Heavy plate - HP 2020 IN
Statement of Reasons - Initiation of an investigation

Complainant

[16] Algoma is a primary iron and steel producer located in Sault Ste. Marie, Ontario, and began producing steel in 1902.

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

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

[18] The other manufacturers of like goods in Canada are: Janco Steel Ltd. (Janco), SSAB Central Inc. (SSAB), Samuel, Son & Co., Ltd. (Samuel), Tidy Steel-Fab Ltd. (Tidy), and Varsteel Ltd. (Varsteel). Contact information for these manufacturers is as follows:

Trade union

[19] The complainant identified one trade union that represents persons employed in the production of heavy plate in Canada:

United Steel Workers
234 Eglinton Avenue East, 8th floor
Toronto, Ontario  M4P 1K7

Exporters

[20] The CBSA identified 36 potential exporters of the subject goods from CBSA import documentation and from information submitted in the complaint. All of the potential exporters were asked to respond to the CBSA’s Dumping request for information (RFI).

Importers

[21] The CBSA identified 34 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.

Governments

[22] Upon initiation of this investigation, the Government of Turkey (GOT) was sent the CBSA’s Government Particular Market Situation RFI.

[23] For the purposes of this investigation, the GOT 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 any law passed by, the government of that country or that provincial, state or municipal or other local or regional government.

Definition

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

Additional product information

[25] Plate is produced to specific grades and standardizations. These grades and standardizations are used for specific end-uses. Common standardizations include American Society for Mechanical Engineers (ASME), and American Society for Testing and Materials (ASTM). For example, ASTM/ASME A36, A283, A573 or A709 may be used for structural plate, which is used in a variety of construction applications. Plate meeting A515 and A516M/A516, grade 70 is used for the construction of pressure vessels, which hold gasses or liquids at high pressure.

[26] Pressure vessel quality (PVQ) plate may be vacuum degassed to achieve desired characteristics, in particular low sulfur, low carbon, low gaseous levels (H2, N2, 02), improved cleanliness and improved ferro alloy recovery. Such characteristics may be used in sour service applications and applications requiring hydrogen-induced cracking (HIC) resistance low temperature fracture toughness.

[27] Some of these gauges and specifications, as well as specific lengths and widths, command a price premium.

Production process

[28] While details may vary from mill to mill, the process by which carbon steel plate is produced is essentially the same for all producers world-wide and entails:

• heating slabs before rolling
• descaling
• rolling
• levelling
• cutting to size
• inspection and testing
• shipping

[29] At 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 slab thickness occurs in the breakdown mill where the slab is reduced in gauge depending on the final plate thickness required.

[30] Heavier plate (i.e. 3/8 inches and thicker) goes directly to the 166" plate mill where it is reduced to its final thickness, levelled and then sent to the plate finishing area where it is sized, sides are trimmed, cut to length (either sheared or flame cut), tested and shipped.

[31] For lighter plate, the 166" plate mill acts as 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.

[32] Separately, certain service centres operate cut-to-length lines which cut plate from coil.

Product use

[33] 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, ships and barges, and pressure vessels.

Classification of imports

[34] The allegedly dumped goods are normally classified under the following tariff classification numbers:

• 7208.51.00.10
• 7208.51.00.93
• 7208.51.00.94
• 7208.51.00.95
• 7208.52.00.10
• 7208.52.00.93
• 7208.52.00.96

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

Standing

[43] 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.

[44] As the complainant and the supporting producers represent the vast majority of the total production of like goods in Canada, the CBSA is satisfied that the standing requirements pursuant to subsection 31(2) of SIMA have been met.

