[Federal Register Volume 64, Number 52 (Thursday, March 18, 1999)]
[Notices]
[Pages 13401-13405]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 99-6535]


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DEPARTMENT OF COMMERCE

International Trade Administration
[A-570-822]


Certain Helical Spring Lock Washers from the People's Republic of 
China; Final Results of Antidumping Duty Administrative Review

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

ACTION: Notice of Final Results of Antidumping Duty Administrative 
Review.

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SUMMARY: The Department of Commerce published the preliminary results 
of the administrative review of the antidumping duty order on certain 
helical spring lock washers from the People's Republic of China in the 
Federal Register on November 9, 1998 (63 FR 60299). This review covers 
sales of this merchandise to the United States during the period 
October 1, 1996 through September 30, 1997. We gave interested parties 
an opportunity to comment on our preliminary results. Based upon our 
analysis of the comments received, we have made changes to the margin 
calculations presented in the preliminary results of the review. The 
final weighted-average dumping margins are listed below in the section 
entitled Final Results of Review.

[[Page 13402]]

    We have determined that sales have been made below normal value 
during the period of review. Accordingly, we will instruct the Customs 
Service to assess antidumping duties based on the difference between 
export price and normal value.

EFFECTIVE DATE: March 18, 1999.

FOR FURTHER INFORMATION CONTACT: Sally Hastings or Vince Kane, Import 
Administration, International Trade Administration, U.S. Department of 
Commerce, 14th Street and Constitution Avenue, N.W., Washington, D.C. 
20230; telephone: (202) 482-3464 or (202) 482-2815, respectively.

Applicable Statute and Regulations

    Unless otherwise stated, 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, as amended (the 
Act) by the Uruguay Round of Agreements Act (URAA). In addition, unless 
otherwise stated, all citations to the Department of Commerce's ( the 
Department's) regulations are to 19 CFR Part 351 (1998).

Background

    The Department published the preliminary results of this review of 
the antidumping duty order on Helical Spring Lock Washers (HSLWs) from 
the People's Republic of China (PRC) in the Federal Register on 
November 9, 1998 (63 FR 60299). On December 9, 1998, the petitioner, 
Shakeproof Assembly Components Division of Illinois Tool Works, 
submitted comments on the Department's preliminary results and on 
December 18, 1998, the respondent, Zhejiang Wanxin Group, Co., Ltd. 
(ZWG), submitted a rebuttal to the petitioner's comments. We held a 
hearing on January 13, 1999. The Department has now completed this 
review in accordance with section 751 of the Act.

Scope of Review

    The products covered by this review are HSLWs of carbon steel, of 
carbon alloy steel, or of stainless steel, heat-treated or non-heat-
treated, plated or non-plated, with ends that are off-line. HSLWs are 
designed to: (1) Function as a spring to compensate for developed 
looseness between the component parts of a fastened assembly; (2) 
distribute the load over the larger area for screws or bolts; and, (3) 
provide a hardened bearing surface. The scope does not include internal 
or external tooth washers, nor does it include spring lock washers made 
of other metals, such as copper.
    HSLWs subject to this review are currently classifiable under 
subheading 7318.21.0030 of the Harmonized Tariff Schedule of the United 
States (HTSUS). Although the HTSUS subheading is provided for 
convenience and customs purposes, the written description of the scope 
of this proceeding is dispositive.
    This review covers one exporter of HSLWs from the PRC, ZWG, and the 
period October 1, 1996 through September 30, 1997.

Comparisons

    We calculated export price and normal value (NV) based on the same 
methodology used in the Preliminary Results, with the following 
exceptions:
    (1) Based on the petitioner's comments, we have recalculated 
factory overhead (FOH), selling, general and administrative (SG&A) 
expenses and profit in plating costs as in the second and third 
administrative reviews of this case, and revised the inland freight 
expense for imported steel (see Comments 2 and 3, respectively.);
    (2) We have updated the surrogate value for brokerage and handling 
based on a submission in Stainless Steel Wire Rod From India for the 
POR 97-98 dated May 12, 1998;
    (3) At verification, we learned of a recalculation of a supplier 
distance which resulted in a change in freight expenses (see Factors 
Memorandum dated March 9, 1999 and verification exhibit 14).

