Antidumping and Countervailing Duty Investigations for Graphite Electrodes from China and India

Content

DATES:

Applicable March 16, 2026.

FOR FURTHER INFORMATION CONTACT:

Joseph Molokwu at (202) 482-8043 (the People's Republic of China (China)) and Nathan James and Olivia Woolverton (India) at
(202) 482-5305 and (202) 482-7453, respectively, 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 countervailing duty (CVD) 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 CVD Petitions were accompanied by antidumping duty (AD) petitions concerning imports of large graphite electrodes from
China and India. (2)

Between February 26 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)

In accordance with section 702(b)(1) of the Tariff Act of 1930, as amended (the Act), the petitioners allege that the Government
of China (GOC) and Government of India (GOI) are providing countervailable subsidies, within the meaning of sections 701 and
771(5) of the Act, to producers of large graphite electrodes in China and India and that such imports are materially injuring,
or threatening material injury to, the domestic industry producing large graphite electrodes in the United States. Consistent
with section 702(b)(1) of the Act and 19 CFR 351.202(b), for those alleged programs on which we are initiating CVD investigations,
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 with respect to the initiation of the requested CVD investigations. (5)

Periods of Investigation (POI)

Because the Petitions were filed on February 24, 2026, the POI is January 1, 2025, through December 31, 2025. (6)

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. (7) Between March 4 and 11, 2026, the petitioners provided clarifications and revised the scope. (8) The description of merchandise covered by these investigations, as described in the appendix to this notice, reflects these
clarifications.

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). (9) 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. (10) 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. [(11)]() 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.

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 AD 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. (12) An electronically filed document must be received successfully in its entirety by the time and date it is due.

Consultations

Pursuant to sections 702(b)(4)(A)(i) and (ii) of the Act, Commerce notified the GOC and GOI of the receipt of the Petitions
and provided an opportunity for consultations with respect to the Petitions. (13) Commerce held consultations with the GOC on March 11, 2026, (14) and the GOI on March 12, 2026. (15)

Determination of Industry Support for the Petitions

Section 702(b)(1) of the Act requires that a petition be filed on behalf of the domestic industry. Section 702(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 702(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, (16) 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. (17)

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 petitioners do not offer a definition of the domestic like product distinct
from the scope of the investigations. (18) 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. (19)

In determining whether the petitioners have standing under section 702(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. (20) We relied on data provided by the

  petitioners for purposes of measuring industry support. [(21)]()

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. (22) 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). (23) Second, the domestic producers (or workers) have met the statutory criteria for industry support under section 702(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. (24) Finally, the domestic producers (or workers) have met the statutory criteria for industry support under section 702(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. (25) Accordingly, Commerce determines that the Petitions were filed on behalf of the domestic industry within the meaning of section
702(b)(1) of the Act. (26)

Injury Test

Because China and India are “Subsidies Agreement Countries” within the meaning of section 701(b) of the Act, section 701(a)(2)
of the Act applies to these investigations. Accordingly, the ITC must determine whether imports of the subject merchandise
from China and/or India materially injure, or threaten material injury to, a U.S. industry.

Allegations and Evidence of Material Injury and Causation

The petitioners allege that imports of the subject merchandise are benefiting from countervailable subsidies and that such
imports are causing, or threaten to cause, material injury to the U.S. industry producing the domestic like product. In addition,
the petitioners allege that subject imports from China and India individually exceed the negligibility threshold provided
for under section 771(24)(A) of the Act. (27)

The petitioners contend that the industry's injured condition is illustrated by a significant increase in the volume of subject
imports; lost sales and revenues; underselling and price depression; declines in production, capacity utilization, and U.S.
shipments; and negative impact on financial performance. (28) 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. (29)

Initiation of CVD Investigations

Based upon the examination of the Petitions and supplemental responses, we find that they meet the requirements of section
702 of the Act. Therefore, we are initiating CVD investigations to determine whether imports of large graphite electrodes
from China and India benefit from countervailable subsidies conferred by the GOC and GOI, respectively. In accordance with
section 703(b)(1) of the Act and 19 CFR 351.205(b)(1), unless postponed, we will make our preliminary determinations no later
than 65 days after the date of this initiation.

China

Based on our review of the Petitions, we find that there is sufficient information to initiate a CVD investigation on 28 programs
alleged by the petitioners. For a full discussion of the basis for our decision to initiate on each program, see the China CVD Initiation Checklist. A public version of the initiation checklist for this investigation is available on ACCESS.

India

Based on our review of the Petitions, we find that there is sufficient information to initiate a CVD investigation on 30 programs
alleged by the petitioners. For a full discussion of the basis for our decision to initiate on each program, see the India CVD Initiation Checklist. A public version of the initiation checklist for this investigation is available on ACCESS.

Respondent Selection

China and India

In the Petitions, the petitioners identified 28 companies in China and three companies in India. (30) Commerce intends to follow its standard practice in CVD investigations and calculate company-specific subsidy rates in the
investigations. Following standard practice in CVD investigations, in the event Commerce determines that the number of companies
is large, and it cannot individually examine each company based upon Commerce's resources, where appropriate, Commerce intends
to select mandatory respondents based on U.S. Customs and Border Protection (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.

