CPF2 2017 IN
Certain Copper Pipe Fittings
Statement of Reasons

[7] The complainant, Cello Products Inc. (Cello), is a privately owned Canadian company that was founded in 1946.

[8] The complainant accounts for all of the production of like goods in Canada.

[9] The contact information of the complainant is as follows:

Cello Products Inc.
210 Avenue Road
Cambridge, Ontario N1R 8H5

[10] The CBSA identified one potential exporter located in Vietnam and five potential exporters/vendors, located outside of Vietnam, of the subject goods from CBSA import documentation and from information submitted in the complaint. The potential exporter located in Vietnam was asked to respond to the CBSA’s Exporter Dumping Request for Information (RFI) and to the CBSA’s Exporter Subsidy RFI. All other potential exporters located outside Vietnam were requested to respond to only the Exporter Dumping RFI.

[11] The CBSA identified 18 potential importers of the subject goods from CBSA import documentation and from information submitted in the complaint. All of the potential importers were asked to respond to the CBSA’s Importer RFI.

[12] Upon initiation of the investigations, the GOV was sent the CBSA’s Government Subsidy RFI requesting information concerning the alleged subsidy programs available to producers/exporters of subject goods located in Vietnam.

[13] For the purposes of these investigations, “Government of Vietnam (GOV)” refers to all levels of government, i.e., federal, central, provincial/state, regional, municipal, city, township, village, local, legislative, administrative or judicial, singular, collective, elected or appointed. It also includes any person, agency, enterprise, or institution acting for, on behalf of, or under the authority of, or under the authority of any law passed by, the government of that country or that provincial, state or municipal or other local or regional government.

[14] For the purposes of these investigations, subject goods are defined as:

Pressure pipe fittings and drainage, waste and vent pipe fittings, made of cast copper alloy, wrought (or “wrot”) copper alloy or wrought copper for use in heating, plumbing, air conditioning and refrigeration applications originating in or exported from the Socialist Republic of Vietnam, restricted to the products enumerated in the attached Appendix 1.

[15] CPF are available in a large number of sizes and configurations. Common examples of CPF include: Tees, Elbows, Bushings, Fitting Reducer, and Adapters.

[16] CPF sold in Canada are manufactured to a variety of standards including:

• ASME/ANSI Std. B16.22 – 2013 (Wrought Copper and Copper Alloy Solder Joint Pressure Fittings);
• ASME/ANSI Std. B16.18 – 2012 (Cast Copper Alloy Solder Joint Pressure Fittings);
• ASME/ANSI Std. B16.29 – 2012 (Wrought Copper and Wrought Copper Alloy Solder Joint Drainage Fittings – DWV)
• ASME/ANSI Std. B16.23 – 2016 (Cast Copper Alloy Solder Joint Drainage Fittings);
• ASME/ANSI Std. B16.24 – 2016 (Cast Copper Alloy Pipe Flanges, Flanged Fittings, and Valves: Classes 150, 300, 600, 900, 1500, and 2500);
• ASME/ANSI Std. B16.50 – 2013 (Wrought Copper and Copper Alloy Braze – Joint Pressure Fittings);
• MSS SP-104 – 2012 (Wrought Copper LW Solder Joint Pressure Fittings);
• MSS SP-106 – 2012 (Cast Copper Alloy Flanges and Flanged Fittings Class 125, 150, 300).

[17] CPF may be either cast brass, produced from copper alloy ingots and recycled cast brass scrap, or wrought copper, produced from extruded copper tube or hollow shapes. There is a variety of tapping, threading and reaming equipment that can be used to manufacture either cast or wrought adapters, elbows and tees. Versatile equipment like computer numerical control (CNC) lathes are used to machine both cast and wrought fittings. Both product lines end up being inspected and packaged on the same equipment.

Cast Fittings

[18] Cast fittings are commonly produced using the green-sand casting process. Each fitting has a wooden, plastic or aluminum pattern, which is close to the same size and shape as the finished casting.

[19] A sand core for each fitting is made, using an aluminum or steel core box. Sand cores are made from resin-coated sand that is hardened to shape by heating in gas-fired core machines. There are other methods of making sand cores, including sand mixed with air-cured materials, which form solid sand cores without heat. The sand core forms the inside shape and surface of the fitting when the liquid brass is poured into the mould.

