Brass Sheet and Strip from Canada: Preliminary Results of Antidumping Duty Administrative Review and Notice of Intent To Revoke Order in Part

Federal RegisterFeb 9, 1998

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DEPARTMENT OF COMMERCE

International Trade Administration

[A-122-601]

Brass Sheet and Strip from Canada: Preliminary Results of

Antidumping Duty Administrative Review and Notice of Intent To Revoke

Order in Part

agency: Import Administration, International Trade Administration,

Commerce.

action: Notice of preliminary results of Antidumping Duty

Administrative Review and Notice of Intent to Revoke Order in Part.

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summary: In response to a request by the respondent, the Department of

Commerce is conducting an administrative review of the antidumping duty

order on brass sheet and strip from Canada. The review covers one

manufacturer/exporter of this merchandise to the United States,

Wolverine Tube (Canada), Inc. The period covered is January 1, 1996

through December 31, 1996. As a result of the review, the Department

has preliminarily determined that no dumping margins exist for this

respondent. We intend to revoke the order with respect to brass sheet

and strip from Canada manufactured by Wolverine, based on our

preliminary determination that Wolverine has sold the merchandise at

not less than fair value for a period of three consecutive years and

that it is not likely that Wolverine will sell this product to the

United States at less than normal value in the future.

We invite interested parties to comment on these preliminary

results. Parties who submit argument in this proceeding are requested

to submit with the argument (1) a statement of the issue and (2) a

brief summary of the argument.

effective date: February 9, 1998.

for further information contact: Paul Stolz or Tom Futtner, Office of

Antidumping/Countervailing Duty Enforcement, Import Administration,

International Trade Administration, U.S. Department of Commerce, 14th

[[Page 6520]]

Street and Constitution Avenue, NW., Washington, DC 20230; telephone:

(202) 482-4474 or 482-3814, respectively.

Applicable Statute and Regulations

Unless otherwise stated, all citations to the Tariff Act of 1930,

as amended (the Act) are references to the provisions effective January

1, 1995, the effective date of the amendments made to the Act by the

Uruguay Round Agreements Act (URAA). In addition, unless otherwise

indicated, all references to the Department's regulation are to 19 CFR

part 353 (April 1, 1997).

supplementary information:

Background

The Department of Commerce (the Department) published an

antidumping duty order on brass sheet and strip from Canada on January

12, 1987 (52 FR 1217). On January 14, 1997, the Department published a

notice of ``Opportunity to Request an Administrative Review'' of the

antidumping duty order on brass sheet and strip from Canada (62 FR

1874). On January 31, 1997, a manufacturer/exporter, Wolverine Tube

(Canada), Inc. (Wolverine) requested an administrative review of its

exports of the subject merchandise to the United States for the period

of review January 1, 1996, through December 31, 1996. In accordance

with 19 CFR 353.22(c), we initiated the review on March 3, 1997 (62 FR

9413). The Department is now conducting this administrative review in

accordance with section 751 of the Act.

Scope of Review

Imports covered by this review are shipments of brass sheet and

strip (BSS), other than leaded and tinned BSS. The chemical composition

of the covered products is currently defined in the Copper Development

Association (C.D.A.) 200 Series or the Unified Numbering System

(U.N.S.) C2000. This review does not cover products the chemical

compositions of which are defined by other C.D.A. or U.N.S. series. In

physical dimensions, the products covered by this review have a solid

rectangular cross section over 0.006 inches (0.15 millimeters) through

0.188 inches (4.8 millimeters) in finished thickness or gauge,

regardless of width. Coiled, wound-on-reels (traverse wound), and cut-

to-length products are included. The merchandise is currently

classified under Harmonized Tariff Schedule (HTS) item numbers

7409.21.00 and 7409.29.00. Although the HTS item numbers are provided

for convenience and customs purposes, the written description of the

scope of this order remains dispositive. Pursuant to the final

affirmative determination of circumvention of the antidumping duty

order, covering the period September 1, 1990, through September 30,

1991, we determined that brass plate used in the production of BSS

falls within the scope of the antidumping duty order on BSS from

Canada. See Brass Sheet and Strip from Canada: Final Affirmative

Determination of Circumvention of Antidumping Duty Order, 58 FR 33610

(June 18, 1993).

