[Federal Register Volume 81, Number 106 (Thursday, June 2, 2016)]
[Notices]
[Pages 35320-35323]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-12969]
[[Page 35320]]
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DEPARTMENT OF COMMERCE
International Trade Administration
[A-475-832]
Certain Corrosion-Resistant Steel Products From Italy: Final
Determination of Sales at Less Than Fair Value and Final Affirmative
Determination of Critical Circumstances, in Part
AGENCY: Enforcement and Compliance, International Trade Administration,
Department of Commerce.
SUMMARY: The Department of Commerce (``the Department'') determines
that certain corrosion-resistant steel products (``corrosion-resistant
steel'') from Italy is being, or is likely to be, sold in the United
States at less than fair value (``LTFV''), as provided in section
735(a) of the Tariff Act of 1930, as amended (``the Act''). The period
of investigation (``POI'') is April 1, 2014, through March 31, 2015.
The final dumping margins of sales at LTFV are listed below in the
``Final Determination'' section of this notice.
DATES: Effective Date: June 2, 2016.
FOR FURTHER INFORMATION CONTACT: Julia Hancock or Susan Pulongbarit,
AD/CVD Operations, Office V, Enforcement and Compliance, International
Trade Administration, U.S. Department of Commerce, 14th Street and
Constitution Avenue NW., Washington, DC 20230; telephone: (202) 482-
1394 or (202) 482-4031, respectively.
SUPPLEMENTARY INFORMATION:
Background
On January 4, 2016, the Department published the Preliminary
Determination of this antidumping duty (``AD'') investigation.\1\ The
following events occurred since the Preliminary Determination was
issued.
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\1\ See Certain Corrosion-Resistant Steel Products From Italy:
Preliminary Affirmative Determination of Sales at Less Than Fair
Value and Postponement of Final Determination, 81 FR 69 (January 4,
2016) (``Preliminary Determination'').
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Between January and April 2016, the Department received
supplemental questionnaire responses and revised databases from
Acciaieria Arvedi SPA (``Arvedi'') and Marcegaglia SpA
(``Marcegaglia''), the mandatory respondents in this investigation.
As explained in the memorandum from the Acting Assistant Secretary
for Enforcement and Compliance, the Department has exercised its
discretion to toll all administrative deadlines due to the closure of
the Federal Government. All deadlines in this segment of the proceeding
have been extended by four business days. The revised deadline for the
final determination is now May 24, 2016.\2\
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\2\ See Memorandum for the Record, from Ron Lorentzen, Acting
Assistant Secretary for Enforcement and Compliance, ``Tolling of
Administrative Deadlines as a Result of the Government Closure
during Snowstorm Jonas,'' dated January 27, 2016.
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Between April 19, and April 20, 2016, Petitioners \3\ submitted
timely, properly filed case briefs.\4\ Between April 25, and April 28,
2016, Arvedi, and Petitioners submitted timely, properly filed rebuttal
briefs.\5\ Additionally, on April 27, 2016, Marcegaglia submitted a
timely, properly filed case brief.\6\ Moreover, on May 2, 2016,
Marcegaglia submitted a timely, properly filed rebuttal brief.\7\
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\3\ United States Steel Corporation, Nucor Corporation,
ArcelorMittal USA, AK Steel Corporation, Steel Dynamics, Inc., and
California Steel Industries, Inc., (collectively ``Petitioners'').
\4\ See Letter to the Secretary of Commerce from Petitioners
``Case Brief Submitted on behalf of Petitioners: Brief on Arvedi,''
(April 19, 2016) (``Petitioners' Case Brief on Arvedi''); Letter to
the Secretary of Commerce from Petitioners ``Case Brief Submitted on
Behalf of Petitioners: Brief on Marcegaglia,'' (April 20, 2016)
(``Petitioners' Case Brief on Marcegaglia'').
\5\ See Letter to the Secretary of Commerce from Petitioners
``Rebuttal Brief on Marcegaglia Submitted on behalf of
Petitioners,'' (April 28, 2016) (``Petitioners' Rebuttal Brief on
Marcegaglia''); Letter to the Secretary of Commerce from Arvedi
``Arvedi's Rebuttal Brief,'' (April 25, 2016) (``Arvedi's Rebuttal
Brief''); Letter to the Secretary of Commerce from Marcegaglia,
``Marcegaglia's Rebuttal Brief,'' (April 28, 2016) (``Marcegaglia's
Rebuttal Brief'')..
