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Final Determination - Certain hot-rolled carbon steel plate and high-strength low-alloy steel plate
OTTAWA, December 19, 2003
4258-121
AD1304
STATEMENT OF REASONS
Concerning the final determination of dumping pursuant to paragraph 41(1)(a) of the Special Import Measures Act regarding
CERTAIN HOT-ROLLED CARBON STEEL PLATE AND HIGH-STRENGTH LOW-ALLOY STEEL PLATE ORIGINATING IN OR EXPORTED FROM BULGARIA, THE CZECH REPUBLIC AND ROMANIA.
DECISION
On December 9, 2003, pursuant to paragraph 41(1)(a) of the Special Import Measures Act, the Commissioner of Customs and Revenue made a final determination of dumping regarding hot-rolled carbon steel plate and high-strength low-alloy steel plate not further manufactured than hot-rolled, heat-treated or not, in cut lengths in widths from 24 inches (+/- 610 mm) to 152 inches (+/- 3,860 mm) inclusive and in thicknesses from 0.187 inches (+/- 4.75 mm) to 5.25 inches (+/-133 mm) inclusive, originating in or exported from Bulgaria, the Czech Republic and Romania, excluding plate produced to American Society for Testing & Materials (ASTM) specifications A515 and A516M/A516 Grade 70 in thickness greater than 3.125 inches (+/- 79.3 mm), universal mill plate, plate for use in the manufacture of pipe and plate having a rolled, raised figure at regular intervals on the surface (also known as floor plate).
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TABLE OF CONTENTS
Information Received From Importers
Summary of Results of the Investigation
Summary of Events
[1] Following a number of discussions and meetings with the Canada Customs and Revenue Agency (CCRA), Algoma Steel Inc. (Algoma) of Sault Ste. Marie, Ontario, submitted a formal complaint on May 5, 2003 alleging that dumped imports of certain hot-rolled carbon steel plate and high-strength low-alloy steel plate originating in or exported from Bulgaria, the Czech Republic and Romania were causing injury to domestic producers. The company alleged that the dumping of the goods in question was harming Canadian production by causing reduced market share, lost sales, price erosion, price suppression and underutilization of capacity.
[2] The CCRA informed the complainant on May 26, 2003, that the complaint was properly documented. The CCRA also notified the governments of Bulgaria, the Czech Republic and Romania. At the same time, the CCRA also notified the government of the United States of America (United States) that although goods of that country were not subject to this investigation, information before the CCRA indicated that some companies located in that country may have exported subject goods to Canada that originated in the named countries.
[3] On June 13, 2003, the Commissioner of Customs and Revenue (Commissioner) initiated an investigation respecting the alleged injurious dumping of certain hot-rolled carbon steel plate and high-strength low-alloy steel plate originating in or exported from Bulgaria, the Czech Republic and Romania.
[4] On receiving notice of the investigation, the Canadian International Trade Tribunal (Tribunal) started its preliminary injury inquiry. On August 12, 2003, the Tribunal made a preliminary determination that the evidence disclosed a reasonable indication that the alleged dumping of the subject goods has caused injury to the domestic industry. The CCRA subsequently made a preliminary determination of dumping on September 11, 2003, and levied provisional duty on dumped subject goods.
[5] The CCRA has now completed its investigation. The Commissioner is satisfied that the subject goods have been dumped and that the margins of dumping are not insignificant. Accordingly, on December 9, 2003, the Commissioner made a final determination of dumping in accordance with paragraph 41(1)(a) of the Special Import Measures Act (SIMA).
[6] The Tribunal's inquiry concerning the question of injury to the Canadian industry is continuing. Provisional duty will continue to be levied on importations of dumped subject goods until the Tribunal issues its finding.
Period of Investigation
[7] The CCRA's dumping investigation examined imports of subject goods into Canada during the period of April 1, 2002 to March 31, 2003. This period is referred to as the Period of Investigation (POI).
Interested Parties
[8] The complainant, Algoma, is a major producer of hot-rolled carbon steel plate and high-strength low-alloy steel plate in Canada. The only other producers of like products in Canada, IPSCO Inc. of Regina, Saskatchewan, and Stelco Inc. of Hamilton, Ontario, have expressed their support for the complaint.