Analysis of Comments Received

Comment 1: Use of Market Economy Import Prices to Value Non-Imported 
Steel Wire Rod

    The petitioner argues that the Department's use of imported steel 
prices to value ZWG's domestically sourced steel wire rod (SWR) is 
contrary to the statute. In addition, the petitioner contends that the 
decision in Lasko Metal Products, Inc. v. United States, 810 F.Supp. 
314, 316 (1992), aff'd 43 F.3d 1442 (Fed. Cir. 1994) (Lasko) does not 
apply to materials obtained in a nonmarket economy (NME) country from a 
NME supplier. Therefore, the petitioner reasons that the Department 
should have used Indian surrogate values to value ZWG's domestically 
sourced steel.
    Though the petitioner recognizes and cites section 351.408(c)(1) of 
the Department's regulations, which states that:

The Secretary normally will use publicly available information to 
value factors. However, where a factor is purchased from a market 
economy supplier and paid for in a market economy currency, the 
Secretary normally will use the price paid to a market economy 
supplier. In those instances where a portion of the factor is 
purchased from a market economy supplier and the remainder from a 
nonmarket economy supplier, the Secretary normally will value the 
factor using the price paid to the market economy supplier.

as governing the information used to value factors of production (FOP) 
in NME cases, the petitioner states that neither the antidumping 
statute nor court precedent(s) sanctions the Department's use of import 
prices to value inputs obtained from a NME supplier in NME currency.
    The petitioner argues that Congress has addressed the issue of 
factor valuation in the instant case. In addition, the petitioner 
quotes the Act which states that ``when insufficient information exists 
to determine dumping margins by normal methods, * * * (1) normal value 
shall be determined on the basis of the value of the FOP utilized and 
(2) the valuation of the FOP shall be based on the best available 
information regarding the values of such factors in a market economy 
country or countries to be considered appropriate.'' (19 U.S.C. 
1677b(c)(1)). See Lasko at 1445.
    The petitioner notes that only if the Department determines that 
``available information is inadequate for the purpose of determining NV 
on the basis of FOP,'' does the statute allow the Department to rely on 
market economy prices. Moreover, citing the legislative history of the 
NME section of the statute, the petitioner asserts that Congress 
rejected the use of market prices in favor of FOPs and intended that 
the Department should avoid using prices ``which it has reason to 
believe or suspect may be dumped or subsidized'' when determining FOPs. 
See Conference Report, Omnibus Trade & Competitiveness Act of 1998, 
H.R. 3 at 590 (HR Rep. 100-576).
    The petitioner acknowledges that Lasko allows the Department to use 
market economy prices to value an input when the NME manufacturer 
directly obtains the input from a market economy country, pays for it 
in market economy currency, and uses the input in the production of 
subject merchandise. However, the petitioner states that Lasko does not 
apply to materials obtained in a NME from NME suppliers and cannot be 
used to give the Department unbridled discretion to use the import 
prices of a factor as a ``short-cut'' to determine the value of all 
non-imported materials. The petitioner alleges that this short-cut 
methodology conflicts with the statute and Congressional intent. 
Congress has

[[Page 13403]]

expressed a preference for surrogate country values methodology and 
that preference will be eviscerated by the imputation of import prices 
even if it advances the goal of accuracy.
    The petitioner also argues that, even assuming that the Act and the 
Department's regulations grant the Department discretion to use the 
prices of imports to value non-imported inputs, the Department has 
abused its discretion in this case. The petitioner asserts that 
accuracy is not gained by the use of import prices and prices of small 
quantities of imported goods may be aberrational. The petitioner argues 
that the Department is required to examine the criteria adopted in 
Olympia Industrial Inc. v. United States (Olympia), Slip Op. 98-49 
(April 17, 1998), wherein the Department examined ``(1) the volume and 
value of steel imports, (2) the type and quality of the imported steel, 
and (3) consumption of imported steel by the NME producers' to 
determine the reliability of steel import prices as alternative 
surrogate values. The petitioner asserts that the Department's failure 
to apply the Olympia criteria constitutes an abuse of discretion.
    The respondent, on the other hand, argues that the Department 
correctly used ZWG's imported SWR prices to value all of its SWR 
production inputs in the preliminary results. Moreover, the respondent 
states that this valuation methodology is supported by the Department's 
prior practice, the Department's regulations, court decisions and the 
Act. The respondent also states that ZWG's purchase of imported SWR 
satisfies all the conditions of section 351.408(c)(1) of the 
Department's regulations. Thus, the respondent asserts that the 
Department is obligated by that provision of the regulations to use the 
price paid for imported SWR to value all the SWR consumed by ZWG. The 
respondent adds that this regulation codifies the decision of the 
United States Court of Appeals for the Federal Circuit (CAFC) in Lasko, 
and Departmental practice in a number of recent NME cases such as 
Collated Roofing Nails from the PRC, 62 FR 51410, 51416 (October 1, 
1997), Helical Spring Lock Washers from the PRC, 62 FR 61794, 61795 
(November 19, 1997) and Melamine Institutional Dinnerware from the PRC, 
62 FR 1707, 1710 (January 13, 1997). In support of this argument, the 
respondent cited the following section from Lasko:

