Meridian Products, LLC v. United States, 2015 Ct. Intl. Trade LEXIS 135

Meridian filed a scope ruling request (Jan. 11, 2013) asking to exclude three kitchen appliance door handles from the antidumping and countervailing duty orders on aluminum extrusions from China.
Commerce issued a Final Scope Ruling (June 21, 2013) concluding all three handle types fall within the Orders.
Meridian filed suit seeking judgment on the agency record, challenging the Final Scope Ruling as contrary to law.
The court held oral argument (Feb. 12, 2015) and later issued an opinion affirming in part and remanding in part.
Court affirmed Type A and Type C conclusions but remanded for reconsideration as to Type B handles due to a flawed basis in the Department’s reasoning about scope language and exclusions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Type A and Type C handles are within the scope	Meridian contends Type A/C not excluded by scope	Commerce properly included Type A/C within the scope	Affirmed: Type A and Type C are within the scope
Whether Type B handles are within the scope based on reasonable interpretation	Meridian argues Type B is not reasonably within the general scope language	Department reasonably included Type B as within scope	Remanded for reconsideration: the general-scope interpretation is not reasonable
Whether finished merchandise or finished goods kit exclusions apply to Type B	Meridian alleges exclusions should exclude Type B	Commerce rejected exclusions as inapplicable	Remanded for reconsideration: Department’s application of exclusions flawed

Duferco Steel, Inc. v. United States, 296 F.3d 1087 (Fed. Cir. 2002) (scope orders interpreted to include merchandise only if reasonably within language)
Mid Continent Nail Corp. v. United States, 725 F.3d 1295 (Fed. Cir. 2013) (orders cannot be extended beyond scope unless reasonably interpreted to include it)
Walgreen Co. v. United States, 620 F.3d 1350 (Fed. Cir. 2010) (scope initiation does not require (k)(2) if (k)(1) applies)