[20] A mould is made by filling a form flask with conditioned sand, binder and water to give it strength, and by pressing the pattern into it. This leaves a hollow impression that forms the outside of the casting. The sand core is set into this hollow impression once the pattern is removed and the mould is closed. Molten brass at the proper temperature is then poured into the mould through a hollow sprue that leads to runners and gates and finally into the space between the outside surface of the core and the inside surface of the conditioned sand mould.

[21] The metal is allowed to cool and solidify, forming the raw casting. The resultant raw casting is removed from the mould by vibration and is cleaned and conditioned in preparation for machining. The cutaway sprue, runners and gates are then returned to the furnace for re melting.

[22] Castings are machined on special-purpose reaming machines, turret lathes or CNC lathes. All cast fittings have at least one end reamed to allow a copper tube to be joined to it using one of the joining methods described above. The other end or ends (tees) are either reamed, tapped (internally threaded) or has a male thread cut onto it.

Wrought Fittings

[23] Wrought tees are produced from lengths of heat-treated (fully annealed or softened) wrought copper tubing that is cut into short slug lengths. After the tubing is cut, the resulting tee slugs are compressed in a hydraulic press, forming the tee branch. Another machine then decaps the branches and sizes the three ends to make a finished product that is ready for cleaning and packaging.

[24] Straight couplings (e.g. ¾” x ¾”) are in a finished state after they have been cut from the copper tubing. Reducing couplings and bushings are produced from straight-cut slugs. A specialty machine expands one end of the straight-cut slug to produce a finished fitting. Alternatively, one end is either hit down or spun down to a smaller size to form a reducing coupling or bushing.

[25] Elbows are produced from lengths of heat-treated copper tubing, using special bending equipment which bends the elbows to the proper degree (commonly 45º or 90º) and a saw cuts the elbows. Another machine then swedges (expands) the ends to create uniform cup dimensions. The ends of the elbows are then "faced" to provide a square soldering cup.

[26] Female and male wrought copper adapters can be made from machining hollow octagons or hexagons on CNC lathes or by hitting heavy wall tubing or solid copper rods on hydraulic presses.

[27] CPF are used to connect copper pipes, tubes or other CPF to one another. The methods of joining CPF include soldering, silver brazing and epoxy or similar gluing techniques. The connection is made by fitting two pieces together and heating the ends of the tubing and fittings, filling the gap between the two with melted solder or brazing material that solidifies while cooling, resulting in a strong leak-proof intermetallic connection. The threaded fittings can also be used to connect copper tubing to other metal systems.

[28] CPF that are commonly referred to as “pressure pipe fittings” may be used to convey liquids (e.g. potable water), gases and air under pressure in residential, industrial, commercial and institutional buildings.

[29] CPF that are commonly referred to as “drainage, waste and vent fittings (DWV)” are used primarily to convey waste from buildings to sewers and for venting purposes under low-pressure conditions.

[30] In addition, CPF are also used in a variety of air conditioning and refrigeration (ACR) applications. CPF used in air conditioning applications are typically identified by reference to their outside diameters, whereas the same CPF used in non ACR applications such as plumbing and heating are typically identified by reference to their inside or “nominal” diameters. Apart from the reference to diameter, a particular CPF for an ACR application is the same as a CPF for a non-air conditioning application. It is common practice to label CPF by reference to both their inside (nominal) and outside diameters.

[31] The subject goods are normally imported under the following Harmonized System (HS) codes:

1. 7412.10.00.11
2. 7412.10.00.19
3. 7412.10.00.90
4. 7412.20.00.11
5. 7412.20.00.12
6. 7412.20.00.19
7. 7412.20.00.90

[32] The listing of HS classification numbers is for convenience of reference only. The HS classification numbers include non subject goods. Also, subject goods may fall under HS classification numbers that are not listed. Refer to the product definition for authoritative details regarding the subject goods.

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

1. the complaint is supported by domestic producers whose production represents more than 50% of the total production of like goods by those domestic producers who express either support for or opposition to the complaint; and
2. the production of the domestic producers who support the complaint represents 25% or more of the total production of like goods by the domestic industry.

