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TABLE OF CONTENTS

• Summary
• Background
• Interested Parties
  • Complainant
  • Importers
  • Exporters
• Product Information
  • Definition
  • Additional Product Information
  • Production Process
  • Classification Of Imports
• Like Goods
• The Canadian Industry
• Canadian Market
• Evidence Of Dumping
  • Normal Value
  • Export Price
  • Estimated Margins Of Dumping
• Margin Of Dumping And Volume Of Dumped Goods
• Evidence Of Injury
  • Price Undercutting, Erosion And Suppression
  • Lost Sales & Lost Market Share
  • Negative Financial Results
  • Reduced Production And Capacity Utilization
  • Impact On Capital Investments
  • Anti-Dumping Measures By Canada & Other Countries In Respect Of Goods Of The Same Description Or In Respect Of Similar Goods
• Threat Of Injury
  • Global Market Conditions
  • Influence Of China
  • Soft European Demand
  • Subject Country Market Conditions
  • Other Injury Indicators
• Causal Link - Dumping And Injury
• Conclusion
• Scope Of The Investigation
• Future Action
• Retroactive Duty On Massive Importations
• Undertakings
• Publication
• Information

Summary

[1] On July 15, 2013, the Canada Border Services Agency (CBSA) received a written complaint from Essar Steel Algoma Inc., of Sault Ste. Marie, Ontario (the complainant) alleging that imports of certain hot-rolled carbon steel plate and high-strength low-alloy steel plate originating in or exported from the Federative Republic of Brazil (Brazil), Chinese Taipei, the Kingdom of Denmark (Denmark), the Republic of Indonesia (Indonesia), the Italian Republic (Italy), Japan, and the Republic of Korea are being injuriously dumped. The complainant alleges that the dumping has caused injury and is threatening to cause injury to the Canadian industry producing like goods.

[2] On August 6, 2013, pursuant to paragraph 32(1)(a) of the Special Import Measures Act (SIMA), the CBSA informed the complainant that the complaint was properly documented. The CBSA also notified the governments of Brazil, Chinese Taipei, Denmark, Indonesia, Italy, Japan and the Republic of Korea that a properly documented complaint had been received.

[3] The complainant provided evidence to support the allegations that certain hot-rolled carbon steel plate and high-strength low-alloy steel plate from Brazil, Chinese Taipei, Denmark, Indonesia, Italy, Japan and the Republic of Korea has been dumped. The evidence also discloses a reasonable indication that the dumping has caused injury and is threatening to cause injury to the Canadian industry producing like goods.

[4] On September 5, 2013, pursuant to subsection 31(1) of SIMA, the President of the CBSA (President) initiated an investigation respecting the dumping of certain hot-rolled carbon steel plate and high-strength low-alloy steel plate from Brazil, Chinese Taipei, Denmark, Indonesia, Italy, Japan and the Republic of Korea.

Background

[5] This is the seventh in a series of complaints which have been filed by the Canadian industry in respect of certain steel plate since 1992. In all of the cases the products are generally similar goods. Each of these complaints has resulted in the imposition of either anti-dumping duty or both anti-dumping and countervailing duties against goods imported from various countries. The measures resulting from three of the six investigations are still in force. Following is a brief history of the six previous plate investigations.

Plate I

[6] On May 6, 1993, in Inquiry No. NQ-92-007, the Canadian International Trade Tribunal (Tribunal) found that dumped imports from Belgium, Brazil, the Czech Republic, Denmark, Germany, Romania, the United Kingdom and the Former Yugoslav Republic of Macedonia were injuring the production of plate in Canada. On May 5, 1998, in Expiry Review No. RR-97-006, the Tribunal concluded that there was no likelihood of resumed dumping from the named countries and, therefore, rescinded its finding. Given this conclusion, it was not necessary for the Tribunal to consider the second fundamental question in a review regarding likelihood of injury.

Plate II

[7] On May 17, 1994, in Inquiry No. NQ-93-004, the Tribunal found that dumped imports from Italy, the Republic of Korea, Spain and Ukraine were injuring the production of plate in Canada. On May 17, 1999, in Expiry Review No. RR-98-004, the Tribunal issued an order continuing its finding. On May 17, 2004, in Expiry Review No. RR-2003-001, the Tribunal concluded that the expiry of this order would not likely result in material injury to the domestic industry in the near to medium term and therefore rescinded its order against the named countries.