On March 13, 2026, Commerce released CBP data on imports of large graphite electrodes from China and India under administrative
protective order (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 days of the publication date of the notice of initiation
of these investigations. (31) 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.

Interested parties must submit applications for disclosure under 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.

Distribution of Copies of the Petitions

In accordance with section 702(b)(4)(A) of the Act and 19 CFR 351.202(f), a copy of the public version of the Petitions has
been provided to the GOC and GOI 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 its initiation, as required by section 702(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. (32) A negative ITC determination for either country will result in the investigation being terminated with respect to that country. (33) Otherwise, these CVD investigations will proceed according to statutory and regulatory time limits.

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 of production 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 (34) 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. (35) 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.

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. (36) 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. (37)

Certification Requirements

Any party submitting factual information in an AD or CVD proceeding must certify to the accuracy and completeness of that
information. (38) Parties must use the certification formats provided in 19 CFR 351.303(g). (39) Commerce intends to reject factual submissions if the submitting party does not comply with the applicable certification requirements.

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 letters of appearance). Note that Commerce has amended certain of its requirements pertaining to the
service of documents in 19 CFR 351.303(f). (40)

This notice is issued and published pursuant to sections 702 and 777(i) of the Act, and 19 CFR 351.203(c).

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.

[FR Doc. 2026-05496 Filed 3-19-26; 8:45 am] BILLING CODE 3510-DS-P

Footnotes

(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.

(2) Id.

(3) See Commerce's Letters, “Supplemental Questions,” dated February 27, 2026 (General Issues Supplemental Questionnaire); Country-Specific
CVD Questionnaires: India CVD Questionnaire and China CVD Questionnaire, dated February 26, 2026 and February 27, 2026, respectively; see also Memorandum, “Teleconference with Counsel to the Petitioners,” dated March 10, 2026 (March 10, 2026, Memorandum).

(4) See Petitioners' Letters, “Petitioners' Supplement to Volume I of the Petition for the Imposition of Antidumping and Countervailing
Duties on Imports from China and India,” dated March 4, 2026 (First General Issues Supplement); Country-Specific CVD Supplemental
Responses: India CVD Supplement and China CVD Supplement, dated March 3, 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).

(5) See section on “Determination of Industry Support for the Petitions,” infra.

(6) See 19 CFR 351.204(b)(2).

(7) See General Issues Supplemental Questionnaire; see also March 10, 2026, Memorandum.

(8) 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.

(9) See Antidumping Duties; Countervailing Duties, Final Rule, 62 FR 27296, 27323 (May 19, 1997) (Preamble); see also 19 CFR 351.312.

(10) See 19 CFR 351.102(b)(21) (defining “factual information”).

(11) 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.”).

(12) 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.

(13) See Commerce's Letters, “Invitation for Consultations to Discuss the Countervailing Duty Petition,” dated February 24, 2026.

(14) See Memorandum, “Consultations with the Government of China,” dated March 11, 2026; see also GOC's Letter, “Comments on CVD Petition on Large Diameter Graphite Electrodes from China (C-570-221),” dated March 13, 2026.

(15) See Memorandum, “Consultations with the Government of India,” dated March 12, 2026; see also GOI's Letter, “GOI's Pre-Initiation Comments and Consultation Note,” dated March 15, 2026.

(16) See section 771(10) of the Act.

(17) 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)).

(18) For a discussion of the domestic like product analysis as applied to these cases and information regarding industry support, see Checklists, “Countervailing Duty Investigation Initiation Checklists: Large Diameter Graphite Electrodes from the People's
Republic of China and India,” dated concurrently with, and hereby adopted by, this notice (Country-Specific CVD 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.

(19) For further discussion, see Attachment II of the Country-Specific CVD Initiation Checklists.

(20) Id.

(21) Id.

(22) Id.

(23) Id.; see also section 702(c)(4)(D) of the Act.

(24) See Attachment II of the Country-Specific CVD Initiation Checklists.

(25) Id.

(26) Id.

(27) For further discussion, see Country-Specific CVD 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.

(28) Id.

(29) Id.

(30) 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.

(31) See Country-Specific Memoranda, “Release of U.S. Customs and Border Protection Entry Data,” dated March 13, 2026.

(32) See section 703(a)(1) of the Act.

(33) Id.

(34) See 19 CFR 351.301(b).

(35) See 19 CFR 351.301(b)(2).

(36) See 19 CFR 351.302.

(37) 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.

(38) See section 782(b) of the Act.

(39) See Certification of Factual Information to Import Administration During Antidumping and Countervailing Duty Proceedings, 78 FR 42678 (July 17, 2013) (Final Rule); see also frequently asked questions regarding the Final Rule, available at https://enforcement.trade.gov/tlei/notices/factual_info_final_rule_FAQ_07172013.pdf.

(40) See Administrative Protective Order, Service, and Other Procedures in Antidumping and Countervailing Duty Proceedings, 88 FR 67069 (September 29, 2023).

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