[Federal Register Volume 69, Number 110 (Tuesday, June 8, 2004)]
[Notices]
[Pages 31961-31965]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 04-12941]
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DEPARTMENT OF COMMERCE
International Trade Administration
[A-580-844]
Steel Concrete Reinforcing Bar From The Republic of Korea: Notice
of Preliminary Results and Preliminary Rescission, in Part, of
Antidumping Duty Administrative Review
AGENCY: Import Administration, International Trade Administration,
Department of Commerce.
ACTION: Notice of preliminary results and preliminary rescission, in
part, of antidumping duty administrative review.
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DATES: Effective Date: June 8, 2004.
SUMMARY: In response to a request from the petitioner,\1\ the
Department of Commerce (``the Department'') is conducting an
administrative review of the antidumping duty order on steel concrete
reinforcing bar (``rebar'') from the Republic of Korea (``Korea''). The
period of review (``POR'') is September 1, 2002, through August 31,
2003. This review covers six manufacturers/exporters of subject
merchandise.
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\1\ The petitioner in this proceeding is the Rebar Trade Action
Coalition and its individual members: Gerdau AmeriSteel, CMC Steel
Group, Nucor Corporation, and TAMCO.
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As a result of our review, we preliminarily determine that four
[[Page 31962]]
respondents had no sales or shipments of subject merchandise to the
United States during the POR. Therefore, we are preliminarily
rescinding the review with respect to these respondents. The remaining
two respondents, Dongil Industries Co. Ltd. (``Dongil'') and Hanbo Iron
& Steel Co., Ltd. (``Hanbo''), failed to respond to our questionnaire.
As a result, we are basing our preliminary results for Dongil and Hanbo
on total adverse facts available (``AFA''). If these preliminary
results are adopted in our final results of review, we will instruct
U.S. Customs and Border Protection (``CBP'') to assess antidumping
duties on all appropriate entries. We invite parties to comment on
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these preliminary results.
FOR FURTHER INFORMATION CONTACT: Richard Johns or Mark Manning,
Antidumping and Countervailing Duty Enforcement Group II, Office 4,
Import Administration, International Trade Administration, U.S.
Department of Commerce, 14th Street and Constitution Avenue, NW.,
Washington, DC 20230; telephone (202) 482-2305 and (202) 482-5253,
respectively.
SUPPLEMENTARY INFORMATION:
Background
On September 7, 2001, the Department published an antidumping duty
order on rebar from Korea. See Antidumping Duty Orders: Steel Concrete
Reinforcing Bars From Belarus, Indonesia, Latvia, Moldova, People's
Republic of China, Poland, Republic of Korea and Ukraine, 66 FR 46777
(September 7, 2001). On September 2, 2003, the Department published a
notice of opportunity to request the second administrative review of
this order. See Antidumping or Countervailing Duty Order, Finding, or
Suspended Investigation; Opportunity to Request Administrative Review,
68 FR 52181 (September 2, 2003). On September 30, 2003, in accordance
with 19 CFR 351.213(b), the petitioner requested an administrative
review of six manufacturers/exporters of rebar from Korea: Dongil,
Dongkuk Steel Mill Co. Ltd. (``DSM''), Hanbo, INI Steel, Korea Iron and
Steel Co., Ltd. (``KISCO''), and Kosteel Co., Ltd. (``Kosteel''). On
October 24, 2003, the Department published the notice of initiation of
this administrative review, covering the period September 1, 2002,
through August 31, 2003. See Initiation of Antidumping and
Countervailing Duty Administrative Reviews, 68 FR 60910 (October 24,
2003).
On October 22, 2003, the Department issued the antidumping
questionnaire to each of the six manufacturers/exporters listed above.
On November 12, 2003, DSM and KISCO notified the Department that they
had no sales or shipments of subject merchandise to the United States
during the POR. On December 3, 2003, Kosteel also notified the
Department that it had no sales or shipments of subject merchandise to
the United States during the POR. Dongil, Hanbo, and INI Steel failed
to respond to the Department's November 12, 2003, questionnaire.
On May 6, 2004, the Department notified interested parties that we
intend to rescind this administrative review with respect to those
manufacturers/exporters that had no sales or shipments during the POR.
See Memorandum to the File from Richard Johns, International Trade
Compliance Analyst, ``Rescission of Antidumping Duty Administrative
Review of Steel Concrete Reinforcing Bars from Korea for the Period of
Review September 1, 2002 through August 31, 2003,'' dated May 6, 2004.
We invited interested parties to comment on our intention to rescind
the review with respect to companies for which there is no evidence of
sales or shipments of subject merchandise to the United States during
the POR.