\6\ See Letter to the Secretary of Commerce from Marcegaglia,
``Revised Case Brief of Marcegaglia,'' (April 27, 2016)
(``Marcegaglia's Revised Case Brief''). We note that this is a
refiled and redacted case brief. See Letter to Marcegaglia from Paul
Walker, Program Manager, Office V, Re: Corrosion-Resistant Steel
Products from Italy: Rejection of New Factual Information, (April
26, 2016); Letter to the Secretary of Commerce from Marcegaglia,
``Corrosion-Resistant Steel Products from Italy: Objection to the
Department's Rejection of Marcegaglia's Case Brief,'' (April 27,
2016).
\7\ See Letter to the Secretary of Commerce from Marcegaglia,
``Revised Rebuttal Brief of Marcegaglia,'' (May 2, 2016)
(``Marcegaglia's Revised Rebuttal Brief''). We note that this is a
refiled and redacted rebuttal brief. See Letter to Marcegaglia from
Paul Walker, Program Manager, Office V, Re: Corrosion-Resistant
Steel Products from Italy: Rejection of New Factual Information in
Rebuttal Brief, (April 29, 2016).
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Additionally, on May 3, 2016, the Department held a public hearing
on this antidumping duty investigation.
Scope of the Investigation
The product covered by this investigation is corrosion-resistant
steel from Italy. For a complete description of the scope of this
investigation, see the ``Scope of the Investigation,'' in Appendix II
of this notice.
Scope Comments
In accordance with the Preliminary Scope Determination,\8\ the
Department set aside a period of time for parties to address scope
issues in case briefs or other written comments on scope issues.
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\8\ See Memorandum to Gary Taverman, Associate Deputy Assistant
Secretary for Antidumping and Countervailing Duty Operations,
``Certain Corrosion-Resistant Steel Products From the People's
Republic of China, India, Italy, the Republic of Korea, and Taiwan:
Scope Comments Decision Memorandum for the Preliminary
Determinations,'' dated December 21, 2015 (``Preliminary Scope
Decision Memorandum''). See also Memorandum to the File, ``Certain
Corrosion-Resistant Steel Products From the People's Republic of
China, India, Italy, the Republic of Korea, and Taiwan: Correction
to Preliminary Determination Scope Memorandum,'' dated January 29,
2016.
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For a summary of the product coverage comments and rebuttal
responses submitted to the record of this final determination, and
accompanying discussion and analysis of all comments timely received,
see the Final Scope Decision Memorandum.\9\ The Final Scope Decision
Memorandum is incorporated by, and hereby adopted by, this notice.
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\9\ See Memorandum to Christian Marsh, Deputy Assistant
Secretary for Antidumping and Countervailing Duty Operations,
``Scope Comments Decision Memorandum for the Final Determinations,''
dated concurrently with this notice.
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Analysis of Comments Received
All issues raised in the case and rebuttal briefs by parties in
this investigation are addressed in the Issues and Decision Memorandum
accompanying this notice, which is hereby adopted by this notice.\10\ A
list of the issues raised is attached to this notice as Appendix II.
The Issues and Decision Memorandum is a public document and is on file
electronically via Enforcement and Compliance's Antidumping and
Countervailing Duty Centralized Electronic Service System (``ACCESS'').
ACCESS is available to registered users at https://access.trade.gov and
it is available to all parties in the Central Records Unit, Room B-8024
of the main Department of Commerce building. In addition, a complete
version of the Issues and Decision Memorandum can be accessed directly
at http://enforcement.trade.gov/frn/index.html. The signed and
electronic versions of the Issues and
[[Page 35321]]
Decision Memorandum are identical in content.
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\10\ See Memorandum to Paul Piquado, Assistant Secretary for
Enforcement and Compliance, from Christian Marsh, Deputy Assistant
Secretary for Antidumping and Countervailing Duty Operations
``Issues and Decision Memorandum for the Final Determination of the
Antidumping Duty Investigation of Certain Corrosion-Resistant Steel
Products from Italy'' (May 24, 2016) (``Issues and Decision
Memorandum'').