[T]he purpose of the Act is to prevent dumping, an activity defined 
in terms of the market-place. The Act sets forth procedures in an 
effort to determine margins ``as accurately as possible.'' * * * 
Where we can determine that an NME producer's input prices are 
market determined accuracy, fairness and predictability are enhanced 
by using those prices. Therefore, using surrogate values when 
market-based values are available would, in fact be contrary to the 
intent of the law.

    Id. at 1446. The CAFC in Lasko also stated that the Departmental 
practice is a legitimate policy choice in interpreting and applying the 
statute. Id. 
    The respondent asserts that it demonstrated at verification that 
the price it paid for the SWR imported from the United Kingdom through 
a market economy trading company was paid for in a market economy 
currency (U.S. dollars). These purchases accounted for almost one-half 
of its total SWR purchases during the period of review (POR). Thus, the 
amount of imported SWR purchased during the POR was not insignificant. 
(The respondent notes that the Department considered the amount of 
imported SWR purchased by ZWG during the third administrative review to 
be meaningful. This amount was less than that imported by ZWG during 
the current POR.) Moreover, based on the Department's verification 
report and exhibits, the respondent states that the imported SWR is the 
same, and has the same range of sizes, as the SWR sourced domestically 
by ZWG. In addition, the respondent argues that because the prices paid 
by ZWG (for imported SWR) deviated from the average price by less than 
one percent, they cannot be considered aberrational.
    With regard to Olympia, the respondent asserts that the case is 
distinguishable from the situation in this review. In Olympia, the 
issue was whether the prices charged by a NME (PRC) trading company, 
which imported market economy steel and resold it to PRC producers in 
renmimbi, were reliable. The respondent argues that even if Olympia was 
applicable, the Department should determine that ZWG's import prices 
are reliable because verification demonstrated that (1) ZWG imported 
SWR from market economy suppliers and paid for the SWR in a market 
economy currency, (2) the imported SWR was used in the production of 
HSLWs, and (3) the deviation in price among the producers of imported 
SWR was not more than one percent.
    Department's Position: We have continued to use the price of the 
imported input to value SWR for ZWG in accordance with 19 CFR 
351.408(c)(1). In our view, this is consistent with the purpose of the 
antidumping statute identified in Rhone Poulenc, Inc. v. United States, 
899 F.2d 1185 (Fed. Cir. 1991), i.e., to determine antidumping margins 
as accurately as possible. It is also consistent with the CAFC's ruling 
in Lasko. As discussed in Lasko, the Department has developed practices 
which emphasize accuracy, fairness, and predictability in establishing 
NV for NME producers. Clearly, because the input imported by ZWG is the 
same material as that domestically purchased by ZWG and ZWG's imports 
of this input were not insignificant, the import price is the most 
accurate price for valuing this factor. Moreover, because use of this 
import price does not involve selecting among several possible 
surrogate values for the input in question, it also enhances the 
predictability of the valuation methodology.
    We disagree with the petitioner that use of import prices for 
valuing domestically sourced inputs in this situation is inconsistent 
with the Act. First, although we agree that Lasko addressed the use of 
import prices only for the portion of the input that was imported, 
Lasko did not prohibit the Department from using the import prices for 
the remaining domestically sourced portion. Indeed, for the reasons 
discussed above, we believe the use of the import price for the SWR 
domestically sourced by ZWG achieves the goals articulated in Lasko. We 
also believe that reliable import prices for the same input are a 
better means of valuing an input than surrogate values. This position 
is reflected in section 351.408(c)(1) of the Department's regulations 
acknowledged by the petitioner. Second, there is no information in the 
instant case that the imports were dumped or subsidized and, hence, to 
be avoided as the legislative history of section 773(c) of the Act 
directs. (Omnibus Trade and Competitiveness Act of 1988, H.R. Conf. 
Rep. No. 100-576, at 590 (1988), reprinted in 1988 U.S.C.C.A.N. 1547, 
1623-1624.)
    Further, we disagree with the petitioner's characterization that 
import data can only be used when ``available information is 
inadequate'' for valuing a factor. When ``available information is 
inadequate'' for using the factors methodology, section 773(c)(2) of 
the Act directs the Department to base NV on the price of merchandise 
that is comparable to the subject merchandise and is sold by a market 
economy country at a comparable level of economic development. In 
deciding to use the import price of the NME input rather than a 
surrogate value for the input, the Department relies instead upon the 
language in section 773(c)(1) of the Act regarding the use of ``best 
available information'' to value factors