[38] Since the complainant is the only known producer of certain CPF in Canada, the CBSA is satisfied that the standing requirements pursuant to subsection 31(2) of SIMA have been met.

Complainant’s Estimates

[46] The complainant was unable to obtain any information regarding domestic selling prices of CPF in Vietnam. Accordingly, the complainant estimated normal values based on paragraph 19(b) of SIMA. Paragraph 19(b) of SIMA uses a constructed cost method of arriving at normal values based on the aggregate of (i) the cost of production of the goods, (ii) a reasonable amount for administrative, selling and all other costs, and (iii) a reasonable amount for profits.

[47] The complainant estimated normal values for 21 benchmark products. The complainant indicated that the benchmarks were selected to capture a cross-section of high volume CPF from the various fitting families and they represent a significant percentage of the complainant’s sales by volume and value, respectively.

[48] The complainant estimated the cost of materials based on their own cost of materials. The complainant noted that the subject goods currently imported from Vietnam are primarily wrought CPF. Copper tube is the raw material input in the production of wrought CPF. The complainant submitted that their own copper tube costs are a reasonable indicator of the raw material costs of Vietnamese producers, as their costs are based on the worldwide price of copper tube, which moves in line with the price of copper. As a traded commodity, the complainant submits that copper prices in different markets track each other closely.^{Footnote 4}

[49] For labour costs, the complainant made adjustments to reflect differences between the complainant’s labour costs and the labour costs in Vietnam. In estimating direct labour costs of Vietnamese producers, the complainant used its own labour costs, adjusted by multiplying the complainant’s per unit labour costs by the ratio of manufacturing wages in Vietnam to manufacturing wages in Canada, as provided by Trading Economics.^{Footnote 5} The latest data for both countries provided by Trading Economics is March 2017.

[50] The complainant was unable to find information on factory overhead costs in Vietnam, and therefore used their own overhead costs when estimating the cost of production. Labour related components of overhead were adjusted to reflect wage differences in Vietnam using the same methodology as was used in estimating direct labour costs.

[51] The complainant could not find public information available to support an estimate for GS&A costs in Vietnam. Consequently, the complainant used the five-year average GS&A ratio of Mueller Industries and Paranapanema, two large public companies that produce CPF located in the United States and Brazil, respectively.^{Footnote 6} This represents the best available information available to the complainant.

[52] No amounts for other costs were added.

[53] The complainant could not find public information available to support an estimate for profits in Vietnam. Consequently, the complainant used the five year average profit ratio of Mueller Industries and Paranapanema. The complainant validated its estimates by comparing its estimated profits with the ratios in the 2016 financial statement for Zhejiang Hailiang Co. Ltd. (Zhejiang Hailiang), the parent company of Hailiang Vietnam Copper Mfg Co. Ltd., (Hailiang Vietnam), a major exporter of CPF to Canada. This represents the best information available to the complainant.

CBSA’s Estimates:

[54] For the purposes of initiation, the CBSA estimated normal values on a monthly basis, for the period of September 1, 2016 to August 31, 2017, for Vietnam, in the following manner.

[55] In light of the lack of data on domestic pricing in Vietnam, the CBSA estimated the normal values for Vietnam on the basis of the aggregate of the estimated costs of production of the goods, a reasonable amount for administrative, selling and all other costs, and a reasonable amount for profits, as per the methodology of paragraph 19(b) of SIMA. Although the CBSA found the complainant’s methodology to be reasonable the CBSA made adjustments to the amount of profit estimated by the complainant. The CBSA used the five year average profit ratio of Mueller Industries and Paranapanema but removed years with losses in estimating a reasonable amount of profit.

[56] The CBSA conducted research on CPF producers and found that, of the top ten exporters of CPF to Canada (by volume) aside from Hailiang Zhejiang, Mueller and Paranapanema were the only two producers that had publically available financial information. The Hailiang Group, including Hailiang Zhejiang and Hailiang Vietnam, are similar to Mueller and Paranapanema in that they are vertically integrated, and multi-national producers of CPF.

[57] 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.

