Certain Welded Stainless Steel Pipe From Taiwan; Preliminary Results of Administrative Review

DEPARTMENT OF COMMERCE

[A-583-815]

Certain Welded Stainless Steel Pipe From Taiwan; Preliminary

Results of Administrative Review

AGENCY: Import Administration, International Trade Administration,

Department of Commerce.

ACTION: Notice of Preliminary Results of Administrative Review.

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SUMMARY: In response to a request by respondent Ta Chen Stainless Pipe

Co., Ltd. (Ta Chen), the Department of Commerce (the Department) is

conducting an administrative review of the antidumping duty order on

certain welded stainless steel pipe from Taiwan (A-583-815). This

review covers one manufacturer/exporter of the subject merchandise to

the United States during the period December 1, 1994 through November

30, 1995.

We preliminarily determine that sales of welded stainless steel

pipe (WSSP) have been made below the normal value (NV). If these

preliminary results are adopted in our final results of administrative

review, we will instruct the U.S. Customs Service to assess antidumping

duties equal to the difference between United States price and NV.

Interested parties are invited to comment on these preliminary results.

Parties who submit comments are requested to submit with the argument:

(1) A statement of the issues; and (2) a brief summary of the argument.

EFFECTIVE DATE: January 10, 1997.

FOR FURTHER INFORMATION CONTACT: Robert James at (202) 482-5222 or John

Kugelman at (202) 482-0649, Antidumping and Countervailing Duty

Enforcement Group III, Import Administration, International Trade

Administration, U.S. Department of Commerce, 14th Street and

Constitution Avenue, NW., Washington, DC 20230.

APPLICABLE STATUTE AND REGULATIONS: Unless otherwise indicated, all

citations to the Tariff Act of 1930, as amended (the Tariff Act), are

to the provisions effective January 1, 1995, the effective date of the

amendments made to the Tariff Act by the Uruguay Round Agreements Act.

In addition, unless otherwise indicated, all citations to the

Department's regulations are to the current regulations, as amended by

the interim regulations published in the Federal Register on May 11,

1995 (60 FR 25130).

SUPPLEMENTARY INFORMATION:

Background

On December 30, 1992, the Department published in the Federal

Register the antidumping duty order on WSSP from Taiwan (57 FR 62300).

On December 4, 1995, the Department published the notice of

``Opportunity to Request Administrative Review'' for the period

December 1, 1994 through November 30, 1995 (60 FR 62070). In accordance

with 19 CFR 353.22(a)(1) (1995), Ta Chen requested that we conduct a

review of its sales. On February 1, 1996, we published in the Federal

Register a notice of initiation of this antidumping duty administrative

review covering the period December 1, 1994 through November 30, 1995

(61 FR 3670).

Because it was not practicable to complete this review within the

normal time frame, on September 12, 1996, we published in the Federal

Register our notice of extension of time limits for this review (61 FR

48126). As a result, we extended the deadline for these preliminary

results to December 30, 1996. The deadline for the final results will

continue to be 120 days after publication of these preliminary results.

Scope of the Review

The merchandise subject to this administrative review is certain

welded austenitic stainless steel pipe (WSSP) that meets the standards

and specifications set forth by the American Society for Testing and

Materials (ASTM) for the welded form of chromium-nickel pipe designated

ASTM A-312. The merchandise covered by the scope of the order also

includes austenitic welded stainless steel pipes made according to the

standards of other nations which are comparable to ASTM A-312.

WSSP is produced by forming stainless steel flat-rolled products

into a tubular configuration and welding along the seam. WSSP is a

commodity product generally used as a conduit to transmit liquids or

gases. Major applications for WSSP include, but are not limited to,

digester lines, blow lines, pharmaceutical lines, petrochemical stock

lines, brewery process and transport lines, general food processing

lines, automotive paint lines, and paper process machines.

Imports of WSSP are currently classifiable under the following

Harmonized Tariff Schedule of the United States (HTS) subheadings:

7306.40.5005, 7306.04.5015, 7306.40.5040, 7306.40.5065, and

7306.40.5085. Although these subheadings include both pipes and tubes,

the scope of this investigation is limited to welded austenitic

stainless steel pipes. Although the HTS subheadings are provided for

convenience and Customs purposes, our written description of the scope

of this order is dispositive.