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Verification
As provided in section 782(i) of the Act, between January and March
2016, the Department verified the sales and cost data reported by
Arvedi and Marcegaglia. We used standard verification procedures,
including an examination of relevant accounting and production records,
and original source documents provided by Arvedi and Marcegaglia.\11\
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\11\ See Memorandum to the File, through Paul Walker, Program
Manager, Office V, from Julia Hancock and Susan Pulongbarit, Senior
International Trade Analysts, and Omar Qureshi, International Trade
Analyst, ``Verification of Home Market Sales of Arvedi in the
Antidumping Duty Investigation of Certain Corrosion-Resistant Steel
Products from Italy,'' (March 29, 2016); Memorandum to the File,
through Paul Walker, Program Manager, Office V, from Susan
Pulongbarit and Julia Hancock, Senior International Trade Analysts,
and Omar Qureshi, International Trade Analyst, ``Verification of
Home Market Sales of Marcegaglia in the Antidumping Duty
Investigation of Certain Corrosion-Resistant Steel Products from
Italy,'' (April 8, 2016); Memorandum to the File, through Paul
Walker, Program Manager, Office V, from Susan Pulongbarit and Julia
Hancock, Senior International Trade Analysts, ``Verification of U.S.
Sales of Marcegaglia in the Antidumping Duty Investigation of
Certain Corrosion-Resistant Steel Products from Italy,'' (April 7,
2016); Memorandum to the File, through Neal Halper, Director, Office
of Accounting, from Christopher Zimpo and James Balog, Accountants,
'' Verification of the Cost of Production and Constructed Value Data
Submitted by Arvedi in the Antidumping Duty Investigation of Certain
Corrosion-Resistant Steel Products from Italy'' (April 7, 2016);
Memorandum to the File, through Neal Halper, Director, Office of
Accounting, from James Balog, Accountant, ``Verification of the Cost
of Production and Constructed Value Data Submitted by Marcegaglia in
the Antidumping Duty Investigation of Certain Corrosion-Resistant
Steel Products from Italy'' (April 12, 2016); Memorandum to the
File, through Neal Halper, Director, Office of Accounting, from
James Balog, Accountant, ``Verification of the Cost of Production
and Constructed Value Data Submitted by Marcegaglia in the
Antidumping Duty Investigation of Certain Corrosion-Resistant Steel
Products from Italy'' (April 12, 2016) ; Memorandum to the File,
through Neal Halper, Director, Office of Accounting, from James
Balog, Accountant, ``Verification of the Further Manufacturing Data
Submitted by Marcegaglia in the Antidumping Duty Investigation of
Certain Corrosion-Resistant Steel Products from Italy'' (April 12,
2016).
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Changes Since the Preliminary Determination and Use of Adverse Facts
Available
Based on our analysis of the comments received and our findings at
verification, we revised the margin for Marcegaglia to reflect the
application of facts available with an adverse inference, pursuant to
sections 776(a)(2)(A)-(D) and 776(b) of the the Act. Additionally, we
made certain changes to the margin calculation for Arvedi and applied
partial facts available with an adverse inference to Arvedi for its
non-prime sales in the home market and affiliated prime sales in the
home market, pursuant to sections 776(a)(2)(A)-(D) and 776(b) of the
Act. We have also revised the all-others rate. For a discussion of
these changes, see the ``Margin Calculations'' section and Comments 1-
11 of the Issues and Decision Memorandum.
All-Others Rate
Section 735(c)(5)(A) of the Act provides that the estimated ``all-
others'' rate shall be an amount equal to the weighted average of the
estimated weighted-average dumping margins established for exporters
and producers individually investigated, excluding any zero or de
minimis margins, and any margins determined entirely under section 776
of the Act. Because Arvedi is the only respondent in this investigation
for which the Department calculated a company-specific rate which is
not zero, de minimis or based entirely on facts available, pursuant to
section 735(c)(5)(A) of the Act, we are using the weighted-average
dumping margin calculated for Arvedi as the estimated weighted-average
dumping margin assigned to all other producers and exporters of the
merchandise under consideration.\12\
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\12\ With two respondents, we would normally calculate (A) a
weighted-average of the dumping margins calculated for the mandatory
respondents; (B) a simple average of the dumping margins calculated
for the mandatory respondents; and (C) a weighted-average of the
dumping margins calculated for the mandatory respondents using each
company's publicly-ranged values for the merchandise under
consideration. We would compare (B) and (C) to (A) and select the
rate closest to (A) as the most appropriate rate for all other
companies. See Ball Bearings and Parts Thereof From France, Germany,
Italy, Japan, and the United Kingdom: Final Results of Antidumping
Duty Administrative Reviews, Final Results of Changed-Circumstances
Review, and Revocation of an Order in Part, 75 FR 53661, 53663
(September 1, 2010).
