Polyethylene Terephthalate Film, Sheet, and Strip From the Republic of Korea; Final Results of Antidumping Duty Administrative Review

DEPARTMENT OF COMMERCE

[A-580-807]

Polyethylene Terephthalate Film, Sheet, and Strip From the

Republic of Korea; Final Results of Antidumping Duty Administrative

Review

AGENCY: Import Administration, International Trade Administration,

Department of Commerce.

ACTION: Notice of Final Results of Antidumping Duty Administrative

Review.

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SUMMARY: On March 6, 1998, the Department of Commerce (the Department)

published the preliminary results of administrative review of the

antidumping duty order on polyethylene terephthalate film sheet, and

strip (PET film) from the Republic of Korea. The review covers one

manufacturer/exporter of the subject merchandise to the United States

and the period June 1, 1996 through May 31, 1997.

As a result of comments we received, the dumping margin has changed

from that presented in our preliminary results.

EFFECTIVE DATE: July 10, 1998.

FOR FURTHER INFORMATION CONTACT:

Michael J. Heaney, or Linda Ludwig, AD/CVD Enforcement Group III,

Import Administration, International Trade Administration, U.S.

Department of Commerce, 14th Street and Constitution Avenue, NW,

Washington, DC 20230, telephone: (202) 482-4475, or 3833, respectively.

SUPPLEMENTAL INFORMATION:

Background

On March 6, 1998, (63 FR 11214), the Department published the

preliminary results of administrative review and recission in part of

the antidumping duty order on PET film from the Republic of Korea, 56

FR 25669, (June 5, 1991).

This review covers one manufacturers/exporter of the subject

merchandise to the United States: SKC Co., Ltd, (SKC), and the period

June 1, 1996 through May 31, 1997.

The Department has concluded this review in accordance with section

751 of the Tariff Act of 1930, as amended (the Tariff Act).

Scope of the Review

Imports covered by this review are shipments of all gauges of raw,

pretreated, or primed polyethylene terephthalate film, sheet, and

strip, whether extruded or coextruded. The films excluded from this

review are metallized films and other finished films that have had at

least one of their surfaces modified by the application of a

performance-enhancing resinous or inorganic layer of more than 0.00001

inches (0.254 micrometers) thick. Roller transport cleaning film which

has at least one of its surfaces modified by the application of 0.5

micrometers of SBR latex has also been ruled as not within the scope of

the order.

PET film is currently classifiable under Harmonized Tariff Schedule

(HTS) subheading 3920.62.00.00. The HTS subheading is provided for

convenience and for U.S. Customs purposes. The written description

remains dispositive as to the scope of the product coverage.

The review covers the period June 1, 1996 through May 31, 1997.

Applicable Statute and Regulations

Unless otherwise indicated, all citations to the Tariff Act of

1930, as amended (the Tariff Act), are references 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 references to the Department's regulations are

to 19 CFR part 353 (1997).

Analysis of Comments Received

We invited interested parties to comment on the preliminary results

of this administrative review. On April 6, 1998, we received timely

comments from the respondent, SKC and the petitioners (E.I. DuPont de

Nemours & Company, Hoechst Celanese Corporation, and ICI America's

Inc.) (Petitioners). SKC and the Petitioners submitted their reply

briefs on April 13, 1998 and April 14, 1998 respectively.

Comment 1: SKC contends that the payment dates for some of the U.S.

sales reported in its December 8, 1997 letter were incorrectly

transcribed, thereby overstating its U.S. credit expense. SKC contends

that the Department should accept the corrected payment dates set forth

in its March 16, 1998 letter. SKC further contends that the correct

payment dates are discernible from the record, and that the error in

question is clearly clerical in nature.