[9] The CCRA's investigation confirmed that three exporters/producers (one in each of the named countries), two exporters located in the United States as well as eight vendors were involved in exporting subject goods to Canada during the POI.
[10] The CCRA's investigation confirmed that there were eight importers of subject goods during the POI.
Product Information
[11] For the purpose of this investigation, the subject goods are defined as:
"Hot-rolled carbon steel plate and high-strength low-alloy steel plate not further manufactured than hot-rolled, heat-treated or not, in cut lengths in widths from 24 inches (+/- 610 mm) to 152 inches (+/- 3,860 mm) inclusive and in thicknesses from 0.187 inches (+/- 4.75 mm) to 5.25 inches (+/-133 mm) inclusive, originating in or exported from Bulgaria, the Czech Republic and Romania, excluding plate produced to American Society for Testing & Materials (ASTM) specifications A515 and A516M/A516 Grade 70 in thickness greater than 3.125 inches (+/- 79.3 mm), universal mill plate, plate for use in the manufacture of pipe and plate having a rolled, raised figure at regular intervals on the surface (also known as floor plate)."
[12] ASTM standards, such as A6/A6M and A20/A20M, recognize permissible variations for dimensions.
[13] It should be noted that the metric equivalent dimensions in the definition of the subject goods are rounded numbers as indicated by the "+/-" symbols.
[14] Plate is manufactured to Canadian Standards Association (CSA), ASTM or other recognized specifications with the result that the products of any manufacturer, whether domestic or foreign, are interchangeable in any application. Therefore, price is the most significant factor in choosing a source of supply. The most common specification for plate in Canada is CSA G40.21 300W/44W.
[15] Carbon steel is, in effect, refined pig iron. Integrated producers make pig iron by combining iron ore, coke, limestone and oxygen and superheating the mixture in a blast furnace. The ensuing hot liquefied pig iron is combined with scrap metal and additional oxygen in a basic oxygen furnace. Mini-mills, on the other hand, produce molten carbon steel in electric arc furnaces. The basic raw material used by mini-mills is scrap metal rather than virgin iron ore.
[16] At this point, in both integrated and mini-mill production, the molten carbon steel is poured from a ladle into the tundish of a continuous strand caster. From the tundish, it flows into the caster's moulds to cool and to form a slab. The slab continues to move through the caster, cooling as it progresses, until it exits the caster, where it is cut to length with a torch. The slab is then either placed in inventory or immediately transferred to a reheat furnace where it is heated to a uniform rolling temperature. The plate is rolled to its final gauge in a series of rolling mills, levelled, identified and inspected for conformance to thickness tolerances and surface requirements.
[17] Heat-treated plate is manufactured in the manner described above. However, after rolling, it is placed in a heat furnace (charged), reheated to a uniform temperature, removed from the furnace and allowed to cool.
[18] Subject hot-rolled carbon steel plate and high-strength low-alloy steel plate can be used in a number of applications, the most common being in the production of rail cars, oil and gas storage tanks, heavy construction machinery, agricultural equipment, bridges, industrial buildings, high rise office towers, automotive parts, and shipbuilding and repairs (including pressure vessels).
[19] The subject goods are properly classified under the following Harmonized System classification numbers:
7208.51.91.10 7208.51.99.10 7208.52.90.10
7208.51.91.91 7208.51.99.91 7208.52.90.91
7208.51.91.92 7208.51.99.92 7208.52.90.92
7208.51.91.93 7208.51.99.93 7208.52.90.93
7208.51.91.94 7208.51.99.94 7208.52.90.94
7208.51.91.95 7208.51.99.95 7208.52.90.95
Canadian Industry
[20] There have been no changes in the structure of the Canadian industry since the investigation was initiated. Algoma is one of three Canadian producers of the subject goods. The other producers are IPSCO, located in Regina, Saskatchewan and Stelco, of Hamilton, Ontario.
Canadian Imports
[21] For the preliminary determination, the CCRA further refined its estimated volume of Canadian imports from all sources. The CCRA had utilized its internal information system, Facility for Information Retrieval Management (FIRM), reviewed customs entries and examined information received during the course of the investigation from importers, exporters and vendors. Since the preliminary determination and following verification of information from two exporters, there has been no further revision to the volume of plate imports. The CCRA is unable to publish the specific figures regarding the volume of dumped imports from each country since the release of this information would result in the disclosure of confidential information from some parties.