Normal values

Complainant’s estimates

[61] The complaint did not include estimates of normal values pursuant to section 15 of SIMA. The complainant explained that the best available source to estimate normal values pursuant to section 15 is source specific MEPS pricing data. This pricing data was available for all named sources with the exception of Malaysia. However, according to the complainant, MEPS data is not appropriate to use as a basis for estimating normal values as it reflects only base products, may include non-subject goods, and provides only a highest and lowest price.^{Footnote 5}

[62] Consequently, the complainant provided estimated normal values using a constructed cost approach to reflect the methodology defined under paragraph 19(b) of SIMA. The complainant based these estimates on their own costs of production as well as public cost and pricing information available with respect to each of the named sources.

[63] The complainant has alleged that a particular market situation exists in the heavy plate market in Turkey. Specifically, based on information provided in the complaint, the complainant submits that pursuant to section 11.2(2) of the Special Import Measures Regulations, a particular market situation exists in Turkey as Turkish producers’ and exporters’ cost of production data do not reasonably reflect the cost of production. However, for the purposes of the complaint, the complainant estimated normal values for Turkey in a manner similar to the other named sources, based on their own cost information adjusted to reflect conditions in the named sources.

[64] One normal value was estimated per quarter for heavy plate from each of the named sources based on the aggregate of the costs of producing the goods (materials, labour, and overhead), a reasonable amount for selling, general and administrative (SG&A) costs and other costs, and a reasonable amount for profits.

[65] Material costs were estimated based on the complaints’ material costs. For iron ore, the material cost was adjusted to reflect the difference between Algoma’s iron ore cost for a given quarter and Platts’ Iodex 62% ore price. According to the complainant, Platts’ Iodex 62% ore price best represents the global ore price for steel. No adjustments were made to the complainants’ costs for coal or other materials.^{Footnote 6}

[66] Labour costs were estimated based on the complainant’s own costs associated with the production of like goods and adjusted to reflect labour costs in the named sources. This adjustment was applied to the costs based on publically available information reported by Trading Economics.^{Footnote 7}

[67] With respect to Turkey, the complainant submits that the labour information available for that country is inadequate for the purposes of estimating normal values. Specifically, the complainant noted that the information available for Turkey is indexed to a prior year, without publishing the wages of that year. Further, the complainant notes that only minimum wages are published and that minimum wages do not adequately reflect manufacturing labour rates.

[68] The complainant submits that Turkish labour information should not be used and has provided the Czech Republic as the appropriate surrogate for labour cost data. The complainant submits that the Czech Republic is a reasonable proxy for Turkey as both countries are located in the Euro area, have a per capita GDP that is far less than that of Germany, France and other European economic leaders, and relatively similar GDP per capita. Finally, the complainant argues that based on the adjustment rate, this is likely a conservative estimate.

[69] The labour adjustment was calculated for each quarter. The adjustments are presented as a percentage of the Canada labour rate and ranged as follows:

• The Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu (Chinese Taipei) – downward adjustment of 49.8% to 68.6%
• Germany – upward adjustment of 143.3% to 146.9%
• South Korea – upward adjustment of 106.7% to 113.0%
• Malaysia – downward adjustment of 28.4% to 29.8%
• Turkey – downward adjustment of 45.9% to 49.0%

[70] Overhead costs were based on the complainant’s factory overhead costs, with an adjustment applied to the portion of overhead relating to indirect labour for each named source.^{Footnote 8}

[71] The complainant estimated the amounts for SG&A and financial expenses, as well as the amounts for profit, based on the publicly available financial statements of plate producers in the named sources.

[72] For the Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu (Chinese Taipei), the complainant used amounts reported by China Steel Corp. in its annual financial statements.

[73] For Germany, the complainant used SG&A and financial expense amounts reported by German steel producer Salzigitter Group and adjusted to account for differences in financial reporting methodologies. During the POI Salzgitter Group reported a negative net income. The complainant submits that a negative amount is not a reasonable figure to use for the purposes of estimating normal values. As such, the complaint has applied 5% as an amount for profit for estimating normal values for Germany. The complainant made reference to rates of return on various investments to support the use of this 5% figure.

[74] For South Korea, the complainant used amounts reported in the financial statements of Hyundai Steel, a plate producer located in South Korea.