The review period (POR) is January 1, 1996 through December 31,

1996. The review involves one manufacturer/exporter, Wolverine.

Verification

As provided in section 782(i) of the Act, we verified information

provided by the respondent, Wolverine, by using our standard

verification procedures, including the examination of relevant sales

and financial records and selection or original documentation

containing relevant information. Our verification results are outlined

in the public version of the verification report--``Sales and Cost

Verification Report, Wolverine Tube (Canada), Inc.''.

United States Price (USP)

In calculating USP for Wolverine, we used export price (EP), as

defined in section 772 of the Act, because the merchandise was sold to

unaffiliated U.S. purchasers prior to the date of importation and

because no other circumstances indicated that constructed export price

was appropriate. We calculated EP based on prices that were delivered

to the customers' premises. In accordance with section 772(c)(1) of the

Act, we adjusted USP for brokerage and handling, foreign and U.S.

inland freight, and customs duty. No other adjustments to EP were

claimed or allowed.

Normal Value

A. Viability

In order to determine whether there was a sufficient volume of

sales in the home market to serve as a viable basis for calculating NV,

we compared Wolverine's volume of home market sales of the foreign like

product to the volume of U.S. sales of the subject merchandise, in

accordance with section 773(a)(1)(B) of the Act. Because Wolverine's

aggregate volume of home market sales of the foreign like product was

greater than five percent of its aggregate volume of U.S. sales of the

subject merchandise, we determined that the home market provides a

viable basis for calculating NV for Wolverine.

B. Below Cost of Production Test

Because we disregarded sales below the cost of production in the

1995 POR, 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. Therefore, pursuant to

section 773(b)(1) of the Tariff Act, we initiated a COP investigation

of sales by Wolverine (see Memorandum to the File, dated March 20,

1997, 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 Wolverine provided in its

questionnaire responses. After calculating COP, we tested whether home

market sales of subject BSS were made at prices below COP within an

extended period of time in substantial quantities, and whether such

prices permitted 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.

For purposes of the below cost of production test conducted for

home market comparison sales we allocated a portion of selling, general

and administrative (SG&A) expenses for the corporate headquarters in

Huntsville/Decatur, Alabama to Wolverine's cost of production (COP).

This additional allocation was based on SG&A and cost of sales

information taken from Wolverine's financial statements. In its

questionnaire response, Wolverine did not allocate SG&A for its

Huntsville/Decatur corporate headquarters although it did allocate SG&A

for its London, Ontario corporate offices. At verification, however,

discussions with company officials and a review of company

correspondence revealed that the Fergus, Ontario facility was subject

to significant guidance and control by corporate headquarters in

Huntsville/Decatur during the POR. (See the analysis memorandum dated

January 20, 1998 for details.)

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

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

prices less

[[Page 6521]]

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 Wolverine'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 Wolverine 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 Wolverine also

indicated that for certain other home market models more than twenty

percent of the home market sales within an extended period of time were

at prices below COP and 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. Model-Matching

We calculated NV using prices of BSS products having the same

characteristics as to form, temper, gauge, width, and alloy. We used

the same gauge and width groupings and the same model-match methodology

in this review as in the last completed administrative review (1995).

As in the 1995 review, we disregarded ``source'' designations in the

product codes for model matching purposes since the ``sources'', i.e.,

whether reroll or nonreroll brass is used to make the product, does not

appear to describe physical characteristics of the resulting subject

merchandise itself. Wolverine claimed in its response that the grain

density of the reroll material obtained from outside suppliers was

higher than that of its own cast material. Although this may be the

case, respondent's claim has not been substantiated on the record of

this review. Moreover, we requested in our supplemental questionnaire

that respondent submit product codes accounting for physical

characteristics only, including grain density, but excluding source. In

its response, respondent did not then report grain density in place of

source. Furthermore, we determined at verification that reporting grain

density would not have caused any hardship for the respondent. The

factory lab was outfitted with equipment capable of accurately

determining grain size/density and other product characteristics such

as purity levels. In addition, we determined that grain density was

routinely monitored throughout the product process. Therefore, since

``source'' does not describe a physical product characteristic, and

since the respondent did not report grain density as we requested, we

are not including ``source'' as a product matching characteristic.