The Investigation
[22] The dumping investigation involved all of the subject goods released into Canada from customs control during the period of April 1, 2002, to March 31, 2003.
[23] In conducting its investigation, the CCRA requested identified exporters and importers to provide sales and cost information necessary to determine the normal values and export prices of the subject goods. Other companies that were identified as parties in the importation of the subject goods were also contacted and requested to provide information.
[24] A normal value is generally based on the domestic selling prices of the goods in the country of export or the total cost of the goods (cost of production, administrative, selling and all other costs) plus an amount for profits. 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 adjusted for freight charges and all other costs resulting from the exportation of the goods. When the export price is less than the normal value, the difference is the margin of dumping.
[25] A response to the CCRA's Request for Information (RFI) was received on July 21, 2003, from Ispat Sidex S.A. Galati (Ispat Sidex) of Romania. On July 30, 2003, the CCRA informed this exporter/producer that its response was incomplete and provided the company with a list of deficiencies. At the same time, the CCRA requested additional information from the company to clarify its original response. Information to complete the company's response to the RFI and to respond to the additional information requested by the CCRA was provided in a timely manner. For purposes of the preliminary determination, the normal values for Ispat Sidex were estimated on the basis of unverified information provided by the exporter. At the same time, the CCRA advised the company that it intended to verify its information after the preliminary determination. The company and the CCRA agreed that verification meetings would commence the week of October 6, 2003. A timely response was also received from METALEXPORTIMPORT S.A. (MEI), a Romanian vendor of subject goods. Arrangements were also made with this company for verification meetings to start on October 2, 2003.
[26] Vitkovice Steel, a.s. (Vitkovice Steel), the exporter/producer from the Czech Republic identified at the initiation of the investigation, provided some information on July 21, 2003 in response to the CCRA's RFI of June 13, 2003. The company advised the CCRA that more information would be provided at a later date. More information was received on August 11 and 25, 2003. On August 27, 2003, the CCRA advised Vitkovice Steel that its response was not complete and a list of deficiencies was given to the company. This information was still outstanding at the time of the CCRA's preliminary determination on September 11, 2003. As a result, normal values were estimated on the basis of an advance of 74.6 per cent over export price based on the highest estimated margin of dumping found for the cooperative exporter during the investigation.
[27] When the CCRA made its preliminary determination on September 11, 2003, Vitkovice Steel was informed that, in the event that the company completed its response, supplemental information would be required before verification was conducted. A listing of the required information was given to the company on that date. On September 22, 2003, the company submitted information to complete its response. The company was informed on September 24, 2003, that the CCRA would proceed with verification starting on October 14, 2003, on the condition that the supplemental information requested on September 11, 2003, was submitted to CCRA officers on October 13, 2003. While the company did provide some of the requested information on this date, it did not provide certain revised cost of production information. Despite this, verification meetings commenced on October 14, 2003, on the condition that the revised cost of production information be provided in a timely manner to allow for a full verification. During the course of the verification, it was determined that this information was vital to the verification.
[28] No other companies that were identified as possible exporters of the subject goods responded to the CCRA's RFI.
[29] Responses to the CCRA's RFI were also received from four importers of subject goods; Accucut Profile & Grinding Limited, of Concord, Ontario, Acier Wirth Steel, of Montreal, Québec, Global Steel Services (formerly Thyssen Canada Inc.), of Toronto, Ontario, and Salzgitter Trade, Inc., of Vancouver, British Colombia. Les Aciers Transbec (1997) Ltée, of Montreal, Québec, also provided information, which confirmed that the company was not an importer of subject goods. During the preliminary stage of the investigation, it was determined that 13 of the companies identified as possible importers at the time of initiation had not imported subject goods during the POI. In addition, an additional importer of the subject goods was identified during the preliminary stage of the investigation.
Results of the Investigation
[30] On October 2, 2003, and from October 7 to 10, 2003, on-site verifications were conducted at the premises of MEI and Ispat Sidex in order to verify and validate the information that the companies submitted concerning sales to Canada, domestic sales of like goods and the full cost of subject and like goods.