[[Page 13404]]

of production. See Lasko, 43 F. 3d at 1446.
    Regarding the petitioner's argument that the Department has abused 
its authority in this case even if it has the discretion to use import 
prices, we disagree. The quantity of imported SWR is not small in 
relation to ZWG's requirements for production of the subject 
merchandise. As ZWG has noted, imported SWR supplied nearly one-half of 
the company's SWR requirements for producing the subject merchandise. 
In addition, the petitioner has not pointed to any other fact 
surrounding the importation of SWR which would lead us to question the 
import transactions.
    Finally, we agree with the respondent's characterization of Olympia 
and find that it is not applicable in this review. In the instant case, 
SWR was purchased from a market economy supplier through a market 
economy trading company and paid for in a market economy currency. In 
Olympia, the imports in question were made through an NME trading 
company. In a remand, the Court of International Trade (CIT) in Olympia 
requested the Department to explain why the prices paid by the NME 
trading company could not be used instead of resorting to a value in a 
surrogate country. In that case, the CIT simply required the Department 
to test the reliability of the prices paid due to the involvement of an 
NME trading company. (Olympia, Slip Op. 99-18 (February 17, 1999).) 
Because we are not dealing with an NME trading company in this case, 
there is no need to test the reliability of the price actually paid for 
the SWR used by ZWG.
    Therefore, in accordance with section 351.408(c)(1) of the 
Department's regulations and Department's practice, we continue to use 
the actual imported steel prices to value ZWG's steel inputs because 
these prices represent the actual market-based prices incurred by ZWG 
in producing the subject merchandise and, as such, are the most 
accurate and appropriate values for this particular factor for the 
purpose of calculating NV.