SKC argues that the Department's established practice is to accept

corrections following the preliminary results when (1) the error in

question is demonstrated to be a clerical error; (2) the corrective

documentation provided in support of the clerical error allegation is

reliable; (3) the respondent availed itself of the earliest reasonable

opportunity to correct the error; (4) the clerical error allegation,

and any corrective documention, is submitted to the Department no later

than the due date for the respondent's administrative case brief; (5)

the clerical error does not entail a substantial revision of the

response; and (6) the respondent's corrective documentation does not

contradict information previously determined to be accurate at

verification. (See e.g., Certain Fresh Cut Flowers from Colombia, Final

Results of Antidumping Duty Administrative Reviews, (Colombian Flowers)

61 FR 42833, 42834 (August 19, 1996).)

SKC asserts that the corrected information meets the criteria

outlined in Colombian Flowers because the error contained in its

December 8, 1997 response is demonstrably clerical, can reliably be

discerned from the data on

[[Page 37335]]

record, and was brought immediately to the Department's attention upon

receipt by SKC of its disclosure materials. Moreover, SKC argues that

correction of this error would not entail a substantial revision of its

response. Finally, SKC notes that the data provided in its March 16,

1998 submission does not contradict any previously verified

information.

Department's Position: We agree with SKC. The Department will

accept a respondent's clerical corrections so long as it fulfills the

criteria first articulated in Colombian Flowers. (See Tapered Roller

Bearings and Parts Thereof, Finished and Unfinished, From Japan, and

Tapered Roller Outside Diameter, and Components Thereof, From Japan,

Final Results of Antidumping Duty Administrative Reviews and

Termination in Part, 20585, 20610 (April 27, 1998) (citing NTN Bearing

Corp. v. United States, 74 F.3d 1204 (Fed. Cir. 1995) and Colombian

Flowers).) The formatting error resulted in the uniform transcription

of ``9'' as ``0'' for certain U.S. sales. For example, payments made on

March 5, 1997 were incorrectly read as ``070305'' rather than

``970305''. This error is clearly clerical in nature. Further, SKC

provided reliable documentation supporting its correction of that

clerical error. SKC corrected the clerical error five days after

receipt of its disclosure materials, and provided the corrective

documentation prior to submission of its case brief. Finally,

correction of this clerical error does not constitute a substantial

revision of SKC's response, and does not contradict previously verified

information. Thus, consistent with the position established in

Colombian Flowers, we have used SKC's corrected payment dates in these

final results.

Comment 2: Consistent with previous administrative reviews of this

case, SKC objects to the Department's equal allocation of scrap costs

to A-grade and B-grade film. SKC contends that its allocation

methodology is reasonable and consistent with widely accepted

accounting concepts. In support of its argument, SKC cites to the March

5, 1996 case brief filed in the second and third administrative reviews

of this case. (See Attachment 1 of SKC's April 6, 1998 case brief.)

SKC states that allocating the cost of scrap film equally to A-

grade and B-grade films improperly overstates the cost of B-grade films

while understating the cost of A-grade films. SKC contends that its

methodology of initially allocating costs equally among A-grade film,

B-grade film, and scrap, and then reallocating the cost of scrap to the

cost of A-grade film is consistent with accepted cost accounting

methodologies.

SKC also asserts that its methodology is consistent with the

Department's treatment of jointly produced products in numerous other

antidumping proceedings, wherein the Department recognized that a pure

quantitative, or physical measures approach to cost allocation is

unreasonable where there is a significant difference in the value of

the jointly produced products.

SKC cites Elemental Sulphur from Canada, 61 FR 8239, 8241-8243

(March 4, 1996) (Sulphur from Canada); Oil Country Tubular Goods from

Argentina, 60 FR 33539, 33547 (June 28, 1995) (OCTG from Argentina);

Canned Pineapple Fruit from Thailand, 60 FR 29553, 29560 (June 5, 1995)

(Pineapple from Thailand) in support of its position.

SKC maintains that it is the Department's well-established practice

to calculate costs in accordance with a respondent's normal cost

accounting system unless the system results in an unreasonable

allocation of costs, and cites Pineapple from Thailand as support for

this assertion. SKC states that its reported cost of manufacturing

(COM) data were calculated in accordance with its normal and long-

established management cost accounting system. SKC notes that in the

first review of this case (covering the period November 30, 1990

through May 31, 1992), the Department allocated all of the costs

associated with the production of scrap film to A-grade film. SKC

contends that this methodology was recently upheld by the Court of

International Trade (CIT). (See E.I. Dupont de Nemours & Co., et al. v.

United States, No. 98-35, Slip. Op. at 12-14 (CIT March 26, 1998

(DuPont).) Based upon the foregoing, SKC concludes that the Department

should allocate all scrap costs to A-grade film.