[75] The complainant submits that they could not obtain publicly available financial information for plate producers in Malaysia. As such, the complainant used SG&A and financial expense data from Malaysia Steel Works, a Malaysian producer of steel billet and steel bar. As this producer reported a negative profit for the POI, the complainant applied the profit amount found for the Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu (Chinese Taipei).

[76] For Turkey, the complainant used data from Ereğli Demir ve Çelik Fabrikaları T.A.Ş, a plate producer located in Turkey. The amounts for SG&A and financial expenses, as well as the amounts for profits, are reported as a percent of the cost of goods manufactured.

CBSA’s estimates

[77] The CBSA has reviewed the complainant’s arguments concerning the use of MEPS domestic price information. Based on the information provided, the CBSA finds the complainant’s arguments to be reasonable.

[78] In the absence of pricing information specific to heavy plate in the named sources, the CBSA was unable to estimate normal values following the methodology described in section 15 of SIMA.

[79] With respect to the complainant’s allegations of a particular market situation in Turkey, the CBSA will endeavor to gather additional information from exporters, and other relevant sources in order to enable the CBSA to form an opinion as to whether a “particular market situation” exists in the domestic market for heavy plate in Turkey and whether the domestic sales in Turkey permit a proper comparison with the sale to the importer in Canada. For the purposes of initiation, the CBSA has estimated normal values pursuant to section 19(b) of SIMA.

[80] The CBSA notes that the complainant’s estimated normal values lack specificity. Although the estimated normal values do not account for all product characteristics which the CBSA recognizes may have an effect on the cost and/or price of heavy plate, the CBSA also recognizes that this approach was reasonable based on the information available to the complainant. The CBSA finds that it is reasonable to assume that the subject goods shipped to Canada during the period of January 1, 2019 to December 31, 2019 would reflect a product mix similar to the complainant’s production for that period. As such, the CBSA finds that the normal value calculated for each quarter may reasonably represent the subject goods shipped to Canada during that period. The CBSA notes that sufficient information was not provided prior to the initiation of the investigation to form an opinion as to whether a particular market situation exists in Turkey.

[81] In analyzing the paragraph 19(b) normal values estimated by the complainant, the CBSA noted that there was an error in the formulas relating to certain cost of goods manufactured (COGM) information provided by the complainant. The CBSA corrected the estimated normal values. Based on the information available to the complainant, the CBSA found that the corrected paragraph 19(b) normal value estimates are reasonable and representative.

[82] With respect to the amount for profits used to calculate normal values for Germany, the CBSA finds that the complainant’s estimate is not well supported but may reflect the best information available. The CBSA recognizes that obtaining publicly available financial data may be difficult and that applying a negative amount for profits is not reasonable. Further, the CBSA finds that the application of information found for other countries is made difficult by the differences in both geography and economic conditions in these countries. Given the information available to the complainant, the CBSA finds that the amount for profits used in calculating normal values for Germany is reasonable.

[83] Based on the information available at this time, the CBSA finds the complainant’s proposed constructed cost methodology to be the best information available. As such, only the adjustment mentioned above was made to the complainant’s estimates of section 19 normal values.

Export price

[84] 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.

[85] The complainant estimated export prices based on importation data available from Statistics Canada for the period of January 1, 2019 to December 31, 2019. For each named source, the complainant estimated one export price per quarter using the total declared value for duty and total declared quantity information for the relevant tariff classification codes for this period.

[86] The CBSA estimated quarterly export prices for heavy plate for each named source based on the value for duty as declared on the customs entry documentation and reports generated through the Facility for Information Retrieval Management (FIRM) of imports of the goods classified under the relevant tariff classification codes during the period of January 1, 2019 to December 31, 2019. In the CBSA’s review of commercial entry information for heavy plate entering Canada, adjustments were made to the FIRM data to correct any errors respecting the quantity and value for duty as necessary.

