Certain Welded Carbon Steel Pipes and Tubes from Thailand: Preliminary Results of Antidumping Duty Administrative Review

DEPARTMENT OF COMMERCE

International Trade Administration

[A-549-502]

Certain Welded Carbon Steel Pipes and Tubes from Thailand:

Preliminary Results of Antidumping Duty Administrative Review

AGENCY: Import Administration, International Trade Administration,

Department of Commerce.

ACTION: Notice of Preliminary Results of Antidumping Duty

Administrative Review: Certain Welded Carbon Steel Pipes and Tubes from

Thailand

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SUMMARY: In response to requests by Saha Thai Steel Pipe Co., Ltd.

(``Saha Thai'') and its affiliated exporter, S.A.F. Pipe Export Co.,

Ltd., (``SAF''), and two importers, Ferro Union Inc. (``Ferro Union''),

and ASOMA Corp. (``ASOMA''), the Department of Commerce (``the

Department'') is conducting an administrative review of the antidumping

duty order on certain welded carbon steel pipes and tubes from

Thailand. This review covers Saha Thai/SAF, a manufacturer/exporter of

the subject merchandise to the United States. The period of review

(POR) is March 1, 1996 through February 28, 1997.

We have preliminarily determined that the respondent sold subject

merchandise at less than normal value (NV) during the POR. If these

preliminary results are adopted in our final results, we will instruct

U.S. Customs to assess antidumping duties based on the differences

between the export price and NV.

Interested parties are invited to comment on these preliminary

results. Parties who submit argument in this proceeding should also

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

summary of the argument.

EFFECTIVE DATE: April 7, 1998.

FOR FURTHER INFORMATION CONTACT: John Totaro or Dorothy Woster, AD/CVD

Enforcement Group III, Office VII, Import Administration, International

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

Constitution Avenue, NW, Washington, DC 20230; telephone: (202) 482-

1374 or (202) 482-3362, respectively.

Applicable Statute

Unless otherwise indicated, all citations to the statute are

references to the provisions effective January 1, 1995, the effective

date of the amendments made to the Tariff Act of 1930 (hereinafter,

``the Act'') by the Uruguay Round Agreements Act (``URAA''). In

addition, unless otherwise indicated, all citations to the Department's

regulations are to the old regulations (19 C.F.R. Part 353 (1997)), as

amended by the interim regulations published in the Federal Register on

May 11, 1995, (60 FR 25130). Although the Department's new regulations,

codified at 19 CFR 351 (62 FR 27296, May 19, 1997) (``Final

Regulations''), do not govern this administrative review, citations to

those regulations are provided, where appropriate, as a statement of

current departmental practice.

[[Page 16975]]

SUPPLEMENTARY INFORMATION:

Background

On March 11, 1986, the Department published in the Federal Register

an antidumping duty order on welded carbon steel pipes and tubes from

Thailand (51 FR 8341). On March 7, 1997, the Department published a

notice of opportunity to request an administrative review of this order

covering the period March 1, 1996 through February 28, 1997 (62 FR

10521). A timely request for an administrative review of the

antidumping order with respect to sales by Saha Thai/SAF during the POR

was filed jointly by Saha Thai, SAF, Ferro Union, and ASOMA. The

Department published a notice of initiation of this antidumping duty

administrative review on April 24, 1997 (62 FR 19988). On May 14, 1997,

certain domestic producers of standard pipe products entered an

appearance in this review: Allied Tube & Conduit Corporation, Sawhill

Tubular Division--Armco, Inc., Wheatland Tube Company, and Laclede

Steel Company, (``petitioners'' or ``domestic interested parties'').

Because the Department determined that it was not practicable to

complete this review within statutory time limits, on November 19,

1997, we published in the Federal Register our notice of extension of

time limits for this review (62 FR 61802). As a result, we extended the

deadline for these preliminary results. The deadline for the final

results will continue to be 120 days after publication of these

preliminary results.

Scope of the Review

The products covered by this administrative review are certain

welded carbon steel pipes and tubes from Thailand. The subject

merchandise has an outside diameter of 0.375 inches or more, but not

exceeding 16 inches. These products, which are commonly referred to in

the industry as ``standard pipe'' or ``structural tubing,'' are

hereinafter designated as ``pipe and tube.'' The merchandise is

classifiable under the Harmonized Tariff Schedule (HTS) item numbers

7306.30.1000, 7306.30.5025, 7306.30.5032, 7306.30.5040, 7306.30.5055,

7306.30.5085 and 7306.30.5090. Although the HTS subheadings are

provided for convenience and Customs purposes, our written description

of the scope of the order is dispositive. This review covers sales by

Saha Thai/SAF during the period March 1, 1996 through February 28,

1997.