Petitioners argue that SKC has not provided justification for the

Department deviating from its current practice which is to allocate

costs equally between prime- and off-grade merchandise. Petitioners

note that the allocation of scrap film has been a contentious issue

from the LTFV investation of this case. Petitioners further note that

the Department's method of allocating yield losses equally between A-

grade and B-grade film is consistent with the ruling of the U.S. Court

of Appeal for the Federal Circuit in IPSCO v. United States, 965 2d.

1056 (Fed Cir., 1992) (IPSCO). Petitioners contend that the methodology

employed by the Department in this review is consistent with that

employed in the second (June 1, 1992 through May 31, 1993) and third

(June 1, 1993 through May 31, 1994) reviews of this case. Additionally,

Petitioners assert that the decision by the CIT in DuPont does not

require the Department to employ the allocation methodology used in the

first review of this case. Petitioners contend that in accepting SKC's

reported costs for the first review, the Department predicated its

acceptance of SKC's allocation methodology on the understanding that

SKC had applied ``a cost methodology that assigns equal costs to the

prime and off-grade PET film in accordance with the Ipsco Appeal.''

(original emphasis). (See Polyethylene Terephthalate Film, Sheet and

Strip From the Republic of Korea; Final Results of Antidumping Duty

Administrative Review, 60 FR 42835, 42839 (August 17, 1995).)

Petitioners assert that this indicates that the Department believed

that ``SKC's reported cost allocation system was based on allocating

equal costs'' to A-grade and B-grade film. Petitioners contend that the

allocation methodology set forth by SKC does not allocate scrap costs

equally to A-grade and B-grade film, and thus should be rejected by the

Department.

Additionally, Petitioners challenge SKC's characterization of its

proposed allocation methodology as ``normal and long-established.''

Petitioners cite to their April 14, 1997 reply brief filed in the fifth

administrative review (June 1, 1995 through May 31, 1996) of this case

in which Petitioners contend that SKC had historically assigned equal

costs to all PET film and devised its current cost system only after

the initiation of this dumping case.

Department's Position: We agree with Petitioners and disagree with

SKC. As we explained in the final results of previous reviews of this

order, we have determined that A-grade and B-grade PET film have

identical production costs. Accordingly, we continue to rely on an

equal cost methodology for both grades of PET film in these final

results (See Polyethylene Terephthalate Film, Sheet, and Strip from the

Republic of Korea: Final Results of Review and Notice of Revocation in

Part 61 FR 35177, 33182-83 (July 5, 1996) (Second and Third Reviews);

Polyethylene Terephthalate Film, Sheet, and Strip from the Republic of

Korea; Final results of Review and Notice of Revocation in Part 61 FR

58374, 58375-76, (November 14, 1996) (Fourth Review); and Polyethylene

Terephthalate Film, Sheet, and Strip from the Republic of Korea; Final

Results of Review, 62 FR 38064, 38065-66, (July 16, 1997) (Fifth

Review).)

[[Page 37336]]

Moreover, as noted in the final results of the second through the

fifth reviews, the CIT has also ruled that our allocation of SKC's

production costs between A-grade and B-grade film is reasonable (see

E.I. DuPont de Nemours & Co., Inc. et al. v. United States, 932 F.

Supp. 296 (CIT 1996)).

As Petitioners have indicated, our acceptance of SKC's allocation

of scrap costs in the first review of this case was based upon our

understanding that SKC had properly allocated the costs of A-grade and

B-grade film. In that review, we did not verify SKC's costs data. We

determined that no verification of SKC was necessary because SKC was

verified in the original investigation. Second and Third Reviews, 60 FR

at 42839. Based upon the evidence existing in the record during that

proceeding, we accepted SKC's computations because we were satisfied

that it had calculated actual costs consistent with the IPSCO decision.

During the second and third administrative reviews, however, we

carefully examined SKC's allocation methodology and conducted a

thorough verification of SKC's accounting records. We determined that

the allocation methodology employed by SKC fails to capture the actual

production costs of A-grade and B-grade film. Based upon this

determination, we have consistently required SKC to allocate yield

losses equally between A-grade and B-grade film since the second review

of this case. Further, we have determined that A-grade and B-grade film

undergo an identical production process that involves an equal amount

of material and fabrication expenses. The only difference in the

resulting A- and B-grade film is that at the end of the manufacturing

process a quality inspection is performed during which some of the film

is classified as high quality A-grade product while other film is

classified as lower quality B-grade film (see Fourth Review (covering

the period June 1, 1994 through May 31, 1995), 61 FR at 58375).

