ARCHIVED - Anti-dumping and Countervailing Program

This page has been archived.

Final Determination - Xanthates

OTTAWA, February 3, 2003

4240-50
AD/1282

STATEMENT OF REASONS

Concerning the making of a final determination of dumping with respect to

CERTAIN XANTHATES ORIGINATING IN OR EXPORTED FROM THE PEOPLE'S REPUBLIC OF CHINA

DECISION

Pursuant to paragraph 41(1)(a) of the Special Import Measures Act, the Commissioner of Customs and Revenue has today made a final determination of dumping regarding xanthates of all grades in dry or liquid forms, excluding cellulose xanthates, originating in or exported from the People's Republic of China.

This Statement of Reasons is also available in French.
Cet énoncé des motifs est également disponible en français.

Contents

SUMMARY
INTERESTED PARTIES

• Complainant
• Exporters
• Importers

BACKGROUND
PRODUCT INFORMATION

• Product Definition
• Product Description
• Product Information and Uses
• Production Process
• Classification of Imports

CANADIAN INDUSTRY AND CANADIAN MARKET
THE INVESTIGATION
RESULTS OF THE INVESTIGATION

• a) Domestic Industry:
• b) Export Trade:
• c) Domestic Pricing:
• d) Normal Values:
• e) Export Prices:
• f) Margins of Dumping:
• g) Summary of Results:

DECISION
FUTURE ACTION
PUBLICATION
INFORMATION
APPENDIX 1

STATEMENT OF REASONS

SUMMARY

On June 21, 2002, the Commissioner of Customs and Revenue (Commissioner) initiated an investigation respecting the alleged injurious dumping into Canada of certain xanthates originating in or exported from the People's Republic of China (China). The investigation was initiated in response to a complaint filed by Charles Tennant & Company (Canada) Limited (Charles Tennant) of Fort Saskatchewan, Alberta.

On August 20, 2002, the Canadian International Trade Tribunal (Tribunal) made a preliminary finding that the evidence disclosed a reasonable indication that the alleged dumping of the subject goods had caused injury to the domestic industry.

On August 28, 2002, pursuant to paragraph 39(1)(a) of the Special Import Measures Act (SIMA), the Commissioner extended to 135 days the time period for rendering a preliminary determination of dumping or for terminating the investigation in whole or in part, due to the complexity or novelty of the issues presented by the investigation.

On November 4, 2002, the Commissioner made a preliminary determination of dumping.

The Canada Customs and Revenue Agency (CCRA) continued its investigation and, on the basis of the results, the Commissioner is satisfied that the subject goods have been dumped and that the margins of dumping are not insignificant. Consequently, on February 3, 2003, the Commissioner made a final determination of dumping pursuant to paragraph 41(1)(a) of the SIMA.

The Tribunal's inquiry into the question of injury to the Canadian industry is continuing. Provisional duty will continue to be imposed on the subject goods originating in or exported from China until the Tribunal renders its decision. The Tribunal will issue its finding by March 4, 2003.

INTERESTED PARTIES

Complainant

Charles Tennant is the only known Canadian producer of xanthates. Its manufacturing division, Prospec Chemicals Division, produces the goods in Fort Saskatchewan, Alberta. Charles Tennant's head office is located at 34 Clayson Road, Weston, Ontario.

Exporters

The CCRA identified four exporters and two vendors that were involved in exports of subject goods during the period of investigation (POI) (January 1, 2001 - March 31, 2002).

Importers

The CCRA investigation identified three importers of the subject goods in the period of investigation.

BACKGROUND

On May 6, 2002, Charles Tennant filed a formal complaint with the CCRA, alleging that the dumped imports of certain xanthates originating in or exported from China were causing injury to the domestic producer. On May 27, 2002, the CCRA notified Charles Tennant that its complaint was properly documented and notified the Government of China (GOC) that a complaint had been received regarding the alleged dumping of certain xanthates.

On June 21, 2002, the Commissioner initiated a dumping investigation and notified the Tribunal of that decision. The Tribunal subsequently initiated a preliminary injury inquiry into whether the evidence discloses a reasonable indication of injury, retardation or threat of injury caused by the dumping of the goods. On August 20, 2002, the Tribunal made a preliminary determination that the evidence disclosed a reasonable indication that the alleged dumping of the subject goods had caused injury.