Estimated margins of dumping

[87] The CBSA estimated the margins of dumping for the named sources by comparing the estimated normal values with the weighted average estimated export prices. Based on this analysis, it is estimated that heavy plate imported into Canada from each of the named sources was dumped. The estimated margins of dumping are listed in the table below.

Lost sales^{Footnote 12}

[100] The complainant provided evidence of lost sales on an offer specific basis. Specifically, the complaint includes examples of numerous sales that were lost either entirely or in part by the complainant to imports of the allegedly dumped goods. The evidence includes a detailed statement of evidence from a Regional Sales Director for Algoma as well as Import Activity Reports to support the specific lost sales allegations.

[101] Based on the CBSA’s analysis of information detailing individual lost sales contained in the complaint as well as the CBSA’s estimate of imports and market share, the CBSA finds the complainant’s claim of lost sales to be reasonable and well supported. As such, the CBSA is of the opinion that this injury factor is sufficiently supported and linked to the allegedly dumped goods.

Price depression and price undercutting^{Footnote 13}

[102] The complainant argues that the allegedly dumped goods have captured market share by undercutting the prices of the Canadian producers. Based on the import data estimates provided by the complainant, it is evident that the prices of the subject goods have been significantly lower than Canadian producer pricing.

[103] The complainant also provided specific examples of sales offers for which prices of the subject goods were less than the complainant’s. The average import prices calculated by the CBSA reveal a trend similar to that described by the complainant.

[104] As a result of these significant price discrepancies, the complainant states that it has been forced to reduce its pricing. In support of this, the complainant provided evidence of several instances where they were forced to discount pricing in order to compete with imports of subject goods.

[105] The complainant also alleged that the named sources have been import price leaders and have been undercutting prices from the United States, the primary source of other imports, in addition to the domestic producers. To support this claim, the complainant included a comparison of prices of subject goods to that of the United States to demonstrate that subject goods have been priced well below the price of the United States’ imports.

[106] Based on the CBSA’s analysis of import pricing as well as the information contained in the complaint, the CBSA finds the claim of price depression and price undercutting to be supported and sufficiently linked to the allegedly dumped goods.

Stagnation of market share^{Footnote 14}

[107] The complainant claims that the named sources have increased their market share from 2016 to 2019, which has caused injury through reduced revenues, profitability and capacity utilization. The complainant used Statistics Canada import data and domestic production to estimate market shares for the period of 2016 to 2019.

[108] The complainant notes that the United States’ antidumping and countervailing measures on plate in 2017 and the 232 measures in 2018 provided protection for US producers, which allowed the United States to increase their domestic sales. This caused the United States’ exports to Canada to decrease, reducing their market share in Canada. The complainant stated that they expected to replace the US imports with domestic production, however, the exporters of subject goods leveraged these conditions to increase their share of sales.

[109] The complainant has provided significant evidence of lost sales due to the allegedly dumped goods. The loss of these sales has negatively impacted the complainant’s market share. This supports the stagnation of market share, as the presence of the allegedly dumped goods appears to have slowed the growth of the complainant’s market share.

[110] Based on the CBSA’s analysis of the information contained in the complaint, the CBSA finds stagnation of market share to be an injury factor.

Impacted financial results^{Footnote 15}

[111] The complainant alleges that the injurious impact of the allegedly dumped goods is demonstrated by diminished gains in net income. To support this allegation the complainant has provided financial performance information for the period of 2016 to 2019.^{Footnote 16}

[112] Detailed information regarding the revenue and profitability cannot be divulged for confidentiality reasons. However, the CBSA has reviewed this information and found that there has been a trend to the impact on the financial results which supports the complainant’s allegations. The CBSA finds it reasonable to assume that the presence of the other injury factors would have some impact on the financial results of the domestic industry, and that the information in the complaint has sufficiently linked the allegedly dumped goods to the complainant’s impacted financial results.

