[Federal Register Volume 60, Number 88 (Monday, May 8, 1995)]
[Notices]
[Pages 22557-22561]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-11263]
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DEPARTMENT OF COMMERCE
[A-549-812]
Final Determination of Sales at Less Than Fair Value: Furfuryl
Alcohol From Thailand
Agency: Import Administration, International Trade Administration,
Department of Commerce.
EFFECTIVE DATE: May 8, 1995.
FOR FURTHER INFORMATION CONTACT: John Brinkmann or Greg Thompson,
Office of Antidumping Investigations, Import Administration, U.S.
Department of Commerce, 14th Street and Constitution Avenue, N.W.,
Washington, D.C. 20230; telephone (202) 482-5288 or 482-2336,
respectively.
Final Determination
We determine that furfuryl alcohol from Thailand is being, or is
likely to be, sold in the United States at less than fair value (LTFV),
as provided in section 735 of the Tariff Act of 1930, as amended (the
Act). The estimated margins are shown in the ``Suspension of
Liquidation'' section of this notice.
Case History
Since the preliminary determination of sales at LTFV on December 9,
1994 (59 FR 65014, December 16, 1994), the following events have
occurred.
At the request of the petitioner, QO Chemicals, the Department
postponed the final determination until May 1, 1995 (59 FR 66901,
December 28, 1994). Pursuant to the Department's request, on January
17, 1995, the respondent, Indo-Rama Chemicals (Thailand) Ltd. (IRCT),
submitted additional information pertaining to its potential exports
sales price (ESP) transactions. In addition, IRCT submitted its
response to Section D of the questionnaire, which requests information
on the cost of production (COP) and constructed value (CV). The
petitioner commented on this response, which IRCT later supplemented
pursuant to our request on February 6, 1995.
Verification of IRCT's sales and COP/CV questionnaire responses was
conducted during the months of February and March, 1995. The Department
issued reports concerning these verifications on March 21, 1995.
IRCT and the petitioner submitted case briefs on March 29, 1995,
and rebuttal briefs on March 31, 1995. At the petitioner's request, the
Department held a hearing on April 4, 1995.
Scope of Investigation
The product covered by this investigation is furfuryl alcohol
(C4H3OCH2OH). Furfuryl alcohol is a primary alcohol, and
is colorless or pale yellow in appearance. It is used in the
manufacture of resins and as a wetting agent and solvent for coating
resins, nitrocellulose, cellulose acetate, and other soluble dyes.
The product subject to this investigation is classifiable under
subheading 2932.13.00 of the Harmonized Tariff Schedule of the United
States (HTSUS). Although the HTSUS subheading is provided for
convenience and customs purposes, our written description of the scope
of this proceeding is dispositive.
Period of Investigation
The period of investigation (POI) is December 1, 1993, through May
31, 1994.
Applicable Statute and Regulations
Unless otherwise indicated, all citations to the statute and to the
Department's regulations are in reference to the provisions as they
existed on December 31, 1994.
Such or Similar Comparisons
For purposes of the final determination, we have determined that
furfuryl alcohol constitutes a single ``such or similar'' category of
merchandise. Since the respondent sold merchandise in the home market
identical to that sold in the United States during the POI, we made
identical merchandise comparisons.
Fair Value Comparisons
To determine whether sales of furfuryl alcohol from Thailand to the
United States were made at less than fair value, we compared the United
States price (USP) to the foreign market value (FMV), as specified in
the ``United States Price'' and ``Foreign Market Value'' sections of
this notice. In accordance with 19 CFR 353.58 (1994), we made
comparisons at the same level of trade, where possible.
United States Price
We based USP on purchase price, in accordance with section 772(b)
of the Act, because the subject merchandise was sold to an unrelated
purchaser before importation into the United States and because
exporter's sales price methodology was not otherwise indicated (see
Comment 2 below).
With regard to the calculation of movement expenses, we made
deductions from the U.S. sales price, where appropriate, for foreign
brokerage, foreign inland freight, ocean freight, and marine insurance
in accordance with section 772(d)(2)(A) of the Act.
Since IRCT discounts all account receivables pertaining to its U.S.
sales, we calculated U.S. credit expenses based on IRCT's average
short-term interest rate. In accordance with section 772(d)(1)(B) of
the Act, we added to USP the amount of the Thai import duties, not
collected on material inputs, by reason of exportation of the subject
merchandise to the United States.