On May 11, 2004, the Department sent a letter to Dongil, Hanbo, and
INI Steel informing these companies that we did not receive a response
from them to the antidumping questionnaire. In the letter, the
Department stated that, if the reason as to why they did not respond to
the antidumping questionnaire is that they had no shipments of subject
merchandise to the United States during the POR, they should inform the
Department of this fact; otherwise, the Department may conclude that
these companies decided not to cooperate with the Department's review.
In response, on May 13, 2004, INI Steel reported that it had no sales
or shipments of subject merchandise to the United States during the
POR. Dongil and Hanbo did not respond to the Department's May 11, 2004,
letter.
On May 12, 2004, the Department released to interested parties the
results of a U.S. Customs and Border Protection (``CBP'') data query
for shipments of subject merchandise to the United States during the
POR. See Memorandum to the File from Richard Johns, International Trade
Compliance Analyst, ``U.S. Customs and Border Protection Data Query
Results,'' dated May 12, 2004. We invited interested parties to comment
on the results of this data query. We received the petitioner's
comments regarding the Department's May 6, 2004, and May 12, 2004,
memoranda on May 20, 2004. In its comments, the petitioner did not
provide any evidence of sales or shipments from DSM, INI Steel, KISCO,
or Kosteel. The petitioner recommends that the Department apply total
AFA against Dongil and Hanbo because these companies failed to provide
the information requested by the Department's October 22, 2003,
antidumping questionnaire and May 11, 2004, letter. The petitioner also
recommends that the Department not rescind the review with respect to
DSM, INI Steel, KISCO, and Kosteel because the Department's query of
CBP data covered only the months of the POR. According to the
petitioner, limiting the data query to only the months of the POR fails
to capture sales made during the POR which were based upon entries made
prior to the POR, in addition to sales made during the POR which were
based upon entries made after the POR. To account for these potential
problems, the petitioner urges the Department to request further
information from DSM, INI Steel, KISCO, and Kosteel regarding the date
of sale used by these companies when they informed the Department that
they had no sales during the POR.
Due to the unexpected emergency closure of the main Commerce
building on Tuesday, June, 1, 2004, the Department has tolled the
deadline for these preliminary/final results by one day to June 2,
2004.
As noted above, DSM, INI Steel, KISCO, and Kosteel notified the
Department that they had no sales or shipments of subject merchandise
in the United States during the POR. The Department obtained data from
CBP that supported their claims of no entries during the POR. In
addition, no interested party provided evidence of sales or shipments
of subject merchandise from DSM, INI Steel, KISCO, or Kosteel during
the POR. Furthermore, with respect to the arguments raised by the
petitioner in its comments on our intent to rescind this review in
part, we note that the antidumping questionnaire issued to the six
respondents contains clear instructions on how to identify the universe
of sales that should be reported in this POR. Accordingly, we are
preliminarily rescinding the review with respect to DSM, INI Steel,
KISCO, and Kosteel. Because Dongil and Hanbo failed to respond to the
Department's October 22, 2003, questionnaire and May 11, 2004, letter,
we preliminarily find that the application of total AFA is warranted in
this case.
Scope of the Review
The product covered by this administrative review is all rebar sold
in
[[Page 31963]]
straight lengths, currently classifiable in the Harmonized Tariff
Schedule of the United States (``HTSUS'') under item number 7214.20.00
or any other tariff item number. Specifically excluded are plain rounds
(i.e., non-deformed or smooth bars) and rebar that has been further
processed through bending or coating. The HTSUS subheadings are
provided for convenience and customs purposes. The written description
of the scope of this proceeding is dispositive.
Facts Available
Section 776(a)(2) of the Tariff Act of 1930, as amended (``the
Act''), provides that if any interested party: (A) Withholds
information that has been requested by the Department; (B) fails to
provide such information by the deadlines for submission of the
information or in the form or manner requested; (C) significantly
impedes an antidumping investigation; or (D) provides such information
but the information cannot be verified, the Department shall, subject
to section 782(d) of the Act, use facts otherwise available in making
its determination.
Section 782(d) of the Act provides that, if the Department
determines that a response to a request for information does not comply
with the request, the Department will inform the person submitting the
response of the nature of the deficiency and shall, to the extent
practicable, provide that person the opportunity to remedy or explain
the deficiency. If that person submits further information that
continues to be unsatisfactory, or this information is not submitted
within the applicable time limits, the Department may, subject to
section 782(e), disregard all or part of the original and subsequent
responses, as appropriate.