Underutilization of capacity^{Footnote 17}

[113] The complainant states that capacity utilization rates with respect to the production of heavy plate have suffered due to the presence of the dumped goods. The complainant alleges that due to the decline of prices they have been unable to increase production or utilization. To support this claim, the complainant has provided production information for 2016 to 2019.^{Footnote 18}

[114] Based on the CBSA’s analysis of information contained in the complaint, including the complainant’s confidential production information, the CBSA finds that there is a reasonable link between the presence of the allegedly dumped goods and the complainant’s inability to increase capacity utilization with respect to heavy plate.

CBSA's conclusion - injury

[115] Overall, based on the evidence provided in the complaint, and supplementary data available to the CBSA through its own research and customs documentation, the CBSA finds that the evidence discloses a reasonable indication that the dumping of the subject goods from the named sources has caused injury to the heavy plate industry in Canada. The nature of the injury is well documented with respect to lost sales, price depression and price undercutting, stagnation of market share, impacted financial results and underutilization of capacity.

Weak steel and steel plate demand globally^{Footnote 20}

[118] In the complainant’s discussion of international market conditions, the complainant alleges that the global steel outlook is weak and that the heavy plate market is affected by the uncertainty present in the steel industry. The complainant cites various reports published by the business intelligence company called the CRU Group and the World Steel Association which support the complainant’s allegation that uncertainty and concern continue to exist in the steel industry as a whole.

[119] Despite declining steel demand growth, the complainant indicates that steel production in China especially, has continued to grow, leading to imbalances in the Chinese steel market. The complainant alleges this creates a climate whereby oversupply encourages the export of low-priced steel products, affecting global markets and Canada.

[120] The CBSA’s analysis of the global demand information contained in the complaint revealed weak demand for steel and steel plate, which the CBSA recognizes may lead heavy plate producers in the named sources to target certain export markets, including Canada.

Global excess capacity and production^{Footnote 21}

[121] The complainant has referenced information published by a variety of sources, including the Organisation for Economic Co-operation and Development Steel Committee, the European Steel Association (EUROFER) and the International Monetary Fund (IMF), to support the allegation of excess global capacity in the steel industry.^{Footnote 22} The complainant also included data from the CRU Group Outlook for global capacity, consumption and production for reversing mill plate, coil plate, and hot-rolled sheet for the years 2017-2019, as well as forecasts for 2020-2022.^{Footnote 23} The data and forecasts show significant excess plate for all years.

[122] The complainant points to China’s surplus production as a driving force behind the overcapacity problem in the global heavy plate market, stating that the low priced Chinese imports put pressure on the named sources’ markets, especially South Korea and Germany, which are the second and fourth largest export markets for Chinese reversing mill plate, respectively. The complaint states that this poses a significant threat to the complainant as these countries are forced to seek new markets for their surplus heavy plate. The complainant also noted a decision made by the CITT for the Plate 7 expiry review in March of 2020, where the CITT notes that global steel excess capacity remains a threat of injury.^{Footnote 24}

[123] The CBSA recognizes the significant excess capacity of heavy plate in the global market, including the named sources, which, if directed to Canada, could result in a significant increase of subject imports, and pose a threat to the domestic industry.

Weakening steel market and economy in Europe and Asia^{Footnote 25}

[124] The complainant alleges that the weakening steel market in Europe is causing producers that traditionally sell in Europe to find other markets for the production. The complainant cites sources such as EUROFER, IMF and CRU Group reports to support this claim. Based on publications by the EUROFER, the complainant states that steel imports have flooded the European Union (EU) market, overwhelming the market and satisfying its limited demand growth. The complainant alleges that this poses a threat to the Canadian plate market as subject goods producers, specifically those in Germany and Turkey, will be incentivized to increase export sales.

[125] The complainant also alleges that there is weak demand in both Europe and Asia, and has included production and demand forecasts published by the CRU Group for both Europe and Asia to support this claim.^{Footnote 26} The complainant suggests the weak demand threatens the domestic Canadian market as it will likely cause exporters from the Europe and Asia to increasingly rely on export markets such as Canada.