Plate III

[8] On October 27, 1997, in Inquiry No. NQ-97-001, the Tribunal found that dumped imports from Mexico, the People's Republic of China (China), the Republic of South Africa and the Russian Federation were threatening to cause material injury to the domestic industry. On January 10, 2003, in Expiry Review No. RR-2001-006, the Tribunal continued its finding against China, South Africa and the Russian Federation and rescinded its finding against Mexico. On January 9, 2008, in Expiry Review No. RR-2007-001, the Tribunal continued its order against China and rescinded its order against South Africa and the Russian Federation. On January 8, 2013, in Expiry Review No. RR-2012-001, the Tribunal continued its finding against China.

Plate IV

[9] On June 27, 2000, in Inquiry No. NQ-99-004, the Tribunal found that dumped imports

from Brazil, Finland, India, Indonesia, Thailand and Ukraine and subsidized imports from India, Indonesia and Thailand had caused material injury to the domestic industry. On June 27, 2005, in Expiry Review No. RR-2004-004, the Tribunal concluded that the expiry of the finding would not likely result in material injury to the domestic industry in the near to medium term and therefore rescinded its finding against the named countries.

Plate V

[10] On January 9, 2004, in Inquiry No. NQ-2003-002, the Tribunal found that dumped imports from the Republic of Bulgaria, the Czech Republic and Romania had caused material injury to the domestic industry. On January 8, 2009, in Expiry Review No. RR-2008-002, the Tribunal continued its finding against the named countries. On April 24, 2013, the Tribunal initiated Expiry Review No. RR-2013-002 of its order made on January 8, 2009 and the review is currently underway.

Plate VI

[11] On February 2, 2010, in Inquiry No. NQ-2009-003, the Tribunal found that dumped imports from Ukraine did not cause injury to the domestic market but threatened to cause injury to the domestic industry.

[12] In summary, at this time there are three plate findings/orders being enforced by the CBSA; Plate III against subject goods from China; Plate V against subject goods from the Republic of Bulgaria, Czech Republic and Romania; and Plate VI against subject goods from Ukraine.

Interested Parties

Complainant

[13] The complainant is a major producer of hot-rolled carbon steel plate and high-strength low-alloy steel plate in Canada. The complainant's goods are produced at a manufacturing facility located in Sault Ste. Marie, Ontario.

[14] The name and address of the complainant is:

Essar Steel Algoma Inc.
105 West Street
Sault Ste. Marie, Ontario P6A 7B4

[15] Essar Steel Algoma Inc., (Essar Algoma) produces plate on its 166" plate mill and its 106" wide strip mill. This includes carbon steel plate in widths of up to 152" (3,860 mm) and in thicknesses of up to 3.0" (76.2 mm) and other carbon and alloy steel plate and hot-rolled sheet. Essar Algoma also produces cold-rolled sheet at its facility.

[16] Algoma, the company name at the time, was incorporated on June 1, 1992 and on January 29, 2002 the company was reorganized under a Plan of Arrangement and Reorganization pursuant to the Companies' Creditors Arrangement Act. Algoma became a part of Essar Steel Holdings Limited as a wholly owned subsidiary of Algoma Holdings B.V. in June 2007. On May 8, 2008, the company changed its name to Essar Steel Algoma Inc.

[17] Another major producer of like goods is Evraz Inc. NA Canada (Evraz) of Regina Saskatchewan. Evraz produces hot-rolled plate, in addition to hot-rolled sheet and strip, oil country tubular goods, standard pipe and piling pipe. SSAB Central Inc., (SSAB) of Toronto, Ontario, is a service center that does not heat or roll plate in Canada. However, it operates plate-dedicated cut-to-length facilities that produces plate from coil and resells discrete plate that it purchases from other manufacturers. Evraz and SSAB have provided letters to the complainant indicating their respective support of the complaint.[1]

[18] In addition there are a few domestic steel service centres that have the capability to cut plate from coil. In the recent expiry review, RR-2010-001, the Canadian International Trade Tribunal (Tribunal) included plate cut from hot-rolled coil as part of Canadian production and the complainant believes that the volume of domestic production by several Canadian service centres that have this capability is minimal.[2]

Importers

[19] The CBSA has identified 46 potential importers of the subject goods from CBSA import documentation and from information submitted in the complaint.