Section 782(e) of the Act states that the Department shall not
decline to consider information deemed ``deficient'' under section
782(d) if: (1) The information is submitted by the established
deadline; (2) the information can be verified; (3) the information is
not so incomplete that it cannot serve as a reliable basis for reaching
the applicable determination; (4) the interested party has demonstrated
that it acted to the best of its ability; and (5) the information can
be used without undue difficulties.
Furthermore, section 776(b) of the Act states that if the
Department ``finds that an interested party has failed to cooperate by
not acting to the best of its ability to comply with a request for
information from the administering authority or the Commission, the
administering authority or the Commission * * *, in reaching the
applicable determination under this title, may use an inference that is
adverse to the interests of that party in selecting from among the
facts otherwise available.'' See also Statement of Administrative
Action (``SAA'') accompanying the URAA, H.R. Rep. No. 103-316 at 870
(1994).
Application of Facts Available
The evidence on the record of this review establishes that,
pursuant to section 776(a)(2)(A) of the Act, the use of total facts
available (``FA'') is warranted in determining the dumping margin for
U.S. sales of rebar made by Dongil and Hanbo because these two
companies failed to provide requested information. As stated above, on
October 22, 2003, the Department issued the antidumping questionnaire
to six manufacturers/exporters of the subject merchandise. Four
companies ultimately advised the Department that they did not have
shipments or sales of subject merchandise to the United States during
the POR. Dongil and Hanbo failed to respond to the Department's
antidumping questionnaire. On May 11, 2004, we informed Dongil and
Hanbo that, because they failed to respond to the Department's
antidumping questionnaire, and had not informed the Department as to
whether they had sales or shipments of subject merchandise to the
United States during the POR, we may use AFA to determine their dumping
margins. Dongil and Hanbo did not respond to the Department's May 11,
2004, letter. Based on the data obtained from CBP, the Department
cannot conclude that these companies had no sales to the United States
during the POR. See Memorandum to the File from Richard Johns,
International Trade Compliance Analyst, ``Entry Data With Respect to
Dongil and Hanbo,'' dated June 1, 2004.
Because Dongil and Hanbo failed to provide the necessary
information requested by the Department, pursuant to section
776(a)(2)(A) of the Act, we must establish the margins for these
companies based on the facts otherwise available.
Use of Adverse Inferences
In selecting from among the facts otherwise available, pursuant to
section 776(b) of the Act, an adverse inference is warranted when the
Department has determined that a respondent has ``failed to cooperate
by not acting to the best of its ability to comply with a request for
information.'' Section 776(b) of the Act goes on to note that an
adverse inference may include reliance on information derived from (1)
the petition; (2) a final determination in the investigation under this
title; (3) any previous review under section 751 or determination under
section 753, or (4) any other information on the record.
Adverse inferences are appropriate ``to ensure that the party does
not obtain a more favorable result by failing to cooperate than if it
had cooperated fully.'' See SAA at 870; Borden, Inc. v. United States,
4 F. Supp. 2d 1221 (CIT 1998); Mannesmannrohren-Werke AG v. United
States, 77 F. Supp. 2d 1302 (CIT 1999). The Court of Appeals for the
Federal Circuit (CAFC), in Nippon Steel Corporation v. United States,
337 F. 3d 1373, 1380 (Fed. Cir. 2003), provided an explanation of the
``failure to act to the best of its ability'' standard, holding that
the Department need not show intentional conduct existed on the part of
the respondent, but merely that a ``failure to cooperate to the best of
a respondent's ability'' existed, i.e., information was not provided
``under circumstances in which it is reasonable to conclude that less
than full cooperation has been shown.'' Id. The CAFC did acknowledge,
however, that ``deliberate concealment or inaccurate reporting'' would
certainly be a reason to apply AFA, although it indicated that
inadequate responses to agency inquiries ``would suffice'' as well. Id.
To examine whether the respondent ``cooperated'' by ``acting to the
best of its ability'' under section 776(b) of the Act, the Department
considers, inter alia, the accuracy and completeness of submitted
information and whether the respondent has hindered the calculation of
accurate dumping margins. See Certain Welded Carbon Steel Pipes and
Tubes From Thailand: Final Results of Antidumping Duty Administrative
Review, 62 FR 53808, 53819-53820 (October 16, 1997).
The record shows that Dongil and Hanbo failed to cooperate to the
best of their ability, within the meaning of section 776(b) of the Act.