On August 28, 2002, pursuant to paragraph 39(1)(a) of the SIMA, the Commissioner extended to 135 days the time period for rendering a preliminary determination of dumping or terminating the investigation. The extension was required in order to review in detail the information provided by the GOC and exporters of the subject goods in order to assess whether the xanthates industry in China was operating under market conditions.

On November 4, 2002, the Commissioner made a preliminary determination of dumping of the subject goods and provisional duty has been in place since that date.

PRODUCT INFORMATION

Product Definition

For the purpose of this investigation, the subject goods are defined as:

"xanthates of all grades in dry or liquid forms, excluding cellulose xanthates, originating in or exported from the People's Republic of China."

Product Description

Xanthates are water-soluble chemicals that are used primarily in the mining industry. Other names for xanthates include xanthogenates, carbondithioates, dithiocarbonates and sodium or potassium salts of xanthanic (or dithiocarbonic) acids.

The subject goods include all grades of sodium or potassium salts of ethyl, butyl (isobutyl, normal butyl, secondary butyl), propyl (isopropyl, normal propyl) and amyl (isoamyl, normal amyl, secondary amyl) xanthates, in dry forms, such as powder, granules, pellets, tablets or flakes, or liquid forms, such as solution or slurry. Xanthates in dry forms and liquid forms are interchangeable products. The subject goods do not include cellulose xanthates, which are produced as intermediates in the production of viscose (rayon) and cellophane.

Product Information and Uses

Xanthate is the common name for chemical reagents used in the flotation of base and precious metals, which is the standard method for separating valuable minerals, such as gold, copper or zinc (referred to as "values"), from non-valuable minerals, such as limestone or quartz.

To extract values, conditioned ores are mixed in a solution of water and xanthates and then agitated in flotation cells, which resemble large washing machines. Xanthates may be added in liquid or solid form. The xanthates cause the minerals to attach themselves to air bubbles and then float to the top of the flotation cell. As values reach the surface, the bubbles form a froth that overflows into a trough for collection. The residual may be re-used for additional recovery or removed for disposal. Most of the xanthate is consumed in the process.

Several separate flotations are typically required for different ores. Since each ore is unique, there is no standard flotation procedure and no standard grade or type of xanthate used to extract specific values. Each producer has its own grades for xanthate composition, including purity, which is stated as a minimum percentage up to 100 per cent, and moisture.

Four types of xanthates (ethyl, butyl, propyl and amyl) are produced in various combinations with sodium and potassium, which are stabilizers in the chemical formula.

Mine operators may use different xanthates to extract the same value. Certain xanthates are stronger than others, for example, potassium amyl xanthate (PAX) versus potassium ethyl xanthate (PEX). PAX is therefore used to produce high-grade concentrates or to promote the flotation of difficult-to-float minerals. A mine operator may however decide to use PEX if a cost benefit can be made.

Xanthates are also used as defoliants, herbicides, insecticides and fungicides in agricultural production and as additives in the curing and vulcanization of rubber and as high-pressure lubricant additives. Reported new uses of xanthates include inhibition of fertilizer nitrogen transformation and colour development for image-recording materials.

Production Process

Xanthates are prepared by reacting sodium or potassium hydroxide with an alcohol and carbon disulphide. In most commercial processes, the end product of the reaction is a wet mixture, which is then dried, normally in a vacuum dryer to allow the lowest temperature possible to be used. Since the decomposition of xanthate increases with temperature, the lower the temperature, the higher are the quality and yield.

Classification of Imports

The goods in question are usually classified under the following Harmonized System classification numbers:

2930.10.10.10
2930.10.10.20
2930.10.10.90
2930.10.90.00

CANADIAN INDUSTRY AND CANADIAN MARKET

There have been no changes in the structure of the Canadian industry since the investigation was initiated. Charles Tennant is the only known Canadian producer of xanthates. Its manufacturing division, Prospec Chemicals Division, located in Fort Saskatchewan, Alberta, produces the goods.

The CCRA validated the information concerning imports provided by the complainant by means of its own internal information system, the Facility for Information Retrieval Management (FIRM), customs documents and submissions from importers and exporters. The CCRA accordingly confirmed the trend in the aggregate volume of imports that was emerging at the initiation of the investigation and calculated the volume of goods dumped during the period of the investigation. The only other imports of xanthates originated in Mexico, a non-subject country.