Finally, SKC's argument that DuPont affirmed SKC's allocation

methodology is without merit. DuPont does not require the Department to

accept an allocation methodology that does not accurately capture the

actual cost of A-grad and B-grade film. In DuPont, the CIT concluded

that the Department's acceptance of SKC's calculations was supported by

substantial evidence. The Court further concluded that the calculations

properly reflected SKC's actual costs of production. The CIT, however,

did not affirm SKC's allocation methodology. It merely accepted the

allocations resulting from the methodology because those allocations

(based upon record evidence) reflected actual production costs as

required by IPSCO.

In the four previous reviews of this case, the Department has

determined that SKC's allocation methodology fails to capture the

actual cost of A-grade and B-grade film. We continue to maintain that

SKC's reliance on Sulphur from Canada. Pineapple from Thailand, and

OCTG from Argentina is misplaced. Those cases concerned the appropriate

cost methodology for products manufactured from a joint production

process. SKC has mischaracterized the continuous production process of

PET film as a joint production process. A joint production process

occurs when ``two or more products result simultaneously from the use

of one raw material as production takes place.'' (See, Management

Accountants Handbook, Keeler, et al., Fourth Edition at 11:1.) A joint

production process produces two distinct products and the essential

point of a joint production process is that ``the raw material, labor,

and overhead costs prior to the initial split-off can be allocated to

the final product only in some arbitrary, although necessary, manner.''

Id. The identification of different grades of merchandise does not

transform the manufacturing process into a joint production process

which would require the allocation of costs. In this case, since

production records clearly identify the amount of yield losses for each

specific type of PET film, our allocation of yield losses to the films

bearing those losses is reasonable, not arbitrary (Fourth Review, 61 FR

at 58575-76).

It is the Department's practice to calculate costs in accordance

with a respondent's management accounting system. Where that system

reconciles to the respondent's normal financial and cost accounting

records and results in a reasonable allocation of costs. Management

accounting deals with providing information that managers inside an

organization will use. Managerial accounting reports typically provide

more detailed information about product costs, revenue and profits.

They are used to identify problems, objectives or goals, and possible

alternatives. In order to respond to the Department's questionnaires,

SKC officials devised a management accounting methodology for

allocating costs incurred in the film and chip production cost centers

to individual products produced during the period of investigation. SKC

adopted this cost accounting system to reflect a management goal (i.e.,

to respond to the Department). Under this system, SKC assigns the yield

loss from the production of A- and B-grade films exclusively to the A-

grade films. This methodology helps management to focus on the film

types with low yields. However, notwithstanding SKC management's

concern that it accurately portray the cost of their A-grade products,

this managerial accounting methodology is not appropriate for reporting

the actual costs of A- and B-grade products. As previously noted, A-

grade and B-grade films undergo an identical production process. B-

grade film is made using the same materials, on the same equipment, at

the same time as the A-grade film. As such, scrap costs must be

allocated equally to A- and B-grade films. It is within the

Department's mandate to accept or reject the allocation methodologies

devised by respondents. In this instance, we have continued to rely on

an equal cost allocation methodology which reflects the actual costs

incurred for both A-grade and B-grade film.

Comment 3: SKC asserts that the Department double counted inventory

carrying costs in its calculation of COP and CV. SKC contends that all

COP interest expenses were included in the variable RCOP, and that all

CV interest expenses were included in the variable INTEXCV.

Department's Position: We agree with SKC. In these final results,

we have revised the computer program to eliminate the double-counting

of inventory carrying costs in our calculation of COP and CV.

Comment 4: SKC asserts that the Department failed to include U.S.

indirect selling expenses incurred in the home market for purposes of

calculating CEP profit. SKC contends that the Department should adjust

its calculation of CEP profit to account for all U.S. selling expenses.

regardless of where they were incurred.

