Notice of Final Determination of Sales at Not Less Than Fair Value: Stainless Steel Bar from Italy

DEPARTMENT OF COMMERCE

[A-475-813]

Notice of Final Determination of Sales at Not Less Than Fair

Value: Stainless Steel Bar from Italy

Agency: Import Administration, International Trade Administration,

Department of Commerce.

Effective Date: December 28, 1994.

For Further Information Contact: Kate Johnson or Irene Darzenta,

Office of Antidumping Investigations, Import Administration, U.S.

Department of Commerce, 14th Street and Constitution Avenue, N.W.,

Washington, D.C. 20230; telephone (202) 482-4929 or 482-6320,

respectively.

Final Determination

We determine that stainless steel bar (SSB) from Italy is not

being, nor is likely to be, sold in the United States at less than fair

value, as provided in section 735 of the Tariff Act of 1930, as amended

(the Act). The estimated de minimis margins are shown in the

``Discontinuance of Suspension of Liquidation'' section of this notice.

Scope of Investigation

The merchandise covered by this investigation is SSB. For purposes

of this investigation, the term ''stainless steel bar'' means articles

of stainless steel in straight lengths that have been either hot-

rolled, forged, turned, cold-drawn, cold-rolled or otherwise cold-

finished, or ground, having a uniform solid cross section along their

whole length in the shape of circles, segments of circles, ovals,

rectangles (including squares), triangles, hexagons, octagons or other

convex polygons. SSB includes cold-finished SSBs that are turned or

ground in straight lengths, whether produced from hot-rolled bar or

from straightened and cut rod or wire, and reinforcing bars that have

indentions, ribs, grooves, or other deformations produced during the

rolling process.

Except as specified above, the term does not include stainless

steel semi-finished products, cut length flat-rolled products (i.e.,

cut length rolled products which if less than 4.75 mm in thickness have

a width measuring at least 10 times the thickness, or if 4.75 mm or

more in thickness having a width which exceeds 150 mm and measures at

least twice the thickness), wire (i.e., cold-formed products in coils,

of any uniform solid cross section along their whole length, which do

not conform to the definition of flat-rolled products), and angles

shapes and sections.

The SSB subject to this investigation is currently classifiable

under subheadings 7222.10.0005, 7222.10.0050, 7222.20.0005,

7222.20.0045, 7222.20.0075 and 7222.30.0000 of the Harmonized Tariff

Schedule of Schedule of the United States (HTSUS). Although the HTSUS

subheading is provided for convenience and customs purposes, our

written description of the scope of this investigation is dispositive.

Period of Investigation

The period of investigation (POI) is July 1 to December 31, 1993.

Case History

Since publication of the notice of preliminary determination on

August 4, 1994 (59 FR 39736), the following events have occurred.

On August 5, 1994, Acciaierie Valbruna S.r.l. (Valbruna) submitted

its response to Section D of the Department's questionnaire. It

supplemented this response on October 3, 1994.

On August 9 and 10, 1994, Valbruna and petitioners, respectively,

requested the opportunity to participate in a hearing, if held. None

was held.

Also, on August 10, 1994, Valbruna alleged that the Department made

certain ministerial errors in its preliminary margin calculations. On

August 11, 1994, petitioners submitted comments and rebuttal regarding

these ministerial errors. With respect to these allegations, on

September 13, 1994, we published a notice of amended preliminary

determination correcting the ministerial errors in the preliminary

margin calculations (59 FR 46961).

On August 12, 1994, Foroni S.p.A. (Foroni) tentatively requested a

hearing in this investigation. It withdrew its request on October 26,

1994.

Verification of Valbruna's and Foroni's responses took place in

August and October, 1994.

Case and rebuttal briefs were submitted on November 17, and 23,

1994, respectively.

At the Department's request, Valbruna and Foroni submitted revised

computer tapes correcting certain minor clerical errors found at

verification on November 22 and 30, 1994, respectively.

Product Comparisons

We have determined that all products covered by this investigation

constitute a single category of such or similar merchandise. We made

fair value comparisons on this basis. In accordance with the

Department's standard methodology, we first compared identical

merchandise. Where there were no sales of identical merchandise in the

home market to compare to U.S. sales, we made similar merchandise

comparisons on the basis of the criteria defined in Appendix V to the

antidumping questionnaire, on file in Room B-099 of the main building

of the Department of Commerce.

Consistent with our preliminary determination, we altered the order

of the SSB grades specified within the grade criteria of Appendix V to

account for certain other SSB grades which Foroni sold during the POI,

but which were not taken into account in Appendix V. We also reversed

the order of the size and shape criteria in Appendix V.

Fair Value Comparisons

To determine whether sales of SSB from Italy to the United States

were made at less than fair value, we compared the United States price

(``USP'') to the foreign market value (``FMB''), as specified in the

``United States Price'' and ``Foreign Market Value'' sections of this

notice. In accordance with 19 C.F.R. 353.58, we made comparisons at the

same level of trade, where possible.

We made revisions to both respondents' reported data, where

appropriate, based on verification findings.

United States Price

Foroni

All of Foroni's U.S. sales to the first unrelated purchaser took

place after importation into the United States. Therefore, we based USP

on exporter's sales prices (ESP), in accordance with section 772(c) of

the Act. In accordance with section 772(d) of the Act, we calculated

ESP based on FOB warehouse and FOB port prices to unrelated customers

in the United States. We made deductions, where appropriate, for

foreign brokerage, ocean freight (including foreign inland freight and

loading/unloading charges), U.S. brokerage and handling, U.S. inland

freight, U.S. import duties (including harbor maintenance fees and

merchandise processing fees), and export processing fees. For those

sales of subject merchandise with FOB U.S. port sales terms, we made no

deduction for the U.S. inland freight charges reported in respondent's

U.S. sales listing.

We also deducted credit expenses, warranty expenses, product

liability premiums, and commissions paid to an employee, in accordance

with section 772(e)(2) of the Act. We recalculated credit expenses to

account for updated shipment and payment information which we reviewed

at verification. For sales with missing shipment and payment dates, we

calculated credit using the average credit days outstanding for all

other sales in the U.S. databases. We also deducted U.S. indirect

selling expenses, including pre-sale warehousing costs incurred in the

United States, advertising, and inventory carrying costs. We

recalculated certain indirect selling expenses, including advertising

and pre-sale warehousing expenses, in accordance with verification

findings.