The period for this review is December 1, 1994 through November 30,

1995. This review covers one manufacturer/exporter, Ta Chen.

Use of Facts Available

We preliminarily determine that the use of facts available is

appropriate for a portion of Ta Chen's U.S. sales, in accordance with

section 776(a) of the Tariff Act, because Ta Chen mischaracterized a

portion of its U.S. sales as EP sales when, in fact, these are properly

considered Constructed Export Price (CEP) sales. Ta Chen reported in

its initial questionnaire response of April 30, 1996 that all of its

U.S. sales were EP sales with each reported sale being made to an

unaffiliated customer. However, in its November 12, 1996, supplemental

questionnaire response, Ta Chen provided additional information with

respect to one U.S. customer which clearly indicates that Ta Chen and

this customer were affiliated within the meaning of section 771(33) of

the Tariff Act.

Section 771(33)(G) of the Tariff Act holds that two parties shall

be considered ``affiliated'' if one party ``controls'' the other. One

party controls another if the party ``is legally or operationally in a

position to exercise restraint or direction over the other person.''

From the information provided by Ta Chen, we have preliminarily

determined that Ta Chen was ``operationally in a position to exercise

restraint or direction over'' the U.S. customer at issue. Ta Chen

reported that it controlled this customer's disbursements and had

physical custody of its signature stamp used to

[[Page 1436]]

execute checks and other instruments. The two parties also shared

common sales department personnel. Further, Ta Chen had full and

complete access, via computer modem, to this customer's accounting

system, including its accounts receivable, accounts payable, payroll,

and other company books. Ta Chen also indicated that its president

participated directly in negotiating the terms of certain sales this

customer made to subsequent purchasers of WSSP in the United States.

Finally, this customer offered its accounts receivable and inventory as

security for a line of credit obtained from a local bank by Ta Chen

International (TCI), Ta Chen's wholly-owned U.S. subsidiary. Thus, this

customer placed its continued ability to operate in the hands of a

putatively unaffiliated party, TCI. Based upon the totality of evidence

before the Department in this matter, we preliminarily determine that

Ta Chen effectively exercised operational control over this putatively

unaffiliated customer. See the public version of the Department's

Preliminary Analysis Memorandum to the File, on file in Room B-099 of

the Main Commerce Building.

Since Ta Chen reported its sales prices to this affiliated

customer, and not the customer's sales prices to the first unaffiliated

customer in the United States, Ta Chen failed to provide the Department

with a complete and reliable listing of its U.S. sales. We

preliminarily determine, therefore, pursuant to section 776(a)(2) of

the Tariff Act, that Ta Chen withheld information requested by the

Department by failing to report all of its sales to its first

unaffiliated customers in the United States. In selecting the facts

available, section 776(b) of the Tariff Act provides that where, as

here, an interested party has failed to cooperate by not acting to the

best of its ability to comply with a request for information, the

Department may use an inference that is adverse to the interests of

that party in selecting among the facts available. Section 776(b) also

authorizes the Department to use as adverse facts available information

derived from the petition, the final determination, a previous

administrative review, or other information placed on the record.

Because information from prior proceedings constitutes secondary

information, section 776(c) of the Tariff Act provides that the

Department shall, to the extent practicable, corroborate that secondary

information from independent sources reasonably at its disposal. The

Statement of Administrative Action (SAA) notes that ``corroborate''

means simply that the Department will satisfy itself that the secondary

information to be used has probative value (see H. Doc. 316, Vol. 1,

103d Cong., 2d Sess. 870 (1996)). To corroborate secondary information,

the Department will, to the extent practicable, examine the reliability

and relevance of the information to be used. However, unlike for other

types of information, such as input costs or selling expenses, there

are no independent sources for dumping margins. Thus, when in an

administrative review the Department chooses as facts available a

dumping margin from a prior segment of the proceeding, it is not

necessary to question the reliability of the margin for the time

period. With respect to the relevance aspect of corroboration, however,

the Department will consider information reasonably at its disposal as

to whether there are circumstances that would render a margin

irrelevant. In this case, there are no circumstances present to

indicate that the selected margin is not appropriate as facts

available. In this case, we have used the highest rate from any prior

segment of the proceeding, 31.9 percent, the highest rate from the

less-than-fair-value (LTFV) determination, for Ta Chen's sales made

through this particular U.S. customer.