In accordance with our standard practice, pursuant to the decision
of the U.S. Court of International Trade (CIT) in Federal-Mogul
Corporation and The Torrington Company v. United States, 834 F. Supp.
1391 (CIT 1993), our calculations include an adjustment to U.S. price
for the consumption tax levied on comparison sales in Thailand (See
Preliminary Antidumping Duty Determination: Color Negative Photographic
Paper and Chemical Components from Japan, 59 FR 16177, 16179 (April 6,
1994), for an explanation of this methodology). [[Page 22558]]
Cost of Production
As we indicated in our preliminary determination, the Department
initiated an investigation of potential below-cost home market sales on
November 21, 1994. In order to determine whether home market sales
prices were below COP within the meaning of section 773(b) of the Act,
we calculated COP based on the sum of the respondent's cost of
materials, fabrication, general expenses and packing, in accordance
with 19 CFR 353.51(c). We made the following adjustments to the
respondent's reported COP data:
1. We recalculated IRCT's corn cob consumption based on the
weighted-average cost of corn cobs used in the production of furfuryl
alcohol during the POI;
2. We recalculated depreciation expense based on the fixed asset
lives reported in IRCT's 1993 audited financial statements; and
3. We allocated annual general and administrative expenses based on
annual cost of sales.
After computing COP, we added the sales-specific VAT and home market
packing to the COP figure. We compared COP to reported prices that were
net of movement charges, direct and indirect selling expenses, and
inclusive of VAT and home market packing. In accordance with section
773(b) of the Act, we followed our standard methodology to determine
whether the home market sales of each product were made at prices below
COP in substantial quantities over an extended period of time, and
whether such sales were made at prices that would permit recovery of
all costs within a reasonable period of time in the normal course of
trade.
To satisfy the requirement of section 773(b)(1) that below-cost
sales be disregarded only if made in substantial quantities, we apply
the following methodology. Where we find that over 90 percent of a
respondent's sales were at prices above the COP, we do not disregard
any below-cost sales because we determine that a respondent's below-
cost sales are not made in substantial quantities. If between ten and
90 percent of a respondent's sales were at prices above the COP, we
disregard only the below-cost sales if made over an extended period of
time. Where we find that more than 90 percent of a respondent's sales
were at prices below the COP and were sold over an extended period of
time, we disregard all sales and calculate FMV based on CV, in
accordance with section 773(b) of the Act. In this case, we found that
between ten and 90 percent of the sales were made below the COP. As a
result, we tested whether those below cost sales had been made over an
extended period of time.
In accordance with section 773(b)(1) of the Act, in order to
determine whether below-cost sales had been made over an extended
period of time, we compare the number of months in which below-cost
sales occurred to the number of months in the POI in which the product
was sold. If a product was sold in three or more months of the POI, we
do not exclude below-cost sales unless there were below-cost sales in
at least three months during the POI. When we find that sales occurred
in one or two months, the number of months in which the sales occurred
constitutes the extended period of time; i.e., where sales were made in
only two months, the extended period of time was two months, where
sales were made in only one month, the extended period of time was one
month. (See Final Determination of Sales at Less Than Fair Value:
Certain Carbon Steel Butt-Weld Pipe Fittings from the United Kingdom
(60 FR 10558, 10560, February 27, 1995)). In this case, we found that
the respondent had made sales of furfuryl alcohol at prices below the
COP in two of the months that sales were made. As a result, none of the
sales made below the COP were disregarded.
Foreign Market Value
As stated in the preliminary determination, we found that the home
market was viable for sales of furfuryl alcohol, in accordance with 19
CFR 353.48(a). We calculated FMV based on delivered prices, and
deducted home market inland freight, unloading charges and insurance in
accordance with 19 CFR 353.56(a).
FMV was reduced by home market packing costs and increased by U.S.
packing costs in accordance with section 773(a)(1) of the Act. The
Department also made circumstance-of-sale adjustments for home market
direct selling expenses, which included imputed credit expenses and
technical services in accordance with 19 CFR 353.56(a)(2). We also
deducted commissions incurred on home market sales and added total U.S.
indirect selling expenses, capped by the amount of home market
commissions in accordance with 19 CFR 353.56(b). The total U.S.
indirect selling expenses included U.S. inventory carrying costs, and
indirect selling expenses incurred in Thailand on U.S. sales.