For purposes of the preliminary determination of dumping, the Commissioner has responsibility for determining whether the actual and potential volume of dumped goods is negligible. After a preliminary determination of dumping, the Tribunal assumes this responsibility. In accordance with subsection 42(4.1) of SIMA, the Tribunal is required to terminate its inquiry in respect of any goods if the Tribunal determines that the volume of dumped goods from a country is negligible.

The CCRA is unable to publish the specific figures regarding the Canadian market since there is only one Canadian producer and the release of this information would result in the disclosure of confidential information.

THE INVESTIGATION

The dumping investigation involved all subject goods that were released into Canada during the POI, that is, from January 1, 2001, to March 31, 2002.

Generally, the normal value of the goods is based on the domestic selling prices of the like goods in the country of export, or the full cost of the goods including the direct costs of production and administrative, selling and all other costs, plus an amount for profits. However, pursuant to section 20 of the SIMA, where in the opinion of the Commissioner, the Government of an export country has a monopoly or a substantial monopoly of its export trade and substantially determines the domestic prices of like goods similar to those subject to the investigation, the normal value of the goods is generally calculated on the basis of the domestic market selling price or on the full costs of like goods in a surrogate country operating under market conditions, or on the re-sale price in Canada of like goods produced in and imported from a surrogate country.

The export price of subject goods shipped to Canada is normally the lesser of the exporter's ex-factory selling price or the importer's purchase price. When the export price is less than the normal value, the difference is the margin of dumping.

For purposes of the SIMA, the CCRA has traditionally considered China as being a non-market economy country. Various publications including reports in respect of other countries' investigating authorities taking trade actions involving China, and the World Trade Organization's (WTO) Report of the Working Party on the Accession of China, available to the CCRA at the time of the initiation of the investigation, contained comments which supported the CCRA's traditional treatment of China in anti-dumping investigations. Information was therefore requested from the GOC and exporters of subject goods in order to assess whether the xanthates industry in China was operating under market conditions. The GOC provided a detailed submission within the required time frame.

At the initiation of the investigation, the CCRA had also requested selling and costing information from companies identified as possible exporters or possible importers of the subject goods. Only one exporter, Qixia Tongda Flotation Reagent Co., Ltd. (Tongda), submitted a detailed response to the CCRA's Request for Information (RFI). Complete responses were also received from three importers of subject goods, Aslchem International Inc. (Aslchem), Sumitomo Canada Ltd. and Cominco Ltd. One of the companies identified as a possible importer at initiation advised the CCRA that it had not imported the subject goods during the POI. It was determined that two other importers identified at the initiation of the investigation were in fact vendors of subject goods.

Information was also requested from producers of xanthates in India and Mexico in the event that the Chinese xanthate industry was not considered to be operating under market conditions. Only one producer located in Mexico provided information to the CCRA.

During the month of September 2002, verification meetings were held with representatives of the GOC in Beijing as well as representatives at the provincial and municipal level in Jinan, Shandong. The purpose of the meetings was to verify information submitted in response to the CCRA's RFI as well as to obtain additional information with respect to the xanthate industry in China. Verification meetings were also held with Tongda representatives in Qixia and Yantai, Shandong, as well as with representatives of Aslchem in Richmond, B.C.

It should be noted that the verification of the information submitted by Tongda revealed that not all costs incurred for the production of like goods sold domestically and goods sold to Canada were reported by the company. While Tongda submitted additional costing information after the preliminary determination of dumping, the CCRA cannot ascertain that the full costs have been reported.

On October 23, 2002, the CCRA received confidential representations from the complainant supporting the treatment of the xanthates industry as not operating in market conditions in China. A public version of the representations was received on November 1, 2002.

On November 4, 2002, a preliminary determination of dumping was made. While the GOC had provided a response to the CCRA's RFI and verification meetings were held with the various levels of government in China, the information before the CCRA at that time contained conflicting data, incomplete details and inaccuracies. Therefore, for purposes of that phase of the investigation, the CCRA maintained the position that the xanthate industry in China was not operating under market conditions. At the time of the preliminary determination, the GOC was provided with a list of outstanding issues and was afforded an opportunity to provide additional information.

As well, given that the Commissioner's opinion to be made regarding section 20 of the SIMA concerns the entire xanthates industry, at the time of the preliminary determination, all known xanthates producers in China were requested to provide information in order to assess if the xanthates industry was operating under market conditions. Complete responses from the producers were necessary for a clear understanding of the xanthates industry in China and the economic environment in which the industry operates, as well as to corroborate the information provided or to be provided by the GOC.

