CIT sustains Commerce's second remand redetermination in UAE circular welded steel pipe review

The U.S. Court of International Trade sustained Commerce's Second Remand Redetermination in the 2020-2021 administrative review of the antidumping duty order on circular welded carbon-quality steel pipe from the United Arab Emirates, Slip Op. 26-98, Court No. 23-00113. On remand following the CAFC's decision in Marmen III, 134 F.4th 1334 (Fed. Cir. 2025), Commerce discontinued the Cohen's d test and applied a new three-step differential pricing analysis, revising Universal Tube and Plastic Industries' weighted-average dumping margin from 2.63% to 3.64%. The court also accepted Commerce's explanation for applying both the inter-quarter and same-quarter comparisons in the same review.