On September 30, 2026, UTLX Manufacturing LLC (Petitioner or UTLX) filed companion petitions requesting the imposition of antidumping and countervailing duties on imports of certain railway tank cars and parts thereof (tank cars) from Mexico.
SCOPE OF THE INVESTIGATION
The proposed scope of these investigations is as follows:
Subject merchandise includes pressure and non-pressure railway tank cars, whether finished or unfinished, and regardless of capacity, dimensions, tare weight, shell thickness, insulation, thermal protection system, jacket configuration, underframe design, or tank compartment configuration. A tank car is a type of freight railcar that typically includes, but is not limited to, tanks, truck sets, underframes, wheelsets, couplers, draft systems, running gear, jackets, valves, fittings, end platforms, ladders, and top platforms.
Subject tank cars meet or exceed the following standards: DOT-111, DOT-115, DOT-117, AAR-206, AAR-211, DOT-105, DOT-109, DOT-112, DOT-114, DOT-120, including standards that are substantially similar to such standards and/or subsequently developed standards.
Subject merchandise includes the following subassemblies:
Tank assemblies, whether finished or unfinished, consisting of one or more cylindrical shell sections or courses joined by welding and enclosed by tank heads or end closures. The tank assembly is capable of transporting bulk liquids, gases, and other lading and may be uninsulated, insulated, jacketed, clad, lined, equipped with a thermal protection system, or otherwise configured for specific service requirements. Tank assemblies may be imported separately from the underframe assembly.
Underframe assemblies, whether finished or unfinished, consisting of a center sill or stub sills, body bolsters, and draft sill or draft-pocket structures, with or without crossbearers, crossties, end sills, center plates, draft gear components, safety appliances, mounting structures, or other structural attachments. Underframe assemblies support the tank assembly and associated equipment and transmit the buffing, draft, and other service loads encountered during rail transportation.
These subassemblies are subject to the investigation, whether entered alone or with other subassemblies and whether assembled or unassembled and whether finished or unfinished. The absence of any subassembly from an otherwise finished or unfinished tank car does not remove the tank car from the investigation. Processing or assembly of finished or unfinished tank cars or subassemblies including, but not limited to, welding, pressing, shaping, cleaning, plating, coating, bolting, painting, and machining, does not remove the product from the scope. Inclusion of other components not identified as comprising the finished or unfinished tank car does not remove the product from the scope.
Specifically excluded products include DOT-111 tank cars with tank shells and tank heads constructed primarily of stainless steel; DOT-105 and DOT-112 tank cars with a specified pressure rating of 499 pounds per square inch gauge or greater; and DOT-113 cryogenic tank cars.
The merchandise subject to this investigation is classified under the Harmonized Tariff Schedule of the United States (HTSUS) statistical subheading 8606.10.0000. Merchandise subject to this investigation may also be imported under subheadings 7309.00.0030, 7309.00.0090, 7311.00.0030, 7311.00.0060, 7311.00.0090, 7326.90.8688, 8607.99.1000, and 8609.00.0000. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of this investigation is dispositive.
PETITIONERS
UTLX Manufacturing LLC
181 West Madison Street
Suites 2500 & 2600
Chicago, IL 60602
COUNSEL FOR PETITIONERS
BUCHANAN INGERSOLL & ROONEY PC
1700 K Street, NW, Suite 300
Washington, DC 20006
(202) 452-7900
NAMED PRODUCERS/EXPORTERS
For a list of foreign producers/exporters alleged by Petitioner, please see Attachment I.
NAMED IMPORTERS
For a list of importers alleged by the Petitioner, please see Attachment II.
ESTIMATED SCHEDULE
| Event | Earliest Date |
| Petition Filed | September 30, 2026 |
| DOC Initiation | October 20, 2026 |
| ITC Preliminary Investigation: | |
| Questionnaires Due | October 14, 2026 |
| Request to appear at hearing | October 19, 2026 |
| Hearing | October 21, 2026 |
| Briefs | October 24, 2026 |
| ITC Vote | November 14, 2026 |
| DOC Investigation Schedule: | |
| DOC Preliminary Antidumping Determination | March 9, 2027 |
| DOC Final Antidumping Determination | May 23, 2027 |
| DOC Preliminary Countervailing Determination | December 24, 2026 |
| DOC Final Countervailing Determination | March 9, 2027 |
| ITC Final Investigation: | |
| ITC Final AD Determination | July 7, 2027 |
| ITC Final CVD Determination | April 23, 2027 |
ALLEGED DUMPING MARGINS
Mexico: 12.70% – 32.58%
ALLEGED COUNTERVAILING DUTY MARGINS
Above de minimis.
ALLEGED SUBSIDIES
For a list of alleged subsidies by the Petitioner, please see Attachment III.
IMPORTS OF SUBJECT MERCHANDISE
U.S. imports of tank cars from Mexico are set forth below, based on Official U.S. import statistics and Association of American Railroads (AAR) and Umler system data. As a note, official U.S. import statistics do not capture imports of tank cars from Mexico because tank cars have historically entered informally under the “instrument of international traffic” exemption rather than through formal customs entry. As a result, Mexico does not appear in the official USITC Trade DataWeb statistics for the HTSUS subheading covering tank cars (8606.10.0000), shown in Table 1 below for reference and reported in Exhibit I-19 of the Petition.
Table 1—Official U.S. Imports for Consumption, HTSUS 8606.10.0000, Countries Other Than Mexico (Source: USITC Trade DataWeb)
| Country | 2023 | 2024 | 2025 | H1 2025 | H1 2026 |
| Quantity (number of units) | |||||
| Canada | 0 | 1 | 0 | 0 | 2 |
| China | 0 | 1 | 0 | 0 | 0 |
| India | 3 | 0 | 0 | 0 | 0 |
| United Kingdom | 1 | 3 | 0 | 0 | 0 |
| Landed Duty-Paid Value (USD) | |||||
| Canada | $0 | $4,017 | $0 | $0 | $977,534 |
| China | $0 | $10,578 | $0 | $0 | $0 |
| India | $5,184 | $0 | $0 | $0 | $0 |
| United Kingdom | $5,847 | $19,046 | $0 | $0 | $0 |
Instead, the Petition based volume of subject imports on AAR/Umler data which indicate where the tank car was substantially constructed, shown in Table 2 below for reference and reported in Exhibit I-20 of the Petition. Underlying figures are marked business proprietary in the exhibit and are shown below as bracketed ranged data, consistent with the public version of the petition.
| Category | 2023 | 2024 | 2025 | Jan–Jun 2025 | Jan–Jun 2026 |
| Subject Imports from Mexico (units) | [Business proprietary] | 4,531 | 3,302 | [Business proprietary] | [Business proprietary] |
| Total U.S. Market (units) | [Business proprietary] | [Business proprietary] | 7,841 | [Business proprietary] | [Business proprietary] |
| Mexico’s Market Share (percent) | [Business proprietary] | 70.4% | 95.4% | [Business proprietary] | [Business proprietary] |
CONTACT US
For more information concerning this petition and how it may affect your business, please contact Nithya Nagarajan or Stephen Brophy.