[31] One of the issues examined during the verifications was Ispat Sidex's use of compensation arrangements as a payment mechanism during the POI. The CCRA needed to assess how this system was used by Ispat Sidex and needed to determine the reliability of the sales and costing data submitted by the exporter for purposes of determining normal values.
[32] In this regard, before considering the use of domestic sales of like goods in the determination of normal values, the CCRA needed to consider whether sales settled by means of compensation arrangements were made in the ordinary course of trade and whether the terms of such sales reflected fair market value. A similar assessment had to be made with respect to purchases of goods and services that form part of the costs of production of the goods sold to Canada and in the exporter's domestic market, which were paid for by means of compensation arrangements. Furthermore, the CCRA needed to be satisfied that the payment of such transactions was fully verifiable.
[33] In Romania, such compensation mechanisms are subject to legislation and accompanying regulations, which were adopted to bring such accounting settlements within the law and subject to defined rules. Typically, Romanian companies that are using compensation arrangements as a means of payment send an electronic list of all outstanding invoices to be paid for by this mechanism to the Institute of Management and Informatics of the Ministry of Industry and Trade (Institute). The object is the settling of reciprocal payment obligations between two or more parties, through the setoff of the lowest payment obligation between those parties, through compensation orders. The compensation office of the Institute will identify compensation circuits based on the data submitted by several parties. When a compensation circuit has been identified, a compensation session is held, during which compensation records are drafted, stipulating the names of the parties and the amounts involved. This document is signed by the parties' representatives and by the compensation agent designated by the compensation office and is subject to the companies' seals. The description of the documents identifying the basis for the amounts compensated (i.e. invoice number) are then listed on the back of the compensation order. The compensation order issued by the compensation office represents the legal basis for the accounting entry setting-off the debts and payment obligations that were the subject of compensation. The compensation order must be attached to the accounting entry.
[34] Based on its analysis of the exporter's submission and on the results of the on-site verifications, the CCRA concluded that Ispat Sidex's use of compensation arrangements for the settlement of sales of the goods sold to Canada, sales of like goods in the domestic market and purchases of goods and services used in the production of the goods provided reliable sales and cost data for purposes of determining normal values under sections 15 and 19 of the SIMA. The CCRA concluded that the transactions involving the exporter that were settled by means of compensation arrangements were fully verifiable, that the terms of the sales and purchases were monetary-based and that they reflected fair market value. It must be noted that this conclusion regarding the acceptance of sales and purchases that were settled by such arrangements is unique to this investigation, to this exporter and to the circumstances surrounding the individual sales and purchases that were examined and verified.
[35] Normal Value - Based on an analysis of Ispat Sidex's domestic sales, it was determined that, for a number of products in its domestic market, the exporter had a sufficient number of profitable sales to determine normal values pursuant to section 15 of the SIMA. Normal values were based on the weighted average domestic selling price of the like goods during the 60-day periods corresponding to each sale made to Canada during the POI. Ispat Sidex requested an adjustment under the Special Import Measures Regulations (SIMR) to account for a difference in the conditions of sale between the goods sold to the importer in Canada and the like goods. Paragraph 5(d) of the SIMR applies when there is a difference in the conditions of sale between the goods sold to the importer in Canada and the like goods and this difference would be reflected in a difference between the price of the like goods and the price at which the goods that are identical in all respects, including the conditions of sale, to the goods sold to the importer in Canada would be sold in the country of export. For a number of sales of subject goods to Canada, it was determined that there was no difference in the terms of sale between these sales and the sales of like goods in the domestic market. For those sales where there was a difference in the conditions of sale, the CCRA determined that the difference in the conditions of sale would not result in a difference in price as specified in the SIMR. For these reasons, the requested adjustment was not granted by the CCRA.
[36] For those products where there were not a sufficient number of acceptable sales of like goods in the domestic market, normal values were determined in accordance with paragraph 19(b) of the SIMA, using the cost of production of the goods, a reasonable amount for administrative, selling, and all other costs, plus a reasonable amount for profits. An amount for profit was calculated in accordance with subparagraph 11(1)(b)(ii) of the SIMR, based on sales of goods in the domestic market that were of the same general category as the goods sold to the importer in Canada. The normal values of approximately 12 per cent of the subject goods exported to Canada by Ispat Sidex were determined using this method.
