[Federal Register Volume 61, Number 200 (Tuesday, October 15, 1996)]
[Notices]
[Pages 53702-53711]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 96-26358]


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DEPARTMENT OF COMMERCE
[A-570-815]


Sulfanilic Acid From the People's Republic of China; Final 
Results and Partial Rescission of Antidumping Duty Administrative 
Review

AGENCY: International Trade Administration, Import Administration, 
Department of Commerce.

ACTION: Notice of final results and partial rescission of antidumping 
duty administrative review.

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SUMMARY: On June 7, 1996, the Department of Commerce (the Department) 
published the preliminary results of its administrative review of the 
antidumping duty order on sulfanilic acid from the People's Republic of 
China (PRC). This review covers the period August 1, 1994 through July 
31, 1995.

EFFECTIVE DATE: October 15, 1996.

FOR FURTHER INFORMATION CONTACT: Karin Price or Maureen Flannery, 
Import Administration, International Trade Administration, U.S. 
Department of Commerce, 14th Street and Constitution Avenue, N.W., 
Washington D.C. 20230; telephone (202) 482-4733.

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 (the Act) by the 
Uruguay Round Agreements Act (URAA). In addition, unless otherwise 
indicated, all citations to the Department's regulations are to the 
current regulations, as amended by the interim regulations published in 
the Federal Register on May 11, 1995 (60 FR 25130).

Background

    On June 7, 1996, the Department published in the Federal Register 
(61 FR 29073) the preliminary results of its administrative review of 
the antidumping duty order on sulfanilic acid from the PRC (57 FR 
37524, August 19, 1992). We conducted a hearing on July 24, 1996. We 
have now completed the administrative review in accordance with section 
751 of the Act.

Scope of the Review

    Imports covered by this review are all grades of sulfanilic acid, 
which include technical (or crude) sulfanilic acid, refined (or 
purified) sulfanilic acid and sodium salt of sulfanilic acid.
    Sulfanilic acid is a synthetic organic chemical produced from the 
direct sulfonation of aniline with sulfuric acid. Sulfanilic acid is 
used as a raw material in the production of optical brighteners, food 
colors, specialty dyes, and concrete additives. The principal 
differences between the grades are the undesirable quantities of 
residual aniline and alkali insoluble materials present in the 
sulfanilic acid. All grades are available as dry, free flowing powders.
    Technical sulfanilic acid contains 96 percent minimum sulfanilic 
acid, 1.0 percent maximum aniline, and 1.0 percent maximum alkali 
insoluble materials. Refined sulfanilic acid contains 98 percent 
minimum sulfanilic acid, 0.5 percent maximum aniline and 0.25 percent 
maximum alkali insoluble materials.
    Sodium salt is a powder, granular or crystalline material which 
contains 75 percent minimum equivalent sulfanilic acid, 0.5 percent 
maximum aniline based on the equivalent sulfanilic acid content, and 
0.25 percent maximum alkali insoluble materials based on the equivalent 
sulfanilic acid content.
    This merchandise is classifiable under Harmonized Tariff Schedule 
(HTS) subheadings 2921.42.22 and 2921.42.90. Although the HTS 
subheadings are provided for convenience and customs purposes, our 
written description of the scope of this proceeding is dispositive.
    This review covers 13 manufacturers/exporters of sulfanilic acid 
from the PRC, and the period August 1, 1994 through July 31, 1995.

[[Page 53703]]

Analysis of Comments Received

    We invited interested parties to comment on the preliminary 
results. We received written comments from Yude Chemical Industry Co. 
(Yude), Zhenxing Chemical Industry Co. (Zhenxing), Sinochem Hebei 
Import and Export Corporation (Sinochem Hebei), PHT International, Inc. 
(PHT), and New Chemic (U.S.A.), Inc. (New Chemic) (collectively, 
respondents); and from the petitioner, Nation Ford Chemical Company. At 
the request of PHT and the petitioner, a public hearing was held on 
July 24, 1996.

Comment 1

    Petitioner argues that, because sales to the United States of 
sulfanilic acid produced by Yude and Zhenxing were made by China 
National Chemical Construction Corporation (CNCCC), Yude and Zhenxing 
are not the proper respondents in this case. Instead, petitioner 
contends that CNCCC is the proper respondent.
    Petitioner states that, in the preliminary results, the Department 
considered sales to PHT, the U.S. importer, of sulfanilic acid produced 
by Yude and Zhenxing to be constructed export price (CEP) sales because 
PHT is affiliated with Yude and Zhenxing. However, petitioner notes 
that Yude and Zhenxing are not related to CNCCC, Yude and Zhenxing sold 
the sulfanilic acid to CNCCC, CNCCC exported the sulfanilic acid 
produced by Yude and Zhenxing to the United States after purchasing the 
sulfanilic acid, and CNCCC, not PHT, paid Yude and Zhenxing for the 
sulfanilic acid. As a result, petitioner contends that CNCCC is the 
proper respondent in this review with respect to these sales, and that 
Yude and Zhenxing are not entitled to a separate margin and should 
receive the PRC-wide rate of 85.20 percent. Petitioner further argues 
that CNCCC is a named respondent in this review and did not respond to 
the questionnaire sent to it by the Department. Accordingly, petitioner 
claims that the margin which should be assigned to CNCCC, as the 
exporter, should be based on facts available and should be the PRC-wide 
rate of 85.20 percent.
    Respondents reply that Yude and Zhenxing are the proper respondents 
because they set the export price, and these sales were properly 
reported and treated as CEP sales. According to respondents, PHT 
negotiates the export price with Yude and Zhenxing directly, and CNCCC 
simply processes the paperwork. Respondents contrast this situation 
with a typical sale involving a PRC trading company, in which the U.S. 
importer negotiates the export price with the trading company, not the 
factory, and the trading company sources the product from the factory, 
even though the U.S. importer often knows of and specifies the factory 
in its order. Respondents further note that the invoices to PHT are 
from either Yude or Zhenxing, not from CNCCC, and that, prior to the 
establishment of the joint ventures, the invoices were from CNCCC. 
Respondents cite the Department's proposed regulations, which state 
that the Department will normally use the date of invoice as the date 
of sale. As a result, respondents argue, since the invoice date 
establishes the date of sale, and since invoices are between either 
Yude and Zhenxing and PHT or between PHT and its unaffiliated U.S. 
customers, the first unrelated U.S. sale is between PHT and its 
unrelated U.S. customers, and Yude and Zhenxing are the proper 
respondents.

Department's Position

    We disagree with petitioner, and have continued to consider these 
sales to be CEP sales made by Yude and Zhenxing. We found at 
verification that CNCCC's role in the sale of the merchandise to the 
United States is limited to processing paperwork, such as packing 
lists, and arranging for shipments, and that CNCCC receives a profit 
for these activities. We also found that PHT talks to the factories two 
or three times each year to negotiate the price between PHT and the 
factories, and that the price paid to the factory is fairly constant. 
We did find that PHT pays CNCCC, who then pays the factories. However, 
payment is made this way because the factories are small and do not 
have foreign exchange bank accounts, and the transaction between CNCCC 
and the factories is made in renminbi. See page 3 of the May 30, 1996 
PHT verification report. Since the price to PHT is determined through 
negotiations with Yude and Zhenxing, and CNCCC's role is limited to 
processing paperwork, Yude and Zhenxing are the proper respondents in 
this review, and we have reviewed PHT's sales to its unaffiliated 
customers. As in the preliminary results of review, Yude and Zhenxing 
have received a separate rate, and CNCCC has received a rate based on 
facts available because it did not respond to the questionnaire.