In reviewing the evidence on the record, the Department finds that
Dongil and Hanbo failed to provide requested information. Moreover,
these companies failed to offer any explanation for their failure to
respond to our antidumping questionnaire or May 11, 2004, letter. As a
general matter, it is reasonable for the Department to assume that
these companies possessed the records necessary to participate in this
review; however, by not supplying the information the Department
requested, these companies failed to cooperate to the best of their
ability. As these companies have failed to cooperate to the best of
their ability, we are applying an adverse inference pursuant to section
[[Page 31964]]
776(b) of the Act. As AFA for Dongil and Hanbo, we have used a rate of
102.28 percent, which is the highest margin from any segment of the
proceeding. Specifically, this rate was the highest margin alleged for
any Korean company in the petition and is the rate used as AFA for
Hanbo in the final determination of the less-than-fair-value (``LTFV'')
investigation. See Notice of Final Determination of Sales at Less Than
Fair Value: Steel Concrete Reinforcing Bars From the Republic of Korea,
66 FR 33526 (June 22, 2001).
Corroboration of Information
Section 776(c) of the Act requires the Department to corroborate,
to the extent practicable, secondary information used as FA. Secondary
information is defined as ``{i{time} nformation derived from the
petition that gave rise to the investigation or review, the final
determination concerning the subject merchandise, or any previous
review under section 751 concerning the subject merchandise.'' See SAA
accompanying the URAA, H.R. Doc. No. 103-316 at 870 (1994) and 19 CFR
351.308(d).
The SAA further provides that the term ``corroborate'' means that
the Department will satisfy itself that the secondary information to be
used has probative value. See SAA at 870. Thus, to corroborate
secondary information, the Department will, to the extent practicable,
examine the reliability and relevance of the information used. During
the LTFV investigation, we examined the reliability of the 102.28
percent rate selected as AFA for Hanbo and found it to be reliable. See
Memorandum to Troy H. Cribb, Assistant Secretary for Import
Administration, from Holly A. Kuga, Acting Deputy Assistant Secretary
for AD/CVD Enforcement, Group II, ``The Use of Facts Available for
Hanbo Iron & Steel Co. Ltd., and Corroboration of Secondary
Information,'' dated January 16, 2001, and placed on the record of this
review concurrently with these preliminary results. We have re-examined
the information used as FA in the LTFV investigation and we consider it
reliable, for purposes of this second administrative review.
As to the relevance of the AFA rate, the CIT has stated that
Congress ``intended for an adverse facts available rate to be a
reasonably accurate estimate of the respondent's actual rate, albeit
with some built-in increase intended as a deterrent to non-
compliance.'' F.Lli De Cecco Di Filippo Fara S. Martino S.p.A., v.
U.S., 216 F.3d 1027, 1032 (Fed. Cir. 2000). The Department considers
information reasonably at its disposal to determine whether a margin
continues to have relevance. Where circumstances indicate that the
selected margin is not appropriate as AFA, the Department will
disregard the selected margin and determine an appropriate margin. See
e.g., Fresh Cut Flowers from Mexico: Final Results of Antidumping
Administrative Review, 61 FR 6812 (February 22, 1996).
With respect to the rate selected for Dongil and Hanbo, we note
that in determining the relevant AFA rate, the Department assumes that
if an uncooperative respondent could have demonstrated that its dumping
margin is lower than the highest prior margin, it would have provided
information showing the margin to be less. See Rhone Poulenc, Inc. v.
United States, 899 F.2d 1185, 1190-91 (Fed. Cir. 1990) (``Rhone
Poulenc''). Given Dongil and Hanbo's failure to cooperate to the best
of their respective abilities in the instant administrative review, we
have no reason to believe that the dumping margins for their sales of
subject merchandise would be any less than the current ``all others''
rate of 22.89 percent for Dongil, which does not have its own
individual rate, or Hanbo's current cash deposit rate of 102.28
percent. In Rhone Poulenc, the CAFC found that the presumption that,
``the highest prior margin was the best information of current
margins'' was a permissible interpretation of 19 U.S.C. 1677e(c). See
Rhone Poulenc, 899 F.2d at 1190. In upholding this presumption, the
CAFC cited the rationale underlying the adverse inference rule, that
the presumption ``reflects a common sense inference that the highest
prior margin is the most probative evidence of current margins because,
if it were not so, the importer, knowing of the rule, would have
produced current information showing the margin to be less.'' Id. In
other proceedings, the Department has used the highest margin as AFA.
See, e.g., Freshwater Crawfish Tail Meat from the People's Republic of
China; Notice of Final Results of Antidumping Duty Administrative
Review, 68 FR 19504 (April 21, 2003). In fact, the Department used the
102.28 percent rate as AFA in the final determination of the LTFV
investigation with respect to Hanbo. Therefore, Dongil and Hanbo had
notice that the 102.28 percent rate may be used as the AFA rate that
would be applied for their failure to cooperate. Consequently, in
keeping with Rhone Poulenc, we consider the 102.28 percent rate to be
the most probative evidence of current margins for Dongil and Hanbo
because, if it were not so, these two manufacturers/exporters, knowing
of the rule, would have produced current information showing the margin
to be less. Therefore, we consider the 102.28 percent rate to be
relevant.