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Final Determination
The Department determines that the final weighted-average dumping
margins are as follows:
------------------------------------------------------------------------
Weighted-
average
Exporter/producer margin
(percent)
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Acciaieria Arvedi S.p.A..................................... 12.63
Marcegaglia S.p.A........................................... 92.12
All-Others.................................................. 12.63
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Disclosure
We will disclose the calculations performed to interested parties
within five days of the public announcement of this final determination
in accordance with 19 CFR 351.224(b).
Final Affirmative Determination of Critical Circumstances, in Part
On November 5, 2015, the Department issued its preliminary critical
circumstances determination. Pursuant to this determination, the
Department determined that critical circumstances did not exist for
imports of subject merchandise from Arvedi, Marcegaglia, and ``all-
others.'' \13\ Based on Arvedi's and Marcegaglia's final dumping
margins, and further analysis following the Preliminary Determinations
of Critical Circumstances, we are modifying our findings for the final
determination and finding critical circumstances exist for Marcegaglia.
For a complete discussion of this issue, see the ``Affirmative Finding
of Critical Circumstances, In Part'' section of the Issues and Decision
Memorandum.
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\13\ See Antidumping and Countervailing Duty Investigations of
Corrosion-Resistant Steel Products from India, Italy, the People's
Republic of China, the Republic of Korea, and Taiwan: Preliminary
Determinations of Critical Circumstances, 80 FR 68504 (November 5,
2015) (``Preliminary Determinations of Critical Circumstances'').
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Suspension of Liquidation
In accordance with section 735(c)(1)(B) of the Act, the Department
will instruct U.S. Customs and Border Protection (``CBP'') to continue
to suspend liquidation of all appropriate entries of corrosion-
resistant steel from Italy, as described in Appendix I of this notice,
which were entered, or withdrawn from warehouse, for consumption on or
after January 8, 2016, the date of publication of the Preliminary
Determination of this investigation in the Federal Register. However,
because prior to this final determination provisional measures were not
in effect for Marcegaglia, the Department reached a negative critical
circumstances determination at the Preliminary Determination, and has
reached an affirmative critical circumstances determination with
respect to Marcegaglia for this final determination, pursuant to
section 735(c)(4)(C) of the Act, the Department will instruct CBP to
suspend liquidation of all entries of corrosion-resistant steel from
Italy from Marcegaglia which were entered, or withdrawn from warehouse,
for consumption on or after 90-days prior to the date of publication of
this final determination in the Federal Register, and require a cash
deposit for such entries as noted above.
Further, CBP shall require a cash deposit equal to the estimated
amount by which the normal value exceeds the U.S. price, as follows:
(1) The rate for the mandatory respondents listed above will be the
respondent-specific
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weighted-average dumping margin determined in this final determination;
(2) if the exporter is not a firm identified in this investigation, but
the producer is, the rate will be the rate established for the producer
of the subject merchandise; and (3) the rate for all other producers or
exporters will be 12.63 percent. The instructions suspending
liquidation will remain in effect until further notice.
Pursuant to section 735(c)(1)(B)(ii) of the Act and 19 CFR
351.210(d), the Department will instruct CBP to require a cash deposit
equal to the weighted-average amount by which the NV exceeds U.S. price
as indicated in the chart above,\14\ adjusted where appropriate for
export subsidies.\15\ The Department has determined in its companion
countervailing duty investigation of corrosion-resistant steel from
Italy that subject merchandise exported by Arvedi and Marcegaglia did
not benefit from export subsidies.\16\ As a result, the Department will
make no adjustment to Arvedi's or Marcegaglia's cash deposit rates. The
rate for all other producers or exporters when adjusted for export
subsidies is 12.48 percent.
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\14\ See Modification of Regulations Regarding the Practice of
Accepting Bonds During the Provisional Measures Period in
Antidumping and Countervailing Duty Investigations, 76 FR 61042
(October 3, 2011).
\15\ See section 772(c)(1)(C) of the Act. Unlike in
administrative reviews, the Department calculates the adjustment for
export subsidies in investigations not in the margin calculation
program, but in the cash deposit instructions issued to CBP. See
Notice of Final Determination of Sales at Less Than Fair Value, and
Negative Determination of Critical Circumstances: Certain Lined
Paper Products from India, 71 FR 45012 (August 8, 2006), and
accompanying Issues and Decision Memorandum at Comment 1.