The GOC provided a response to the CCRA's questionnaire on November 28, 2002. In regard to information requested from the GOC relating to the xanthates manufacturers, the GOC stated that in spite of its effort to gather the required information and documentation relating to the industry, producers had not supplied the information. Furthermore, no xanthates producers in China, with the exception of Tongda, responded to any of the CCRA's questionnaires. Consequently, the requested industry information is still incomplete.

Under Article 15 of the WTO Anti-dumping Agreement, developed countries are to give regard to the special situation of developing country Members when considering the application of anti-dumping measures under the Agreement. Possibilities of constructive remedies provided for under the Agreement are to be explored before applying anti-dumping duty where they would affect the essential interests of developing country Members.

The Commissioner recognizes China as a developing country for purposes of actions taken pursuant to the SIMA. In this particular investigation, this obligation was met by providing an opportunity for exporters to submit price undertakings. No interest to conclude this investigation by means of price undertakings was expressed by exporters.

RESULTS OF THE INVESTIGATION

The CCRA's assessment of the conditions described in section 20 of the SIMA addressed the issues of both de jure and de facto government controls (i.e. in law and in fact), in the export trade and domestic pricing of xanthates.

a) Domestic Industry:

As the majority of xanthates producers in China did not participate in the GOC's effort to collect information and did not respond to the CCRA's RFI, the CCRA was unable to fully determine the structure of the xanthates industry in China and to perform a proper assessment of its size and configuration. This information was deemed necessary in order to determine the applicability of the various laws and regulations to the xanthates producers, their impact on the xanthates industry and to assess the level of state ownership and/or control over the industry. Without this information, the CCRA was unable to analyse the extent of the GOC's control of the export trade or domestic pricing of xanthates in China.

b) Export Trade:

According to the GOC's submission, certain producers in China were subject to a permissive system of granting foreign trade rights. The CCRA considers such a mechanism to be a control of the export trade. The GOC claimed that as far as the xanthates industry is concerned, this permissive system was not being applied as a trade control mechanism during the POI. During the verification visit with the GOC, Government officials explained that any xanthates producer would be granted the right to engage in foreign trade if it applied for such rights. However, corroborative evidence was not provided by the GOC and the producers of xanthates in China to substantiate these claims. In this regard, neither the GOC nor the majority of producers provided the requested documents relating to the approval of trading rights. Therefore, the trading right status of the majority of the producers is still either unknown or unconfirmed.

The missing information is considered material in forming an opinion as to whether the GOC has a substantial monopoly of the export trade of xanthates. As a result, the Commissioner does not have sufficient information on which to form the opinion referred to in section 20(1)(a) of the SIMA.

c) Domestic Pricing:

Information available to the CCRA indicates that the GOC may have influenced the domestic prices of xanthates in China during the POI. Potential controls by the GOC manifested themselves particularly through the influence of State-Owned Enterprises (SOE) in and on the xanthates industry, the sourcing and pricing of raw materials, as well as through possible restrictions of exports.

For example, based on the CCRA's review of legislative documents concerning SOE's, it appears that there is a potential for the GOC to interfere and influence the decisions of SOE's.

In this regard, the fact that the Government is responsible to appoint, remove, reward or punish the factory director, as stated in article 52 and 55 of the State-owned Industrial Enterprises Law of the People's Republic of China, and article 42 of the Regulations for Transformation of Operational Mechanism of State-owned Industrial Enterprises (SOE Regulations), is an indicator of government influence / control on the operations of the SOE's. Furthermore, while the SOE Regulations appear to confer a range of managerial decision powers to SOE's, there remains a wide range of provisions that are indicative of governmental influence. For example, while article 8 of the SOE Regulations states that "Enterprises shall have autonomy in making their own decisions on production and management", it also states that the State enjoys the authority to issue instructive plan, which enterprises shall execute. Finally, some rights afforded to SOE's pursuant to the SOE Regulations are subject to approval by government departments. For example, article 12 of the SOE Regulations states that "Enterprises enjoy the right to import and export" while the same article then specifies that such rights are subject to approval by the GOC and require appropriate qualifications. These are all indicators of potential Government interference in the decisions of SOE's. As such, the pricing decisions of either state-owned xanthates producers or state-owned suppliers of raw materials sold to xanthates producers may not reflect market-based supply and demand consideration.