Comment 2

    Petitioner argues that use of Indian import prices of aniline as 
the surrogate value for aniline is inappropriate. Petitioner contends 
that the domestic market prices of aniline reported in Chemical 
Business and Chemical Weekly should be used as surrogate values because 
they accurately reflect the prices paid for aniline by Indian 
manufacturers of sulfanilic acid. It notes that the import value of 
aniline used for the preliminary results of review is less than half 
the prices reported in Chemical Business and Chemical Weekly.
    Petitioner states that, in selecting surrogate values for a 
factors-of-production analysis, the Department attempts to calculate 
values for raw materials in a manner which closely approximates the 
actual costs of the raw materials paid by manufacturers in the 
surrogate country market. As support, petitioner cites to 19 U.S.C. 
Sec. 1677b(c), the Final Determination of Sales at Less Than Fair 
Value: Coumarin from the People's Republic of China (59 FR 66895, 
December 28, 1994) (Coumarin), and the Notice of Final Determination of 
Sales at Less Than Fair Value: Saccharin from the People's Republic of 
China (59 FR 58818, November 15, 1994) (Saccharin).
    Petitioner contends that the data it submitted from Chemical 
Business and Chemical Weekly provide the most accurate source of 
surrogate values for aniline, and points to the consistency of the data 
reported in those publications as an indication of the accuracy and 
reliability of that data. It states that the fact that the import value 
of aniline is so much lower than the prices reported in Chemical 
Business and Chemical Weekly is evidence that the prices in those 
publications are more reliable. Petitioner notes that these 
publications have been used as sources of surrogate values in other 
cases, including the Notice of Final Determination of Sales at Less 
Than Fair Value: Sebacic Acid from the People's Republic of China (59 
FR 28053, May 31, 1994) (Sebacic Acid) and the Notice of Final 
Determination of Sales at Less Than Fair Value: Bicycles from the 
People's Republic of China (61 FR 19026, April 30, 1996) (Bicycles), 
and were also used to determine surrogate values for sulfuric acid and 
activated carbon in the preliminary results of this review. According 
to petitioner, it makes no sense for the Department to use Chemical 
Business and Chemical Weekly for two surrogate values in this review, 
but to reject them for valuing aniline.
    Petitioner further argues that there is nothing on the record to 
suggest that the PRC producers only use aniline imported into the PRC, 
or that Indian manufacturers of sulfanilic acid only use imported 
aniline. Without substantial evidence pointing to import values as the 
source for the surrogate values, it believes that the Department

[[Page 53704]]

should not rely on the low import values.
    Moreover, petitioner contends that the Indian import statistics 
used by the Department for the preliminary results reflect the value of 
the aniline at the foreign port of export, and, therefore, the cost to 
produce aniline in the country of exportation, not India. As a result, 
the import statistics do not reflect costs incurred by Indian 
sulfanilic acid manufacturers and should be rejected.
    Petitioner also claims that reliance on Indian import statistics 
assumes that Indian sulfanilic acid producers can purchase aniline in 
bulk quantities at low per-unit prices, noting that chemicals such as 
aniline are imported in large quantities by Indian importers. By 
contrast, Indian sulfanilic acid producers are small operations without 
the need or ability to purchase, store, or use large volumes of 
aniline, and would pay a higher per-unit cost than do Indian importers 
of such chemicals. Petitioner argues that the reported Indian domestic 
prices of aniline in Chemical Business and Chemical Weekly reflect the 
development of the Indian industry, which is similar to that of the 
Chinese industry and consists of smaller facilities without modern, 
efficient methods of production.
    Petitioner contends that respondents' argument in comments 
submitted before the preliminary results that the Department should 
disregard the domestic prices of aniline, a petroleum-based product, in 
Chemical Business and Chemical Weekly because India is not a petroleum 
producing country, resulting in artificially high domestic aniline 
prices, is unfounded. Petitioner states that respondents have not 
offered support for this claim, and notes that leading aniline 
exporters, such as Japan or the Netherlands, do not produce large 
amounts of petroleum. Accordingly, petitioner contends that petroleum 
production does not determine the price of aniline.
    Petitioner further contends that the import prices should not be 
used because they cover a period prior to the period of review and do 
not include imports during four months of the period of review. 
According to petitioner, by contrast, the data provided by petitioner 
in Chemical Business and Chemical Weekly cover the entire period of 
review.
    Lastly, petitioner argues that the Department has considered 
whether Indian import statistics merit consideration as surrogate 
values in other cases. Petitioner cites specifically to Coumarin, in 
which the Department found that Indian import statistics for chlorine 
were aberrational because they varied sharply from ``numerous examples 
of alternative price sources,'' and therefore did not use the import 
values for chlorine. Instead, the Department used non-publicly 
available price quotes supplied by the petitioner. Petitioner also 
notes that counsel for respondents has argued in other cases that 
import values were aberrational and should not be used as surrogate 
values, citing to the Final Determination of Sales at Less Than Fair 
Value: Sulfur Dyes, Including Sulfur Vat Dyes, from the People's 
Republic of China (58 FR 7537, February 8, 1993), and Saccharin. 
Petitioner contends that the situation in this case is no different, 
because a number of sources of information on the record of this review 
indicate that the value of aniline is at least two times greater than 
the import value used by the Department in the preliminary results of 
review.
    Respondents contend that the Department should continue to use 
import prices for valuing aniline, as was done in the less-than-fair-
value (LTFV) investigation of this case (see Final Determination of 
Sales at Less Than Fair Value: Sulfanilic Acid from the People's 
Republic of China (57 FR 29705, July 6, 1992) (Sulfanilic Acid)). They 
state that the Department's primary objective in a review is to 
calculate antidumping margins as accurately as possible for the PRC 
producers/exporters, citing the Final Determinations of Sales at Less 
Than Fair Value: Oscillating Fans and Ceiling Fans from the People's 
Republic of China (56 FR 55271, October 25, 1991) (Fans). To do so, the 
Department must determine the actual cost of aniline for an Indian 
manufacturer that produces sulfanilic acid for export. They state that 
the evidence on the record of this review shows that Indian sulfanilic 
acid producers use imported aniline to produce sulfanilic acid for 
export. They note that they have submitted to the record a letter from 
an Indian sulfanilic acid producer stating that it uses imported 
aniline to produce sulfanilic acid for export, a letter from an Indian 
sulfanilic acid exporter describing in detail how an Indian producer 
uses imported aniline for export without paying import duties, and a 
letter from a sulfanilic acid end user stating that Indian sulfanilic 
acid producers could not use domestic aniline to produce sulfanilic 
acid for export because their prices would not be competitive. They 
contend that since there is no publicly available published information 
regarding the source of aniline for Indian sulfanilic acid producers, 
the Department must rely on this next best information to show that 
imported aniline is used by Indian sulfanilic acid producers. They 
further note that there is nothing on the record showing that Indian 
manufacturers use domestically-produced aniline to produce sulfanilic 
acid for export.
    According to respondents, the domestic Indian aniline market is 
inefficient and protected by high tariffs. Therefore, respondents 
argue, Indian-produced aniline is very expensive, and the Indian 
government allows aniline to be imported duty free for production of 
sulfanilic acid for export. Respondents contend that petitioner fails 
to take into account that Indian sulfanilic acid producers use 
different aniline inputs for producing sulfanilic acid for the domestic 
and export markets. Respondents state that, while the prices reported 
in Chemical Business and Chemical Weekly may reflect the cost of 
domestically-produced aniline, they do not reflect the cost of imported 
aniline used to produce sulfanilic acid for export and should therefore 
be rejected in favor of import prices.
    They further claim that the Indian import prices are not 
aberrational, stating that they are close to the world market price and 
have remained relatively steady during the period of review. They argue 
that the fact that the import prices are very stable reflects a 
consistency in grade, type, and quality of the aniline imported into 
India. Lastly, respondents note that the Department is not required to 
choose one source of surrogate information to value all factors in the 
face of evidence that it will lead to inaccurate results, and that the 
Department has access to Indian import statistics covering the entire 
period of review.