Exporters

[20] The CBSA has identified 75 potential exporters of the subject goods from CBSA import documentation and from information submitted in the complaint.

Product Information

Definition

[21] For the purpose of this investigation, 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 thicknesses from 0.187 inches (+/- 4.75 mm) up to and including 3.0 inches (76.2 mm) (with all dimensions being plus or minus allowable tolerances contained in the applicable standards), but excluding plate for use in the manufacture of pipe and tube (also known as skelp); plate in coil form, plate having a rolled, raised figure at regular intervals on the surface (also known as floor plate), originating in or exported from the Federative Republic of Brazil, Chinese Taipei, the Kingdom of Denmark, the Republic of Indonesia, the Italian Republic, Japan, and the Republic of Korea.

Additional Product Information

[22] For greater certainty, the subject goods include steel plate which contains alloys greater than required by recognized industry standards provided that the steel does not meet recognized industry standards for an alloy-grade steel plate.

[23] Hot-rolled carbon steel plate is manufactured to meet certain Canadian Standards Association (CSA) and/or American Society for Testing & Materials (ASTM) specifications, or equivalent specifications. CSA specification G40.21 covers steel for general construction purposes. In the ASTM specifications, for instance, specification A36M/A36 comprises structural plate; specification A572M/A572 comprises high-strength low-alloy steel plate; and specification A516M/A516 comprises pressure vessel quality plate. ASTM standards, such as A6/A6M and A20/A20M, recognize permissible variations for dimensions.

Production Process

[24] 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 (EAF's). The basic raw material used by mini-mills is scrap metal rather than virgin.

[25] 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, leveled, identified and inspected for conformance to thickness tolerances and surface requirements. The plate is then either formed directly into rectangular shapes or coiled and later unwound and cut into lengths. The former is known as "discrete plate" and the latter as "plate from coil" or "cut to length plate".

[26] At Essar Algoma, slabs are charged into re-heating furnaces and are progressively brought forward and heated to approximately 2370 °F (1300 °C) before being discharged then descaled by high pressure water sprays. The first reduction of steel thickness occurs in the breakdown mill where the slab is reduced in gauge depending on the final plate thickness required.

[27] The heavier plates (i.e., 3/8" and thicker) go directly to Essar Algoma's 166" Plate Mill where they are reduced to their final thickness, are levelled and then sent to the plate finishing area where the plate is sized, side trimmed, cut to length (either sheared or flame cut), tested and shipped.

[28] For the lighter plate, Essar Algoma's 166" Plate Mill acts a breakdown mill and the extended slab proceeds to the 106" Wide Strip Mill where it is reduced to its final thickness through this 6-stand operation and then coiled. The coils are sent to the #1 finishing line, where they are uncoiled, levelled, cut-to-length, tested, bundled and shipped.

Classification Of Imports

[29] Imports into Canada of the subject goods described above are normally, but not exclusively, classified under the following Harmonized System (HS) classification numbers for importations that occurred prior to January 1, 2012:

• 7208.51.10.00
• 7208.51.91.10
• 7208.51.91.91
• 7208.51.91.92
• 7208.51.91.93
• 7208.51.91.94
• 7208.51.91.95

• 7208.51.99.10
• 7208.51.99.91
• 7208.51.99.92
• 7208.51.99.93
• 7208.51.99.94
• 7208.51.99.95
• 7208.52.11.00

• 7208.52.19.00
• 7208.52.90.10
• 7208.52.90.91
• 7208.52.90.92
• 7208.52.90.93
• 7208.52.90.94
• 7208.52.90.95

[30] As a result of the amendments made to the 2012 Customs Tariff, imports into Canada of the subject goods on or after January 1, 2012 are normally, but not exclusively, classified under the following HS Classification numbers:

• 7208.51.00.10
• 7208.51.00.91
• 7208.51.00.92
• 7208.51.00.93

• 7208.51.00.94
• 7208.51.00.95
• 7208.52.00.10
• 7208.52.00.91

• 7208.52.00.92
• 7208.52.00.93
• 7208.52.00.94
• 7208.52.00.95

[31] The listing of HS classification numbers is for convenience of reference only. Refer to the product definition for the authoritative details regarding the subject goods.

Like Goods

[32] Subsection 2(1) of SIMA defines "like goods," in relation to any other goods, as goods that are identical in all respects to the other goods, or in the absence of identical goods, goods for which the uses and other characteristics closely resemble those of the other goods.