Verification

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

information provided by the respondent Saha Thai from March 2-6, 1997,

using standard verification procedures, including examination of

relevant financial records and analysis of original documentation used

by Saha Thai to prepare responses to requests for information from the

Department. We also verified sales and level of trade issues at one of

Saha Thai's home market resellers which the Department determined was

an affiliate of Saha Thai. Our verification results are outlined in the

public version of the verification report (Memorandum to Roland L.

MacDonald) from John B. Totaro and Dorothy A. Woster, March 19, 1998

(``Saha Thai Verification Report'').

Affiliation and Collapsing Determinations

Pursuant to section 771 (33) of the Act, the Department considers

the following persons or parties to be affiliated:

A. Members of a family, including brothers and sisters (whether by

the whole or half blood), spouse, ancestors, and lineal descendants.

B. Any officer or director of an organization and such

organization.

C. Partners.

D. Employer and employee.

E. Any person directly or indirectly owning, controlling, or

holding with power to vote, five percent or more of the outstanding

voting stock or shares of any organization and such organization.

F. Two or more persons directly or indirectly controlling,

controlled by, or under common control with, any person.

G. Any person who controls any other person and such other person.

For the purposes of this paragraph, a person shall be considered to

control another person if the person is legally or operationally in a

position to exercise restraint or direction over the other person.

It is the Department's practice to collapse affiliated producers

for purposes of calculating a margin when the facts demonstrate that

the relationship is such that there is a strong possibility of

manipulation of prices and production decisions that would result in

circumvention of the antidumping order. Although the Department's new

regulations published May 19, 1997 (62 FR 27410) do not govern this

review, they do codify the Department's current practice. Current

practice calls for the Department to treat two or more affiliated

producers as a single entity (i.e., ``collapse'' the firms) for

purposes of calculating a dumping margin when the following three

criteria are met:

1. The producers must be affiliated;

2. The producers must have production facilities for similar or

identical products that would not require substantial retooling of

either facility in order to restructure manufacturing priorities; and

3. There must be a significant potential for the manipulation of

price or production. Final Regulations, 62 FR 27296, 27410.

In identifying whether there is a significant potential for the

manipulation of price or production, the factors the Department

considers include: the level of common ownership; whether managerial

employees or board members of one of the affiliated producers sit on

the board(s) of directors of the other affiliated parties; and whether

operations are intertwined, such as through the sharing of sales

information, involvement in production and pricing decisions, the

sharing of facilities or employees, or significant transactions between

the affiliated producers.

A. Producers of Subject Merchandise

The Department finds that Saha Thai is affiliated under section

771(33)(F) of the Act with two Thai producers of the subject

merchandise that are not respondents in this review: Thai Tube Co.,

Ltd. (``Thai Tube''), and Thai Hong Steel Pipe Import Export Co., Ltd.

(``Thai Hong''). This affiliation is established through common control

by the Lamatipanont family. For a more detailed discussion of the

Department's analysis, see Memorandum to the File, March 31, 1998

(``Producers Affiliation-Collapsing Memorandum.'')

Further, based on public information on the record of this review,

the Department determines that Thai Tube and Thai Hong are both

producers of the subject merchandise, and therefore have production

facilities for identical products to those produced by Saha Thai. We,

therefore, conclude that Thai Tube and Thai Hong could restructure

their production priorities to produce the subject merchandise with

little or no retooling of their facilities.

In considering the ``significant potential'' factors described

above, the Department finds, based on the evidence on the record, that

there is substantial involvement in the ownership and management of

these three producers by members of the Lamatipanont family. However,

because there is no evidence of intertwined

[[Page 16976]]

operations, we preliminarily find that a significant potential for

manipulation of price or production does not exist between Saha Thai

and Thai Tube or between Saha Thai and Thai Hong. Therefore, we have

not collapsed these three entities for the purpose of calculating a

dumping margin. However, we will continue to examine this issue for the

final results. See Producers Affiliation-Collapsing Memorandum.