We adjusted for the consumption tax in accordance with our practice
(see ``United States Price'' section of this notice).
Currency Conversion
We have made currency conversions based on the official exchange
rates, as certified by the Federal Reserve Bank of New York, in effect
on the dates of the U.S. sales, pursuant to 19 CFR 353.60.
Verification
As provided in section 776(b) of the Act, we verified the
information used in making our final determination.
Interested Party Comments
What follows are summaries of the parties' arguments, followed by
the Department's positions on each of the issues raised.
Comment 1: Using Best Information Otherwise Available (BIA)
The petitioner states that the Department should use BIA for
purposes of the final determination because IRCT impeded the conduct of
the investigation by failing to divulge the extent of its relationship
with the U.S. importer, Indo-Rama Chemicals (America), Inc. (IRCA). The
petitioner claims that IRCT should have reported its U.S. sales as ESP
rather than on a purchase price basis, and only reported ESP data after
the Department specifically requested it to do so.
The respondent states that it provided the Department with all the
necessary ESP data in a timely manner when it was requested and,
further, that it fully cooperated in the investigation regarding the
relationship between IRCA and IRCT.
DOC Position
We agree with the respondent that IRCT and IRCA cooperated with the
Department throughout this investigation. They submitted all requested
information, and documented it during verification. Because IRCT did
not impede our investigation, we have used the respondent's data for
purposes of the final determination.
Comment 2: ESP or Purchase Price
IRCT contends that its categorization of IRCA as an unrelated party
is consistent with the Department's definition of related parties
pursuant to section 771(13), was verified by the Department, and that
the U.S. price should be based upon the purchase price methodology. The
respondent's argument is fully discussed in the proprietary version of
its case brief.
The petitioner argues that the record evidence indicates that IRCT
and IRCA are related parties and, therefore, if the Department decides
not to resort to BIA, it should base USP on ESP. The petitioner's
argument is fully discussed [[Page 22559]] in the proprietary version
of its case brief. The following are some of the non-proprietary points
that the petitioner raises: (1) The owner of IRCA is also president and
director to a sister company of IRCT; and (2) the ESP response was
filed on behalf of IRCT by, and the entire response was certified only
by, IRCT's counsel.
DOC Position
We determined that the information on the record, as verified by
the Department, does not satisfy the criteria set forth in section
771(13) of the Act for recognizing the U.S. sales as ESP transactions.
An analysis of the individual criteria considered requires reference to
proprietary information and is discussed in the proprietary version of
the concurrence memorandum, dated May 1, 1995. Because we found that
IRCA does not act as IRCT's principal or agent, under 771(13), at least
one of the parties would have to own or control an interest in the
other, or some other person or persons would have to own or control
sufficient interest in both, for the Department to determine USP on the
basis of ESP data (see Small Business Telephone Systems from Korea, 54
FR 53141 (1989) and/or Certain Forged Steel Crankshafts from Japan, 52
FR 36984 (1987)). The Department confirmed at verification that there
was no ownership or controlling interest between IRCT and IRCA, and no
common ownership or controlling interest by a third party. Therefore,
we have based the USP on purchase price.
Comment 3: Indirect Selling Expenses
The petitioner argues that, because the respondent failed to
provide the Department with information concerning additional indirect
selling expenses and storage charges incurred in the United States, the
Department should use BIA to determine the indirect selling expenses
for the POI. As BIA, the petitioner requests that the Department rely
on information in the petition.
The respondent asserts that it did not understate any selling
expenses incurred in the importation, storage, or sale of furfuryl
alcohol. The respondent argues that the Department verified both IRCT
and IRCA with respect to these expenses. Therefore, in the event the
Department makes its final determination based on ESP, the respondent
argues that the Department should calculate U.S. indirect selling
expenses on the information provided. The respondent further states
that many of the indirect selling expenses that the petitioner
referenced simply do not exist.
DOC Position
Based on the Department's decision to use the purchase price
methodology, this issue has been rendered moot.
Comment 4: Interest Rate
The petitioner argues that the Department should use the
appropriate interest rate from IRCA's response in computing any credit
expenses and inventory carrying cost. The petitioner's argument is
fully discussed in the proprietary version of its March 29, 1995 case
brief.