Department's Position

    We disagree with petitioner. The evidence placed on the record of 
this review by the respondents indicates that Indian sulfanilic acid 
producers use imported aniline in their production process when they 
produce sulfanilic acid for export (see Appendix 2B of respondents' 
April 11, 1996 submission). Therefore, these values best approximate 
the cost paid by the sulfanilic acid exporters in India, and we have 
continued to use import prices reported in the Monthly Statistics of 
the Foreign Trade of India, Volume II--Imports (Indian Import 
Statistics) to value aniline for the final results of review, as in the 
LTFV investigation of this case (see our response to Comment 1 in 
Sulfanilic Acid). For the final results of review, we have used import 
statistics for the months of the period of review which were 
unavailable at the

[[Page 53705]]

time of the preliminary results of review.
    With regard to petitioner's argument that the import statistics 
reflect the value at the port of export, we note that the introductory 
comments to the Indian Import Statistics state that the values are 
reported on a CIF (cost, insurance, freight) basis (see our response to 
Comment 3). Therefore, we disagree with petitioner that the import 
values are inappropriate because they reflect only the cost to produce 
in the country of exportation.
    Contrary to petitioner's argument that it does not make sense to 
reject Chemical Business and Chemical Weekly for aniline but to use 
them for other factors, we believe that we can use different sources 
for valuing different factors when we find that the surrogate values 
are appropriate. Therefore, it is not inappropriate to use the Indian 
Import Statistics to value aniline and to use Chemical Business and 
Chemical Weekly to value other factors.

Comment 3

    Petitioner argues that, if the Department continues to use import 
prices as the surrogate value for aniline, the import prices should be 
adjusted to account for ocean freight from the port of export to India, 
Indian port terminal and brokerage charges, the Indian importers' mark-
up, and the Indian import duty, in order to approximate costs incurred 
by Indian sulfanilic acid producers. Petitioner contends that the 
aniline import values relied upon by the Department in the preliminary 
results are FOB values at the foreign port of export, and, therefore, 
do not include such costs. Petitioner states that the ultimate 
purchaser of the aniline, the Indian sulfanilic acid producer, would 
clearly be charged these expenses, and that an upward adjustment is 
necessary to reflect the total cost of the aniline. Petitioner contends 
that even the respondents have acknowledged the fact that the import 
values should be adjusted upwards, citing the letter from a sulfanilic 
acid end user, submitted by respondents, in which the end user stated 
that when determining an appropriate delivered price to a sulfanilic 
acid producer in India, one must ``add typical ocean freight and 
delivery charges.'' Petitioner suggests that the profit margin reported 
to the Department by PHT be used to make the adjustment for the 
importer's markup.
    With regard to import duties, petitioner states that aniline 
imported into India during the period of review was subject to an ad 
valorem duty of 85 percent which was not added to the surrogate value 
for aniline in the preliminary results of this review. According to 
petitioner, the letter from the sulfanilic acid exporter provided by 
the respondents, which states that import duties on aniline are not 
collected when the sulfanilic acid is exported, does not demonstrate 
that this 85 percent duty should not be included in the surrogate 
value. Petitioner notes that the Department has previously concluded 
that the import duty exemption for aniline was a countervailable 
subsidy under the U.S. law, citing the Preliminary Affirmative 
Countervailing Duty Determination: Sulfanilic Acid from India (57 FR 
35784, August 11, 1992), and argues that the alleged forgiveness of 
import duties, a countervailable subsidy, does not warrant the 
disregarding of the import duty in the factors-of-production analysis.
    Respondents reply that the Department should not make any 
adjustments to the import value of aniline. They state that, in 
previous cases, such as Sebacic Acid, Saccharin, and the Notice of 
Final Determination of Sales at Less Than Fair Value; Polyvinyl Alcohol 
from the People's Republic of China (61 FR 14057, March 29, 1996) 
(Polyvinyl Alcohol), the Department has eliminated from the surrogate 
values excise taxes, freight, and all other charges associated with the 
surrogate values because the Department already adds amounts for 
freight charges and other markups. Respondents note that, in this 
review, the Department has added to the surrogate value for aniline 
freight costs for transporting the aniline from the supplier in the PRC 
to the sulfanilic acid factory and PRC brokerage and handling costs. 
Therefore, respondents contend, the petitioner is arguing that the 
Department double count such expenses.
    Respondents also state that they have submitted evidence to the 
record of this review showing that, pursuant to the Indian government's 
duty drawback program, Indian importers of aniline import the chemical 
duty free and export the sulfanilic acid without the payment of the 
import duty. Therefore, the import duty would not be included in the 
cost of the aniline to the sulfanilic acid producer.
    Respondents further argue that the Department should not add to the 
surrogate value for aniline an amount for the importer's markup. First, 
respondents state that the petitioner has not submitted any evidence as 
to what the importer's markup would be for aniline. Further, since the 
surrogate value should be as close as possible to the price at the 
factory gate and the import value of aniline represents the closest 
approximation of the actual aniline cost to the Indian manufacturer, it 
should not include any upward adjustments after importation which would 
artificially inflate the aniline cost.