Moreover, the absence of grain density information does not favor

Wolverine. Purchased re-roll material, presumably of higher quality and

higher cost materials, was sold during the period of review only in the

home market. Thus, those sales were matched with Wolverine's own cast

materials, sold in the U.S. market, thereby increasing the likelihood

and magnitude of dumping margins.

D. Level of Trade

In our supplemental questionnaire we specifically asked the

respondent to describe its reasons for claiming there were different

terms of sale or selling prices to different classes of customer.

Respondent described three distinct customer categories in the home

market and one in the U.S. market, but did not explain how Wolverine's

selling functions varied for each customer category.

As documentation to support its level of trade (LOT) claim, the

respondent supplied price lists, but these lists do not show any

differences in selling functions or illustrate the source of price

differences for different customer categories. The respondent did not

provide any other information to document, justify, or quantify its

reported differences in selling functions in order to establish the

claimed three different LOTs in the home market. Further, at

verification we discussed the process by which customers were placed in

a particular category. We noted no indication of different selling

functions corresponding to various customers on the basis of customer

category or otherwise.

Upon review of the case record, we have determined that although

distinct customer categories existed, there is no evidence on the

record, in terms of selling functions performed by Wolverine,

correlating them to levels of trade. Thus, although customer categories

may exist, they are distinct from any level of trade designations which

we may consider in calculating dumping margins for Wolverine. Because

the record does not show that Wolverine performed different selling

functions with respect to different channels of distribution, we

determined that there is only one LOT in the home market. See

Ferrosilicon from Brazil: Notice of Partial Termination and Preliminary

Results of Antidumping Duty Administrative Review, 63 FR 2661 (January

16, 1998). Furthermore, since we noted no different selling functions

in the U.S. market, no LOT adjustment is necessary.

E. Price-to-Price Comparisons

We calculated NV using monthly weighted-average prices of BBS

having the same characteristics as to form, temper, gauge, width, and

alloy. We based NV on the price at which the foreign like product is

first sold for consumption in the exporting country, in the usual

commercial quantities and in the ordinary course of trade, and at the

same level of trade as the export price, as defined by section

773(a)(1)(B)(i) of the Act.

We reduced NV for home market credit and warranty expenses, and

increased NV for U.S. credit expenses in accordance with section

773(a)(6)(C)(iii), due to differences in circumstances of sale. We

reduced NV for home market movement expenses, in accordance with

section 773(a)(6)(B)(ii); and for packing costs incurred in the home

market, in accordance with section 773(a)(6)(B)(i); and increased NV to

account for U.S. packing expenses. No other adjustments to NV were

claimed or allowed.

Revocation

On January 31, 1997, Wolverine submitted its request for an

administrative review covering the 1996 POR and, pursuant to 19 CFR

353.25(b), requested revocation of the antidumping duty order with

respect to Wolverine. In its request, Wolverine stated that it expected

to received a de minims margin in the 1996 POR. Wolverine noted that

this would be the third consecutive de minimis margin received, and

thus Wolverine would be eligible for revocation. In accordance with 19

CFR 353.25(a)(2)(iii), this request was accompanied by certifications

from the firm that it had not the relevant class or kind of merchandise

at less than normal valve (NV) for a three-year period including this

review period, and would not do so in the future. Wolverine also agreed

to its immediate reinstatement in the

[[Page 6522]]

relevant antidumping duty order, as long as any firm is subject to this

order, if the Department concludes under 19 CFR 353.22(f) that,

subsequent to revocation, it sold the subject merchandise at less than

NV. On August 1, 1997, the petitioner submitted a request that the

deadline for the preliminary results in this review be fully extended

by 120 days in order to develop the administrative record with respect

to revocation. In addition, the petitioner claimed that the burden for

demonstrating ``no likelihood'' of future dumping as stipulated under

19 CFR 353.25(a)(2) was on the respondent, and that the respondent

should be required to place on the record historical data covering its

operations over the preceding five years. In addition, the petitioner

requested that the Department require the respondent to submit specific

planning data regarding future production of subject and non-subject

merchandise.