[37]Export Price - As the goods were sold to unrelated importers in Canada, export prices were determined pursuant to section 24 of the SIMA on the basis of the lesser of the exporter's selling price and the importer's purchase price, less all costs, charges and expenses resulting from the exportation of the goods to Canada. In all cases, the exporter's selling price was the lower of the two prices.
[38] Margin of Dumping - During the period of investigation, 100 per cent of Ispat Sidex's exports to Canada were found to have been dumped by a weighted average margin of dumping of 52.6 per cent. The margins of dumping ranged from 39.3 per cent to 74.6 per cent.
[39] Verification meetings were held from October 14 to 17, 2003, at the premises of Vitkovice Steel and Osinek a.s. (Osinek), the parent company of Vitkovice Steel, for the purpose of verifying and validating information submitted on sales to Canada, domestic sales of like goods and the full cost of subject and like goods.
[40] During the verification meetings, the CCRA was able to confirm that the exporter and producer of subject goods was in fact Osinek since Vitkovice Steel operates on a tolling basis for its parent company. Osinek is both the benefactor of the cost of producing subject and like goods and the beneficiary of all sales of subject and like goods.
[41] An attempt was made by the CCRA to verify cost of production information submitted by Vitkovice Steel and Osinek. However, the companies failed to comply with verification information requests in a timely manner, thus not allowing the CCRA to fully satisfy itself as to the accuracy and completeness of the actual full costs of production of subject and like goods. In fact, the companies submitted revised costing information on October 24 and 30, 2003, more than a week after the conclusion of verification meetings. In light of inconsistencies in the costing data presented after the on-site verification, this unverified information served to increase the CCRA's reservations as to the accuracy of the actual costs of production presented by the companies. The CCRA was thus not able to conduct a complete and satisfactory verification of information provided by Vitkovice Steel and Osinek.
[42] Normal Value - Since the information provided by Vitkovice Steel and Osinek was not found to be reliable for purposes of determining normal values for the goods exported to Canada, normal values were determined pursuant to ministerial specification under section 29 of the SIMA based on the highest margin of dumping determined for the cooperative exporter for the investigation. The normal values were therefore determined to be equal to the export price plus an amount equal to 74.6 per cent of that export price.
[43] Export Price - For the majority of the goods sold to the importer in Canada, export prices were determined pursuant to section 24 of the SIMA on the basis of the lesser of the exporter's selling price and the importer's purchase price, less all costs, charges and expenses resulting from the exportation of the goods to Canada. In all cases, the exporter's selling price was the lower of the two prices. For some other imported goods from the Czech Republic, the exporter's ex-factory selling price could not be determined because the goods imported into Canada could not be traced to specific sales to Canada reported by the exporter. Furthermore, for two shipments originating in the Czech Republic but exported from the United States, the export price could not be determined pursuant to section 24 of the SIMA because no information was received from exporters in the United States. In such cases where the export prices could not be determined pursuant to section 24 of the SIMA, the export prices were based on the declared selling price to the importer on customs entry documentation pursuant to ministerial specification under section 29 of the SIMA.
[44] Margin of Dumping - During the period of investigation, the CCRA determined that 100 per cent of the goods were dumped by margin of dumping of 74.6 per cent, expressed as a percentage of export price.
[45] Information was not received from any parties involved in the export of subject goods from Bulgaria. For subject goods originating in or exported from Bulgaria imported into Canada during the POI, the normal values were therefore determined pursuant to ministerial specification under section 29 of the the SIMA based on the highest margin of dumping determined for the cooperative exporter for the investigation. The export prices for Bulgarian shipments during the POI were based on the declared selling prices found on the customs entry documentation, pursuant to section 29 of the SIMA. The CCRA determined that 100 per cent of the goods were dumped by margin of dumping of 74.6 per cent, expressed as a percentage of export price.
[46] Although goods of United States origin are not subject to this investigation, some companies located in the United States exported subject goods to Canada that originated in a named country. Since no information was received from these parties, the normal values for the subject goods exported from the United States were determined pursuant to ministerial specification under section 29 of the SIMA based on the highest margin of dumping determined for the cooperative exporter for the investigation.