In addition, we made no adjustment for U.S. packing expenses

because Foroni claimed, and we verified, that the subject merchandise

is not packed for shipment to the customer.

We also made an adjustment to USP for the value-added tax (VAT)

paid on the comparison sales in Italy in accordance with our practice,

pursuant to the Court of International Trade's (CIT) decision in

Federal-Mogul Corp. and The Torrington Co. v. United States, Slip Op.

93-194 (CIT October 7, 1993). (See Final Determination of Sales at Less

Than Fair Value: Calcium Aluminate Cement, Cement Clinker and Flux from

France. 59 FR 14136, March 25, 1994).

Valbruna

For Valbruna, we based USP on both ESP and purchase price (PP), in

accordance with section 772 of the Act, because Valbruna made sales

both before and after importation into the United States. We calculated

both PP and ESP based on packed prices to unrelated customers. In

accordance with section 772(d)(2)(A) of the Act, for both PP and ESP

sales we made deductions, where appropriate, for ocean freight

(including foreign inland freight, foreign inland insurance, marine

insurance and foreign brokerage and handling), U.S. import duties, U.S.

merchandise processing and harbor maintenance fees, U.S. inland

freight, U.S. brokerage and handling, and containerization expenses

(including drayage, stripping, and storage expenses). We added freight

income (i.e., freight charges paid by the customer but not included in

the gross price) to both ESP and PP sales.

For ESP sales only, we further deducted credit expenses, in

accordance with section 772(e)(2) of the Act. Accordingly, we deleted

the affected invoice from the database. We also deducted indirect

selling expenses incurred in Italy on sales to the United States, as

well as indirect selling expenses incurred in the United States, and

inventory carrying costs. We recalculated indirect selling expenses

incurred in the United States to reflect verification findings. With

regard to the reported warranty expenses applicable to one U.S. sales

invoice, we made no adjustment because we determined that these

expenses were not characteristic of ``warranty'' expenses; rather, they

reflected a return to merchandise.

Finally, we made an adjustment to USP for the VAT paid on the

comparison sales in Italy in accordance with our practice, as described

above for Foroni.

Foreign Market Value

In order to determine whether there were sufficient sales of SSB in

the home market to serve as a viable basis for calculating FMV, we

compared the volume of home market sales of SSB to the volume of third

country sales of SSB in accordance with section 773(a)(1)(B) of the

Act. Based on this comparison, we determined that both respondents had

viable home markets with respect to sales of SSB during the POI.

Foroni

We calculated FMV based on ex-factory prices charged to unrelated

customers in the home market. Pursuant to 19 C.F.R. 353.56(a)(2), we

deducted credit expenses. We also deducted home market indirect selling

expenses capped by the sum of U.S. commissions and indirect selling

expenses (including inventory carrying costs), in accordance with 19

C.F.R. 353.56(b).

We made adjustments, where appropriate, for differences in the

physical characteristics of the merchandise (difmer), in accordance

with section 773(a)(4)(C) of the Act. We recalculated difmers to take

into account quality control expenses, which we verified were related

to production.

We adjusted for VAT in accordance with out practice for those home

market sales for which we verified that VAT applied. (See the ``United

States Price'' section of this notice.)

In addition, we made no adjustment for U.S. packing expenses

because Foroni claimed, and we verified, that the subject merchandise

is not packed for shipment to the customer.

Valbruna

We calculated FMV based on packed prices charged to related and

unrelated customers in the home market. We included arm's-length sales

to related customers, pursuant to 19 C.F.R. 353.45. We excluded from

our analysis sales of secondary merchandise, which we verified were not

made in the ordinary course of trade.

We deducted cash discounts. We added freight income (i.e., freight

charges paid by the customer but not included in the gross price) to

both ESP and PP sales.

In light of the Court of Appeals for the Federal Circuit's (CAFC)

decision in Ad Hoc Committee of AZ-NM-TX-FL Producers of Gray Portland

Cement V. United States, 13 F.3d 398 (Fed. Cir. 1994), the Department

no longer can deduct home market movement charges from FMV pursuant to

its inherent power to fill in gaps in the antidumping statute. Instead,

we will adjust for those expenses under the circumstances-of-sale

provision of 19 C.F.R. 353.56(a) and the ESP offset provision of 19

C.F.R. 353.56(b)(2), as appropriate. Accordingly, in the present case,

we deducted post-sale movement charges from FMV under the

circumstances-of-sale provision of 19 C.F.R. 353.56(a). This adjustment

included home market inland freight (including inland insurance) from

respondent's factory or service centers to its home market customers.

We adjusted for pre-sale movement charges in the ESP offset.

For comparison to ESP sales, we also deducted credit expenses and

home market commissions from FMV. We considered pre-sale warehousing

expenses incurred by Valbruna's service centers and inventory carrying

costs related to pre-sale warehousing at these service centers to be

direct selling expenses (see Comment 10 in the ``Interested Party

Comments'' section of this notice). Accordingly, we deducted these

expenses. We then deducted home market indirect selling expenses

(including pre-sale movement charges) capped by the sum of U.S.

indirect selling expenses and inventory carrying costs.

For comparison to PP sales, we made a circumstance-of-sale

adjustment for differences in credit expenses, pursuant to 19 C.F.R.

353.56(a)(2). We also deducted home market commissions from FMV and

added to FMV the U.S. indirect selling expenses capped by the amount of

home market commissions.

Furthermore, we made no adjustment for the claimed imputed VAT

expenses (see Comment 4 in the ``Interested Party Comments'' section of

this notice).

For both ESP and PP sales, we deducted home market packing costs

and added U.S. packing costs, in accordance with section 773(a)(1) of

the Act.

We made adjustments, where appropriate, for difmers, in accordance

with section 773(a)(4)(C) of the Act.

We adjusted the VAT in accordance with our practice for those home

market sales for which we verified that VAT applied. (See the ``United

States Price'' section of this notice, above.)

Cost of Production

Petitioners alleged that Valbruna made home market sales during the

POI at prices below the cost of production (COP). Based on petitioners'

allegation, and in accordance with section 773(b) of the Act, we

concluded that we had reasonable grounds to believe or suspect that

sales were made below COP. Thus, we initiated an investigation to

determine whether Valbruna made home market sales of subject

merchandise at prices below its COP.