The respondent states that it is not related to IRCA. However,
should the Department base its determination on ESP sales, the
respondent argues that the Department should not use IRCA's interest
rate. The respondent's argument is fully discussed in the proprietary
version of its case brief.
DOC Position
The use of the importers's interest rate in the calculation of
credit expense and inventory carrying cost for U.S. sales is not at
issue because the calculation of USP is based on the purchase price
methodology. Therefore, the interest rate used to calculate both
expenses for U.S. sales is based on IRCT's short-term borrowing
experience. Because the U.S. sales are made in U.S. dollars, the
interest rate used to calculate the credit expense and inventory
carrying cost is the rate that IRCT incurs for its U.S. dollar
denominated short-term borrowing for the POI (see Final Determination
of Sales at Less than Fair Value: Disposable Pocket Lighters from
Thailand, 51 FR 14270, 14265 (March 16, 1995)).
Comment 5: Technical Service
IRCT contends that home market ``outside'' technical service
expenses are directly related to specific sales, and are properly
deductible as direct selling expenses.
DOC Position
This issue is moot because the expenses were incurred on sales
which are not included in our final calculations, having occurred at a
level of trade different than that of the U.S. sales.
Comment 6: Home Market Sale Outside the Ordinary Course of Trade
In its original sales listing, IRCT categorized one home market
sale as outside of the ordinary course of trade. IRCT states that the
sale was inadvertently reported as a normal sale in the revised sales
listing. IRCT states that this sale was (1) a single isolated trial
sale for a different application, (2) of a quantity far smaller than
the standard quantity sold for all other home market sales, and (3) at
a price substantially higher than that charged to IRCT's regular
customers.
DOC Position
We agree with the respondent. Section 771(15) of the Act defines
``ordinary course of trade'' as those conditions and practices which
are ``normal in the trade under consideration.'' The documents for this
sale were verified and the sale was found to be an isolated, non-
recurring sale, and at a quantity inconsistent with the standard
quantity shipped. Therefore, because the sale was not normal in the
trade under consideration, we found it to be made outside the ordinary
course of trade under section 771(15) of the Act. Accordingly, we have
not included it in our margin analysis.
Comment 7: Allocation of Indirect Selling Expenses
IRCT argues that the Department should use the revised allocation
percentages for unassigned indirect selling expenses (e.g., office
rental, phone, etc.) that were presented during verification because
these percentages more accurately reflect the actual time spent by the
sales personnel.
The petitioner contends that this revised allocation constitutes a
submission of untimely, unsupported data in the middle of verification
and, therefore, should not be relied upon by the Department.
DOC Position
Based on the fact that neither IRCT's original allocation nor its
revised allocation of indirect selling expenses was supported by
documentation, neither was used in our final determination. Instead,
the Department allocated these expenses based on the quantity of
furfuryl alcohol sold in the domestic and export markets. Given the
lack of information, this was the most reasonable allocation
methodology available (see concurrence memorandum dated, May 1, 1995).
Comment 8: Corn Cob Costs
The petitioner asserts that the cost of corn cobs, a primary direct
material of furfuryl and furfuryl alcohol, should be calculated based
on the respondent's actual corn cob expenses incurred during the POI,
rather than on the annual weighted-average methodology submitted by
IRCT. Further, the petitioner argues for the use of actual expenses
because the respondent's corn cob prices vary according to competitive
[[Page 22560]] market conditions, rather than the seasonality of corn
production claimed by the respondent.
The respondent contends that its methodology accurately reflects
corn cob consumption because it eliminates seasonal trends in pricing,
availability, and purchases. Additionally, the respondent states its
submission methodology is consistent with its normal accounting system.
Moreover, the petitioner's proposed methodology ignores the value of
corn cob in beginning inventory. Therefore, the respondent argues that
the Department should reject the petitioner's claim.
DOC Position
The most appropriate cost calculation methodology for corn cobs
used in the production of furfuryl alcohol should take into account the
actual corn cobs used during the POI based on IRCT's normal weighted-
average inventory cost flow assumption. Therefore, we have recalculated
IRCT's corn cob cost based on the weighted-average cost of corn cob
inventories at the beginning of the POI, plus all purchases of the
input made during the POI.