In view of the potential influence the GOC may exert over SOE's, the GOC could, by controlling the state-owned suppliers of raw materials, exert a strong influence on the cost of production of xanthates in China, which in turn could have an effect on the determination of the selling price of the final product, or influence directly the pricing decision of state-owned xanthates manufacturers. Due to the lack of participation by the producers in China, the CCRA could not determine the market share of state-owned xanthates producers in the domestic industry and could not assess if the GOC did in fact interfere with their decisions. The CCRA also could not assess any pricing differences between the raw materials supplied by SOE's and the raw materials supplied by non-SOE's.

If producers in China had provided sufficient information, it would have allowed the CCRA to perform a more accurate appraisal of the extent of these controls. Again, the missing information is considered material in forming an opinion as to whether the GOC substantially determined the domestic prices of xanthates during the POI. As a result, the Commissioner does not have sufficient information on which to form the opinion referred to in section 20(1)(b) of the SIMA.

d) Normal Values:

Section 29 of the SIMA provides that, where in the opinion of the Commissioner, sufficient information has not been furnished or is not available to enable the determination of normal values or export price as provided for in the relevant sections of the SIMA, such determinations will be made in such manner as the Minister of National Revenue specifies.

In view of the circumstances described in the previous section, the normal values for the subject goods exported by Tongda during the POI were calculated pursuant to section 29 of the SIMA. While the CCRA had contacted xanthates producers in India and Mexico to request selling and costing information, only one producer in Mexico provided a response to the CCRA's RFI. This response was deemed to be incomplete; therefore, the CCRA did not consider this information for calculating normal values pursuant to section 29 of the SIMA. However, even with a complete response, the rules of confidentiality would have precluded the CCRA from using information from a single party. Therefore, the full costs of specific xanthate products manufactured in China estimated by the complainant were considered appropriate to calculate normal values. For estimating the costs of production in China, the complainant used its own costs of production as a basis, and adjusted them based on its expertise in the field as well as information from various public sources. The complainant also provided evidence to support assumptions relating to the production method in China. The CCRA adjusted the complainant's estimated full costs of production downward based on confidential information gathered during the investigation relating to certain cost elements in China. A reasonable amount for profits, based on historical profit levels earned by the complainant on sales of xanthates, was also included in the calculation.

For purposes of the final determination, normal values for subject goods from all other exporters were determined pursuant to section 29 of the SIMA and were equal to the export price as determined under section 29 of the SIMA, plus an amount equal to 49.5% of the export price. This advance represents the highest margin of dumping, excluding anomalies, found in this investigation for the cooperative exporter, expressed as a percentage of the export price.

e) Export Prices:

For purposes of the final determination, the export price for subject goods shipped by Tongda were, pursuant to section 24 of the SIMA, the lower of the exporter's selling price or the importer's purchase price adjusted for inland freight and port charges.

For subject goods shipped by exporters who did not provide complete submissions to the CCRA, export prices were determined pursuant to section 29 of the SIMA and based on the declared invoice price of the goods on Customs documentation.

f) Margins of Dumping:

The margin of dumping is the difference by which the normal value of a good exceeds export price.

The CCRA's investigation of imports from China between January 1, 2001, and March 31, 2002, revealed that 100 per cent of the total volume of subject goods imported was dumped. For Tongda, the margins of dumping ranged from 2.5 to 49.5 per cent, when expressed as a percentage of the export price. The weighted average margin of dumping is 29.2 per cent for all goods when expressed as a percentage of the export price.

For all other exporters of subject goods to Canada during the POI, the weighted average margin of dumping is 49.5 per cent, when expressed as a percentage of the export price.

g) Summary of Results:

In making a final determination of dumping, the Commissioner must be satisfied that the subject goods have been dumped and that the margin of dumping is not insignificant. Subsection 2(1) of the SIMA stipulates that the margin of dumping is insignificant if it is less than 2 per cent of the export price of the goods. During the period of investigation, 100 per cent of the subject goods originating in or exported from China were dumped by a weighted average margin of dumping of 44.7 per cent, expressed as a percentage of the export price.

DECISION

Based on the results of the investigation, the Commissioner is satisfied that the subject goods originating in or exported from China have been dumped and that the margin of dumping is not insignificant. Accordingly, on February 3, 2003, the Commissioner has made a final determination of dumping pursuant to paragraph 41(1)(a) of the SIMA.