In order to determine whether home market prices were below COP

within the meaning of section 773(b) of the Act, we performed a

product-specific cost test, in which we examined whether each home

market product sold during the POI was priced below the COP of that

product. We calculated COP based on the sum of respondent's cost of

materials, fabrication, general expenses and packing costs, in

accordance with 19 C.F.R. 353.51(c). (See, e.g., Final Determination of

Sales at Not Less Than Fair Value: Saccharin from Korea (59 FR 58826;

November 15, 1994)) (Saccharin from Korea). We compared the COP for

each product to the home market price, net of movement expenses and

discounts.

We relied on submitted COP data except in the following instances.

We recalculated cost of manufacturing (COM) to exclude the change in

inventory adjustment claimed by respondent (see Comment 14 in the

``Interested Party Comments'' section of this notice). We also

recalculated general and administrative and interest expenses based on

the adjusted COM.

In accordance with section 773(b) of the Act, we also examined

whether Valbruna's home market sales were made below COP in substantial

quantities over an extended period of time, and whether such sales were

made at prices that would permit the recovery of all costs within a

reasonable period of time in the normal course of trade.

To satisfy the requirement of section 773(b)(1) of the Act that

below cost sales be disregarded only if made in substantial quantities,

the following methodology was used: For each product where less than

ten percent, by quantity, of the home market sales made during the POI

were made at prices below the COP, we included all sales of that model

in the computation of FMV. For each product where ten percent or more,

but less than 90 percent, of the home market sales made during the POI

were priced below COP, we excluded from the calculation of FMV those

home market sales which were priced below COP, provided that the below

cost sales of that product were made over an extended period of time.

Where we found that more than 90 percent of the respondent's sales of a

particular product were at prices below the COP and were made over an

extended period of time, we disregarded all sales of that product and

calculated FMV based on constructed value (CV), in accordance with

section 773(b) of the Act.

In accordance with section 773(b)(1) of the Act, in order to

determine whether below-cost sales had been made over an extended

period of time, we compared the number of months in which below-cost

sales occurred for each product to the number of months in the POI in

which that product was sold. If a product was sold in three or more

months of the POI, we did not exclude below-cost sales unless there

were below-cost sales in at least three months during the POI. When we

found that sales of a product only occurred in one or two months, the

number of months in which the sales occurred constituted the extended

period of time; i.e., where sales of a product were made in only two

months, the extended period of time was two months, where sales of a

product were made in only one month, the extended period of time was

one month. (See Saccharin from Korea and Preliminary Results and

Partial Termination of Antidumping Duty Administrative Reviews: Tapered

Roller Bearings, Four Inches or Less in Outside Diameter, and

Components Thereof, from Japan (58 FR 69336, 69338, December 10,

1993)).

Valbruna provided no indication that the disregarded sales were at

prices that would permit recovery of all costs within a reasonable

period of time and in the normal course of trade. (See 19 U.S.C.

1677b(b)(2)).

Currency Conversion

We made currency conversions based on the official exchange rates

in effect on the dates of the U.S. sales as certified by the Federal

Reserve Bank of New York. See 19 C.F.R. 353.60.

Verification

As provided in section 776(b) of the Act, we conducted verification

of the information provided by Foroni and Valbruna by using standard

verification procedures, including the examination of relevant sales,

cost and financial records, and selection of original source

documentation.

Interested Party Comments

Foroni

Comment 1:

Foroni argues that its failure to report a relatively small portion

of U.S. sales was unintentional and does not warrant the application of

adverse BIA. It contends that given the Department's thorough review of

these sales at verification, this error does not cast any doubt on the

reliability of Foroni's overall response. Foroni states that the

Department verified that the gross prices indicated on these invoices

were comparable to those observed for reported sales of the same

products. Furthermore, Foroni asserts that its underreporting of these

sales resulted in the overestimation of U.S. selling expenses and,

hence, an exaggerated dumping margin.

Foroni believes that if the Department must substitute information

for these sales, it should base such information on the overall

weighted-average margin calculated for Foroni. At worst, Foroni

believes the Department should use the highest margin found for any

U.S. sale. Foroni argues that if other information or BIA is applied in

these circumstances it should be based on either of the above-mentioned

approaches, particularly where the petition contained no information or

allegations regarding Foroni.

Petitioners assert that in calculating final dumping margins, the

Department should make certain adverse inferences based on Foroni's

failure to report all sales. Petitioners argue that, with regard to the

statement in the verification report concerning the gross prices of

these omitted sales, gross prices are not used in the dumping analysis.

Petitioners state that only after deductions to U.S. price are made and

the identical or most similar home market comparison sale is selected

can a dumping margin be calculated. Furthermore, according to

petitioners, because of the number of adjustments to USP and FMV,

transaction margins can and do vary widely. Petitioner sales believe

that the omission of a portion of U.S. sales could have a dramatic

effect on Foroni's dumping margin. Petitioners argue that the

Department should assign the highest calculated non-aberrational margin

to these unreported sales.

DOC Position

During our sales reconciliation at verification, company officials

explained that all sales records generated prior to the point of

invoicing are manually maintained, and that in order to compile a

listing of U.S. sales made during the POI based on the reported date of

sale methodology (i.e., purchase order date), company officials were

required to search their invoice files for all invoices generated

during and after the POI pursuant to purchase orders issued within the

POI.

To ensure that Foroni had accurately reported all sales to the

Department including those that may have been invoiced after the POI

pursuant to purchase orders within the POI, we conducted a manual

search of the company's 1994 invoiced file. During this exercise, the

Department discovered certain invoices related to subject merchandise

ordered within the POI which had not been reported in the U.S. sales

listing. We established the total unreported quantity and value. Upon

close examination, the verifiers concluded that the gross prices

indicated on these invoices were comparable to those for reported sales

of the same products.

When questioned, company officials stated that they were previously

unaware of this apparent omission. The officials speculated that they

had misplaced certain purchase orders in the warehouse (at the time

respondent prepared its response these orders had not been filled). The

officials further explained that, for example, with regard to one

misplaced purchase order, which accounted for the majority of the

unreported sales quantity, it had taken between five and eight months

to fill the order. Once the purchase order was filled, however, the

relevant invoices issued were filed in the company's 1994 invoice book,

in accordance with the company's normal business practice.

Consequently, our audit of the company's 1994 invoice book revealed

these unreported sales.

Given the unique circumstances noted above, we determine that

application of an adverse BIA rate to the subject sales is unwarranted.