Comment 9: Depreciation
The petitioner argues that the Department should reject IRCT's
claimed increase in the useful lives of its buildings and machinery
which was submitted in accordance with a change in IRCT's depreciation
policy. According to the petitioner, IRCT's proposed change in its
depreciation policy was approved after the initiation of this case. It
maintains that, at a minimum, the Department should recompute
depreciation expense for IRCT's buildings and machinery based on the
original useful lives of the assets. However, the petitioner claims
that even these useful lives, as well as the useful lives of other
assets owned by IRCT, are inconsistent with U.S. generally accepted
accounting principals (GAAP) and thus distort the costs associated with
the production of furfuryl alcohol.
IRCT argues that its submitted depreciation expense reflects its
normal record keeping for the period that most closely corresponds to
the POI. It claims that it extended the useful lives of its buildings
and machinery because the assets were constructed of ``high-quality,
long-lasting'' materials. The decision to change the estimated useful
lives of its assets, IRCT states, was made prior to the initiation of
this investigation.
DOC Position
In computing COP for the subject merchandise, the Department
generally relies on the accounting records maintained by respondent in
the normal course of its operations. These records, however, must be
kept in accordance with respondent's home country GAAP if those GAAP
reasonably reflect the costs associated with producing the subject
merchandise.
In IRCT's case, the change in the useful lives of buildings and
machinery assets, although reflected in the company's accounting
records during 1994, had yet to be approved by the company's
independent auditors or the Thai government as of the date of our
verification. Thus, we believe that it is inappropriate for us to
determine whether IRCT's change in the useful lives of these assets
reasonably reflects the company's depreciation expense for the POI
since it is impossible for us to conclude that the new policy is in
accordance with Thai GAAP.
We disagree with the petitioner's argument that the original useful
lives of IRCT's assets are not in accordance with U.S. GAAP and thus
distort furfuryl alcohol production costs. U.S. GAAP allows companies
to determine the useful lives of production assets based on the
estimated economic lives of those assets. In IRCT's case, we have no
reason to believe that the depreciable lives historically utilized by
the company fail to reflect the economic lives of the underlying
assets. Therefore, we have calculated depreciation expense based on the
original useful lives of the assets.
Comment 10: General and Administrative Expense (``G&A'') Allocation
The petitioner contends that IRCT provided no justification for
deviating from the Department's normal G&A calculation methodology by
allocating G&A expenses to non-productive cost centers. According to
the petitioner, IRCT's methodology distorts the cost of production for
furfuryl alcohol. Therefore, as BIA, the petitioner asserts the
Department should allocate all G&A expenses solely to furfuryl alcohol.
IRCT argues that its G&A allocation methodology is consistent with
GAAP and appropriate for this investigation. According to IRCT, the
Department's normal methodology of allocating G&A, on the basis of cost
of sales, overstates furfuryl alcohol production costs. IRCT contends
that, its G&A allocation methodology more properly matches benefits
received from G&A expenditures to the appropriate business cost
centers.
DOC Position
We agree with the petitioner that IRCT did not adequately support
is G&A allocation methodology. To compute G&A expense for COP, IRCT
allocated its G&A expense equally among its four cost centers. Two of
those cost centers did not produce any products during the POI.
During verification, IRCT provided no evidence to support its
allocation methodology for G&A expenditures, nor did IRCT demonstrate
that the allocation methodology was used in its normal accounting
system. Instead, we found that IRCT's submitted G&A allocation
methodology was based on subjective factors. We have, therefore,
recalculated IRCT's G&A expenses by allocating reported fiscal year
1993 company-wide G&A expense based on the company's cost of sales for
that year. This is in accordance with our normal G&A methodology, as
stated in section D of the Department's questionnaire.
Comment 11: G&A Expense Calculation Period
IRCT reported G&A expenses based on the six-month POI rather than
on an annual basis. IRCT contends its six-month G&A expense calculation
accurately reflects the actual G&A costs incurred during the POI.
DOC Position
Ordinarily, G&A expenses are considered to be period costs for
accounting purposes. As such, they differ from product costs like
direct materials, labor, and overhead in that G&A expenses are not
included in inventory costs but, instead, are accounted for as expenses
during the period in which they are incurred. This is because, unlike
product costs, G&A can neither be easily nor accurately matched to the
revenues generated from the sales of an individual unit of production.