Export Price

Ta Chen reported in its initial and supplemental questionnaire

responses that all of its U.S. sales were first sold to unrelated

purchasers prior to importation into the United States. A substantial

portion of these sales were made through Ta Chen's U.S. subsidiary,

TCI. Ta Chen claims that for each of these sales, TCI acted merely as a

``facilitator,'' handling sales- and Customs-related paper work. In

each instance, according to Ta Chen, the price and quantity of the U.S.

sale were determined prior to importation into the United States. The

remainder of Ta Chen's U.S. sales were to an unrelated importer, who

subsequently resold the merchandise after importation into the United

States. Therefore, with the exception noted above under ``Use of Facts

Available,'' in calculating U.S. price we used export price (EP) for

all of Ta Chen's sales, as defined in section 772(a) of the Tariff Act.

We calculated EP as the packed, delivered or ex-U.S. port price to

unaffiliated purchasers in the United States. In accordance with

section 772(c)(2)(A) of the Tariff Act, we reduced this price by

Taiwanese pre-sale inland freight, international ocean freight, marine

insurance, Taiwanese brokerage and handling, U.S. brokerage and

handling, U.S. duty, and U.S. inland freight. Where appropriate, we

also reduced the EP by Taiwanese and U.S. bank charges.

Duty Absorption

On July 16, 1996, petitioners requested that the Department

determine whether Ta Chen had absorbed antidumping duties during the

period of review (POR) pursuant to section 751(a)(4) of the Tariff Act.

Section 751(a)(4) requires the Department, if requested, to determine,

during an administrative review initiated two years or four years after

publication of the order, whether antidumping duties have been absorbed

by a foreign producer or exporter subject to the order, if the subject

merchandise is sold in the United States through an importer who is

affiliated with such foreign producer or exporter. Section 751(a)(4)

was added to the Tariff Act by the URAA. The Department's interim

regulations do not address this provision of the Tariff Act.

For transition orders as defined in section 751(c)(6)(C) of the

Tariff Act, i.e., orders in effect as of January 1, 1995, section

351.213(j)(2) of the Department's proposed antidumping regulations

provides that the Department will make a duty absorption determination,

if requested, for any administrative review initiated in 1996 or 1998.

See Notice of Proposed Rulemaking, 61 FR 7308, 7366 (February 27,

1996). The preamble to the proposed antidumping regulations explains

that reviews initiated in 1996 will be considered initiated in the

second year and reviews initiated in 1998 will be considered initiated

in the fourth year. Id. at 7317. Although these proposed antidumping

regulations are not yet binding upon the Department, they do constitute

a public statement of how the Department expects to proceed in applying

section 751(a)(4) of the amended statute. This approach assures that

interested parties will have the opportunity to request a duty

absorption determination on entries for which the second and fourth

years following an order have already passed, prior to the time for

sunset review of the order under section 751(c). Because the order on

WSSP from Taiwan has been in effect since 1992, this qualifies as a

transition order. Therefore, based on the policy stated above, the

Department will first consider a request for an absorption

determination during a review initiated in 1996. This being a review

initiated in 1996, we are making a duty-absorption determination as

part of this segment of the proceeding.

The statute provides for a determination on duty absorption if the

[[Page 1437]]

subject merchandise is sold in the United States through an affiliated

importer. In this case, TCI, Ta Chen's wholly owned subsidiary, is the

importer of record for a majority of Ta Chen's U.S. sales, i.e., the

exporter and the importer are the same entity. Therefore, the importer

and the exporter are ``affiliated'' within the meaning of 751(a)(4).

Furthermore, we have preliminarily determined that there is a dumping

margin for Ta Chen on 13.47 percent (by quantity) of its U.S. sales

during the POR. In addition, we cannot conclude from the record that

the unaffiliated purchaser in the United States will pay the ultimately

assessed duty. Under these circumstances, therefore, we preliminarily

find that antidumping duties have been absorbed by Ta Chen on 13.57

percent of its U.S. sales.