Although the Department was under no obligation to accept or review

these sales during verification, in this case the verifiers reviewed

the invoices for these sales and concluded that the prices for these

sales were similar to those for reported sales of the same products. In

light of the circumstances surrounding the omission, the limited number

of transactions involved, and the overall accuracy of Foroni's

response, the Department determines that it is reasonable to fill this

gap with a neutral surrogate. See Replacement Parts for Self-Propelled

Bituminous Paying Equipment from Canada; Final Results of

Administrative Review of Antidumping Finding, 58 FR 15481, 15482 (March

23, 1993). Accordingly, we have assigned Foroni's overall weighted-

average calculated margin to these unreported sales.

Comment 2: Petitioners argue that the Department should reject

Foroni's assignment of unique grade codes and control numbers to sales

of 316LUG and 316LN (because they are most similar to 316L, which is

the product sold in the United States), and should account for any

differences in the products through a difmer adjustment as opposed to a

change in control number. According to petitioners, although Foroni

argues that the chemical composition of these grades is different than

for 316L, chemical composition is not one of the six principal matching

criteria in Appendix V of the Department's questionnaire. Accordingly,

petitioners assert that Foroni should not be permitted to change the

Department's matching hierarchy at such a late point in the proceeding.

Foroni requests that, for the final determination, the Department

assign a unique grade code to the three unique products previously

misidentified by Foroni. Foroni contends that its failure to assign

unique grade codes to home market sales of grades 25.22.2, 316LUG, and

316LN was an inadvertent error.

Foroni argues that, contrary to petitioners' contention, the

chemical composition of each grade of SSB is precisely what

differentiates it from any other grade. Foroni further argues that it

is not in any way attempting to alter the Department's matching

criteria, but rather to comply with them. Respondent states that

petitioners' claim that grades 315LUG and 316LN should not have unique

grade codes because these sales are most similar to sales of 316L is

irrelevant because U.S. sales of 316L can be compared to sales of

identical merchandise in Italy. Foroni states that it did not sell

grades 316LUG or 316LN in the U.S. market during the POI. Finally,

Foroni claims that the Department reviewed these product identification

errors and verified the information provided by Foroni.

DOC Position: We agree with respondent and have corrected the

misidentified grade codes in the revised home market sales listing

provided by respondent on November 30, 1994. We reviewed the

information provided by Foroni regarding the different chemical

compositions and material costs of each product prior to, as well as

during, verification and determined that grades 316LUG and 316LN are in

fact chemically different from grade 316L. Based on our review of the

chemical compositions and material costs as stated above, we determined

that these products are not the most similar to grade 316L sold in the

United States.

Furthermore, we disagree with petitioners' contention that Foroni

is attempting to alter the matching hierarchy. Grade, which takes into

account chemical composition, is in fact one of the matching criteria

in Appendix V of the questionnaire.

Comment 3: Petitioners argue that the Department should not accept

the updated shipment, payment and quantity information collected at

verification, which represents information for nine percent of the

total U.S. transactions, because this information was submitted

subsequent to the Department's deadline for submission of factual

information. Petitioners believe that in filling in these missing

dates, the Department should make certain adverse assumptions. For

example, petitioners argue that the Department should assume that the

payment date is the date of the final determination for purposes of

calculating credit.

Foroni argues that certain minor clerical errors, as well as

verified updated information, should be substituted in Foroni's sales

data prior to the final determination. Foroni states that, in any

event, the Department has requested that Foroni submit a revised sales

listing on computer disk to include this data.

DOC Position: We agree with respondent and have allowed it to

revise its U.S. sales listing to reflect the actual shipment/payment

dates and quantity data for the subject U.S. transactions where the

information had previously been missing or estimated. Respondent

presented the updated information at issue in the context of minor

clerical errors found in preparation for verification and the accuracy

of this information was verified.

Valbruna

Comment 1: Petitioners believe the home market sales for which

Valbruna reported limited data (``File 2'' sales) should be included in

the Department's final analysis. Valbruna requested that these sales be

excluded from the analysis based on its representations that the sales

would not be ``similar'' because the difmer exceeds 20 percent.

Petitioners note that the Department required Valbruna to provide

worksheets showing a difmer in excess of 20 percent for all these sales

and that respondent did not provide the worksheets.

Petitioners also compare the first four product characteristics for

File 2 sales to the home market sales that Valbruna did report as

comparable merchandise to SSB sold in the United States (``File 1''

sales). According to petitioners, this comparison shows that several

products are identical (based on the first four matching criteria) to

subject merchandise reported by Valbruna. Accordingly, petitioners

contend that File 2 sales should be included in the Department's

analysis because certain products in this file are in fact identical to

sales reported in File 1.

Respondent counters with the following arguments. First, at

verification Valbruna demonstrated that there were no sales in File 2

within the first five identical or most similar matches for Valbruna's

reported U.S. sales. Second, since the File 2 sales would never match

to a U.S. sale based on product characteristics, there was no need to

provide worksheets showing that the size of the difmer exceeds 20

percent. Third, petitioners' analysis of the File 1 and File 2 is

flawed because the analysis takes into account only four of the six

matching criteria that Valbruna reported and which the Department used

in its preliminary determination.

DOC Position: We verified the fact that these sales would not be

used for matching purposes. Therefore, consistent with our preliminary

determination, we have continued to disregard the sales in File 2 for

purposes of our margin calculation.

With regard to petitioners' argument that Valbruna failed to

provide worksheets showing difmers in excess of 20 percent for sales in

File 2, our letter of April 1, 1994, to Valbruna stated that we would

require worksheets for any sales not reported solely because of the

size of the difmer (as opposed to those that did not match to a U.S.

sale based on product characteristics). As respondent states, and as we

verified, because the sales in File 2 would never match to U.S. sales

based on the six product characteristics specified in Appendix V of the

questionnaire issued in this case, there was no need for respondent to

provide worksheets. Finally, concerning petitioners' argument that a

comparison of File 2 sales to U.S. sales shows several products with

identical matches, we agree with respondent that this argument is

incorrect because petitioners based their analysis on only the first

four product characteristics as opposed to the six point

characteristics that the Department required for matching purposes in

Appendix V of the questionnaire. As explained above, when all of the

matching characteristics are considered, the sales in question would

not be used for matching purposes.