Complainant’s Estimates

[58] The export prices estimated by the complainant are based on an export price list issued by Hailiang Vietnam, which the complainant believes is the main exporter of subject goods to Canada. The complainant obtained the price list because it purchased products from Hailiang Vietnam.^{Footnote 7}

[59] In order to estimate ex-factory prices, the complainant made several deductions to the published price lists. The complainant estimated a nominal percentage as a deduction to export price to account for inland freight. Also, the complainant estimated a percentage discount based on its previous experience with the exporter. Finally, the complainant made adjustments for selling commissions provided to export agents involved in the sales transaction.

CBSA’s Estimates:

[60] The CBSA estimated export prices on a monthly basis based on the value for duty as declared on the customs entry documentation and reports generated through the Facility for Information Retrieval Management (FIRM) for each individual shipment imported from September 1, 2016 to August 31, 2017. The CBSA reviewed customs entry documentation for certain CPF entering Canada and adjusted the FIRM data to correct any errors respecting the quantity and value for duty.

[61] The CBSA estimated the margin of dumping by comparing the weighted average estimated normal values with the weighted average estimated export prices for Vietnam. Based on this analysis, it is estimated that certain CPF imported into Canada from Vietnam was dumped. The estimated margin of dumping is reported the table below.

Complainant’s Estimates

[80] The complainant was unable to estimate the amounts of subsidy on a program basis for the subject goods imported from Vietnam. However, the complainant estimated the amounts of subsidy by calculating the difference between the estimated costs of production for the subject goods and their corresponding export prices. The complainant demonstrated that the export price of the subject goods were below their cost of production, indicating a significant amount of subsidy.

CBSA’s Estimates:

[81] The CBSA estimated the amount of subsidy conferred on the producers of the subject goods from Vietnam by comparing the estimated full costs of the subject goods, which includes cost of material, cost of labour, cost of overhead and a reasonable amount of GS&A, with their weighted average export prices, as estimated above in the evidence of dumping section.

[82] It is the CBSA’s understanding that subsidies have the effect of lowering the full cost of the goods, including the cost of production and GS&A, which allows exporters to pass-through the subsidy benefits in reducing the selling price of those goods to Canada. Therefore, the CBSA is satisfied that the exporter’s ability to sell subject goods to Canada at prices substantially below their estimated full costs supports the complainant’s allegations that subsidies are being conferred on the imported goods.

[83] The CBSA’s analysis of the information indicates that subject goods imported into Canada during the period of January 1, 2016 to August 31, 2017, were subsidized. The estimated amount of subsidy, as a percentage of the export price, found for Vietnam is summarized in the table below.

[87] The complainant alleged that there has been a significant increase in the absolute volume of imports of subject goods from Vietnam. The complainant also stated that imports of subject goods from Vietnam relative to total imports from all countries increased from 28% in 2014 to 40% in 2016. Imports from Vietnam relative to the total market increased from 28% in 2014 to 39% in 2016, while the domestic industry’s share of the market declined significantly. The complainant stated that imports decreased during the first six months of 2017, but this may be due to the timing of imports. The complainant alleged that this increase in the volume of imports and the dumping and subsidizing of these subject goods has been the direct cause of the complainant’s decrease in the market share.^{Footnote 12}

[88] It is important to note that the import share estimated by the complainant is based on information reported by Statistics Canada for all goods under the relevant HS Codes in which CPF including non-subject goods are normally imported. As previously mentioned, the CBSA estimates reported in Table 1 and 2 of this Statement of Reasons are based on analysis of import data and customs documentation. Although CBSA’s estimates of import share reported in Tables 1 and 2 do not support the complainant’s allegations of increasing share of Vietnam, the information in Table 1 and 2 indicate that imports of subject goods from Vietnam have maintained a significantly large share of imports as well as of the total apparent market between 2014 and 2017.

[89] The complainant stated that pricing pressure from dumped and subsidized imports have caused direct and immediate impact on their price performance, and that dumped and subsidized imports of the subject goods have permitted Vietnamese exporters to severely undercut their prices in the Canadian market^{Footnote 13}.

[90] The complainant submitted evidence showing that the average selling prices from Vietnam, from 2014 to the first six months of 2017, are substantially lower than those of the complainant.^{Footnote 14}

[91] Based on the information provided in the complaint, the CBSA finds the claim of the price undercutting to be well supported and sufficiently linked to the allegedly dumped and subsidized goods.