[33] Certain steel plate produced by the domestic industry has the same physical characteristics and end uses as the subject goods imported from the named countries. The goods produced in Canada and the named countries are fully interchangeable when manufactured to industry standards and specifications. Subject goods from the named countries compete directly with like goods produced by the complainant. Therefore, the CBSA has concluded that certain steel plate produced by the Canadian industry constitute like goods to the subject goods.

[34] Like goods and the subject goods are made from the same primary input materials and in similar manufacturing processes. When chemical and dimensional specifications of either subject or like goods meet industry standards, the only differentiating factor is price. When sold, certain steel plate is sold in the same channels of distribution, whether subject or like goods, to the same types of customers and in many cases, to the same customers.

[35] The Tribunal has previously recognized plate as a single class of goods. In considering the issue of like goods, the Tribunal typically looks at a number of factors, including the physical characteristics of the goods, their market characteristics and whether the domestic goods fulfill the same customer needs as the subject goods. In the most recent completed expiry review involving plate, the Tribunal quoted from its statement of reasons in the original inquiry[3] that :

"In this regard, the Tribunal was presented with no evidence or argument that warrants a departure from its following finding in the original inquiry, which was maintained in Expiry Review Nos. RR-2001-006 and RR-2007-011:

"[...]carbon steel plate is produced to meet various specifications. The evidence in this inquiry indicates that, for each specification, carbon steel plate produced domestically competes with, has the same end uses as and can be substituted for the subject goods, as defined by the Deputy Minister. Therefore, the Tribunal is of the view that all domestically produced carbon steel plate...is "like goods" to the subject goods."

The Tribunal therefore reaffirms that plate produced by the domestic producers, which is defined in the same manner as the subject goods, are "like goods" in relation to the subject goods. The Tribunal is also satisfied that hot-rolled carbon steel plate comprises a single class of goods[4]"

[36] There has been no change of circumstances with respect to the criteria identified by the Tribunal. Therefore, the CBSA is of the opinion that plate produced by the domestic industry forms a single class of like goods to the subject goods.

The Canadian Industry

[37] As previously stated, the complainant accounts for a substantial percentage of known Canadian domestic production of like goods.

[38] Subsection 31(2) of SIMA requires that the following conditions for standing be met in order to initiate an investigation:

• the complaint is supported by domestic producers whose production represents more than fifty per cent of the total production of like goods by those domestic producers who express either support for or opposition to the complaint; and
• the production of the domestic producers who support the complaint represents twenty-five per cent or more of the total production of like goods by the domestic industry.

[39] Based on an analysis of information provided in the complaint, the complainant and the other Canadian producer of like goods, Evraz and the plate dedicated cut-to-length processor SSAB together, account for almost all of known Canadian production of like goods. The CBSA is satisfied that the standing requirements of subsection 31(2) of SIMA have been met by the complainant. The remainder of the market is comprised of steel service centres in Canada that have the facility to cut plate from coil. On January 8, 2013, the Tribunal in Expiry Review No. RR-2012-001 regarding similar goods from China stated that these service centres account for a small volume of total domestic production.[5]

Canadian Market

[40] According to the complainant, the subject goods and the like goods are used in a number of applications, the most common of which are the production of rail cars, oil and gas storage tanks, heavy machinery, agricultural equipment, bridges, industrial buildings, high rise office towers, automobile and truck parts, ships and barges, and pressure vessels.

[41] Plate is a commodity product and the subject goods compete among themselves and with the like goods produced by the Canadian industry. Subject goods from all of the named countries have all of the same technical characteristics and meet the same technical specification. In previous cases, the Tribunal found that carbon steel plate, once in Canada, was fungible regardless of source and that it was appropriate to consider the goods cumulatively.[6] The complainant submitted that in assessing injury it is appropriate to cumulatively assess the effects of imports of subject goods from all of the named countries.

[42] The complainant estimated the Canadian Plate Market based on its own Canadian sales, the estimated sales of other Canadian producers and service centres and on publicly available import data obtained from Statistics Canada for the relevant HS codes listed earlier in this document.

[43] The complainant noted that the total domestic mills production includes some portion of non-subject alloy plate and the total domestic sales of cut-to-length plate by service centres is likely less than estimated.