\16\ See Countervailing Duty Investigation of Certain Corrosion-
Resistant Steel Products from Italy: Final Affirmative
Determination, dated concurrently with this notice.
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ITC Notification
In accordance with section 735(d) of the Act, we will notify the
ITC of the final affirmative determination of sales at LTFV. Because
the final determination in this proceeding is affirmative, in
accordance with section 735(b)(2) of the Act, the ITC will make its
final determination as to whether the domestic industry in the United
States is materially injured, or threatened with material injury, by
reason of imports of corrosion-resistant steel from Italy no later than
45 days after our final determination. If the ITC determines that
material injury or threat of material injury does not exist, the
proceeding will be terminated and all cash deposits will be refunded.
If the ITC determines that such injury does exist, the Department will
issue an antidumping duty order directing CBP to assess, upon further
instruction by the Department, antidumping duties on all imports of the
subject merchandise entered, or withdrawn from warehouse, for
consumption on or after the effective date of the suspension of
liquidation.
Notification Regarding Administrative Protective Orders (``APO'')
This notice serves as a reminder to parties subject to APO of their
responsibility concerning the disposition of proprietary information
disclosed under APO in accordance with 19 CFR 351.305(a)(3). Timely
notification of the return or 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 violation
subject to sanction.
This determination and this notice are issued and published
pursuant to sections 735(d) and 777(i)(1) of the Act.
Dated: May 24, 2016.
Paul Piquado,
Assistant Secretary for Enforcement and Compliance.
Appendix I--Scope of the Investigation
The products covered by this investigation are certain flat-
rolled steel products, either clad, plated, or coated with
corrosion-resistant metals such as zinc, aluminum, or zinc-,
aluminum-, nickel- or iron-based alloys, whether or not corrugated
or painted, varnished, laminated, or coated with plastics or other
non-metallic substances in addition to the metallic coating. The
products covered include coils that have a width of 12.7 mm or
greater, regardless of form of coil (e.g., in successively
superimposed layers, spirally oscillating, etc.). The products
covered also include products not in coils (e.g., in straight
lengths) of a thickness less than 4.75 mm and a width that is 12.7
mm or greater and that measures at least 10 times the thickness. The
products covered also include products not in coils (e.g., in
straight lengths) of a thickness of 4.75 mm or more and a width
exceeding 150 mm and measuring at least twice the thickness. The
products described above may be rectangular, square, circular, or
other shape and include products of either rectangular or non-
rectangular cross-section where such cross-section is achieved
subsequent to the rolling process, i.e., products which have been
``worked after rolling'' (e.g., products which have been beveled or
rounded at the edges). For purposes of the width and thickness
requirements referenced above:
(1) Where the nominal and actual measurements vary, a product is
within the scope if application of either the nominal or actual
measurement would place it within the scope based on the definitions
set forth above, and
(2) where the width and thickness vary for a specific product
(e.g., the thickness of certain products with non-rectangular cross-
section, the width of certain products with non-rectangular shape,
etc.), the measurement at its greatest width or thickness applies.
Steel products included in the scope of this investigation are
products in which: (1) Iron predominates, by weight, over each of
the other contained elements; (2) the carbon content is 2 percent or
less, by weight; and (3) none of the elements listed below exceeds
the quantity, by weight, respectively indicated:
2.50 percent of manganese, or
3.30 percent of silicon, or
1.50 percent of copper, or
1.50 percent of aluminum, or
1.25 percent of chromium, or
0.30 percent of cobalt, or
0.40 percent of lead, or
2.00 percent of nickel, or
0.30 percent of tungsten (also called wolfram), or
0.80 percent of molybdenum, or
0.10 percent of niobium (also called columbium), or
0.30 percent of vanadium, or
0.30 percent of zirconium
Unless specifically excluded, products are included in this
scope regardless of levels of boron and titanium.
For example, specifically included in this scope are vacuum
degassed, fully stabilized (commonly referred to as interstitial-
free (``IF'')) steels and high strength low alloy (``HSLA'') steels.
IF steels are recognized as low carbon steels with micro-alloying
levels of elements such as titanium and/or niobium added to
stabilize carbon and nitrogen elements. HSLA steels are recognized
as steels with micro-alloying levels of elements such as chromium,
copper, niobium, titanium, vanadium, and molybdenum.