B. Siam Steel Group

The Department finds that the member companies of the Siam Steel

Group are affiliated under section 771(33)(F) of the Act because they

are owned and managed by the Karuchit/Kunanantakul family. In

discussing the scope of the Department's analysis of affiliation

through ``control'' under section 771(33) of the Act, the Statement of

Administrative Action accompanying the Uruguay Round Agreements Act

states that ``[a] company may be in a position to exercise restraint or

direction, for example, through corporate or family groupings * * *''

Statement of Administrative Action, H.R. Doc. 316, Vol.1, 103d Cong.

(1994) (``SAA'') at 838. The facts on the record in this review

demonstrate that the Siam Steel Group, a grouping of Thai entities

(including Saha Thai) which produce, sell and provide services related

to various steel products under common control by the Karuchit/

Kunanantakul family, is the type of ``corporate or family grouping''

envisioned in the SAA and the Final Regulations. Based on the facts in

this case, we find that Saha Thai is affiliated under section

771(33)(F) with each and every member of the Siam Steel Group. See

Memorandum to the File, March 31, 1998 (``SSG Affiliation-Collapsing

Memorandum.'')

``Company E'' is a producer of PVC-lined steel pipes and a member

of the Siam Steel Group. Therefore, we considered whether Saha Thai and

Company E should be collapsed as a single entity for purposes of

calculating an antidumping margin. Company E produces standard welded

steel BS-medium grade pipe as an intermediate product to finished PVC-

lined pipe. In doing so, Company E uses a production process similar to

that used by Saha Thai to manufacture the subject merchandise with

additional steps to yield PVC-lined pipe. Saha Thai stated that Company

E subjects the intermediate, unlined steel pipe to substantial

additional manufacturing operations and associated costs to transform

this the intermediate product to PVC-lined pipe. In consideration of

these facts, we preliminarily do not conclude that it would not require

substantial retooling of Company E's facilities to shift production of

the subject merchandise from Saha Thai to Company E. Evidence on the

record indicates that executing this type of shift would require

extensive and expensive infrastructure changes in Company E. Therefore,

the second collapsing criterion of section 351.401(f) of the Final

Regulations is not satisfied. We will continue to examine this issue

for the final results.

Because we determine that the second collapsing criterion is not

satisfied, it is not necessary to consider the third criterion in the

collapsing analysis--identifying the potential for manipulation of

price or production. See Certain Porcelain-on-Steel Cookware From

Mexico: Final Results of Antidumping Duty Administrative Review, 62 FR

42496, 42497 (August 7, 1997). For these reasons, we determine that it

is not appropriate to treat the affiliated companies Saha Thai and

Company E as a single entity for the purposes of calculating an

antidumping margin. See SSG Affiliation-Collapsing Memorandum.

C. Resellers

The record evidence demonstrates that the Sae Haeng/Ratanasirivilai

family controls both Saha Thai and Company A, the Lamatipanont family

controls both Saha Thai and Company B, and the Ampapankit family

controls both Saha Thai and Company C. The record therefore supports

our finding of affiliation under section 771(33)(F) of the Act between

Saha Thai and these three resellers. See Memorandum to the File, March

31, 1998 (``Resellers Affiliation Memorandum'').

Fair Value Comparisons

To determine whether sales of steel pipes and tubes from Thailand

to the United States were made at less than normal value (NV), we

compared the United States price (USP) to the NV for Saha Thai as

specified in the ``United States Price'' and ``Normal Value'' sections

of this notice. In accordance with section 777A(d)(2), we calculated

monthly weighted-average prices for NV and compared these to individual

U.S. transactions.

United States Price

We based USP on EP, in accordance with section 772(b) of the Act,

when the subject merchandise was sold to unaffiliated purchasers in the

United States prior to importation. Saha Thai sells to the United

States through its affiliated export company SAF. We classified all

Saha Thai sales to United States customers as EP sales because we did

not find Saha Thai/SAF to be affiliated with its U.S. distributors.

Certain Welded Carbon Steel Pipes and Tubes From Thailand: Final

Results of Antidumping Duty Administrative Review, 61 FR 56515, 56517

(November 1, 1996). In this review, the record evidence presents no

factual circumstances warranting a change from this prior analysis.