On September 15, 1997, the Department extended the deadline for the

preliminary determination. However, the Department did not find

compelling cause to request respondent to produce the extensive

historical and planning data which the petitioner proposed was

necessary to determine whether future dumping was ``not likely.'' On

October 16, 1997, the Department informed interested parties that the

administrative record would be re-opened for submission of comments and

rebuttal comments pertaining to the issue of likelihood of future

dumping. Both respondent and petitioner submitted comments and rebuttal

comments in a timely manner.

Interested Party Comments on Whether Future Dumping is Likely

On November 10, 1997, Wolverine and petitioner submitted comments

on the issue of whether or not it is likely that Wolverine would resume

dumping if the Department granted revocation as to that firm. First,

the respondent noted that it received two consecutive zero or de

minimis margins and is committed to refrain from dumping in the future

and has made certifications to this effect as stipulated under the

Department's regulations. The petitioner has not challenged these facts

or the adequacy of the certifications.

Second, Wolverine states that dumping is unlikely to resume given

the similar nature of price, supply, and demand patterns common to both

the Canadian and U.S. markets. Wolverine asserts that this limits the

potential for price differences in each market. Petitioner states that

Wolverine's claim that North America is a unified market for BSS is

unsubstantiated by specific company information.

Third, Wolverine cites favorable market conditions which it claims

render future dumping unlikely. In its November 10, 1997, submission of

comments regarding the likelihood of future dumping, Wolverine included

as exhibits market reports and articles from American Metal Market and

Purchasing which characterize the market for copper, copper alloys and

brass as strong and steady. The articles and reports cite increasing

lead times, low inventories, rising prices and strong demand as factors

contributing to an environment in which dumping is not likely. In

addition, respondent cites expanded applications of brass mill

products, such as used in construction of ship hulls and electric

vehicles, which may result in increased demand.

Fourth, Wolverine notes that it lacks both the means and the

incentive to abuse revocation. Respondent notes that it competes

largely by servicing established home market customers with a

diversified product range. Since its customers require a diversified

product range, its brass production capacity is limited and although

its brass business is profitable, if it received an order for its other

more profitable products it would choose the latter. Therefore,

according to Wolverine, the potential impact of its brass sales on the

U.S. market would be miniscule in any case. Petitioner claims that

respondent did not substantiate its claims that it had no economic

incentive to devote its entire capacity to production for the U.S.

market. In addition, petitioner notes that Wolverine's statements

regarding its minimal potential impact on the U.S. market are

irrelevant and do not support a finding that it is not likely that

Wolverine will dump in the future.

Petitioner's comments cited its August 1, 1997, letter in which it

requested five-year historical data and background/planning information

and reiterated its request that the Department require that Wolverine

(or the Department) place this information on the record of this

proceeding. Petitioner has stated that much of this information was

placed on the records of prior proceedings. Petitioner reiterated its

view that the burden of showing that Wolverine is not likely to resume

dumping following revocation rests on the respondent. In this respect,

petitioner argues that five-year historical data on many aspects of

Wolverine's trade with the United States is necessary to establish

sales trends in order to determine the likelihood of future dumping,

and claims that much of the requested information is already on the

record of prior proceedings and would not be difficult to collect.