Department's Position

    We agree with petitioner that, in order for the surrogate values to 
reflect the true costs to India for the raw materials, the surrogate 
values should include freight to India. However, the introductory notes 
to the Indian Import Statistics, used to determine the surrogate value 
for aniline, state that the values reported are reported on a CIF 
basis. Thus, the reported import values include the costs of 
transporting the merchandise to India, and an adjustment for ocean 
freight from the port of export to India and for Indian port terminal 
and brokerage charges is not necessary. This does not double count 
freight charges, as argued by respondents. We add freight costs to the 
cost of manufacturing to account for costs for transporting the raw 
materials from the suppliers of the raw materials to the factory 
producing the subject merchandise, not freight to the surrogate 
country.
    We also disagree that we should add an importer's markup to the 
surrogate value. There is no evidence on the record of the review 
indicating who imports the aniline, the sulfanilic acid producer or an 
importer who sells the aniline to the sulfanilic acid producer. 
Accordingly, there is no basis for determining that an importer's 
markup would be included in the price to the Indian sulfanilic acid 
producer and for adjusting the surrogate value for such a markup.
    With respect to petitioner's argument that we should include an 
amount for import duties in the surrogate value for aniline, we note 
that respondents have placed on the record evidence showing that the 
import duty is not paid when the sulfanilic acid is exported. 
Therefore, we disagree with petitioner, and have not made an adjustment 
for import duties.

Comment 4

    Petitioner argues that the Department should deduct commissions 
paid by PHT from the U.S. starting price. Respondents reply that, if 
the Department decides to make an adjustment for commissions, it should 
only make the adjustment to those sales for which a commission expense 
was incurred, as verified by the Department.

[[Page 53706]]

Department's Position

    We agree with petitioner that such commissions should be deducted 
in calculating CEP. However, as noted in the May 30, 1996 analysis 
memorandum, commissions have already been deducted. The commission 
amounts deducted were the verified amounts.

Comment 5

    Petitioner argues that, if CNCCC is not treated as the respondent, 
then the Department should deduct from the U.S. starting price the 
profit earned by CNCCC for these sales. Petitioner contends that this 
profit is a commission earned for export services rendered and would be 
paid by Yude, Zhenxing, and PHT.

Department's Position

    We agree with petitioner. The amount paid to CNCCC for processing 
paperwork on each sale was paid by PHT and is directly related to each 
sale. Therefore, this amount should be deducted in the calculation of 
CEP.

Comment 6

    Petitioner argues that the Department should use facts available to 
value sales it claims that the Department was unable to verify. 
Petitioner cites to the PHT verification report to show that the 
Department found at verification a pattern of inconsistencies in PHT's 
monthly sales account balances between April and September 1995. 
Specifically, petitioner notes that PHT was unable to account for the 
difference between the ending sales account balance for June and the 
beginning sales account balance for July. According to petitioner, the 
lack of documentation and internal control calls into question the 
integrity of the reported June and July sales information. As a result, 
petitioner argues that the Department could not verify the June and 
July sales and should use facts available for any sales made by PHT in 
June and July 1995. As facts available, petitioner suggests the highest 
margin calculated for any sale made by PHT which the Department was 
able to verify.
    Respondents reply that the September 1995 ending balance in PHT's 
sales account matches the total sales revenue amount reported on PHT's 
end-of-year financial statement and tax return. Further they note that, 
at verification, PHT informed the Department that the reason for any 
differences between the ending balance in the sales account for one 
month and the beginning balance for the next month is due to manual 
adjustments made at the end of each month to account for errors. They 
further state that there is no indication that the relatively small 
amount of the difference between the June ending balance and the July 
beginning balance has anything to do with sulfanilic acid. Moreover, 
respondents state that the PHT verification report indicates that the 
Department was able to verify that all sales of sulfanilic acid during 
the period of review had been reported.

Department's Position

    We disagree with petitioner. At verification, we were unable to use 
PHT's sales account (i.e., PHT's accounting system used to prepare its 
financial statements) to determine whether all sales of sulfanilic acid 
had been reported. However, we were able to review internal worksheets 
kept by PHT in the ordinary course of business listing all sales of all 
products. These worksheets tied to PHT's financial statements and tax 
returns. From these worksheets, we were able to determine that all 
sales of sulfanilic acid made by PHT during the period of review had 
been reported. See page 5 of the PHT verification report. As we are 
satisfied that all sales were reported, we have not used facts 
available for PHT's June and July sales.

Comment 7

    Respondents argue that the Department should exclude from the U.S. 
sales database certain sales made by PHT to the petitioner because, 
they claim, the Department has ``no jurisdiction'' over these sales. 
Respondents state that, on May 2, 1996, they submitted to the 
Department documents establishing that these sales should be excluded 
from the analysis. However, the Department returned the submission on 
May 20, 1996 stating that, because the documents were submitted after 
verification, it could not accept them.
    Petitioner responds that PHT's sales to the petitioner were 
reported by the respondents, were verified by the Department, and 
should not be excluded from the analysis. Petitioner argues that the 
respondents' arguments are based entirely on their May 2, 1996 
submission, which petitioner believes did not raise any jurisdictional 
issues or provide any reasons for disregarding these sales. Moreover, 
petitioner argues that this submission was submitted to the Department 
after verification and after the deadline for submission of factual 
information set forth in section 353.31 of the Department's 
regulations, and was therefore returned by the Department. It notes 
that the Department stated in its letter returning the submission that 
it would not consider the information in its preliminary or final 
results of review. According to petitioner, respondents never disputed 
the fact that the submission was untimely, and, without this 
submission, there is no support for respondents' ``jurisdictional'' 
argument.

Department's Position

    We disagree with respondents. On May 2, 1996, Yude and Zhenxing 
submitted new information which we returned as untimely filed. As 
stated in our May 20, 1996 letter, we had not requested such 
information, and the information was submitted after the deadline for 
submission of factual information provided in section 353.31(a)(11) of 
our regulations. We also stated that this information was submitted 
after the verification which took place at PHT. At verification, we 
verified PHT's sales to petitioner, and found nothing which would 
indicate that these sales were not properly included in the analysis.
    Respondents' claim that the information contained in its May 2, 
1996 submission raised a ``jurisdictional'' issue is unfounded. Because 
Yude and Zhenxing made undisputed sales to the United States during the 
period of review, they are parties subject to this review, and we may 
examine or, for proper cause supported by information on the record, 
decline to examine all of their sales of subject merchandise during the 
period of review, whether to the United States, in the home market, or 
to third countries. We do not need to demonstrate ``jurisdiction'' on a 
sale-by-sale basis. Yude's and Zhenxing's objection to our analysis of 
the sales at issue, therefore, raises no ``jurisdictional'' issue. It 
is simply a challenge to our selection of sales for the U.S. database, 
which we need not address on its merits because it was raised after the 
deadline for submitting new factual information and because the alleged 
facts upon which it is based can no longer be verified. Accordingly, we 
have included these sales in our analysis.