Accordingly, we calculated the EP based on the price from Saha Thai/

SAF to unaffiliated parties in the United States where these sales were

made prior to importation into the United States, in accordance with

section 772(a) of the Act. Where appropriate, in accordance with

section 772(c)(2) of the Act, we made deductions from the starting

price for ocean freight to the U.S. port, foreign inland freight,

foreign brokerage and handling, foreign inland insurance, and bill of

lading charge. We also added duty drawback rebated to Saha Thai upon

exportation of subject merchandise made from imported coil in

accordance with section 771(c)(1) of the Act.

Normal Value

In order to determine whether there is a sufficient volume of sales

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

compared the volume of Saha Thai's home market sales of the foreign

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

accordance with section 773(a)(1)(C) of the Act. Based on this

comparison, we determined that the aggregate volume of Saha Thai's home

market sales of the foreign like product is greater than five percent

of the aggregate volume of Saha Thai's U.S. sales. Thus, we determined

that Saha Thai had a viable home market during the POR. Consequently,

we based NV on home market sales.

As discussed above, we found Saha Thai and its three home market

resellers affiliated under section 771(33)(F) of the Act. Based on this

finding, we applied the standard arm's length test to Saha Thai's sales

to these affiliated resellers. Because these sales were not made at

arm's length prices, we required Saha Thai to report the downstream

sales made in the home market by the affiliated resellers. These sales

were included in our home market normal value calculation. See

Memorandum to File from Dorothy Woster, March 31, 1998 (``Analysis

Memorandum'').

Pursuant to section 773(b) of the Act, there were reasonable

grounds to believe or suspect that Saha Thai had made home market sales

at prices below its COP in this review because the

[[Page 16977]]

Department had disregarded sales below the COP in the 1994-1995

administrative review (i.e., the most recently completed review at the

time we issued our antidumping questionnaire). As a result, the

Department initiated an investigation to determine whether Saha Thai

made home market sales during the POR at prices below its COP. We

calculated the COP based on the sum of respondent's cost of materials

and fabrication for the foreign like product, plus amounts for SG&A and

packing costs, in accordance with section 773(b)(3) of the Act.

We used respondent's reported COP amounts to compute weighted-

average COPs during the POR. We compared the COP figures to home market

sales of the foreign like product as required under section 773(b) of

the Act, in order to determine whether these sales had been made at

prices below the COP. On a product-specific basis, we compared the COP

to home market prices, less any applicable movement charges, discounts

and credit notes.

In determining whether to disregard home market sales made at

prices below the COP, we examined (1) whether, within an extended

period of time, such sales were made in substantial quantities, and (2)

whether such sales were made at prices which permitted the recovery of

all costs within a reasonable period of time in the normal course of

trade.

Pursuant to section 773(b)(2)(C) of the Act, where less than 20

percent of the respondent's sales of a given product were at prices

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

product because we determined that the below-cost sales were not made

in ``substantial quantities.'' Where 20 percent or more of the

respondent's sales of a given product during the POR were at prices

less than the COP, we determined such sales to have been made in

substantial quantities within an extended period of time in accordance

with section 773(b)(1)(A) of the Act. In such cases, we also determined

that such sales were not made at prices which would permit recovery of

all costs within a reasonable period of time, in accordance with

section 773(b)(1)(B) of the Act. Therefore, we disregarded the below-

cost sales.

On January 8, 1998, the Court of Appeals for the Federal Circuit

issued a decision in CEMEX v. United States, 1998 WL 3626 (Fed Cir.,

1998). In that case, based on the pre-URAA version of the Act, the

Court discussed the appropriateness of using constructed value (CV) as

the basis for foreign market when the Department finds home market

sales to be outside the ``ordinary course of trade.'' This issue was

not raised by any party in this proceeding. However, the URAA amended

the definition of sales outside the ``ordinary course of trade'' to

include sales disregarded as below cost. See Section 771(15) of the

Act. Consequently, the Department has determined that it would be

inappropriate to resort directly to CV, in lieu of foreign market

sales, as the basis for NV if the Department finds foreign market sales

of merchandise identical or most similar to that sold in the United

States to be outside the ``ordinary course of trade.'' Instead, the

Department will use sales of similar merchandise, if such sales exist.

