Trailer, RV trade groups seek tire duties exemption

WASHINGTON (Sept. 26, 2014) — The National Association of Trailer Manufacturers (NATM) and Recreation Vehicle Industry Association (RVIA), supported by more than a dozen distributors of specialty trailer tires, are seeking an exemption for specialty trailer tires from possible import and/or antidumping duties the U.S. government is considering for car and light truck tires imported from China.

The NATM, which represents manufacturers of light- and medium-duty trailers that are towed behind vehicles, said it petitioned the Department of Commerce to seek clarification of this issue because the “vast majority” of specialty trailer tires — those marked “for trailer use only” — are manufactured outside of the U.S.

The association submitted its petition on Aug. 11 after it concluded the countervailing and/or antidumping duties the U.S. government is considering imposing on consumer tires imported from China could include ST tires, an action that would lead to higher costs and potential shortages of ST tires.

Either action “would have a significant adverse impact on the light- and medium-duty trailer industry,” the NATM said.

Commerce has yet to reply to or act on the NATM's petition, but association Executive Director Pam Trusdale told the trade group's members in a recent blog posting that the group had made “significant progress” toward getting trailer tires excluded from the import investigation.

In her posting, Ms. Trusdale noted that the United Steelworkers (USW) union — which is pushing for duties — in large part agrees with the NATM's position, with a few exceptions.

“We view this development as a very positive step towards the desired outcome of excluding specialty trailer tires from the investigation,” she wrote. “However, the Department of Commerce must still act before the scope is officially modified, which we hope will be the case in light of the union's comments.”

The USW, which initiated the action against Chinese tire imports, stated in its filing with the Commerce Department that it agrees with the NATM's position on excluding certain ST tires. The union's position suggests defining the tires to be excluded as those “designed to be used exclusively on trailers and marketed for that purpose.”

The USW proposes, however, that the importers of products to be excluded demonstrate certain physical characteristics be present, such as ensuring that:

• Tires have molded sidewall markings indicating dimensions and load index consistent with those outlined for specialty trailer tires in the Tire and Rim Association Yearbook;
• Tires are marked “ST” on the sidewall;
• Tires incorporate a warning molded into the sidewall indicating “For Trailer Service Only” or “For Trailer Use Only;” and
• Tires marked with a speed rating not to exceed 81 mph.

According to Statistical Surveys Inc., a Grand Rapids, Mich.-based market intelligence entity, there were approximately 900,000 tow-along utility, boat, livestock, etc., trailers registered in the U.S. in 2013, or roughly 65,000 more than in 2012.

Based on the number of one-, two-, three-, etc. axle trailers registered, the number of trailers registered represents a need for roughly 3.8 million tires, extrapolating out the data from Statistical Surveys, which estimates the value of new trailer sales in the U.S. at about $3 billion annually.

Registrations in 2014 are running about 8 percent ahead of 2013.

Recreational vehicle manufacturers produced and shipped 268,035 towable travel and fifth-wheel trailers in 2013, according to RVIA data.

These trailers are not included in the Statistical Surveys data.

Sales of towables are running more than 8 percent ahead of 2013.

The majority of specialty trailer tires are 13, 14 and 15 inches in rim diameter, based on an analysis of specialty tire marketers' product literature and other sources.

Imports of tires in those sizes last year were 8.26 million, 27.7 million and 42.4 million units, respectively, with China being the largest source in each case, accounting for 45, 40 and 33 percent of each size, according to Tire Business' analysis of Commerce Department import data.

Similarly, Kenda Rubber Industrial Co. Ltd. has requested an exemption for temporary spares, and a number of other petitioners are requesting exemptions for certain ATV tires, noting that some ATV tires are passenger and/or light truck-sized but which are marked “AT” for all-terrain and/or “NHS” for “not highway service” and are rated for speeds of no more than 50 mph.

Among those submitting comments to Commerce supporting the ST trailer tire exemption are: American Omni Trading Co. L.L.C.; Badger Tire & Wheel; China Manufacturers Alliance; Crown International Corp.; CTP Transportation Products L.L.C.; Dunlap & Kyle Tire Co. Ltd.; ITG Voma Corp.; Kenda Rubber Industrial Co. Ltd. and its U.S. subsidiaries; Lionshead Specialty Tire & Wheel L.L.C.; Shandong Changfeng Tyres Co. Ltd.; Strategic Tires Supply Group L.L.C.; TBC Corp.; Trans Texas Tire L.L.C.; Tredit Tire & Wheel Co.; and Zhongce Rubber Group Co. Ltd.

Trailers manufactured by NATM member companies transport a diverse range of items, such as livestock, ATVs, boats, snowmobiles, landscaping equipment, etc., the Topeka, Kan.-based trade group said, and also serve as portable power generators, traffic control systems and law enforcement command centers.

Reston, Va.-based RVIA is the national trade association representing recreation vehicle manufacturers and their component parts suppliers, which together build more than 98 percent of all RVs produced in the U.S.

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To reach this reporter: [email protected]; 330-865-6145. Twitter — @reifenmensch.