Comment 8

    Respondents argue that the Department should extend the deadline 
for allowing Sinochem Hebei to submit its questionnaire response and 
should accept Sinochem Hebei's questionnaire response. Respondents cite 
as support Bowe-Passat v. United States, 17 CIT 335, 1993 WL 179269 
(1993), in which the Court of International Trade (CIT) stated that the 
Department routinely accepts data after the deadlines and found that 
the Department acted

[[Page 53707]]

arbitrarily and capriciously in rejecting plaintiff's submission of 
facts.
    Respondents contend that the facts of this case are unique. 
Respondents state that the previous administrative review, covering the 
period August 1, 1993 through July 31, 1994 (93/94 review), was 
initiated in September 1994, and that verification of that review was 
conducted during May and July 1995. Respondents note that they were 
informed that the preliminary results of the 93/94 review were 
scheduled to be issued in August 1995, but that the results were not 
issued until May 1996, despite letters and phone calls by counsel for 
respondents and the Embassy of the PRC. In the preliminary results of 
the 93/94 review, published on May 20, 1996, Sinochem Hebei received a 
margin of 2.01 percent.
    Respondents continue that the Department conducted verification of 
the current review in April 1996, before the verification reports from 
the 93/94 review were issued. In the current review, Sinochem Hebei 
received an 85.20 percent margin for failing to respond to the 
questionnaire. Respondents submit that Sinochem Hebei would have 
responded to the Department's questionnaire in the current review 
within the time frame specified in the questionnaire had it known its 
preliminary margin from the 93/94 review at the time its response in 
the current review was due.
    Respondents note that, while the margin is assigned to the 
exporter, Sinochem Hebei, the U.S. importer is the party which must 
bear the consequences as a result of the retroactive nature of the 
antidumping review process. They contend that New Chemic, an importer 
of subject merchandise from Sinochem Hebei during this period of 
review, would be ``wiped out'' as a result of this retroactive duty. 
Respondents state that the purpose of the antidumping law is to 
determine margins as accurately as possible, in accordance with the 
goals of fairness, accuracy, and predictability, citing to Fans, 56 FR 
at 55275 (Comment 1). They argue that the failure of the Department to 
issue the preliminary results of the 93/94 review in a timely manner 
unnecessarily penalizes the U.S. importer, does not serve the purpose 
of the antidumping duty law, and is contrary to the intent of the U.S. 
Congress in protecting the U.S. industry. They further claim that 
denying New Chemic the right to have Sinochem Hebei's response 
considered by the Department would unfairly and unjustly destroy a 
small business because of the Department's delay in issuing the 
preliminary results of the 93/94 review.
    Petitioner responds that the Department cannot accept Sinochem 
Hebei's questionnaire response after verification and after publication 
of the preliminary results of review. Petitioner states that Sinochem 
Hebei, as a named respondent, was sent a questionnaire by the 
Department on October 6, 1995 and was represented by counsel. Sinochem 
Hebei disregarded the deadlines for responding to the questionnaire, 
and its counsel withdrew its appearance on behalf of Sinochem Hebei. 
Petitioner notes that the Department assigned to Sinochem Hebei the 
PRC-wide rate of 85.20 percent in the preliminary results because it 
did not respond to the questionnaire. Petitioner further notes that 
Sinochem Hebei's questionnaire response was submitted to the Department 
several weeks after the preliminary results of the review had been 
published, and contends that the Department cannot allow respondents to 
dictate how and when they should respond to questionnaires.
    According to petitioner, respondents' argument that Sinochem Hebei 
would have responded to the questionnaire had it known the adverse 
consequences for not doing so is unavailing. Petitioner notes that 
Sinochem Hebei had counsel which knew that failure to submit timely 
requests for information can lead to adverse consequences in the form 
of facts available, and that the questionnaire sent to Sinochem Hebei 
stated this.

Department's Position

    We disagree with respondents. In this administrative review, 
Sinochem Hebei was originally represented by U.S. counsel and actively 
requested an administrative review of its own sales. We note that 
petitioner also requested a review of Sinochem Hebei's sales. 
Accordingly, on October 6, 1995, we sent a questionnaire to Sinochem 
Hebei. Sinochem Hebei was required to respond to the questionnaire by 
the applicable due dates, which were October 27, 1995 for Section A of 
the questionnaire and November 20, 1995 for Sections C and D of the 
questionnaire. Sinochem Hebei did not submit a questionnaire response 
or request an extension of time for filing its questionnaire response 
by these deadlines pursuant to section 353.31(b)(3) of our regulations, 
and Sinochem Hebei's counsel withdrew its representation of Sinochem 
Hebei on November 29, 1995, after the due dates for Sinochem Hebei's 
questionnaire responses. Section 776(a)(2)(B) of the Act provides that 
if an interested party fails to provide necessary information by the 
deadline for submission, the Department shall use the facts available 
in reaching the applicable determination. The fact that the results of 
the 93/94 review of this case were not yet issued did not relieve 
Sinochem Hebei of its legal responsibility to respond to the 
Department's questionnaire for the current review period as requested 
by the Department. Each antidumping review is a separate proceeding 
covering merchandise entering the United States during a specific time 
period, and the facts of each review are considered separately based on 
information submitted for that proceeding. Therefore, in the 
preliminary results of this review, we correctly assigned a margin to 
Sinochem Hebei based on facts available.
    We note that New Chemic requested on June 19, 1996, more than seven 
months after Sinochem Hebei's questionnaire response was due, that we 
extend the deadline for accepting Sinochem Hebei's questionnaire 
response. We also note that Sinochem Hebei submitted a questionnaire 
response on June 28, 1996, after the preliminary results of this review 
were published, and that we returned this response on July 23, 1996. We 
cannot extend Sinochem Hebei's time to respond to the questionnaire. 
Our regulations require that Sinochem Hebei submit any request for 
extension in writing before the time limit for submitting the 
information expires (see section 353.31(b)(3)). Therefore, the request 
for extension was untimely, and, further, it was not submitted by 
Sinochem Hebei. Moreover, section 353.31(a)(ii) of our regulations 
states that submissions of factual information are to be submitted not 
later than the earlier of the date of publication of the notice of 
preliminary results or 180 days after the publication of the notice of 
initiation of the review. The preliminary results of this 
administrative review were published in the Federal Register on June 7, 
1996, and the notice of initiation was published on September 15, 1995. 
Therefore, the questionnaire response was untimely and was correctly 
rejected.
    We also note that Sinochem Hebei was involved in the LTFV 
investigation of this case and in the 93/94 review, and, in both of 
those proceedings, responded to the Department's requests for 
information. Further, in both of those proceedings, we verified the 
reported information at Sinochem Hebei's facilities in the PRC. 
Therefore, Sinochem Hebei was not unfamiliar with the way in which 
antidumping proceedings are conducted, and could

[[Page 53708]]

have consulted either its own counsel or the Department regarding the 
consequences of not responding to the questionnaire. The questionnaire 
sent to Sinochem Hebei provided the name and telephone number of the 
appropriate Department official to contact if it had any questions or 
if it was unable to respond to the questionnaire within the specified 
time limits. Furthermore, any claims as to what Sinochem Hebei ``would 
have done'' had the 93/94 preliminary results been issued prior to the 
time its response was due are purely speculative. New Chemic, which was 
required to post antidumping duty deposits on imports of the subject 
merchandise from the PRC, knew or should have known that these deposits 
were not necessarily equivalent to the antidumping rates which will 
ultimately be assessed on such entries and should have sought the 
cooperation of its supplier at an appropriate stage in the review 
process.
    As a result, for the final results, we have continued to base 
Sinochem Hebei's margin on facts available. As facts available, we have 
used the highest rate from any segment of the proceeding, 85.20 
percent, the rate from the LTFV investigation of this case.