Comment 2: Factory Overhead, SG&A Expenses In Plating Costs

    The petitioner asserts that the Department erred in the preliminary 
results by failing to include FOH, SG&A, and profit for the plating 
operation. The Department's calculations for NV should reflect that the 
plating company and lock washer facility are separate, non-integrated 
entities. The petitioner argues that because the Department did not use 
a surrogate value for plating, but rather calculated surrogate values 
for the factor inputs used in plating, the Department is required to 
value separately the plating company's FOP and to include FOH, SG&A, 
and profit for plating. This CV should then be included as a ``cost'' 
to the lock washer producer. Moreover, the petitioner alleges that the 
Department included these costs separately in previous proceedings and 
did not explain its change in methodology in its preliminary results of 
review.
    ZWG contends that the Department correctly calculated NV by 
computing FOH, SG&A and profit for total factors to produce HSLWs. ZWG 
states that the petitioner's suggestion to include FOH, SG&A, and 
profit in the calculation of ZWG's plating costs and then to calculate 
FOH, SG&A, and profit again for total factors to produce HSLWs, 
(including the plating materials, plating energy and plating labor) 
would double-count FOH, SG&A, and profit for the plating portion of 
production. To illustrate that point, the respondent notes that, 
although ZWG does not have plating equipment, the cost of depreciation 
for plating equipment would be included in NV twice: once as a part of 
plating operations and again as part of total production.
    ZWG disagrees with the petitioner that the Department has changed 
its methodology from earlier reviews. Although the calculation was set 
up differently, the respondent states that the methodology used in the 
preliminary results of this review is mathematically identical to the 
methodology used in all previous reviews.
    Department's Position: The respondent is correct that the 
methodology used for calculating NV in the preliminary results is 
mathematically identical with the result that would have been obtained 
had we applied the methodology used in previous reviews. Nevertheless, 
we have decided, for purposes of clarity, to set up the calculation in 
the same manner as in the second (1994-95) and third (1995-96) reviews 
of this case. Thus, in these final results, we have calculated NV in 
the following manner: (1) we added ZWG's costs of direct materials 
(including transportation), labor, and factory overhead in order to 
obtain ZWG's cost of manufacturing; (2) we calculated ZWG's SG&A and 
profit and added these to the cost of manufacturing in order to obtain 
ZWG's cost of production; (3) we performed the same calculation to 
obtain the plating company's cost of production; and, (4) we calculated 
the NV of the subject merchandise by adding ZWG's and the plating 
company's costs of production.
    This calculation does not result in treating the cost of production 
for plating as an input into ZWG's production process, in the sense 
that the SG&A and profit calculated for ZWG does not include SG&A and 
profit calculated for the plating activity. Since the Department does 
not accord any significance to transactions between NME enterprises 
(e.g., we do not consider using prices between NME producers and NME 
trading companies), we do not attempt to construct the price that would 
exist between an NME supplier (the plating company) and the NME 
producer of the subject merchandise (the HSLW producer).

Comment 3: Inland Freight Expense for Imported Steel

    The petitioner argues that the Department incorrectly calculated 
freight expenses for domestically sourced SWR. The petitioner 
acknowledges that under Sigma Corporation v. United States, 117 F.3d 
1401 (Fed. Cir. 1997) (Sigma), where surrogate values are based on CIF 
imports in the surrogate country, the Department must not ``double 
count'' in determining the freight amount assigned to the FOP. However, 
the petitioner argues that in this case Sigma does not apply because 
the Department is using the price at which the PRC producer actually 
imports SWR. Thus, for domestically sourced SWR, the Department should 
use the distance between the supplier and ZWG. This does not violate 
the principles of the Sigma case because ZWG had a choice between 
domestic and foreign sourcing of its SWR and made a voluntary business 
decision to purchase SWR from both sources.
    The respondent asserts that Sigma should apply to all situations 
where the Department uses actual CIF import prices to value 
domestically sourced inputs. The respondent contends that the 
Department's methodology reflects the reasoning of the CAFC in Sigma as 
it recognizes that market economy producers would tend to purchase 
inputs from the closer of an import source or domestic source and 
treats the actual CIF price of SWR as a ``surrogate value'' for SWR in 
determining freight costs. Thus, because surrogate values are merely 
the best approximation of what a PRC producer would pay if the producer 
were operating in a market economy, the respondent states that the 
Department should continue to apply Sigma to all distances to ZWG's 
material input suppliers in China.
    Department's Position: We agree with the petitioner that Sigma does 
not apply in a situation where the Department

[[Page 13405]]

values an input using the price actually paid by the NME producer. 
However, we do not agree that we should assign a freight value based on 
the distance to the NME supplier for that portion of the input that is 
domestically sourced. Because we are using an actual import value and 
have the actual distance that the imported merchandise had to be 
shipped, we are using that import value and that freight amount to 
value SWR, whether the SWR is imported or not.