Department's Position: We agree with SKC. Consistent with our

established practice, we have not distinguished ``activities in the

United States from other selling expenses'' in our calculation of CEP

profit. (See Import Administration Policy Bulletin No. 97/1.

Calculation of Profit for Constructed Export Price Transactions

(September 4, 1997).)

Comment 5: SKC contends that the Department should offset interest

revenue against imputed credit in building up the pool of U.S. selling

expenses used to allocate profit to CEP sales. SKC notes that the

Department made this offset in the final results of the fifth review.

(See Final Analysis

[[Page 37337]]

Memorandum for SKC from Analyst to the file, June 30, 1997.)

Department's Position: We agree with SKC. In these final results,

we have offset SKC's interest expense with the interest revenue

realized by SKC.

Comment 6: Petitioners contend that the Department should revise

SKC's imputed credit expenses on sales to Anacomp. Petitioners assert

that SKC's calculation of credit expense is inconsistent with the

ruling of the Federal Circuit in LMI-LaMetalli Industriale, S.p.A. v.

United States. (LMI) 912 F.2d 455 (Fed. Cir. 1990) because SKC has not

based its calculation of U.S. credit expense upon ``usual and

reasonable commercial behavior.'' (LMI at 461.)

Petitioners contend that the Department's calculation of SKC's U.S.

imputed credit expense should consider Anacomp's ``poor financial

condition and the unusual trade credit term that SKC provided to

Anacomp.'' Petitioners note that Anacomp declared bankruptcy just prior

to the period of review, and emerged from bankruptcy in June 1996.

Petitioners point to Anacomp's debt-to-equity ratio as another

indication of the company's poor financial condition. Petitioners also

note that the interest rate incurred by SKC on borrowings in the U.S.

is below the U.S. prime rate. Petitioners assert that Anacomp's

financial condition ``is shaky at best,'' and that credit expenses on

sales to Anacomp should reflect Anacomp's poor financial condition.

Petitioners further contend that the Department should use a rate

higher than the rate used to calculate SKC's interest revenue on sales

to Anacomp. Petitioners note that in DuPont, the CIT granted the

Department's request for a remand to consider Anacomp's financial

condition in determining the short-term interest rate to be utilized on

SKC's U.S. sales. DuPont at 24.

SKC contends that the purpose of making an adjustment for U.S.

credit expenses is to account for the opportunity cost that the seller

incurs in waiting for payment from the buyer. SKC argues that the

Department requested a remand in DuPont only because the issue had not

been addressed on the record of that review. SKC further contends that

the cost of extending credit can only be measured by the cost that the

seller incurs in borrowing funds. SKC argues that bad debt expense (and

not credit) represents the costs associated with not receiving payment.

SKC further argues that Departmental practice is to base bad debt

expense upon the actual expenses realized by the company. SKC notes

that is has included its actual U.S. bad debt expenses in its

calculation of U.S. indirect selling expenses. Finally, SKC contends

that Petitioners' reliance on LMI is misplaced. SKC notes that in LMI,

the Court instructed the Department to base U.S. interest expense upon

the costs associated with borrowing funds in the United States. SKC

notes that is based its calculation of U.S. credit expense upon the

costs that it incurred in borrowing funds in the United States.

Department's Position: We agree with SKC and disagree with

Petitioners. The Department has adopted a policy of using a short-term

interest rate tied to the currency in which the sales are denominated.

(See Import Administration Policy Bulletin No. 98.2, Imputed Credit

Expenses and Interest Rates (February 23, 1998).) Subsequent to the LMI

decision we established a practice of matching the short-term interest

rate to the currency because we view this measure as accurately

reflecting the cost of providing credit to the customer. (See, e.g.;

AIMCOR v. United States, Nos. 96-1502, 97-1009, 1998 U.S. App. Lexis

7077, at * 40 (Fed. Cir. April 9, 1998) (AIMCOR); Final Determination

of Sales at Less Than Fair Value: Oil Country Tubular Goods From

Austria, 60 FR 33551, 33555 (June 28, 1995); Certain Cut-to-Length

Carbon Steel Plate From Sweden; Final Results of Antidumping

Administrative Review, 61 FR 15772, 15780 (April 9, 1996).) Moreover,

in the second and third administrative reviews where the respondent had

borrowings in the same currency as the transaction we used the

weighted-average borrowing rates realized in that particular currency.