Comment 2: Petitioners argue that the Department should revise its

dumping calculations to account for home market sales that are exempt

from VAT. Petitioners state that VAT was not collected on a portion of

the sales reported in Valbruna's sales listing. Petitioners note,

however, that the Department increased the price on all U.S. sales to

account for the VAT paid on comparison sales in Italy. Furthermore,

petitioners contend that Valbruna is inconsistent in its reporting of

customers that were exempt from VAT. Petitioners request that the

Department:

Adjust the U.S. price for the VAT only if the VAT was paid

on the comparison sales in Italy;

Adjust the U.S. price only to the extent that the VAT is

included in weighted-average FMV; or

Treat all home market sales to ``export-oriented''

companies as tax-exclusive sales and do not adjust the price for any

U.S. sales compared to such home market sales.

Respondent maintains that petitioners' argument is based on the

incorrect inference that VAT-exempt sales were incorrectly reported.

Respondent further maintains that it was not inconsistent in its

reporting of customers that were exempt from VAT because the exemption

is only allowed up to a specified ceiling. According to Valbruna,

customers can elect to use or not use their exemption on specific

sales; therefore, it is not unusual for a customer to pay VAT on some

sales and not on others. Accordingly, respondent believes that

petitioners' requests should be denied.

DOC Position: Prior to verification, respondent revised its home

market sales listing to account for VAT-exempt sales based on its

discovery of this information while preparing for verification. During

verfication we examined sales to which VAT applied as well as VAT-

exempt sales and determined that respondent correctly reported this

information. Accordingly, we have adjusted for VAT on home market sales

to which it applies and have made an adjustment to the USP only if the

VAT was paid on comparison home market sales.

Comment 3: Petitioners state that the Department should deduct cash

discounts on home market sales before calculating adjustments for home

market commissions, credit, direct selling expenses, inventory carrying

charges and imputed VAT. Petitioners claim that the Department noted in

its home market verification report that cash discounts were not

considered in these calculations.

Respondent states that, pursuant to the Department's request, it

submitted a revised computer tape on November 22, 1994, in which it

appropriately accounted for cash discounts in calculating the

adjustments listed above.

DOC Position: We agree with both parties. We used respondent's

revised sales listing, which properly accounts for cash discounts in

calculating the above-referenced adjustments, for purposes of the final

margin calculations.

Comment 4: Respondent argues that the Department should adjust FMV

for the imputed cost or income associated with the timing difference

between respondent's payment of the VAT and receipt of the VAT payment

from the customer. Respondent argues taht the imputed VAT cost or

income is a bona fide adjustment in accordance with the circumstance of

sale provisions of the antidumping statute. Respondent states that

there is no discernible difference between the applicability of these

provisions to credit expense incurred on payment of sales and the

applicability of these provisions to credit expense incurred on VAT

payments.

Additionally, respondent states that the Department verified the

income or expense incurred by Valbruna for financing its customers' VAT

payments. Therefore, according to Valbruna, petitioners' claim that the

opportunity cost was not verified is incorrect unless petitioners do

not consider these amounts to be opportunity costs. According to

respondent, petitioners' argument that imputed VAT cost or income

should be based on the net VAT paid is irrelevant because Valbruna is

virtually exempt from paying VAT taxes on raw materials and services

purchased in connection with the production of merchandise.

Petitioners contend that the Department did not verify whether

there is an opportunity cost associated with Valbruna's VAT payments to

the government. Petitioners also state that VAT law allows an offset to

the VAT payment due the government for VAT paid for raw materials and

services purchased in connection with production of merchandise.

Therefore, according to petitioners, the imputed VAT cost or income

claimed by Valbruna should be based on the net VAT paid and not the

total VAT on the sale. In addition, petitioners believe that Valbruna

should report a theoretical VAT opportunity cost for sales to the

United States if Valbruna claims imputed VAT costs for its Italian

sales.

Petitioners argue that, unless the Department calculates

opportunity costs for all associated charges, an adjustment for VAT

opportunity costs alone would be incomplete. Additionally, petitioners

maintain that allowing adjustments for some of these opportunity costs

but not for others would provide respondents with an opportunity to

manipulate dumping calculations by claiming only those opportunity

costs that would benefit a respondent.

DOC Position: We agree with petitioners and have not allowed this

adjustment, in accordance with the Department's policy outlined in the

Final Determination of Sales at Less Than Fair Value: Sulfur Dyes,

Including Sulfur Vat Dyes, from the United Kingdom, 58 FR 3253 (January

8, 1993). In that case, the Department noted that ``virtually every

charge or expense associated with price-to-price comparisons is either

prepaid or paid for at some point after the cost is incurred.

Accordingly, for each pre- or post-service payment,there is also an

opportunity cost (or gain).

Thus, to allow the type of adjustment suggested by respondent would

imply that in the future the Department would be faced with the

impossible task of trying to determine the opportunity cost (or gain)

of every freight charge, rebate and selling expense for each sale

reported in a respondent's database.'' (See also Final Determination of

Sales at Less Than Fair Value: Calcium Aluminate Cement, Clinker and

Flux from France, 59 FR 14136, 14146, March 25, 1994).

The wording of the Department's regulation providing for

circumstance of sale adjustments supports this interpretation. Section

353.56(a)(2) identifies the type of expenses or differences in

circumstances of sale which the Department normally adjusts for. These

include credit terms and similar expenses which a producer chooses to

incur or which become necessary due to the producer's business

activities. The regulations contain no indication that the Department

should consider granting an adjustment to account for a government

imposed tax such as the VAT, or for any other type of so-called

``opportunity cost.'' Similarly, the CIT has affirmed the Department's

rejection of the claim that a circumstance of sale adjustment is

warranted to offset the effect of accounts payable and imputed expenses

incurred between the seller and its suppliers. Independent Radiomic

Workers of America v. United States, Slip Op. 94-144 at 11 (CIT

September 16, 1994); Federal-Mogul Corp. v. United States, 839 F. Supp.

881, 885-86 (CIT 1993). Finally, and perhaps most fundamentally, the

CIT relied upon the Court of Appeals' decision in Daewoo Electric Co.

v. United States, 6 F. 2d 1511, 1518-19 (Fed. Cir. 1993), to hold that

the Department is simply ``not required to reach the level of precision

in quantifying circumstance of sale adjustments which [the party]

believe[d] is required.'' Federal-Mogul, 839 F. Supp. at 886. The same

conclusion applies to the present investigation.

