of a kind used in furnaces, and whether or not the graphite pin joining system is attached to, sold with, or sold separately from, the large diameter graphite electrode. Unfinished large diameter graphite electrodes are graphitized electrodes that have not undergone final machining. For purposes of these investigations, the country of origin is determined by the country of graphitization.
Excluded from the scope of these investigations are large diameter graphite electrodes that are subject to the existing antidumping duty order on Small Diameter Graphite Electrodes from the People's Republic of China. *See Antidumping Duty Order: Small Diameter Graphite Electrodes from the People's Republic of China,* 74 FR 8775 (February 26, 2009) ( *SDGE China AD Order* ) due to an affirmative determination of circumvention that imports of graphite electrodes from the People's Republic of China, produced and/or exported by Sinosteel Jilin Carbon Co., Ltd. and Jilin Carbon Import & Export Company (collectively, Jilin Carbon), with an actual or nominal diameter of 17 inches and otherwise meeting the description of the scope of the *SDGE China AD Order* constitute merchandise subject to the *SDGE China AD Order. See Small Diameter Graphite Electrodes from the People's Republic of China: Affirmative Final Determination of Circumvention of the Antidumping Duty Order and Rescission of Later-Developed Merchandise Anticircumvention Inquiry,* 78 FR 56864 (September 16, 2013). In the case of graphite electrodes entering the United States determined to be subject to the *SDGE China AD Order,* such order controls. In the case of graphite electrodes entering the United States meeting the scope definition of these investigations and not covered by the scope of the *SDGE China AD Order,* the scope of these investigations controls.
Large diameter graphite electrodes and graphite pin joining systems for large diameter graphite electrodes that are covered by these investigations are currently classified under the Harmonized Tariff Schedule of the United States (HTSUS) statistical reporting number 8545.11.0020. Merchandise covered by these investigations may also enter under HTSUS statistical reporting numbers 3801.10.5090 or 3801.90.0050. The HTSUS numbers are provided for convenience and customs purposes, but the written description of the scope is dispositive.