Petitioner claims that respondent's sales of subject merchandise in the

United States have declined since imposition of the antidumping duty

order. Petitioner also claims that the loss of certain business by

respondent in the home market would dispose respondent to future

dumping. Finally, respondent asserted that the petitioner's comments

contained no factual evidence on the subject of revocation and that

petitioner's actual purpose in requesting additional time to develop

the record with respect to revocation was part of a strategy to delay

the conclusion of this review and to deny respondent revocation.

Department Analysis

Petitioner has not shown that the additional data it requested the

Department gather is necessary to resolve whether it is not likely that

Wolverine would dump subject merchandise were the order revoked as to

that company. Furthermore, we note that much of the data requested by

petitioner is not on the record of prior reviews and collecting it

would impose a considerable administrative burden on the Department. In

view of the fact that each administrative review is conducted as a

separate segment of the proceeding pursuant to the Department's

regulations, the burden of gathering additional information, and the

failure of petitioner to demonstrate any compelling need for the

Department to consider the requested information in determining whether

it should revoke the order as to Wolverine, the Department has declined

to gather (and include) further information in the administrative

record of this review. On this issue, the Department has a considerable

factual record before it. At the request of the parties, the Department

established a process for the submission of factual information on the

issue of whether it is not likely that dumping would resume in the

future. As discussed above, both the petitioner and the respondent made

submissions of information relevant to this issue. Accordingly, the

Department has an adequate record before it on which to make a

determination on the revocation issue.

Under the Department's regulations, the Department may revoke an

order in part if the Secretary concludes that: (1) ``one or more

producers or resellers covered by the order have sold the merchandise

at not less than fair value for a period of at least three consecutive

years''; (2) ``[i]t is not likely that those persons will in the future

sell the

[[Page 6523]]

merchandise at less than fair value * * *''; and (3) ``the producers or

resellers agree in writing to the immediate reinstatement of the order

as long as any producer or reseller is subject to the order, if the

Secretary concludes that the producer or reseller, subsequent to the

revocation, sold the merchandise at less than fair value.'' See 19 CFR

353.25(a)(2).

Upon review of the three criteria described above, and of the

comments and rebuttal comments, and on the basis of all of the evidence

on the record, we have preliminarily determined that the Department's

requirements for revocation have been met. The Department found that

Wolverine's sales reviewed during the eighth (1994) and ninth (1995)

reviews under this order were made at not less than NV. Also, in this

tenth review, we have preliminarily determined that Wolverine's sales

were made at not less than NV. Further, Wolverine has certified its

consent to immediate reinstatement of the order should the situation

described in the third criterion noted above occur.

With respect to the second criterion, the Department stated, in

Brass Sheet and Strip from Germany, Final Results of Antidumping Duty

Administrative Review and Determination Not to Revoke in Part, 61 FR

49728 (9/23/96): ``[i]n prior cases where revocation was under

consideration and the likelihood of resumption of dumped sales was at

issue, the Department has considered, in addition to the respondent's

prices and margins in the preceding periods, such other factors as

conditions and trends in the domestic and home market industries,

currency movements, and the ability of the foreign entity to compete in

the U.S. marketplace without LTFV sales.'' 61 FR at 49731. In this

proceeding, the information submitted by the parties, and the comments

received, centered upon three main conditions: (1) Supply and demand

for BSS, (2) the quantitative trend of respondent's sales in the U.S.

market since respondent received its first zero margin (as a measure of

its ability to sell commercial quantities at fair market value), and

(3) the effects of currency movements with respect to price comparisons

between the home market and the U.S. market.

First, as noted by respondents, demand for subject merchandise in

the U.S. and Canadian markets remains strong and conditions are

favorable to a positive market environment for subject merchandise.

Strong, profitable markets tend not to precipitate dumping. The reports

and articles supplied by respondent in its November 10, 1997,

submission contain factual information and forecasts by industry

analysts which characterize market condition for BSS products as

positive with evidence indicating the likelihood of continued growth

and positive performance. No evidence was placed on the record

characterizing the market otherwise.

We note, however, that Wolverine's argument that dumping would be

precluded because market conditions for BSS products are similar in the

Canadian and U.S. markets is not substantiated by evidence on the

record.