Comment 5: Petitioners maintain that Valbruna did not report all

ocean freight costs. Petitioners cite the Department's verification

report which states that ``one of Valbruna's two shipping companies

separately reports, as a different line item on the same invoice,

freight charges and document processing fees.'' Petitioners believe

that the document processing fees which have been separately reported

have not been accounted for in Valbruna's ocean freight costs and,

therefore, these fees should be deducted from USP for the affected

sales.

Valbruna officials claim that all ocean freight costs borne by

Valbruna have been accounted for. Respondent also states that the

Department explicitly verified ocean freight expenses and found no

discrepancies.

DOC Position: We agree with respondent. We have no reason to

believe that document processing fees were not properly accounted for

simply because they were sometimes separately reported. We verified

ocean freight expenses (including document processing fees) and found

no discrepancies. Therefore, we have deducted ocean freight charges as

reported.

Comment 6: Petitioners point out that the Department's home market

verification report states, ``We noted that bank expenses were not

included in the calculation of the U.S. interest rate. Moreover, the

methodology used to calculate the home market rate was different (from)

that used to calculate the U.S. rate.'' Petitioners add that Valbruna's

home market interest rate calculation includes ``non-interest'' loan

expenses while Valbruna did not include such expenses in its U.S.

interest rate calculation. Petitioners contend the Department should

revise Valbruna's home market interest rate calculation (and all

fields, such as credit, that employ the interest rate) by using the

actual rates charged by banks, exclusive of any ``bank expense''

deductions, and should ensure that the home market interest rate

calculation otherwise is consistent with the interest rate used for

U.S. sales.

Respondent maintains that it included bank expenses in its U.S.

interest rate calculation. Accordingly, respondent claims that its

methodology for calculating its home market interest rate did not

differ from the methodology used to calculate its U.S. interest rate.

DOC Position: We incorrectly noted in our verification report that

bank charges were not included in the calculation of the U.S. interest

rate. Therefore, petitioners' comments are moot. We used the home

market and U.S. interest rates as reported and verified in our

calculations.

Comment 7: Petitioners assert that Valbruna improperly reported

part of its credit expenses on PP sales by reporting as inventory

carrying costs the financing expenses for the period from the date of

shipment from Vicenza to the date of entry at the U.S. port.

Petitioners argue that the credit period for PP sales should begin on

the date the SSB was shipped from the plant in Italy and should include

time in transit to the U.S. port. Petitioners state that Valbruna's

failure to properly report credit expenses for its PP sales resulted in

an understatement of the circumstance of sale adjustment to FMV for

differences in credit expenses.

Respondent contends that it properly reported U.S. credit expenses

for PP sales. Valbruna explains that it finances PP sales for the time

the merchandise is on the water while Avesta Sheffield, Inc. (ASI),

which markets Valbruna's SSB products in the United States, finances

these sales from the date the merchandise is shipped from the U.S. port

to the date of receipt of payment. Valbruna explains that separate

interest rates were used to calculate the credit costs during each of

these shipping phases; therefore, credit expenses is reported under two

variables in the U.S. database.

DOC Position: We have considered both the reported credit expenses,

and the costs reported by respondent as inventory carrying costs for PP

sales, as credit expenses in accordance with our normal practice of

calculating the credit period from the time the merchandise leaves the

factory until it reaches the customer.

Furthermore, with regard to the Valbruna's use of separate interest

rates for each segment of this expense, we used the two U.S. rates as

reported because we verified that a portion of the credit period is

financed by Valbruna and the remainder is financed by ASI.

Comment 8: Petitioners argue that the Department should adjust

respondent's credit calculation to correct for inconsistencies in the

method respondent used to determine the U.S. and home market credit

periods. Petitioners note that the bank deposit date marks the end of

the credit period for U.S. sales while the date the funds were actually

credited to Valbruna's account marks the end of the credit period for

home market sales. Since finds in the home market are usually credited

to the account three days after the deposit date, petitioners believe

the Department should either add three days to the credit period for

all U.S. sales or deduct three days from the credit period for all home

market sales.

Respondent maintains the Department's verification reports show

that the U.S. and home market credit periods were determined using

consistent methods. Respondent notes that the Department's home market

verification report explicitly states that Valbruna reported the date

of receipt of payment as the date that funds were actually credited by

the bank into its account. Respondent further notes that in the U.S.

sales verification report the Department traced the reported date of

receipt of payment to the date funds were actually credited by the

bank. Thus, respondent believes the Department should reject

petitioners' argument.

DOC Position: We agree with respondent that the credit periods were

consistently reported. During the ESP as well as home market

verifications we examined payment documentation for numerous sales and

confirmed that in both markets respondent reported date of payment as

the date funds were actually credited to its account by the bank.

Therefore, we have used the reported and verified payment dates in both

the U.S. and home market credit calculations.

Comment 9: During our review of individual sales transactions

during the U.S. verification, we noted a reduction in sales price for

one transaction. Petitioners contend that if ASI allowed this price

reduction then it is likely that they allowed other price reductions.

Petitioners argue that the Department should reduce the price of other

sales, where appropriate, by the amount of the price reduction

discovered at verification. Furthermore, petitioners contend that there

may be similar price reductions because the above-mentioned price

reduction was discovered from a review of only a few sales. (For

further amplification of petitioners' position see proprietary

Concurrence Memorandum dated December 16, 1994).

Valbruna maintains that ASI does not offer any such reductions in

price to its U.S. customers. Respondent explains that ASI reviewed its

sales records for such reductions in price and, to the best of its

knowledge, it allowed no other price reductions during the POI.

Respondent also maintains that the Department examined numerous sales

transactions and found no trace of any other price reductions.

Respondent notes that it has revised its U.S. sales listing to properly

account for this price reduction. (for further amplification of

respondent's position see proprietary Concurrence Memorandum dated

December 16, 1994).

DOC Position: Based on our review of numerous sales at

verification, we have no reason to believe that Valbruna offered such

price reductions to other customers. At verification we reviewed

respondent's cash posting list and noted that other such price

reductions were for nonsubject merchandise. Accordingly, we believe

that the situation as described above, and in the proprietary record,

is unique and does not reflect a general policy of granting price

reductions on U.S. sales. Moreover, this price reduction has been

accounted for in Valbruna's sales listing.