FUTURE ACTION

The Canadian International Trade Tribunal's inquiry concerning the question of injury to production in Canada is continuing. The Tribunal will issue its finding by March 4, 2003.

Subject goods imported during the provisional period will continue to be assessed provisional duty as determined at the time of the preliminary determination. The provisional period began on November 4, 2002, the date of the preliminary determination of dumping, and will end on the date on which the Tribunal issues its finding. Further information on the application of provisional duty is provided in the Statement of Reasons issued at the time of the preliminary determination, which can be found on the CCRA Web site at: www.cbsa-asfc.gc.ca/sima-lmsi/.

If the Tribunal finds that the dumped goods have not caused injury or do not threaten to cause injury, all proceedings relating to the investigation will be terminated. In such a case, all provisional duty collected or security posted by importers will be returned and future imports of the subject goods will not be subject to anti-dumping duty.

If the Tribunal finds that the dumped goods have caused injury, the CCRA will finalize the anti-dumping duty payable on the subject goods released from Customs possession during the provisional period, pursuant to section 55 of the SIMA. Imports released from Customs possession after the date of the Tribunal's finding will be subject to anti-dumping duty equal to the margin of dumping. In that event, the importer in Canada shall pay all such duty. The Customs Act applies, with any modification that the circumstances require, with respect to the accounting and payment of the anti-dumping duty.

If the Tribunal makes an injury finding, the normal value of future importations of subject goods produced and exported by Qixia Tongda Flotation Reagent Co., Ltd. shall be determined pursuant to section 29 of the SIMA and shall be equal to the export price as determined under section 24, 25 or 29 of the SIMA, plus an amount equal to 29.2% of the export price. This advance is equal to the weighted average margin of dumping calculated for Tongda during this investigation. The normal value of future importations of subject goods produced or exported by any other company shall be determined pursuant to section 29 of the SIMA and shall be equal to the export price as determined under section 24, 25 or 29 of the SIMA, plus an amount equal to 49.5% of the export price. This advance represents the highest margin of dumping, excluding anomalies, found in this investigation for the cooperative exporter, expressed as a percentage of the export price.

It must be noted that the xanthates investigation was conducted under the previous provisions of the SIMA that required the Commissioner to form an opinion on export trade controls and domestic price controls. Effective September 30, 2002, the SIMA was amended by An Act to amend certain Acts as a result of the accession of the People's Republic of China to the Agreement Establishing the World Trade Organization. The new legislation provides specific non-market criteria for a prescribed class of country. For a prescribed class of country, there will be no requirement to examine whether the government of that country has a monopoly or substantial monopoly of its export trade. The new legislation will affect any proceeding, process or action conducted after the Tribunal makes a finding in this investigation.

PUBLICATION

Notice of this final determination is being published in the Canada Gazette pursuant to paragraph 41(3)(a) of the SIMA.

INFORMATION

This Statement of Reasons has been provided to persons directly interested in these proceedings. A free copy may be obtained upon request or from the Web site below. For further information, please contact Mr. Denis Chénier or Mr. Michel Leclair, as follows:

Mail:

Canada Customs and Revenue Agency
Anti-dumping and Countervailing Directorate
191 Laurier Avenue West, 16^th Floor
Ottawa, Ontario
Canada
K1A 0L5

Telephone :

Denis Chénier: (613) 954-7394
Michel Leclair: (613) 954-7232

Fax: (613) 941-2612

Email:

denis.chenier@ccra-adrc.gc.ca
Michel.Leclair@ccra-adrc.gc.ca

Web site: http://www.cbsa-asfc.gc.ca/sima-lmsi/menu-eng.html

 

Suzanne Parent
Director General
Anti-dumping and Countervailing Directorate

Appendix 1

SUMMARY OF FINAL DETERMINATION MARGINS OF DUMPING BY EXPORTER FOR CERTAIN XANTHATES

(January 1, 2001 to March 31, 2002)

Exporters	% of Dumped Goods	Range of Margins of Dumped Goods (% of Export Price)	Weighted Average Margin of Dumping (% of Export Price)
Qixia Tongda Flotation Reagent Co. Ltd	100%	2.5 to 49.5%	29.2%
All other exporters (1)	100%	49.5%	49.5%
Total for China	100%		44.7%

(1) Margin of dumping based on the highest margin of dumping found for the cooperative exporter.