Comment 9

    Respondents contend that, in past cases, the Department has not 
deducted indirect selling expenses and profit in the calculation of the 
CEP because of the difficulty in isolating expenses used in surrogate 
country values. Therefore, such expenses could be double counted. As 
support, respondents cite to Fans, in which the Department determined 
that there was insufficient information to adjust the surrogate country 
expenses; therefore, the Department stated that, for purchase price 
sales, it would be unfair to make an upward adjustment to foreign 
market value (FMV) for selling expenses incurred on the U.S. sales 
without making a downward adjustment to FMV for selling, general, and 
administrative (SG&A) expenses, and that, for exporter's sales price 
sales, an adjustment for selling expenses should not be made since 
these expenses could not be isolated. Respondents also note that the 
Department made similar determinations in numerous other cases, such as 
the Notice of Final Determination of Sales at Less Than Fair Value: 
Pure Magnesium from Ukraine (60 FR 16432, March 30, 1995) and 
Saccharin.
    Respondents contend that the implementation of the URAA does not 
require a change in this policy. They argue that a comparison of the 
statute in effect prior to January 1, 1995 and the statute in effect 
since that date shows that there has been no significant change in the 
law requiring the Department to reconsider its past position. Moreover, 
respondents state that Congress' failure to amend the law in this 
respect is tantamount to approval, citing United States v. Federal Ins. 
Co., 805 F.2d 1012, 1017 (Fed. Cir. 1986), cert. denied, 481 U.S. 1048 
(1987).
    In addition, respondents argue that the Department provided an 
inadequate explanation of its reasons for changing its position in 
Bicycles. They state that an analysis of the public record in Bicycles 
appears to indicate that the reason for the change is based on a change 
in the statutory language. Therefore, respondents claim that, at a 
minimum, the Department should provide an extensive analysis to justify 
such a change in its longstanding policy.
    Petitioner responds that the plain meaning of the law under which 
this review is being conducted requires that the Department deduct from 
CEP indirect selling expenses and profit, and note that the Department 
made the same deductions in Bicycles. It cites to section 772(d)(3) of 
the Act to show that the Department must deduct from CEP all selling 
expenses, including both direct and indirect selling expenses, and 
profit. Petitioner contests respondents' argument that the Department's 
deduction of indirect selling expenses and profit was incorrect because 
it is inconsistent with practice prior to the 1994 amendments to the 
law. It contends that the amended law requires the deduction of 
indirect selling expenses and profit from CEP, without exception for 
non-market-economy (NME) country cases, and that the Department changed 
its practice in order to comply with the provisions of the amended law, 
as was done in Bicycles. According to petitioner, the fact that 
Congress allegedly failed to expressly reject the Department's prior 
practice in this area does not constrain the Department from adopting a 
new practice under the changed language of the amended law. Further, 
the amended law did make relevant changes in this respect because it 
now requires a deduction for indirect selling expenses and for profit, 
as is discussed in the Statement of Administrative Action (SAA) 
accompanying the URAA (see SAA at 153).
    Petitioner further argues that the respondents have not made an 
argument that deductions to CEP for direct selling expenses are 
improper. According to petitioner, section 772(d)(1) of the Act, which 
states that ``any selling expenses'' be deducted, includes both direct 
and indirect selling expenses, and it is impossible to interpret the 
section as permitting the deduction of some selling expenses but not 
others.

Department's Position

    We disagree with respondents. As discussed in Bicycles, section 
772(c)(2)(d)(1) of the Act states that CEP shall be reduced by the 
amount of expenses incurred by or for the account of the producer or 
exporter, or the affiliated seller in the United States, in selling the 
subject merchandise, and section 772(c)(2)(d)(3) of the Act states that 
CEP shall be reduced by the amount of profit allocated to such 
expenses. The statute provides no exceptions for NME cases. 
Consequently, we have continued to deduct from CEP all selling 
expenses, including indirect selling expenses, and CEP profit, as we 
did in Bicycles. We note that we have been following this practice in 
recent cases (see, e.g., Notice of Preliminary Determination of Sales 
at Less Than Fair Value and Postponement of Final Determination: 
Melamine Institutional Dinnerware Products from the People's Republic 
of China (61 FR 43337, August 22, 1996)).

Comment 10

    Respondents contend that, if the Department persists in making 
circumstance-of-sale adjustments to U.S. price for direct selling 
expenses, then it should make a similar adjustment to normal value 
(NV), which is authorized by section 773(a)(6)(C)(iii) of the Act. 
Failure to do so, according to respondents, results in inherently 
unfair results. Respondents argue that the data from the Reserve Bank 
of India Bulletin used for the preliminary results of this review to 
determine surrogate values for factory overhead, SG&A expenses, and 
profit can be used to calculate the adjustments necessary to NV for 
direct selling expenses, such as commissions, advertising, and credit.
    Petitioner responds that there is nothing in the SAA or in Bicycles 
which states that circumstance-of-sale adjustments to NV are required 
by deductions made to CEP. Petitioner further argues that the 
respondents incorrectly cite to section 773(a)(6)(C)(iii) of the Act 
for authority for the circumstance-of-sale adjustment. According to 
petitioner, that section of the Act is superseded by the statutory 
provisions relevant to this review, i.e., the NME country provisions 
provided for by section 773(c) of the Act. Petitioner states that 
application of section 773(c) of the Act is premised on a finding that 
a determination under section 773(a) of the Act regarding NV

[[Page 53709]]

is not appropriate, and that a circumstance-of-sale adjustment pursuant 
to section 773(a) of the Act therefore must be rejected.
    Petitioner states that if the Department makes a circumstance-of-
sale adjustment as requested by respondents, it cannot accept 
respondents' calculation of the adjustment for credit and should not 
make a reduction to NV for this expense. Petitioner contends that the 
expense cited to by respondents as a credit expense is really an 
interest expense, which is a general and administrative expense, not a 
selling expense.

Department's Position

    We do not believe that circumstance-of-sale adjustments to NV are 
either necessarily required by the statute or by the existence of 
deductions made to CEP. As discussed in Bicycles, section 773(a)(6)(C) 
of the Act allows NV to be increased or decreased for differences in 
circumstances of sale as long as it has been established to the 
satisfaction of the administering authority that such adjustments are 
warranted.
    In this case, we do not have enough information about the selling 
expenses included in the surrogate SG&A expenses to make such an 
adjustment to NV or to determine whether such an adjustment is 
warranted. Therefore, for the final results, we have not made such an 
adjustment to NV.