The complainant stated that coincident with the increase in the volume of Vietnamese imports and the continuous declining landed import price of Vietnamese imports, the complainant has had to lower their selling prices in order to maintain sales.^{Footnote 15}

[93] As reviewed by the CBSA, the complaint contains documented instances where the complainant was required to provide discounts and lower prices in order to compete with imports of subject goods, or maintain or recover sales lost to the allegedly dumped and subsidized imported goods from Vietnam.^{Footnote 16}

[94] Based on the above, and the CBSA’s analysis of the information contained in the complaint, the CBSA finds the claim of price depression to be well supported and sufficiently linked to the allegedly dumped and subsidized goods.

[95] The complainant stated that the presence of dumped and subsidized imports has prevented the complainant from adjusting their selling prices in line with the increase in costs. The complainant stated that between 2014 and 2015, their selling prices declined while the costs of goods sold increased, resulting in negative earnings and overall poor financial performance. In the subsequent years, although selling prices increased by small margins, the costs of goods increased at much higher margins continuing the trend of overall poor financial performance.^{Footnote 17}

[96] Based on the information provided in the complaint, the CBSA finds the claim of the price suppression to be well supported and sufficiently linked to the allegedly dumped and subsidized goods.

[97] The complainant alleged that their production of like goods has declined in absolute and relative terms, and is coincident with a significant increase in the volume of allegedly dumped and subsidized imports of subject goods. The complainant provided production information which supports their claim.

[98] Based on the information provided in the complaint, the CBSA finds the claim of declining production volumes to be well supported and sufficiently linked to the allegedly dumped and subsidized goods.

Lost Sales and Market Share

[99] The complainant alleged that the increasing presence of low-priced imports from Vietnam resulted in a significant decline in sales from domestic production. The complainant provided examples and supporting documentation of specific instances of sales lost to subject imports from Vietnam.^{Footnote 18}

[100] The complainant alleged that dumped and subsidized imports of the subject goods have captured market share at the expense of the Canadian industry by offering CPF at lower prices. The complainant stated that since 2014, their market share has been declining and was at an all-time low in 2016. During this time, the market share held by Vietnamese imports increased.^{Footnote 19}

[101] The CBSA’s estimate of imports also indicate that since 2014, imports from Vietnam have remained relatively stable and have been able to capture one of the largest shares of the CPF market in Canada. As a result, the CBSA finds that there is reasonable evidence supporting the allegation of injury with respect to lost sales and lost market share.

[102] The complainant submitted that the injurious impact of the dumped and subsidized goods is demonstrated in its financial results. To support this allegation, the complainant provided its financial statements for 2014 through the first six months of 2017.^{Footnote 20} The complainant alleged that coincident with an increase in the volume of imported goods, the complainant’s financial performance in the domestic market has declined since 2014.^{Footnote 21}

[103] Based on a review of the financial statements, the CBSA observed that the complainant has experienced poor financial performance in regards to their sales in the domestic market, showing deteriorating gross margins since 2014. Based on the evidence provided, the CBSA finds that the complainant’s financial results can be reasonably attributed to the lost sales, price undercutting, price depression, and price suppression resulting from the dumped and subsidized goods from Vietnam.

[104] The complainant stated that the increase in the volume of imported subject goods and the corresponding decline in domestic production of like goods has resulted in a deterioration of the employment figures.^{Footnote 22} The complaint includes employment data which indicate that the complainant experienced a significant reduction in employment.^{Footnote 23}

[105] The complainant stated that production volumes and capacity utilization have deteriorated steadily since 2014, coincident with the increase in the volume of low priced imports from Vietnam.^{Footnote 24} The complainant provided capacity utilization data since 2014 which supports this claim.^{Footnote 25}

CBSA’s Conclusion – Injury

[106] There is a reasonable indication that material injury has occurred to the CPF industry in Canada. The nature of the injury incurred by the complainant is well-documented in terms of an increase in the volume of imports of the allegedly dumped and subsidized goods, price undercutting, price depression, price suppression, declining production volumes, lost sales and market share, negative financial results, reduced employment and underutilization of capacity. The CBSA finds that the injury can be reasonably attributed to the allegedly dumped and subsidized goods from Vietnam.