With respect to the question of whether Wolverine would have an

economic incentive to devote its entire capacity to production for the

U.S. market, it is evident, based on information reviewed at

verification and a review of sales of subject and non-subject

merchandise, that Wolverine does provide a mix of products to a variety

of U.S. and home market customers. We also noted at verification that

there are indications that there may be some strategic and physical

limitations in capacity with respect to production of BSS at the Fergus

plant. This does not preclude future expansion of capacity, however,

under proper market conditions. In addition, we note that, as

petitioner points out, the potential impact of a foreign exporter's

sales on the U.S. market is not relevant in determining whether dumping

is currently taking place or whether it is likely to resume in the

future.

With respect to petitioner's claim that, despite the generally

strong market for BSS, loss of certain business would dispose Wolverine

to future dumping, we noted at verification that this respondent had

taken significant steps and devoted significant resources to restoring/

replacing the business in question, and to developing alternative non-

subject products to make up for lost business. Furthermore, it is not

clear that diminished capacity utilization, even should it occur, would

necessarily contribute to the likelihood of future dumping.

Second, unlike the facts underlying our determination in Brass

Sheet and Strip from Germany, in which we determined not to revoke the

order as to a requesting respondent, this review covers multiple

shipments of subject merchandise to the U.S. market. In Brass Sheet and

Strip from Germany, the respondent in question had made only a single

shipment during the review at issue.

Third, exchange rate data taken from the Import Administration's

currency database indicate that from January of 1996 through September

of 1997, the Canadian dollar-U.S. dollar exchange rate remained stable.

There is no indication that the Canadian dollar might drastically

appreciate, precipitating the potential for disparities in Canadian and

U.S. selling prices of subject merchandise which would make dumping

margins more likely. In fact, the Canadian dollar has actually

depreciated slightly against the U.S. dollar.

Thus, the Department preliminarily determines that this criterion

for revocation has been met.

Preliminary Results of the Review

As a result of our comparison of EP to NV, we preliminarily

determine that a de minimis dumping margin (0.42 percent) exists for

Wolverine for the period January 1, 1996 through December 31, 1996, and

we determine, preliminarily, to revoke partially the antidumping duty

order with respect to imports of subject merchandise from Wolverine.

Parties to the proceeding may request disclosure within five days

of the date of publication of this notice. Any interested party may

request a hearing within 10 days of publication of this notice. Any

hearing will be held 44 days after the date of publication or the first

workday thereafter. Interested parties may submit case briefs within 30

days of the publication date of this notice. Rebuttal briefs, limited

to issues raised in the case briefs, may be filed not later than 37

days after the date of publication. The Department will publish a

notice of the final results of this administrative review, which will

include the results of its analysis of issues raised in any such case

briefs or at a hearing, within 120 days from publication of these

preliminary results. The following deposit requirements will be

effective for all shipments of the subject merchandise that are

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

publication date of the final results of this administrative review, as

provided by section 751(a)(1) of the Act: (1) The cash deposit rate for

Wolverine will be the rate established in the final results of this

review; (2) for previously reviewed or investigated companies not

listed above, the cash deposit rate will 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 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; (4) if neither the

manufacturer nor the exporter is a firm

[[Page 6524]]

covered in this or any previous review, the cash deposit rate will be

8.10 percent, the ``all others'' rate established in the LTFV

investigation. These deposit requirements, when imposed, shall remain

in effect until publication of the final results of the next

administrative review. Furthermore, The Department shall determine, and

the Customs Service shall assess, antidumping duties on all appropriate

entries. This notice serves as a preliminary 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 the subsequent

assessment of double antidumping duties.

This administrative review and this notice are in accordance with

section 751(a)(1) of the Act (19 U.S.C. 1675(a)(1)) and 19 CFR 353.22.

Dated: February 2, 1998.

Robert S. LaRussa,

Assistant Secretary, Import Administration.

[FR Doc. 98-3200 Filed 2-6-98; 8:45 am]

BILLING CODE 3510-DS-M

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