The Department will use CV as the basis for NV only when there are no

above-cost sales that are otherwise suitable for comparison. Therefore,

in this proceeding, when making comparisons in accordance with section

771(16) of the Act, we considered all products sold in the home market

as described in the ``Scope of Review'' section of this notice, above,

that were in the ordinary course of trade (i.e., sales that passed the

cost test) for purposes of determining appropriate product comparisons

to U.S. sales. Where there were no sales in the ordinary course of

trade of the identical or the most similar merchandise in the home

market that were otherwise suitable for comparison, we compared U.S.

sales to sales of the next most similar foreign like product, based on

the characteristics listed in Sections B and C of our antidumping

questionnaire. We have implemented the Court's decision in this case,

to the extent that the data on the record permitted.

Where appropriate, we adjusted Saha Thai's home market sales for

discounts, credit expenses, inland freight, inland insurance, and

warehousing. We also adjusted the home market sales made by reseller

Company B for credit notes. In addition, in accordance with section

773(a)(6), we deducted home market packing costs and added U.S. packing

costs.

In accordance with section 773(e) of the Act, we calculated CV

based on the sum of Saha Thai's cost of materials, fabrication, SG&A,

profit, and U.S. packing costs. In accordance with section 773(e)(2)(A)

of the Act, we based SG&A expenses and profit on the amounts incurred

and realized by Saha Thai in connection with the production and sale of

the foreign like product in the ordinary course of trade, for

consumption in the foreign country. For selling expenses, we used the

average of the selling expenses reported for home market sales that

survived the cost test, weighted by the total quantity of those sales.

For actual profit, we first calculated the difference between the home

market sales value and home market COP, and divided the difference by

the home market COP. We then multiplied this percentage by the COP for

each U.S. model to derive an actual profit.

Level of Trade

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

to the extent practicable, we determine normal value (NV) based on

sales in the comparison market at the same level of trade as the export

price (EP) or the constructed export price (CEP). The NV level of trade

is that of the starting-price sales in the comparison market or, when

NV is based on constructed value (CV), that of the sales from which we

derive selling, general and administrative expenses and profit. For EP,

the U.S. level of trade is the level of the starting-price sale, which

is usually from exporter to importer.

To determine whether NV sales are at a different level of trade

than EP or CEP, we examine stages in the marketing process and selling

functions along the chain of distribution between the producer and the

unaffiliated customer. If the comparison-market sales are at a

different level of trade, and the difference affects price

comparability, as manifested in a pattern of consistent price

differences between the sales on which NV is based and comparison-

market sales at the level of trade of the export transaction, we make a

level of trade adjustment under section 773(a)(7)(A) of the Act. See

Notice of Final Determination of Sales at Less Than Fair Value: Certain

Cut-to-Length Carbon Steel Plate from South Africa, 62 FR 61731

(November 19, 1997).

For the U.S. market, Saha Thai reported only one level of trade for

its EP sales. This single level of trade represents large volume sales

to unaffiliated trading companies/distributors in the U.S. In the home

market, Saha Thai claimed that sales were made at two levels of trade:

(1) large volume home market sales made to unaffiliated trading

companies and distributors (made at the same level of trade as U.S.

sales), and (2) sales made by its affiliated resellers to retailers and

end-users. Saha Thai claimed that the resellers' home market sales are

at a more advanced level of trade than Saha Thai/SAF's U.S. and home

market sales because the reseller sales require keeping varied

inventory on hand, higher warehouse staffing levels, and additional

delivery services and selling expenses.

[[Page 16978]]

To determine whether sales in the home market occur at two

different levels of trade, and therefore, whether a level of trade

adjustment should be applied when U.S. sales are matched to sales by

Saha Thai's resellers, we analyzed the selling expenses and functions

performed by Saha Thai and its affiliated resellers. In comparing the

two claimed home market levels of trade to each other, we note that

both Saha Thai and the resellers performed the following selling

functions: preparing merchandise for shipment, maintaining sales

records, and pricing/ discounts/ rebates. The following selling

functions are performed only by the resellers: maintaining inventory,

collecting bills, extending credit, pre-sale warehousing, and providing

delivery to the customer with its own fleet of trucks. The qualitative

nature of these different selling functions is reflective of a more

advanced marketing stage, viz-a-viz Saha Thai's sales to trading

companies/distributors. Consistent with this finding, we note

significant quantifiable difference in selling expenses (indirect

selling expenses and presale warehousing expenses) reported by the

resellers and Saha Thai. Thus, we determine that resellers' sales were

made at a more advanced level of trade than Saha Thai's sales in the

home market. Accordingly, where possible, we matched EP sales to home

market sales made at the same level of trade, i.e. to home market sales

made by Saha Thai.