Accordingly, we have determined that the rates selected as AFA are
both reliable and relevant. Therefore, we have corroborated these rates
in accordance with section 776(c) of the Act.
Preliminary Results of Review
As a result of our review, we preliminarily determine the following
weighted-average dumping margin exists for the period September 1,
2002, through August 31, 2003:
------------------------------------------------------------------------
Weighted-
Manufacturer/exporter average margin
(percentage)
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Dongil Industries Co. Ltd............................... 102.28
Hanbo Iron & Steel Co., Ltd............................. 102.28
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Public Comment
According to 19 CFR 351.224(b), the Department will disclose any
calculations performed in connection with the preliminary results of
review within five days of the date of publication of the preliminary
notice. However, in the instant review, the Department did not perform
any calculations because all margins result from the application of
total AFA. Therefore, no calculations will be disclosed in this case.
An interested party may request a hearing within 30 days of
publication of the preliminary results. See 19 CFR 351.310(c). We will
issue a memorandum identifying the date of a hearing, if one is
requested. Pursuant to 19 CFR 351.309, interested parties may submit
written comments in response to these preliminary results. Case briefs
are to be submitted within 30 days after the date of publication of
this notice, and rebuttal briefs, limited to arguments raised in case
briefs, are to be submitted no later than five days after the time
limit for filing case briefs. Parties who submit arguments are
requested to submit with the argument (1) a statement of the issue, (2)
a brief summary of the argument, and (3) a table of authorities.
Further, the Department requests that parties submitting written
comments provide the Department with a diskette containing the public
version of those comments. Unless the deadline is extended pursuant to
section 751(a)(3)(A) of the Act, the Department will issue the final
results of this administrative review, including the results of our
analysis of the issues
[[Page 31965]]
raised by the parties in their comments, within 120 days of publication
of the preliminary results. The assessment of antidumping duties on
entries of merchandise covered by this review and future deposits of
estimated duties shall be based on the final results of this review.
Duty Assessments
The Department shall determine, and CBP shall assess, antidumping
duties on all appropriate entries. According to 19 CFR 351.212(b)(1),
the Department normally will calculate an assessment rate for each
importer of subject merchandise covered by the review by dividing the
dumping margin found on the subject merchandise examined by the entered
value of such merchandise for normal customs duty purposes. In the
instant review, for the respondents receiving dumping rates based upon
AFA, the Department will instruct CBP to liquidate entries according to
the AFA ad valorem rate. For the respondents being rescinded from this
review, the Department will instruct CBP to assess antidumping duties
at the cash deposit rate in effect at the time of entry. The Department
will issue appropriate appraisement instructions directly to CBP within
fifteen days of publication of the final results of review.
Cash Deposit Rates
The following cash deposit requirements will be effective upon
completion of the final results of this administrative review for all
shipments of rebar from Korea entered, or withdrawn from warehouse, for
consumption on or after the publication date of the final results of
this administrative review, as provided by section 751(a)(1) of the
Act: (1) The cash deposit rate for Dongil and Hanbo will be the rate
established in the final results of this review; (2) for previously
reviewed or investigated companies not listed above, the cash deposit
rate will continue to be the company-specific rate published for the
most recent review period; (3) if the exporter is not a firm covered in
this review, a prior review, or the LTFV investigation, but the
manufacturer is, the cash deposit rate will be the rate established for
the most recent period for the manufacturer of the subject merchandise;
and (4) the cash deposit rate for all other manufacturers or exporters
will continue to be 22.89 percent, the ``all others'' rate made
effective by the LTFV investigation. See Notice of Final Determination
of Sales at Less Than Fair Value: Steel Concrete Reinforcing Bars From
the Republic of Korea, 66 FR 33526 (June 22, 2001). These required cash
deposit rates shall remain in effect until publication of the final
results of the next administrative review.
Notification to Importers
This notice also serves as a preliminary reminder to importers of
their responsibility under 19 CFR 351.402(f) 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.
We are issuing and publishing this notice in accordance with
sections 751(a)(1) and 777(i)(1) of the Act.
Dated: June 2, 2004.
James J. Jochum,
Assistant Secretary for Import Administration.
[FR Doc. 04-12941 Filed 6-7-04; 8:45 am]
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