Information Received From Importers
[47] Information was received from several importers of subject goods. Where appropriate, this information was used in validating the volume of imports as well as in the determination of the export prices.
Summary of Results of the Investigation
[48] During the POI, 100 per cent of all subject goods imported into Canada were determined to have been dumped. The weighted average margin of dumping for all subject goods is 59.5 per cent when expressed as a percentage of export price. The volumes of dumped goods are 3.1 per cent for Bulgaria, 3.4 per cent for the Czech Republic and 14.2 per cent for Romania. The CCRA is unable to publish the specific figures regarding the volume of dumped imports from each country since the release of this information would result in the disclosure of confidential information for some parties.
[49] For purposes of the preliminary determination of dumping, the Commissioner has responsibility for determining whether the actual or 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 the 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.
[50] 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 two per cent of the export price of the goods. As shown in Appendix 1, the margins of dumping exceed the two per cent threshold.
Decision
[51] Based on the results of the investigation, the Commissioner is satisfied that the subject goods imported into Canada originating in or exported from Bulgaria, the Czech Republic and Romania have been dumped and that the margins of dumping are not insignificant.
[52] Accordingly, on December 9, 2003, the Commissioner made a final determination of dumping pursuant to paragraph 41(1)(a) of the SIMA.
Future Action
[53] The Tribunal's inquiry concerning the question of injury to the domestic industry is continuing. The Tribunal will issue its finding by January 9, 2004.
[54] The provisional period began on September 11, 2003, and will end on the date the Tribunal issues its finding. Subject goods imported during the provisional period will continue to be assessed provisional duty as determined at the time of the preliminary determination of dumping. For further details on the application of provisional duty, refer to the Statement of Reasons issued for the preliminary determination of dumping, on the CCRA Internet web site at http://www.cbsa-asfc.gc.ca/sima-lmsi/menu-eng.html.
[55] If the Tribunal finds that the dumped goods have not caused injury and do not threaten to cause injury, all proceedings relating to this investigation will be terminated. In this situation, all provisional duty or security posted by importers will be returned.
[56] If the Tribunal finds that the dumped goods have caused injury, the anti-dumping duty payable on subject goods released from customs possession during the provisional period will be finalized, 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.
Publication
[57] Notice of this final determination of dumping is being published in the Canada Gazette pursuant to paragraph 41(3)(a) of the SIMA.
Information
[58] This Statement of Reasons has been provided to persons directly interested in these proceedings. It is also posted on the Directorate's Internet website at the address below. For further information, please contact Mr. Denis Chénier or Mr. Michel Leclair as follows:
Mail:
Anti-dumping and Countervailing Directorate
191 Laurier Avenue West, 10th Floor
Ottawa, Ontario K1A 0L5
Canada
Telephone:
Denis Chénier: (613) 954-7394
Michel Leclair: (613) 954-7232
Telefax:
(613) 948-4844
Email:
Denis.Chenier@ccra-adrc.gc.ca
Michel.Leclair@ccra-adrc.gc.ca
Website:
www.ccra.gc.ca/sima
Suzanne Parent
Director General
Anti-dumping and Countervailing Directorate
APPENDIX 1
Margins of Dumping by Exporter/Country
(April 1, 2002 to March 31, 2003)
|
Country |
% of Dumped Goods |
Range of Margins of Dumping (% of Export Price) |
Weighted Average Margin of Dumping (% of Export Price) |
|
Bulgaria |
|||
|
All Exporters(1) |
100% |
74.6% |
74.6% |
|
Country Total |
100% |
74.6% |
74.6% |
|
Czech Republic |
|||
|
All Exporters(1) |
100% |
74.6% |
74.6% |
|
Country Total (2) |
100% |
74.6% |
74.6% |
|
Romania |
|||
|
Ispat Sidex SA Galati. |
100% |
39.3% - 74.6% |
52.6% |
|
Country Total |
100% |
52.6% |
|
|
All Subject Countries |
100% |
39.3% - 74.6% |
59.5% |
(1) Margin of dumping represents the highest margin of dumping found for the cooperative exporter in this investigation.
(2) Country Total figures include goods originating in the Czech Republic but exported from the United States.