Comment 10: Respondent maintains that home market pre-sale

warehousing and inventory carrying costs are directly related to sales

of the subject merchandise. Respondent notes that the Department

treated all pre-sale expenses associated with Valbruna's home market

service centers as indirect selling expenses in the preliminary

determination because Valbruma did not adequately demonstrate that such

expenses are directly attributable to particular sales of the subject

merchandise. Respondent argues that the Department's findings at

verification now provide it with sufficient justification to determine

that Valbruna's presale expenses associated with home market service

centers are directly related to home market sales. In addition,

respondent cites the Final Determination of Sales at Less Than Fair

Value: Certain Hot-Rolled Lead and Bismuth Carbon Steel Products From

the United Kingdom, 58 FR 6207 (January 27, 1993) (Lead and Bismuth) as

well as the Final Determination of Sales at Less Than Fair Value:

Polyethylene Terephthalate Film, Sheet, and Strip from Japan, 56 FR

16300 (April 22, 1991) (PET Film) to support its argument.

Petitioners argue that the cases cited by respondent do not support

Valbruna's claim. Petitioners maintain that Valbruna calculated its

pre-sale warehousing expenses in the same manner as a respondent in the

PET Film case whose claim for direct warehousing expenses was rejected

by the Department. In addition, petitioners note that in PET Film and

Lead and Bismuth the Department stated that a requirement for allowing

pre-sale warehousing expense as a direct expense was that the stock in

question was only available for sales to those specific customers,

which is not the case for Valbruna.

Finally, petitioners request that the Department treat pre-sale

expenses incurred for Valbruna's U.S. sales as direct selling expenses

if the Department determines that Valbrunna's home market pre-sale

expenses are direct selling expenses. Petitioners argue for parallel

treatment because Valbruna manufacturers SSB for its ESP sales to the

customers' exact specifications and, like the regional warehouses in

the home market, the SSB that is inventoried by ASI is merchandise that

is restricted to servicing only those customers located in an assigned

geographic region.

DOC Position: For purposes of the final determination, we have

treated Valbrun's pre-sale warehousing/service center warehousing costs

as direct expenses. We believe that the facts in this case most closely

resemble those in Lead and Bismuth which stated that the respondent:

accepts requests from some home market customers to maintain in

inventory a certain amount of product manufactured to that

customer's specifications. Then, when the customer needs the steel,

it issues a specific purchase order for delivery out of this

customer-specific stock. Customers can thereby obtain immediate

delivery, rather than wait for the normal monthly rolling cycle.

In PET Film, also the Department accepted the respondent's

contention that its pre-sale warehousing expenses were directly related

to its home market sales since the Department verified that the

expenses were incurred and reported on the basis of specific products

sold to specific customers during the POI.

At vertification we reviewed customer purchase orders and Valbruna

order confirmations which stipulated that Valbruna was required to keep

on hand a specified amount of subject merchandise with certain

specifications for particular customers at particular service centers.

The record contains no indication that Valbruna sold this merchandise

to customers other than the ones for which the particular merchandise

was held in inventory. In fact, company officials stated that the

merchandise is usually so specialized that Valbruna would be unable to

sell it to other customers. We also observed during the plant tour

merchandise with ``open order'' tags reflecting open orders against a

customer's supply forecast for which Valbruna was required to maintain

specific inventory levels at its service centers. Furthermore, we

observed that Valbruna's accounting system tracks additional stock

going to a warehouse; it lists the quantity, but not the price, and

states the merchandise is destined for a specific customer.

This approach is consistent with the Department's determination in

other cases, such as Brass Sheet and Strip from West German; Final

Results of Antidumping Administrative Review, 56 FR 60087, 60090

(1991), which the CIT recently upheld in Hussey Copper, Ltd. v. United

States, 834 F. Supp. 413, 421 (CIT 1993). There, the Department

declined to treat expenses associated with pre-sale inventory (``buffer

stock'') as direct expenses. Based upon those facts, the court agreed,

noting in addition that information on the record indicated that

respondent withdrew ``the material for shipment to customers other than

the ones who generally purchase material out of those warehouses.''

Hussey Copper, 834 F. Supp. at 421. See also LMI-La Metalli

Industriale, S.p.A. v. United States, 912 F.2d 455, 457 (Fed. Cir.

1990).

With respect to petitioners' latter argument, ASI's warehousing

practices do not resemble Valbruna's service center warehousing

practices. ASI's customers' purchase orders do not stipulate that ASI

must keep a certain amount of merchandise available for particular

customers. Although SSB that is shipped by Valbruna and inventoried by

ASI may be restricted to servicing only those customers located in an

assigned geographic region, it is not customer-specific, as is the

merchandise stocked at Valbruna's service centers in Italy. In

addition, ASI not only warehouse Valbruna-related products, but also

sells non-subject merchandise, including Avesta Sheffield's standard

and special stainless steel products such as steel plates, sheets,

strips, wire and welded pipe and tubing. Therefore, ASI's warehousing

expenses and corresponding inventory carrying costs cannot be directly

tied to specific sales of the subject merchandise.

Comment 11: Valbruna argues that in the event its final dumping

margin is affirmative, that margin would be due solely to the use of

quarterly exchange rates. Valbruna argues that the Department is

required to use daily exchange rates whenever a dumping margin would be

created by the Department's use of quarterly exchange rates. Therefore,

Valbruna argues that the Department must use daily exchange rates in

this case. Valbruna cites Luciano Pisoni Fabbrica Accessori v. United

States, (Luciano Pisoni) 640 F. Supp. 255 (CIT 1986), in an apparent

attempt to argue that no demonstration need be made that the exchange

rates fluctuated during the POI in order to invoke this rule.

Petitioners argue that exchange rate fluctuations must be

``temporary'' to warrant the use of daily exchange rates (See Final

Determination of Sales of Less Than Fair Value: Coated Groundwood Paper

from Finland, 56 FR 56363 (November 4, 1991), and Valbruna has not

offered any evidence that there were temporary exchange rate

fluctuations during the POI.

DOC Position: We disagree with Valbruna and have continued to use

quarterly exchange rates, in accordance with the Department's

regulations and as warranted by the facts of this case. Pursuant to

section 363.60 of the Department's regulations, we rely upon the

quarterly exchange rates as published by the Federal Reserve Board.

Section 353.60(b) does provide for a special rule under which during an

investigation, the Department may rely upon daily rates if the price of

the merchandise is affected by ``temporary exchange fluctuations.'' The

Department has defined temporary exchange rate fluctuations as

occurring when the daily rate varies from the quarterly average rate by

more than five percent. However, we do not interpret the special rule

outlined in 19 C.F.R. 353.60(b) as envisioning the treatment of an

entire POI as a temporary fluctuation. See, e.g., Final Determination

of Sales at Less Than Fair Value: Certain Portable Electric Typewriters

from Singapore, 58 FR 43334 43338 (1993); Groundwood Paper.