Instead, G&A expenses are typically incurred in connection with a
company's overall operations. Many expenses categorized as G&A, such as
insurance and bonus payments, are incurred sporadically throughout the
fiscal year. Moreover, G&A expenses are often accrued during the fiscal
year based on estimates that are then adjusted to actual expenses at
year-end. Because of their nature as period costs, and due to the
irregular manner in which many companies record G&A expenses, the
Department generally looks to a full-year period in computing G&A
expenses for COP and CV. Such a period encompasses operating results
over a longer time span than the POI and typically reports the results
of at [[Page 22561]] least one business cycle. Under ordinary
circumstances, the most appropriate full-year G&A period is that
represented by the latest fiscal year for which the respondent has
complete and audited financial statements.
IRCT provided no evidence to justify deviating from the
Department's normal practice of using annual financial data for G&A. As
of the last day of verification, IRCT's 1994 audited financial
statements were not available. Consequently, we calculated G&A expense
based on IRCT's 1993 annual audited financial statements.
Comment 12: Waste Water
The petitioner states that IRCT excluded certain waste water
treatment expenses from its submitted COP. As BIA, the petitioner
suggests that the Department include the accounts payable amount
reported in IRCT's May 1994 Trial Balance.
The respondent asserts that it has properly included all waste
water treatment costs in its submitted COP. It states that the
particular account noted by the petitioner reflects costs associated
with the purchase of waste water treatment equipment.
DOC Position
We agree with the respondent. The respondent included all waste
water treatment expenses incurred during the POI in its COP submission.
Therefore, no adjustment is required.
Comment 13: Insurance Proceeds
IRCT offset its submitted COP for furfuryl alcohol by insurance
proceeds received due to an unexpected equipment failure during the
POI. IRCT contends that it properly included insurance revenue received
for both equipment repair costs and for the increase in per-unit costs
resulting from the equipment failure.
The petitioner concedes that IRCT tied part of the insurance
settlement directly to equipment repair costs and should be allowed a
partial offset for these costs. According to the petitioner, however,
IRCT did not show how the remaining proceeds relate to the company's
claimed increase in per-unit costs.
DOC Position
We agree with the respondent that the insurance proceeds should be
used to offset IRCT's furfuryl alcohol costs. During verification, we
found that the insurance proceeds were paid to IRCT for equipment
failure and overhead costs incurred during the period in which the
equipment was under repair. Thus, these proceeds relate directly to the
equipment failure which occurred during the POI. Due to this equipment
failure, IRCT incurred higher per-unit production costs in addition to
the cost of repairs. Accordingly, we consider it reasonable for IRCT to
offset its submitted COP by all proceeds received for the insurance
claim.
Suspension of Liquidation
In accordance with section 735(d) of the Act, we are directing the
Customs Service to suspend liquidation of all entries of furfuryl
alcohol from Thailand, as defined in the ``Scope of Investigation''
section of this notice, that are entered, or withdrawn from warehouse,
for consumption on or after the date of publication of our final
determination1 in the Federal Register.
\1\The preliminary determination was negative in this case.
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The Customs Service shall require a cash deposit or posting of a
bond on all entries equal to the estimated amount by which the FMV
exceeds the USP, as shown below. The suspension of liquidation will
remain in effect until further notice.
------------------------------------------------------------------------
Margin
Producer/manufacturer/exporter percentage
------------------------------------------------------------------------
IRCT........................................................ 5.94
All Others.................................................. 5.94
------------------------------------------------------------------------
ITC Notification
In accordance with section 735(d) of the Act, we have notified the
ITC of our determination. The ITC will make its determination whether
these imports materially injure, or threaten injury to, a U.S. industry
within 45 days of the publication of this notice. If the ITC determines
that material injury or threat of material injury does not exist, the
proceeding will be terminated and all securities posted as a result of
the suspension of liquidation will be refunded or cancelled.
However, if the ITC determines that such injury does exist, we will
issue an antidumping duty order directing the Customs Service officers
to assess an antidumping duty on furfuryl alcohol from Thailand,
entered, or withdrawn from warehouse, for consumption on or after the
date of suspension of liquidation, equal to the amount by which the
foreign market value of the merchandise exceeds the United States
price.
This determination is published pursuant to section 735(d) of the
Act (19 U.S.C. 1673(d)) and 19 CFR 353.20.
Dated: May 1, 1995.
Susan G. Esserman,
Assistant Secretary for Import Administration.
[FR Doc. 95-11263 Filed 5-5-95; 8:45 am]
BILLING CODE 3510-DS-P