Comment 11

    Respondents argue that, in contrast to the situation with respect 
to aniline, there is no evidence on the record of this review which 
indicates that Indian sulfanilic acid producers use imported activated 
carbon to produce sulfanilic acid for export. They believe that it 
makes sense that Indian sulfanilic acid producers would use 
domestically-produced activated carbon, which is substantially cheaper 
than imported activated carbon. Respondents thus argue that the 
Department should use as the surrogate value the export price of 
activated carbon reported in Chemical Weekly, which they submitted to 
the Department before the preliminary results of review were issued, 
because it reflects the actual price in the Indian market used to 
produce sulfanilic acid for export. As support for their argument, they 
cite to section 773(c)(1) of the Act, which requires the Department to 
use the best available information for valuing the factors of 
production in the surrogate country (emphasis added).
    Respondents also note that in Polyvinyl Alcohol, the Department 
rejected the very same import price for activated carbon in favor of 
the export price reported in Chemical Weekly.
    Further, respondents contend that the Department did not take into 
consideration the quality of the activated carbon used by respondents 
or the quality of the activated carbon imported into India. Respondents 
state that the Kirk-Othmer Encyclopedia of Chemical Technology 
designates activated carbon as either gas-phase or liquid-phase 
absorbents. Respondents argue that, even though the data are old, 
activated carbon prices from 1976 quoted in that publication indicate 
that gas-phase activated carbon is more expensive than liquid-phase 
activated carbon. According to respondents, the factories use liquid-
phase activated carbon, as is shown by the production process described 
in their questionnaire response, whereas the price level of the 
imported activated carbon indicates that the imports were of the gas-
phase activated carbon or specialty grades unsuitable for sulfanilic 
acid production. Therefore, respondents argue that the Department 
should determine the types of activated carbon represented by the 
import figures and decide whether it is appropriate to value 
respondents' activated carbon with those import prices.
    Lastly, they claim that the quantities of imported activated carbon 
are inadequate for valuing the factories' factors of production because 
they are much smaller than the quantities used by the factories and 
purchases by the respondents would be in large quantities which would 
merit discounts not reflected by these import prices. Respondents 
further claim that the small quantities are a further indication that 
the imports are of the more expensive gas-phase activated carbon or are 
of specialty grades which are not suitable for the production of 
sulfanilic acid.
    Petitioner responds that the Department properly based the 
surrogate value on the prices reported in Chemical Weekly during March 
and May 1995, the only publicly available data on the record covering 
this period of review. It notes that the price which the respondents 
urge the Department to use is from a September 1993 issue of Chemical 
Weekly, nearly one year before the beginning of the period of review. 
According to petitioner, respondents' argument regarding the valuation 
of activated carbon is fundamentally at odds with its argument 
regarding aniline. It notes that the respondents are arguing that the 
Department use import prices for aniline, but that import prices for 
activated carbon are aberrational. Petitioner states that, if the 
import prices for activated carbon are aberrational, then the 
Department should also find that import prices are also aberrational 
for aniline.
    Petitioner argues that the respondents' submission in its case 
brief of information from the Encyclopedia of Chemical Technology is 
new factual information which must be rejected and returned to the 
respondents, and therefore, their arguments based on information in 
this publication should not be considered.
    According to petitioner, respondents reliance on Polyvinyl Alcohol 
is misplaced. Petitioner notes that, in that case, the Department 
compared import and export prices to other price data to determine 
which were more reliable. In this proceeding, however, the only 
publicly available published information from the period of review is 
that from the March and May 1995 issues of Chemical Weekly, and there 
is no other data from the period of review with which to compare these 
prices.
    Moreover, petitioner contends that the volumes of sales used to 
determine the surrogate value for the preliminary results are 
sufficient for use in determining the surrogate value, and note that 
the value supported by the respondents is based on a smaller volume. 
Petitioner contends that this weakens respondents' argument that the 
export data be used as the surrogate value. Petitioner contends, 
however, that the contemporaneity of the data is more important that 
the relative volume of the sales in question.
    Petitioner lastly contends that the Department should increase the 
surrogate value for activated carbon by the amount of the 85 percent 
import duty, in order to approximate the true cost of the activated 
carbon to the Indian sulfanilic acid manufacturer. It states that 
because the activated carbon is not physically incorporated into the 
sulfanilic acid, imports of activated carbon would not be eligible for 
any import duty exemption upon export of the sulfanilic acid.

Department's Position

    We disagree with respondents. There is no evidence on the record of 
this review which indicates whether Indian sulfanilic acid producers 
use domestic or imported activated carbon to produce sulfanilic acid. 
Further, there is no evidence on the record of this review which 
indicates whether the prices supported by either the respondents or the 
petitioner are for gas-phase or liquid-phase activated carbon. We note 
that respondents never stated in their questionnaire responses that 
they used

[[Page 53710]]

a certain type of activated carbon in their production, or indicated in 
their surrogate value comments that there was more than one type of 
activated carbon.
    In determining the surrogate value used for activated carbon in the 
preliminary results of review, we considered the information placed on 
the record by the petitioner and by the respondents. We selected the 
data submitted by the petitioner because they are more contemporaneous, 
covering imports during the period of review, than those provided by 
respondents, which are from a September 1993 issue of Chemical Weekly 
and are for an export during June 1993. Moreover, with respect to 
respondents' argument that the import prices should not be used because 
of the small quantity of imports, we note that the price which 
respondents urge us to use is from an export involving an even smaller 
quantity. Therefore, for the final results of review, we have continued 
to use the import prices reported in Chemical Weekly during the period 
of review.
    We disagree with petitioner that we should adjust this value for 
import duties. We calculate surrogate values used to value raw 
materials on a tax-exclusive basis, as we have discussed in previous 
cases, such as the Notice of Final Determination of Sales at Less Than 
Fair Value: Manganese Metal from the People's Republic of China (60 FR 
56045, November 6, 1995) (Manganese Metal). See also our response to 
Comment 12 below. Therefore, it is not appropriate to include in the 
surrogate values amounts for import duties.
    We disagree with petitioner that the information submitted by the 
respondents from the Encyclopedia of Chemical Technology constitutes 
new information which should be rejected. As the title of the source 
indicates, the information cited by the respondents in support of their 
argument that the price used in the preliminary results of review to 
value activated carbon was incorrect was of a general, definitional 
nature.

Comment 12

    Respondents argue that the Department should calculate a surrogate 
value for sulfuric acid which is exclusive of taxes. Respondents state 
that the issues of Chemical Weekly used by the Department in the 
preliminary results to value sulfuric acid clearly state that the 
sulfuric acid prices contained therein are inclusive of excise and 
Maharashtra sales taxes. Respondents argue that the Department has a 
long and consistent history in NME country cases of valuing the factors 
of production with tax-exclusive prices, citing to Bicycles, Manganese 
Metal, and Sebacic Acid. Respondents further cite to Polyvinyl Alcohol, 
in which the Department valued sulfuric acid at exactly the same price 
from the same source, but adjusted the values to exclude taxes. 
Respondents note that they submitted documentation on the relevant tax 
rates to the record of this review.
    Petitioner responds that the Department should not revise the 
surrogate value for sulfuric acid. According to petitioner, there is no 
evidence on the record concerning the applicable Indian tax rate for 
sulfuric acid, and, without such information, the Department cannot 
determine a tax-exclusive price. Petitioner contends that, in Polyvinyl 
Alcohol, the respondent was able to specifically identify the 
applicable tax rates. Moreover, petitioner argues that the Department 
only excludes taxes on raw materials where such taxes are refunded upon 
exportation, and that there is no evidence on the record which 
indicates whether taxes paid on sulfuric acid are refunded upon 
exportation. Petitioner notes that, in Aimcor v. United States, 19 CIT 
__, Slip Op. 95-130 (July 20, 1995), (Aimcor), at 22, the CIT stated 
that ``material costs, such as value-added taxes must be included in 
constructed value if they are incurred prior to exportation, with the 
exception of tax remitted or refunded upon exportation.''