Comment 4: Surrogate Truck Value

    The petitioner contends that the Department incorrectly used a rate 
for foreign inland truck freight from a Times of India article 
published on April 20, 1994 (Times of India rate). Instead, the 
petitioner suggests that the Department use the truck freight rates 
listed in the U.S. Embassy cable dated August, 1993. The petitioner 
argues that the Times of India rate applies only to company-owned 
trucks and, since the Department has found that the trucks used by the 
respondent ZWG during the POR were not company-owned, the Department 
should use a different freight rate. The petitioner states that the 
Embassy cable rate was used as the truck rate by the Department in both 
the final determination of the HSLWs investigation and the most recent 
HSLWs administrative review. Furthermore, in Heavy Forged Hand Tools, 
Finished or Unfinished, With or Without Handles, From the People's 
Republic of China: Preliminary Results of Antidumping Duty 
Administrative Reviews, 62 FR 60684, (November 12, 1997), (Hand Tools), 
the Department distinguished between company and non-company owned 
trucks. In Hand Tools, the non-company-owned trucks were assigned a 
truck rate based on the Embassy cable.
    The respondent maintains that the petitioner has misread the Times 
of India article and that the freight rates quoted therein do not apply 
only to company-owned trucks. The respondent believes that a 
distinction between freight rates incurred by company-owned and non-
company-owned trucks is irrelevant and urges the Department to continue 
to use the rates published in Times of India.
    Department's Position: We disagree with the petitioner. The Times 
of India rate is solely for trucks and provides a specific foreign 
inland truck rate, whereas the Embassy cable rate is for all modes of 
transportation in the surrogate country and provides a less specific 
rate for foreign inland trucks. The Department stated in its Final 
Determination of Sales at Less Than Fair Value: Certain Helical Spring 
Lock Washers from the People's Republic of China, 58 FR 48833 
(September 20, 1993), that the August 3, 1993 cable from India (Embassy 
cable) appears to be an aggregate of various rates: trucking, shipping 
and rail. We note that in Hand Tools and Hand Tools, Final Results 
Antidumping Duty Administrative Reviews for 1996-1997, 63 FR 16758 
(April 6, 1998), the Department did not consider the aggregate nature 
of the Embassy cable rate.
    Also, it should be noted that the Times of India rate was used by 
the Department in the last two HSLWs administrative reviews.

Final Results of the Review

    As a result of our analysis of the comments received, we determine 
that the following weighted-average margins exist:

------------------------------------------------------------------------
                                                                Margin
       Manufacturer/exporter              Time period         (percent)
------------------------------------------------------------------------
Zhejiang Wanxin Group Co., Ltd....        10/01/96-09/30/97         3.85
PRC Rate..........................        10/01/96-09/30/97       128.63
------------------------------------------------------------------------

    The Department shall determine, and the Customs Service shall 
assess, antidumping duties on all appropriate entries. Pursuant to 
section 351.212(b)(1) of the Department's regulations, we have 
calculated an importer-specific duty assessment rate based on the ratio 
of the total amount of antidumping duties calculated for the examined 
sales to the total entered value of those sales. In order to estimate 
the entered value, we subtracted international movement expenses from 
the gross sales value. This rate will be assessed uniformly on all 
entries of that specific importer made during the POR. The Department 
will issue appraisement instructions directly to the U.S. Customs 
Service.
    Furthermore, the following deposit rates will be effective upon 
publication of these final results for all shipments of HSLWs from the 
PRC entered, or withdrawn from warehouse, for consumption on or after 
the publication date, as provided for by section 751(a)(1) of the Act: 
(1) for ZWG, which has a separate rate, and all ZWG exports through 
market-economy trading companies, the cash deposit rate will be the 
company-specific rate established in these final results of review; (2) 
for all other PRC exporters, the cash deposit rate will be the PRC rate 
which is 128.63 percent, which is the All Other PRC Manufacturers, 
Producers and Exporters rate from the Final Determination of Sales at 
Less Than Fair Value: Certain Helical Spring Lock Washers from the PRC, 
58 FR 48833 (September 20, 1993); and (3) for non-PRC exporters of 
subject merchandise from the PRC, the cash deposit rate will be the 
rate applicable to the PRC supplier of that exporter. These deposit 
rates 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 section 351.402(f) of the Department's regulations 
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 section 351.305(a)(3) of the Department's 
regulations. 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 the terms of an 
APO is a sanctionable violation.
    This administrative review and notice are in accordance with 
sections 751(a)(1) and 777(i)(1) of the Act.

    Dated: March 9, 1999.
Robert S. LaRussa,
Assistant Secretary for Import Administration.
[FR Doc. 99-6535 Filed 3-17-99; 8:45 am]
BILLING CODE 3510-DS-P