Normal Value

A. Viability

Based upon (i) our comparison of the aggregate quantity of home

market and U.S. sales, (ii) the absence of any information that a

particular marketing situation in Taiwan does not permit a proper

comparison, and (iii) the fact that Ta Chen's quantity of sales in the

home market exceeded five percent of its sales to the U.S. market, we

determined that the quantity of foreign like product Ta Chen sold in

Taiwan was sufficient to permit a proper comparison with the sales of

subject merchandise to the United States pursuant to section 773(a) of

the Tariff Act. Therefore, in accordance with section 773(a)(1)(B)(i)

of the Tariff Act, we based NV on the prices at which the foreign like

products were first sold for consumption in the exporting market, i.e.,

Taiwan.

B. Cost-of-Production Analysis

Because we disregarded sales below the cost of production in the

LTFV investigation (the most-recently completed segment of these

proceedings), we have reasonable grounds to believe or suspect that

sales of the foreign like product under consideration for determining

NV in this review may have been at prices below the cost of production

(COP), as provided in section 773(b)(2)(A)(ii) of the Tariff Act (see

Final Determination of Sales at Less Than Fair Value; Certain Welded

Stainless Steel Pipe from Taiwan, 57 FR 53705 (November 12, 1992)).

Therefore, pursuant to section 773(b)(1) of the Tariff Act, we

initiated a COP investigation of sales by Ta Chen (see Memorandum to

the File, dated February 13, 1996, available in Room B-099 of the Main

Commerce Building).

In accordance with section 773(b)(3) of the Tariff Act, we

calculated COP based on the sum of materials and fabrication employed

in producing the foreign like product, plus selling, general, and

administrative expenses (SG&A) and the cost of all expenses incidental

to placing the foreign like product in condition packed ready for

shipment. We relied on the home market sales and COP information Ta

Chen provided in its questionnaire responses.

After calculating COP, we tested whether home market sales of

subject WSSP were made at prices below COP within an extended period of

time and whether such prices permit the recovery of all costs within a

reasonable period of time. We compared model-specific COPs to the

reported home market prices less any applicable movement charges, and

post-sale price adjustments (reported as discounts).

Pursuant to section 773(b)(2)(C) of the Tariff Act, where less than

twenty percent of Ta Chen's home market sales for a model were at

prices less than the COP, we did not disregard any below-cost sales of

that model because we determined that the below cost sales were not

made within an extended period of time in ``substantial quantities.''

Where twenty percent or more of Ta Chen's home market sales were at

prices less than the COP, we determined that such sales were made

within an extended period of time in substantial quantities in

accordance with section 773(b)(2) (B) and (C) of the Tariff Act. To

determine whether such sales were at prices which would not permit the

full recovery of all costs within a reasonable period of time, in

accordance with section 773(b)(2)(D) of the Tariff Act, we compared

home market prices to the weighted-average COPs for the POR.

The results of our cost test for Ta Chen indicated that for certain

home market models less than twenty percent of the sales of the model

were at prices below COP. We therefore retained all sales of these

models in our analysis and used them as the basis for determining NV.

Our cost test for Ta Chen also indicated that within an extended period

of time (one year, in accordance with section 773(b)(2)(B) of the

Tariff Act) for certain other home market models more than twenty

percent of the home market sales were at prices below COP which would

not permit the full recovery of all costs within a reasonable period of

time. In accordance with section 773(b)(1) of the Tariff Act, we

therefore excluded the below-cost sales of these models from our

analysis and used the remaining above-cost sales as the basis for

determining NV.

C. Product Comparisons

We compared Ta Chen's U.S. sales with contemporaneous sales of the

foreign like product in the home market. We considered pipe identical

based on product nomenclature and considered specifications/alloy,

nominal pipe size, and wall thickness in determining the most similar

types of pipe. We used a twenty percent cap in reported differences in

merchandise as the maximum difference in cost allowable for similar

merchandise. For purposes of these preliminary results, we have used

the difference-in-merchandise information Ta Chen submitted with its

supplemental questionnaire response of November 12, 1996.

D. Level of Trade

As set forth in section 773(a)(1)(B)(i) of the Tariff Act and in

the SAA at 829 through 831, to the extent practicable, the Department

will calculate NV based on sales at the same level of trade as the U.S.

sales. When we are unable to find sales of the foreign like product in

the comparison market at the same level of trade as the U.S. sale, we

may compare U.S. sales to sales at a different level of trade in the

comparison market.