[44] The CBSA conducted its own analysis of imports of subject goods based on actual import data. The CBSA's import data demonstrated similar trends and volumes as the information provided by the complainant.

[45] Detailed information regarding domestic production and the volume of imports of subject goods cannot be divulged for confidentiality reasons. The CBSA has prepared the following table to show the estimated import share for subject goods in Canada.

[46] During the next phase of the investigation, import volumes will continue to be refined using information obtained from exporters and importers of the subject goods.

Evidence Of Dumping

[47] The complainant alleges that certain hot-rolled carbon steel plate and high-strength low-alloy steel plate from Brazil, Chinese Taipei, Denmark, Indonesia, Italy, Japan and the Republic of Korea has been injuriously dumped into Canada. Dumping occurs when the normal value of the goods exceeds the export price to importers in Canada.

[48] Normal values are generally based on the domestic selling price of like goods in the country of export where competitive market conditions exist or on the full cost of the goods plus a reasonable amount for profits.

[49] The export price of goods sold to importers in Canada is generally 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.

[50] Estimates of normal value and export price by both the complainant and the CBSA are discussed below.

Normal Value

[51] The complainant was able to obtain home market pricing for most of the named countries published by MEPS International[7] (MEPS) or CRU[8] . The complainant estimated normal values as per the methodology presented in section 15 of SIMA for six of the seven named countries in the complaint. In several cases, the subject plate imported was known to be a higher grade or premium plate product and for a proper comparison, the complainant added an extra amount, based on its own pricing, to the published MEPS home market prices since MEPS prices only represent a base grade plate. To reflect standard lead times from order date to the delivery, the order for the import was assumed to have been made on an offer three months prior to delivery and referred to here as lagged by three months. In addition, in the case of Japan, there was domestic pricing published by both MEPS and CRU, and the complainant demonstrated that the CRU reported domestic selling prices for plate were more representative than the MEPS reported prices.

[52] Both MEPS and CRU are reputable independent firms which publish statistical data, market trends, activity forecasts and market research on world commodities. In addition, information from these sources is provided in sufficient detail to allow a proper product comparison with plate imported into Canada.

[53] In respect of Indonesia, the complainant had no information available regarding home market pricing and normal values were estimated as per the methodology presented in paragraph 19(b) of SIMA based on the aggregate of the cost of production of the goods, a reasonable amount for administrative and selling and all other costs and a reasonable amount for profits. The complainant cited that the materials and non-labour overhead and GS&A costs to produce plate are comparable in different jurisdictions and therefore used its own costs with a downward adjustment to account for the cost of labour in Indonesia. The amount for profit of 3.1% was taken from the published results of Krakatau Steel, an Indonesian plate producer.

[54] Based on the foregoing, the CBSA found the complainant's normal value estimates to be reasonable and representative with the exception of the normal value for Indonesia. Krakatau Steel registered a net loss in 2012 and in order to estimate an amount for profits for the cost-plus methodology, the complainant averaged the 2012 loss with a net profit in 2011 to arrive at the annualized 2012 estimated normal value. The CBSA considers that the complainant's estimate was not reflective of 2012 and the normal value possibly overstated. Furthermore, the complainant's constructed cost-plus normal value was annualized and did not reflect the dynamics of the Period of Investigation (POI)[9] where the available reported home market plate selling prices for six of the seven named countries generally decreased over the period.

[55] The CBSA estimated normal values based on the complainant's methodology as explained above for six of the seven countries. The CBSA estimated normal values according to section 15 of SIMA based on domestic selling prices for Brazil, Chinese Taipei, Denmark, Italy, and the Republic of Korea based on the respective home market selling prices as reported by MEPS and lagged by three months to match up with the estimated time of sale for the goods shipped to Canada. In respect of Japan, the section 15 normal values were based on the home market selling prices as reported by CRU, also lagged by three months to reflect the estimated time of sale of the goods shipped to Canada.

[56] In respect of Indonesia, neither MEPS nor CRU reports home market selling prices. As stated earlier, the normal values estimated by the complainant may have been overstated as Krakatau Steel was in a loss position in 2012 and this may have also impacted their cost of manufacturing. As such the CBSA estimated normal values using a surrogate country's selling prices in place of using the complainant's cost-plus methodology. The CBSA used MEPS reported prices for Chinese Taipei as a suitable proxy for Indonesian home market plate prices, also lagged by three months to reflect the estimated time of sale of the goods shipped to Canada, to arrive at estimated normal values for Indonesia.