(See Second and Third Reviews at 35184.) In these final results we have

continued to base our calculations of SKC's credit expense upon the

interest rate incurred on SKC's borrowings in the United States. This

approach is consistent with the Court of Appeals' decision in LMI. In

that case the Federal Circuit reversed the Department's calculation of

U.S. imputed credit expenses which used home market borrowing rates

because the respondent had actual U.S. loans at a much lower rate. (LMI

at 460-61.) Inasmuch as the respondent's actual borrowing experience

demonstrated its ability to secure financing in the United States at a

lower rate, the Federal Circuit reasoned that use of the higher

interest rates did not reflect the commercial reality of the

respondent's borrowing experience in the United States.

Petitioner' arguments make clear that they have confused credit and

bad-debt expenses. Bad debt represents the risk that the seller incurs

of not receiving payment, and was separately reported by SKC in its

calculation of indirect selling expenses. In contrast, credit expenses

represents the opportunity cost incurred by the seller in awaiting

payment. The extension of credit constitutes an expense to the firm,

because it obligates funds which would otherwise be available for other

business activities. Anacomp's financial status and condition has no

bearing on SKC's imputed credit expenses computations because imputed

credit expense reflects the opportunity cost experienced by the seller

(See AIMCOR, at *7-8). Anacomp's poor financial condition is irrelevant

in this instance because it has no bearing upon the opportunity costs

incurred by SKC due to delayed payment. Similarly, neither Anacomp's

declared bankruptcy nor it's interest rate in the commercial market

place are reflective of the opportunity costs incurred by SKC in

extending credit. Finally, we note that if we were to adopt the

approach advanced by Petitioners, the distinction between credit

expenses and bad debt would cease to exist.

SKC misapprehends the LMI decision. In LMI, the Federal Circuit

reversed the Department for basing U.S. imputed credit costs upon the

cost of borrowing funds in the home market, as opposed to the market in

which the sales where made. SKC's calculation of U.S. credit, however,

is based upon borrowings undertaken by SKC in the United States. SKC's

calculation is therefore consistent with LMI and the Department's

established practice.

Final Results of Review

As a result of our review, we determine that a weighted-average

margin of 0.36 percent exists for SKC.

The Department shall determine, and the Customs Service shall

assess, antidumpting duties on all appropriate entries. Individual

differences between export price and normal value may vary from the

percentage stated above. The Department will issue appraisement

instructions directly to the Customs Service.

Furthermore, the following deposit requirements will be effective

upon publication of this notice of final results for all shipments of

PET film from the Republic of Korea within the scope of the order

entered, or withdrawn from warehouse, for consumption on or after the

publication date, as provided by section 751(a)(1) of the Tariff Act:

(1) no cash deposit shall be required for SKC because the weighted

average margin is less than 0.5 percent and therefore de minimis; (2)

for previously reviewed or investigated companies not listed above, the

rate will continue to be the company-specific rate published for the

[[Page 37338]]

most recent period; (3) if the exporter is not a firm covered in this

review, a prior review, or the original less-than-fair value (LTFV)

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) for all other producers and/or exporters of

this merchandise, the cash deposit rate will be 21.50 percent, the

``all others'' rate established in the remand redetermination of the

LTFV investigation, as explained below. These deposit requirements

shall remain in effect until publication of the final results of the

next administrative review.

This notice serves as a final reminder to importers of their

responsibility under 19 CFR 353.26 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 antidumping duties occurred and subsequent assessment

of double antidumping duties.

Notification of Interested Parties

This notice also serves as a reminder to parties subject to

administrative protective order (APO) of their responsibility

concerning the disposition of proprietary information disclosed under

APO in accordance with 19 CFR 353.34(d). Timely written notification of

return/destruction of APO materials or conversion to judicial

protective order is hereby requested. Failure to comply with the

regulations and the terms of an APO is a sanctionable violation. Timely

written notification of the return/destruction of APO materials or

conversion to judicial protective order is hereby requested.

This administrative review and 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: July 2, 1998.

Joseph A. Spetrini,

Acting Assistant Secretary for Import Administration.

[FR Doc. 98-18446 Filed 7-9-98; 8:45 am]

BILLING CODE 3510-DS-M