In accordance with section 773(a)(7)(A) of the Tariff Act, if sales

at allegedly different levels of trade are compared, we will adjust the

NV to account for the difference in levels of trade if two conditions

are met. First, there must be differences between the actual selling

activities performed by the exporter at the level of trade of the U.S.

sale and the level of trade of the comparison market sale used to

determine NV. Second, the differences between levels of trade must

affect price comparability as evidenced by a pattern of consistent

price differences between sales at the different levels of trade in the

market in which NV is determined.

In order to determine that there is a difference in level of trade,

the Department must find that two sales have been made at different

stages of marketing, or the equivalent. Different stages of marketing

necessarily involve differences in selling functions, but differences

in selling functions (even substantial differences) are not, in and of

themselves, sufficient to establish a difference in the level of trade.

Similarly, seller and customer descriptions (such as ``distributor''

and ``wholesaler''), while useful in identifying different levels of

trade, are insufficient to establish that there is, in fact, a

difference in the level of trade.

[[Page 1438]]

To implement these principles in this review, we asked Ta Chen to

provide detailed information regarding its selling activities/functions

at each phase of marketing, and to establish any claimed level of trade

based on these activities. In order to determine whether separate

levels of trade actually existed within or between the U.S. and home

markets, we reviewed the selling activities associated with each phase

of marketing claimed by Ta Chen. Pursuant to section 773(a)(1)(B)(i) of

the Tariff Act and the SAA at 827, in identifying levels of trade for

EP and home market sales we considered the selling functions reflected

in the starting price before any adjustments.

We considered all types of selling activities performed by Ta Chen

in our review of Ta Chen's questionnaire responses. We found that no

single selling function in the pipe industry was sufficient to indicate

that a separate level of trade existed (see Notice of Proposed

Rulemaking and Request for Public Comments, 61 FR 7307, 7348 (February

27, 1996)). In addition, in determining whether separate levels of

trade existed in or between the U.S. and home markets, we analyzed the

selling activities associated with the stages of marketing Ta Chen

reported and expected the functions and activities of the seller to be

similar if, as in the instant review, Ta Chen claimed the levels of

trade to be the same.

Ta Chen reported two stages of marketing in the home market (to

unrelated distributors and end users) and a single phase of marketing

in the United States (to unrelated distributors). With respect to the

home market, Ta Chen claimed that its two stages of marketing

constituted a single level of trade. Based upon our examination of

information supplied by Ta Chen in its original and supplemental

questionnaire responses, we agree that only one level of trade existed

for Ta Chen in the home market.

For its U.S. sales, Ta Chen reported a single stage of marketing,

i.e., distributors. In determining whether, in fact, a single stage of

marketing existed, we examined the selling functions as reflected in

the starting price to the unaffiliated U.S. customer. While TCI

processed the paperwork and provided certain selling functions for the

majority of Ta Chen's U.S. sales, the remainder of these sales involved

direct contact between the unaffiliated U.S. customer and Ta Chen

without TCI's ``facilitation.'' We find preliminarily, however, that

TCI provided very limited selling functions for those sales TCI

facilitated and, therefore, found no significant differences in selling

functions between sales through either channel. As a result, we

preliminarily agree with Ta Chen that Ta Chen's EP sales constitute a

single level of trade. We have requested additional clarification from

Ta Chen on this point, and will incorporate this information in our

final results of review.

When we compared Ta Chen's sales at its EP level of trade to its

home market level of trade, we found that the record indicated that Ta

Chen provided little or no strategic or economic planning, market

research, engineering services, advertising, after-sales services, or

post-sale warehousing at either the EP or home market level of trade.

Ta Chen reported that it provided the ``same'' degree of technical

assistance at both the EP and home market level of trade. All packing

expenses at either level were borne by Ta Chen; freight and delivery

arrangements varied between the two markets in that U.S. movement

expenses on certain U.S. sales were incurred by TCI. Based upon our

analysis of the selling functions performed by Ta Chen in both markets,

the similarities lead us to agree preliminarily that the level of trade

of Ta Chen's EP and home market sales is the same.

E. Home Market Price

While we found below-cost home market sales for Ta Chen in this

review, Ta Chen's remaining home market sales at or above cost were

sufficient to serve as the basis for NV.