Department's Position

    We agree with respondents that the surrogate values used to value 
the raw materials should be exclusive of taxes, as we have discussed in 
previous cases, such as Manganese Metal. The issues of Chemical Weekly, 
contained in Attachment 3 of the May 30, 1996 factor value memorandum, 
used to determine the surrogate value for sulfuric acid in the 
preliminary results of this review, state that the prices reported for 
sulfuric acid are inclusive of Excise and Maharashtra taxes. 
Accordingly, we have adjusted the surrogate value or sulfuric acid to 
exclude taxes for the final results of review. To adjust the prices to 
exclude taxes, we have used the Central Excise Tariff of India, 1994-
95, submitted to the record of this review by respondents in their 
April 11, 1996 submission and used to determine the tax-exclusive 
surrogate value for sulfuric acid in Manganese Metal and Polyvinyl 
Alcohol.
    We disagree with petitioner that Aimcor is relevant in NME country 
cases. Aimcor deals with the construction of NV in market economy cases 
pursuant to section 773(e) of the Act, and with material costs incurred 
as a result of the taxes levied by the country whose sales of the 
subject merchandise to the United States constitute the U.S. price to 
which that NV is compared. In this case, by way of contrast, the NV 
being calculated (by applying Indian surrogate values to the PRC 
factors) is a surrogate for material costs in the PRC for comparison to 
the U.S. sales of the Chinese merchandise. Therefore, Indian value-
added taxes, which do not affect PRC sales to the United States, should 
be removed from such surrogate costs.

Comment 13

    Respondents note that, in determining surrogate values for 
overhead, SG&A expenses, and profit, the Department used data contained 
in the April 1995 Reserve Bank of India Bulletin. In making its 
calculation, respondents argue that the Department arbitrarily and 
without explanation allocated 50 percent of the expenses in three 
categories, ``provident fund,'' ``salaries, wages and bonuses,'' and 
``employees' welfare expenses,'' to SG&A expenses and 50 percent to the 
cost of manufacture. As a result, the cost of manufacturing is 
understated and the overhead rate, SG&A rate, and profit rate are 
overstated. They contend that 100 percent of these three categories 
should be applied to the cost of manufacture, as was done in Polyvinyl 
Alcohol.

Department's Position

    We agree with respondents that 100 percent of these labor 
categories should be included in the cost of manufacturing. In the 
absence of any information to the contrary, it makes sense that most of 
these expenses would be applicable to the cost of manufacturing rather 
than to SG&A expenses. In addition, we note that in Polyvinyl Alcohol, 
although we did not use information from the Reserve Bank of India 
Bulletin as surrogate values for overhead, SG&A expenses, and profit, 
we compared values from this source to values from financial statements 
from Indian producers; in each instance, we allocated 100 percent of 
these labor categories to the cost of manufacturing. We have also 
reexamined our classification of other categories in the Reserve Bank 
of India Bulletin, and have determined that several cateogries were 
misclassified in the preliminary results of review. This has been 
corrected for the final results.

Clerical Errors

    Respondents contend that the Department made three clerical errors 
in

[[Page 53711]]

its preliminary results. First, they state that, in valuing activated 
carbon, the Department left out an importation in May 1995. Second, 
they argue that, in calculating the cost of packing materials, the 
Department used the wrong weights for the bags used to pack the 
sulfanilic acid. Third, they state that the Department inaccurately 
determined the freight cost for transporting the raw materials between 
the supplier factories and the sulfanilic acid factories. We have 
reviewed the calculations, and agree that these errors were made. They 
have been corrected for the final results.

Non-Shippers

    Baoding and Hainan Garden stated that they did not have shipments 
during the period of review, and we confirmed this with the United 
States Customs Service. Therefore, we are treating them as non-shippers 
for this review, and are rescinding this review with respect to these 
companies. See 19 CFR Parts 351, 353, and 355 Antidumping Duties; 
Countervailing Duties; Proposed Rule, section 351.213(d)(3) (61 FR 
7365, February 27, 1996). The cash deposit rates for these firms will 
continue to be the rates established in the most recently completed 
final determination.

Final Results of Review

    As a result of our review of the comments received, we have 
determined that the following margins exist:

------------------------------------------------------------------------
                                                                 Margin 
        Manufacturer/exporter               Time period        (percent)
------------------------------------------------------------------------
Yude Chemical Industry Company......  8/1/94-7/31/95             *16.86 
Zhenxing Chemical Industry Company..  8/1/94-7/31/95             *16.86 
PRC Rate \1\........................  8/1/94-7/31/95             85.20  
------------------------------------------------------------------------
* Yude and Zhenxing have been collapsed for the purposes of this        
  administrative review. However, we have listed them separately on this
  chart for Customs purposes.                                           
\1\ This rate will be applied to all firms which have not demonstrated  
  that they are separate from the PRC government, including, but not    
  limited to, the following firms for which a review was requested:     
  China National Chemical Construction Corporation, Beijing Branch;     
  China National Chemical Construction Corporation, Qingdao Branch;     
  Jinxing Chemical Factory; Mancheng Xinyu Chemical Factory, Beijing;   
  Mancheng Xinyu Chemical Factory, Shijiazhuang; Shunping Lile; Sinochem
  Hebei Import and Export Corporation; Sinochem Qingdao; and Sinochem   
  Shandong.                                                             

    The Department will instruct the Customs Service to assess 
antidumping duties on all appropriate entries. The Department will 
issue appraisement instructions directly to the Customs Service.
    Furthermore, the following deposit requirements will be effective 
upon publication of these final results for all shipments of sulfanilic 
acid from the PRC 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 rates for reviewed 
companies named above which have separate rates will be the rates for 
those firms listed above; (2) for the companies named above which were 
not found to have a separate rate, as well as for all other PRC 
exporters, the cash deposit rate will be the highest margin ever in the 
LTFV investigation or in this or prior administrative reviews, the PRC-
wide rate; and (3) the cash deposit rate for non-PRC exporters of 
subject merchandise from the PRC will be the rate applicable to the PRC 
supplier of that exporter. These deposit requirements shall remain in 
effect until publication of the final results of the next 
administrative review.
    This notice also serves as a final reminder to importers of their 
responsibility under 19 CFR 353.26 to file a certificate regarding the 
reimbursement of antidumping duties prior to liquidation of the 
relevant entries during this review period. Failure to comply with this 
requirement could result in the Secretary's presumption that 
reimbursement of antidumping duties occurred and the subsequent 
assessment of double antidumping duties.
    This notice also serves as a reminder to parties subject to 
administrative protective order (APO) of their responsibility 
concerning the disposition of proprietary information disclosed under 
APO in accordance with 19 CR 353.34(d)(1). Timely written notification 
of the return/destruction of APO materials or conversion to judicial 
protective order is hereby requested. Failure to comply with the 
regulations and terms of an APO is a sanctionable violation.
    This administrative review and 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: October 7, 1996.
Robert S. LaRussa,
Acting Assistant Secretary for Import Administration.
[FR Doc. 96-26358 Filed 10-11-96; 8:45 am]
BILLING CODE 3510-DS-P