[57] The CBSA is satisfied that pricing data from MEPS and CRU is an appropriate basis to be used in its analysis. The CBSA did not make any further adjustments to the estimated normal values for differences in plate quality or premium plate as was done by the complainant for several of the normal value estimates. As a result, the CBSA considers its estimated normal values to be more conservative than those provided by the complainant.

Export Price

[58] The export price of goods sold to an importer in Canada is generally determined in accordance with section 24 of SIMA as being an amount equal to the lesser of the exporter's sale price for the goods and the price at which the importer has purchased or agreed to purchase the goods adjusted by deducting all costs, charges, expenses, and duties and taxes resulting from the exportation of the goods.

[59] For each of the named countries where the complainant had specific information on sales or imports to Canada of subject goods importations based on actual price quotations and/or selling prices of subject goods for delivery to Canada during the POI, the complainant estimated the export price for the sale. The complainant used the quoted prices as the basis for estimating export price. Starting with the quoted price the complainant deducted inland freight in the country of origin, ocean freight, and port charges in Canada.

[60] In addition, the complainant estimated export price, for comparison purposes, based on the declared value for duty (VFD) of subject goods imported into Canada during the POI as reported by Statistics Canada.[10] The complainant noted that the VFD amount does not reflect any deductions for inland freight in the country of origin and the resulting margin of dumping is understated and conservative as a result.

[61] In its own estimation of export price, the CBSA relied on actual import data from commercial and customs documentation. No deductions to the VFD were made and the CBSA therefore considers its estimates to be more comprehensive and conservative than those provided by the complainant.

Estimated Margins Of Dumping

[62] The CBSA compared the estimated normal values with the estimated export prices for the subject imports. The estimated margins of dumping were then calculated by deducting the estimated total export price from the estimated total normal value and expressing the result as a percentage of the estimated total export price of the subject goods by country.

[63] Based on this analysis, it is estimated that the subject goods from Brazil, Chinese Taipei, Denmark, Indonesia, Italy, Japan and the Republic of Korea were dumped. The estimated margins of dumping for each country are shown in the table below.

Margin Of Dumping And Volume Of Dumped Goods

[64] Under section 35 of SIMA, if, at any time before the President makes a preliminary determination the President is satisfied that the margin of dumping of the goods of a country is insignificant or the actual and potential volume of dumped goods of a country is negligible, the President must terminate the investigation with respect to that country.

[65] Pursuant to subsection 2(1) of SIMA, a margin of dumping of less than 2% of the export price is defined as insignificant and a volume of dumped goods is considered negligible if it accounts for less than 3% of the total volume of goods that are released into Canada from all countries that are of the same description as the dumped goods, except that where the total volume of dumped goods of three or more countries, each of whose exports of dumped goods into Canada is less than 3% of the total volume of goods, is more than 7% of the total volume of goods, the volume of dumped goods of any of those countries is not negligible.

[66] The results provided in Table 3 below indicate that the volumes for Brazil and the Republic of Korea are greater than 3% and are not negligible. The volumes of imports for Chinese Taipei, Denmark, Indonesia, Italy and Japan are less than 3% each. However, the total volume of imports from Chinese Taipei, Denmark, Indonesia, Italy and Japan is 7.01%. Based on the exception presented above, the volume of imports for each of the countries, Chinese Taipei, Denmark, Indonesia, Italy and Japan, is not negligible.

[67] On the basis of the estimated margins of dumping and the estimated volumes of dumped imports for the period of January 1, 2012 to March 31, 2013, summarized in the following table, the estimated margins of dumping and the estimated volumes of dumped goods are greater than the thresholds outlined above.

Evidence Of Injury

[68] The complainant alleges that the subject goods have been dumped and that such dumping has caused or is threatening to cause material injury to the plate industry in Canada.

[69] SIMA refers to material injury caused to the domestic producers of like goods in Canada. The CBSA considers that the plate produced by the complainant are like goods to those imported from Brazil, Chinese Taipei, Denmark, Indonesia, Italy, Japan and the Republic of Korea.

[70] In support of its allegations, the complainant provided evidence of: price undercutting, erosion and suppression; lost sales and market share; negative financial results; reduced production and capacity utilization; impact on capital investments and employment uncertainty.