Four Heat Sink Models for Fiber Lasers Covered by AD/CVD on Aluminum Extrusions, Commerce Rules

Four models of heat sinks imported by IPG Photonics Corporation are covered by antidumping duty and countervailing duty orders on aluminum extrusions from China, the Commerce Department said in a scope ruling filed Sep. 15.

The merchandise considered in the ruling was aluminum heat sinks meant for use in IPG’s fiber lasers. The language of the orders, meanwhile, describes covered merchandise as extrusions made of certain aluminum alloys, although it carves out exceptions for finished heat sinks “the design and production of which are organized around meeting certain specified thermal performance requirements.”

IPG’s merchandise doesn’t meet the requirements of the finished head sink exclusion, the department ruled.

It agreed that the products were heat sinks made of aluminum. However, it said IPG hadn’t shown the products were designed to meet “specified thermal performance requirements.” Prior scope rulings, it said, have expounded on this test by defining “specified” requirements as being “established before testing, confirmed by testing, and integral throughout the design and production process.”

“The carefully selected scope language included in the Orders implements the [International Trade Commission’s] critical distinction differentiating finished heat sinks from ordinary heat sinks,” it said. “In the ITC’s view, ‘highly trained employees manage the FHS [finished heat sink] design and testing equipment.’”

IPG’s evidence didn’t demonstrate that it gave its manufacturer specific thermal requirements for the merchandise in question that it imported, Commerce said. Rather, it only provided documents that were “general in nature” to all heat sinks.