In this case, Valbruna has not provided any evidence on the record

to demonstrate that the exchange rates fluctuated in the manner

contemplated by the Department's regulations. Accordingly, it is

appropriate to reject Valbruna's claim on this basis. Indeed, Valbruna

did not raise the issue until submitting its case brief. Moreover, we

do not agree with Valbruna's interpretation of the CIT's decision in

Luciano Pisoni. In this decision, the CIT highlighted the fact that the

respondent in that investigation had made only ten relevant home market

sales during the POI. Luciano Pisoni, 640 F. Supp, at 260. The court

stressed that based upon the facts in that case, it would have been

unfair to use quarterly exchange rates. As such, because Luciano Pisoni

can be distinguished from the present investigation on this basis, we

have not addressed any other aspect of the CIT's reasoning in Luciano

Pisoni.

Comment 12: Respondent requests that, pursuant to 19 C.F.R.

353.20(c), if the final determination is above de minimis, the

Department should transmit the output from its margin program to the

U.S. International Trade Commission to alert the Commission (ITC) to

the facts that (1) the amount of sales reflecting transaction margins

is minuscule, and (2) the transaction margins, where they exist,

reflect minimal amounts.

DOC Position: Because Valbruna's final dumping margin is de

minimis, this issue is moot.

Comment 13: Petitioners argue that Valbruna incorrectly reported

the weighted-average COP based on costs incurred during the POI.

Rather, petitioners contend that the Department should adjust

Valbruna's reported data to reflect the actual costs incurred for sales

made during the POI. Petitioners assert that the Section D

questionnaire ``covers cost of production information for the

merchandise sold in the home market/third country.'' Petitioners assert

that the appropriate reporting period for cost would be the

corresponding production months before the POI. Petitioners state that

raw material prices were higher in the period prior to the POI.

Respondent argues that it properly reported costs to reflect the

actual cost for sales during the POI. Valbruna reported that, for its

home market sales, production takes place a number of months before the

product is sold. Respondent asserts that petitioners' analysis is

erroneous, because it relies solely on dollar denominated costs of

stainless steel scrap.

DOC Position: The Department agrees with respondent. Section D of

the questionnaire clearly requests weighted-average production data

based on costs incurred during the POI. The Department has departed

from this general policy only when unique circumstances arise, such as

when there was no production during the POI. Furthermore, companies,

frequently hold inventory for a period of time between production and

shipment and raw materials are held for a period of time between

purchase and production. An average inventory holding period or length

of time between order and production are only estimates. Sales are

sometimes made from existing stock or may be produced to order, or even

a combination of both.

Petitioners raised the issue for the first time in the pre-

verification comments--too late in the investigation for the Department

to perform the appropriate analysis to determine whether a change in

the cost data reporting period is warranted. Furthermore, if the

Department was to accept petitioners' argument, the CV data would be

based on a different accounting period than the COP data, effectively

doubling the burden on all parties. Accordingly, absent strong evidence

to the contrary, the Department assumes that the cost structure

prevailing during the POI is representative and can be sued to

calculate COP.

Comment 14: Petitioners argue that the Department should reject

Valbruna's adjustment for the change in inventory value. Petitioners

assert that the inventory adjustment claim is not consistent with the

inventory policy stated in Valbruna's financial statements.

Furthermore, the calculations obtained by the Department during

verification show that the claim has no bearing on the actual COP for

the SSB sold during the POI. The analysis does not represent an

adjustment to the COP; it merely represents a comparison of the cost of

materials at the beginning of the POI and the end of the POI. The cost

verification report states that Valbruna's management cost accounting

system calculates material costs on a current basis and excludes the

effect of beginning and ending inventory.

Respondent argues that it properly accounted for changes in

inventory. Respondent states that the cost system accumulates material

costs on a current cost basis, and that the financial accounting system

calculates material costs on a historical cost basis. The financial

accounting system takes into account changes in inventory, unlike the

cost accounting system. According to Valbruna, although petitioners

complain that Valbruna inaccurately valued the change in inventory

adjustment, if Valbruna would have used average quantities in the POI,

rather than quantities at the end of the POI, the resulting adjustment

would have been more favorable to Valbruna, as demonstrated at

verification.

DOC Position: The Department agrees with petitioners. Although the

cost methodology used by Valbruna calculates the current production

costs and fails to include the difference in price between the

beginning and ending inventories and the average POI price, the

adjustment is incorrect for two reasons. First, because the beginning

and ending finished goods inventory was included in the calculation,

the adjustment theoretically converts the cost of manufacturing, which

is what should be reported, into cost of goods sold. Secondly, Valbruan

uses the last-in-first-out inventory method for financial statement

purposes which results in something similar to current costing.

Therefore, because the methodology followed by Valbruna, absent the

inventory adjustment, closely reflects the methodologies used for

financial statement purposes, we disallowed the adjustment.

Discontinuance of Suspension of Liquidation

In accordance with section 735(c)(2)(A) of the Act, because the

margins are de minis, we are directing the Customs Service to

discontinue the suspension of liquidation of all entries of SSB from

Italy, that were entered, or withdrawn from warehouse, for consumption

on or after August 4, 1994. Accordingly, all bonds should be released

and estimated antidumping duties deposited should be refunded.

------------------------------------------------------------------------

Margin

Manufacturer/producer/exporter percent

------------------------------------------------------------------------

Acciaierie Valbruna S.r.l..................................... 0.14

Foroni S.p.A.................................................. 0.23

------------------------------------------------------------------------

ITC Notification

In accordance with section 735(d) of the Act, we have notified the

ITC of our determination.

Notification to Interested Parties

This notice serves as the only reminder to parties subject to

administrative protective order (APO) in this investigation of their

responsibility covering the return or destruction of proprietary

information disclosed under APO in accordance with 19 C.F.R. 353.34(d).

Failure to comply is a violation of the APO.

This determination is published pursuant to section 735(d) of the

Act (19 U.S.C. 1673d(d)) and 19 C.F.R. 353.20(a)(4).

Dated: December 19, 1994.

Susan G. Esserman,

Assistant Secretary for Import Administration.

[FR Doc. 94-31805 Filed 12-27-94; 8:45 am]

BILLING CODE 3510-DS-M