We based home market prices on the packed, ex-factory or delivered

prices to unaffiliated purchasers in the home market. We made

adjustments for differences in packing and for movement expenses in

accordance with sections 773(a)(6)(A) and (B) of the Tariff Act. In

addition, we made adjustments for differences in cost attributable to

differences in physical characteristics of the merchandise pursuant to

section 773(a)(6)(C)(ii) of the Tariff Act, and for differences in

circumstances of sale (COS) in accordance with section

773(a)(6)(C)(iii) of the Tariff Act and 19 CFR 353.56. We made further

adjustments by deducting home market direct selling expenses and adding

U.S. direct selling expenses. Finally, where the comparison EP sale

involved a commission, we increased home market price by the amount of

this commission and subtracted home market indirect selling expenses up

to the amount of the U.S. commission, as provided at 19 CFR 353.56(b).

Fair Value Comparison

To determine whether Ta Chen made sales of subject WSSP in the

United States at prices that were less than fair value, we compared the

EP to NV, as described in the ``United States Price'' and ``Normal

Value'' sections of this notice. In accordance with section 777A(d)(2)

of the Tariff Act, we calculated monthly weighted-average prices for NV

and compared these monthly averages to individual U.S. sales

transactions.

Preliminary Results of Review

As a result of our review, we preliminarily determine the weighted-

average margin for Ta Chen for the period December 1, 1994 through

November 30, 1995 is 2.65 percent.

Parties to these proceedings may request disclosure within five

days of the date of publication of this notice and may request a

hearing within ten days of publication. Any hearing, if requested, will

be held 44 days after the date of publication, or the first business

day thereafter. Case briefs and/or written comments from interested

parties may be submitted no later than 30 days after the date of

publication. Rebuttal briefs and rebuttals to written comments, limited

to issues raised in the case briefs and comments, may be submitted no

later than 37 days after the date of publication of this notice.

Parties who submit arguments in these proceedings are requested to

submit with the argument (1) a statement of the issues and (2) a brief

summary of the argument. The Department will issue final results of

these administrative reviews, including the results of our analysis of

the issues in any such written comments or at a hearing, within 180

days of issuance of these preliminary results.

The Department shall determine, and the U.S. Customs Service shall

assess, antidumping duties on all appropriate entries. Individual

differences between U.S. price and NV may vary from the percentage

stated above. The Department will issue appraisement instructions

directly to Customs.

Furthermore, the following deposit requirements will be effective

upon completion of the final results of this administrative review for

all shipments of WSSP from Taiwan entered, or withdrawn from warehouse,

for consumption on or after the publication of the final results of

this administrative review, as provided in section 751(a)(1) of the

Tariff Act:

(1) The cash deposit rate for Ta Chen will be the rate established

in the final results of this administrative review;

(2) For previously reviewed or investigated companies other than Ta

Chen, the cash deposit rate will

[[Page 1439]]

continue to be the company-specific rate published for the most recent

period;

(3) If the exporter is not a firm covered in this review, a prior

review, or the less-than-fair-value investigation, but the manufacturer

is, the cash deposit rate will be the rate established for the most

recent period for the manufacturer of the merchandise; and

(4) If neither the exporter nor the manufacturer is a firm covered

in this or any previous review conducted by the Department, the cash

deposit rate will be 19.84 percent. See Amended Final Determination and

Antidumping Duty Order; Certain Welded Stainless Steel Pipe From

Taiwan, 57 FR 62300 (December 30, 1992).

All U.S. sales by the respondent Ta Chen will be subject to one

deposit rate according to the proceeding. The cash deposit rate has

been determined on the basis of the selling price to the first

unrelated customer in the United States. For appraisement purposes,

where information is available, we will use the entered value of the

subject merchandise to determine the appraisement rate.

This notice serves as preliminary reminder to importers of their

responsibility to file a certificate regarding the reimbursement of

antidumping duties prior to liquidation of the relevant entries during

this review period. Failure to comply with this requirement could

result in the Secretary's presumption that reimbursement of the

antidumping duties occurred and the subsequent assessment of double

antidumping duties. This administrative review and this notice are in

accordance with section 751(a)(1) of the Tariff Act (19 U.S.C.

1675(a)(1)) and 19 CFR 353.22.

Dated: December 30, 1996.

Robert S. LaRussa,

Acting Assistant Secretary for Import Administration.

[FR Doc. 97-633 Filed 1-9-97; 8:45 am]

BILLING CODE 3510-DS-P