Furthermore, this scope also includes Advanced High Strength
Steels (``AHSS'') and Ultra High Strength Steels (``UHSS''), both of
which are considered high tensile strength and high elongation
steels.
Subject merchandise also includes corrosion-resistant steel that
has been further processed in a third country, including but not
limited to annealing, tempering, painting, varnishing, trimming,
cutting, punching and/or slitting or any other processing that would
not otherwise remove the merchandise from the scope of the
investigation if performed in the country of manufacture of the in-
scope corrosion resistant steel.
All products that meet the written physical description, and in
which the chemistry quantities do not exceed any one of the noted
element levels listed above, are within the scope of this
investigation unless specifically excluded. The following products
are outside of and/or specifically excluded from the scope of this
investigation:
Flat-rolled steel products either plated or coated with
tin, lead, chromium, chromium oxides, both tin and lead (``terne
plate''), or both chromium and chromium oxides (``tin free steel''),
whether or not painted, varnished or coated with plastics or other
non-metallic substances in addition to the metallic coating;
Clad products in straight lengths of 4.7625 mm or more
in composite thickness
[[Page 35323]]
and of a width which exceeds 150 mm and measures at least twice the
thickness; and
Certain clad stainless flat-rolled products, which are
three-layered corrosion-resistant flat-rolled steel products less
than 4.75 mm in composite thickness that consist of a flat-rolled
steel product clad on both sides with stainless steel in a 20%-60%-
20% ratio.
The products subject to the investigation are currently
classified in the Harmonized Tariff Schedule of the United States
(``HTSUS'') under item numbers: 7210.30.0030, 7210.30.0060,
7210.41.0000, 7210.49.0030, 7210.49.0091, 7210.49.0095,
7210.61.0000, 7210.69.0000, 7210.70.6030, 7210.70.6060,
7210.70.6090, 7210.90.6000, 7210.90.9000, 7212.20.0000,
7212.30.1030, 7212.30.1090, 7212.30.3000, 7212.30.5000,
7212.40.1000, 7212.40.5000, 7212.50.0000, and 7212.60.0000.
The products subject to the investigation may also enter under
the following HTSUS item numbers: 7210.90.1000, 7215.90.1000,
7215.90.3000, 7215.90.5000, 7217.20.1500, 7217.30.1530,
7217.30.1560, 7217.90.1000, 7217.90.5030, 7217.90.5060,
7217.90.5090, 7225.91.0000, 7225.92.0000, 7225.99.0090,
7226.99.0110, 7226.99.0130, 7226.99.0180, 7228.60.6000,
7228.60.8000, and 7229.90.1000.
The HTSUS subheadings above are provided for convenience and
customs purposes only. The written description of the scope of the
investigation is dispositive.
Appendix II--List of Topics Discussed in the Issues and Decision
Memorandum
I. Summary
II. Background
III. Period of Investigation
IV. Changes Since the Preliminary Determination
V. Application of Total Adverse Facts Available With Regard to
Marcegaglia
VI. Selection of AFA Rate and Corroboration
VII. Affirmative Finding of Critical Circumstances, In Part
VIII. List of Comments
IX. Discussion of Comments
Comment 1: Application of Total Adverse Facts Available (``AFA'') to
Marcegaglia
A. Misclassified Export Price (``EP'') Sales
Comment 2: Corporate Name Change of Marcegaglia
Comment 3: Application of Adverse Facts Available (``AFA'') to
Arvedi's Non-Prime Sales
Comment 4: Application of AFA to Arvedi's Packing Revenue
Comment 5: Treatment of Arvedi's Cost of Manufacturing (``COM'')
A. Other Operating Costs
B. Net Extraordinary Charges
C. Bad Debt Expenses
D. Offset of Electricity Sales to COM
E. Adjust Variable Manufacturing Cost Based on Sales Quantities
F. Disallow Insurance Claim as ``Indirect Damages'' As An Offset
to Fixed Overhead Costs
Comment 6: Programming Errors in Arvedi's Margin Program
A. Net U.S. Price Variable
B. Marine Insurance
Comment 7: Revised U.S. Sales Data for Arvedi
Comment 8: Adjustments to Arvedi's Cost Data Based on Verification
[FR Doc. 2016-12969 Filed 6-1-16; 8:45 am]
BILLING CODE 3510-DS-P