[108] The complainant alleged that the rapid increase in the volume of dumped and subsidized goods, at prices that undercut domestically produced like goods, indicate a likelihood of substantially increased imports, and pose a threat of further injury to the Canadian industry. The complainant submitted that Vietnamese imports have an important presence in the Canadian market substantiated by their increasing market share every year since 2014.^{Footnote 27}

[109] The CBSA’s analysis of import data show that imports of subject goods from Vietnam have fluctuated between January 1, 2014 and August 31, 2017; however, the import data show that Vietnamese imports continue to capture significant share in each year relative to total imports from all countries.

[110] The complainant provided information to support the allegation of excess capacity in Vietnam. The complainant alleged that there is significant production capacity available to produce certain CPF in Vietnam. The complainant submitted that nearly all of the production in Vietnam is export oriented. The complainant also alleged that Vietnamese producers plan to expand copper tube production which could create a greater incentive to increase production of certain CPF.^{Footnote 28}

[111] Based on the CBSA’s analysis of the evidence and information provided in the complaint, the CBSA recognizes the significant capacity under-utilization of CPF producers in Vietnam. As such, the CBSA finds the complainant’s allegation of threat of injury posed by the capacity under-utilization of CPF in Vietnam to be reasonable and well supported.

[112] The complainant stated that imports are entering the Canadian market at prices that are having severely depressive and suppressive effects on their own prices. The complainant also stated that existing anti-dumping and countervailing measures on CPF from China, the Republic of Korea and the United States may lead to a further increase in demand for imports from Vietnam at lower prices.^{Footnote 29}

[113] The complainant also noted that due to the decline in value of non-residential investment in 2017, demand for CPF has been negative. With only a modest growth forecasted for 2018, demand for CPF is not expected to increase and therefore prices for CPF are not expected to increase, with low priced imports from Vietnam continuing to undercut the complainant’s prices.^{Footnote 30}

[114] As discussed in the respective sections, overall the CBSA finds the complainant’s allegations of price depression and price suppression to be well documented, well supported and reasonable. While import data in Table 1 and 2 show that demand for goods from the Republic of Korea and the United States are decreasing and demand for goods from China are increasing, the import data also show that goods from Vietnam continue to capture significant market share between January 1, 2017 and August 31, 2017, relative to total imports from all countries. Therefore, the CBSA finds that the continued presence of these conditions threaten to cause further injury to the domestic industry.

[115] The complainant stated that the magnitude of alleged dumping of the subject goods is concerning and demonstrates a real threat to the domestic industry. The complainant also noted that the subsidy programs available to exporters and producers of subject goods in Vietnam are contingent on exports and therefore pose a threat of injury to the domestic industry.^{Footnote 31}

[116] The CBSA has found that sufficient evidence exists to support the fact that the subject goods are being dumped and subsidized, and that the margin of dumping and amount for subsidy are not insignificant. The CBSA recognizes that the dumping and subsidizing of subject goods could significantly impact the trade of subject goods.

[117] The complainant submitted that CPF producers in Vietnam will look to export their products as domestic demand will decline in the near term.^{Footnote 32} This allegation is supported by the fact that the current outlook for Vietnam is for a declining gross domestic product (GDP) in general, and a decline in GDP from construction.^{Footnote 33} The complainant alleged that this will likely result in a weakened demand for construction goods in Vietnam, with CPF included.^{Footnote 34}

[118] The complainant also submitted that Vietnam has had positive economic growth recently, driven by exports. The complainant alleged that Canada will remain an attractive export market for Vietnamese producers.

[119] The CBSA’s analysis of the information contained in the complaint revealed market conditions which the CBSA recognizes may result in Vietnamese producers of CPF continuing to target certain export markets, including Canada. As such, the CBSA finds the complainant’s allegations of the threat of injury posed by market conditions in Vietnam to be reasonable and well supported.

[120] The complaint contained reasonable evidence that the import volume of subject goods from Vietnam is likely to continue to remain significant, and likely to increase in the future, considering the market conditions in Vietnam and the level of capacity under-utilization of the subject goods in Vietnam. The significant volume of imports from Vietnam at prices that substantially undercut Canadian domestic producer prices will continue to depress or suppress domestic prices and threaten to capture market share from the Canadian producer. The CBSA is of the opinion that the complaint contained reasonable evidence that such imports are likely to cause material injury in the foreseeable future.