When we compare U.S. sales to home market sales at a different

level of trade, we make a level-of-trade adjustment if the difference

in levels of trade affects price comparability. We determine any effect

on price comparability by examining sales at different levels of trade

in a single market, the home market. Any price effect must be

manifested in a pattern of consistent price differences between home

market sales used for comparison and sales at the equivalent level of

trade of the export transaction. To quantify the price differences, we

calculate the difference in the average of the net prices of the same

models sold at different levels of trade. We use the average difference

in net prices to adjust NV when NV is based on a level of trade

different from that of the export sale. If there is a pattern of no

price differences, the difference in levels of trade does not have a

price effect and, therefore, no adjustment is necessary. Because

comparisons of home market net prices did not reveal a pattern of

consistent price differences between Saha Thai's home market sales and

the resellers' home market sales, no level of trade adjustment was

granted.

Currency Conversion

For purposes of the preliminary results, we made currency

conversions based on the exchange rates in effect on the dates of the

U.S. sales as certified by the Federal Reserve Bank of New York. See

Change in Policy Regarding Currency Conversions, 61 FR 9434 (March 8,

1996). Section 773A(a) directs the Department to use a daily exchange

rate in order to convert foreign currencies into U.S. dollars unless

the daily rate involves a fluctuation. It is the Department's practice

to find that a fluctuation exists when the daily exchange rate differs

from the benchmark rate by 2.25 percent. The benchmark is defined as

the moving average of rates for the past 40 business days. When we

determine a fluctuation to have existed, we substitute the benchmark

rate for the daily rate, in accordance with established practice.

Preliminary Results of the Review

We preliminarily determine that the following weighted-average

dumping margins exist:

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

Margin

Manufacturer/exporter Period (percent)

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

Saha Thai/SAF........................... 3/1/96-2/28/97 1.92

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

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. Any hearing, if

requested, will be held 44 days after the date of publication or the

first business day thereafter. Case briefs and/or other written

comments from interested parties may be submitted not later than 30

days after the date of publication. Rebuttal briefs and rebuttals to

written comments, limited to issues raised in those comments, may be

filed not later than 37 days after the date of publication of this

notice. The Department will publish the final results of this

administrative review, which will include the results of its analysis

of issues raised in any such comments, within 120 days from the date of

publication of these preliminary results.

Upon issuance of the final results of review, the Department shall

determine, and the U.S. Customs Service shall assess, antidumping

duties on all appropriate entries. We calculated importer-specific ad

valorem duty assessment rates for the class or kind of merchandise

based on the ratio of the total amount of antidumping duties calculated

for the examined sales made during the POR to the total customs value

of the sales used to calculate those duties. This rate will be assessed

uniformly on all entries that particular importer made during the POR.

(This is equivalent to dividing the total amount of the antidumping

duties, which are calculated by taking the difference between statutory

NV and statutory EP, by the total statutory EP value of the sales

compared, and adjusting the result by the average difference between EP

and customs value for all merchandise examined during the POR). Upon

completion of this review, the Department will issue appraisement

instructions directly to the Customs Service.

Furthermore, the following deposit rates will be effective upon the

publication of the final results of these administrative reviews for

all shipments of circular welded carbon steel pipes and tubes from

Thailand entered, or withdrawn from warehouse, for consumption on or

after the publication date, as provided for by Section 751(a)(2)(c) of

the Act: (1) the cash deposit rate for the reviewed companies will be

that 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, or the original 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) the

cash deposit rate for all other manufacturers or exporters will

continue to be 15.67 percent, the ``All Others'' rate made effective by

the LTFV investigation. These requirements, when imposed, shall remain

in effect until publication of the final results of the next

administrative review.

[[Page 16979]]

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.

These preliminary results of review are issued and published in

accordance with section 751(a)(1) and 777(i)(1) of the Act and 19 CFR

353.22.

Dated: March 31, 1998.

Robert S. LaRussa,

Assistant Secretary for Import Administration.

[FR Doc. 98-9091 Filed 4-6-98; 8:45 am]

BILLING CODE 3510-DS-P