[126] The CBSA’s analysis of the information provided by the complainant revealed market and economic conditions in Europe and Asia which the CBSA recognizes may lead heavy plate producers in the named sources to target certain export markets, including Canada.

Named source market conditions^{Footnote 27}

[127] The complainant states that heavy plate producers in each of the named sources have significant capacity, continued overproduction of steel and a propensity to export. The complainant has used publically available information to estimate production capacity of heavy plate for each named source. In linking the capacity of the producers of subject goods to their likeliness to export to Canada, the complainant discusses domestic demand in the named sources, volumes of exports to other countries, including Canada, and other trade measures in force against the named sources with respect to similar goods.

[128] The CBSA’s analysis of the information contained in the complaint revealed market conditions in the named sources which the CBSA recognizes may encourage heavy plate producers to target certain export markets, including Canada.

Trade measures against the named sources^{Footnote 28}

[129] The complainant states that several countries have imposed trade remedies against goods of the same or similar description from certain named sources. Specifically, the complainant submits that the Section 232 steel tariffs and quotas imposed in the United States has resulted in a decline of steel plate imported in the United States. The complainant also named several anti-dumping, countervailing and safeguard measures imposed by other World Trade Organization (WTO) members against steel plate products from the named sources. The complainant alleges that these trade measures are likely to lead to diversion of subject goods into the Canadian market.

[130] The CBSA acknowledges the presence of trade remedy actions in the United States and other countries, which may further increase the volume of subject goods imported into Canada. Furthermore, the CBSA recognizes that these restrictions may have a significant impact on the Canadian market for heavy plate.

Investment^{Footnote 29}

[131] The complainant states that it has undertaken a plate modernization plan to improve and modernize its plate production facilities. The complainant intends to sell any additional tonnes primarily in the Canadian market. The complainant states that the absence of a positive Finding would threaten the success of this project, and reduce its ability to earn a sustainable return on the investment.

[132] The CBSA recognizes that the allegedly dumped goods could continue to cause injury to the complainant’s financial results, which could negatively impact the success of investment activities.

Domestic market conditions^{Footnote 30}

[133] Referencing forecasts made by RBC and CBC News, the complainant states that the Canadian economy will be facing difficulties, including a projected recession. Reports provided by the complainant indicate that various factors, including COVID-19, low oil prices and railway disruptions, have created uncertainty which is expected to limit economic growth.

[134] The complainant described the Canadian plate market using its Canadian plate market table, as well as the CRU Group’s forecasts for the Canadian demand of plate and reversing mill plate.

[135] The complainant also notes that the relatively higher domestic prices in Canada makes it attractive to exporters of the subject goods. To support this claim, the complainant referenced a recent expiry review for Plate 5, where the CITT stated that the rescinding of the order would make the Canadian market attractive to the subject goods due to the high prices in the market.^{Footnote 31} The complainant further notes that during this expiry review the CITT deemed the CRU Group US Midwest prices to be a reasonable proxy for Canadian pricing trends. In order to support the allegation of high prices, the complainant provided data from the CRU Group Steel Plate Products Market Outlook which shows that the US Midwest prices have been above, and are forecasted to remain above, prices in other markets such as the German, Italian, and Chinese domestic markets, as well as the Far East import market. The complainant states that this data suggests that the Canadian market will be attractive to exporters from the named sources, if a finding is not put into place.

[136] The CBSA recognizes that due to domestic market conditions, Canada remains an attractive open heavy plate market to exporters of subject goods, which poses a threat to domestic producers.

CBSA's conclusion - threat of injury

[137] The complaint contains evidence that discloses a reasonable indication that there is a threat of injury to the heavy plate industry in Canada. The information provided by the complainant indicates that persisting imbalances in the global steel industry, global excess capacity, weakening steel market and economic conditions in Europe and Asia, named source market conditions, trade measures against named sources and Canadian market conditions, as described above, are collectively posing a threat to the Canadian industry.