[Federal Register Volume 81, Number 156 (Friday, August 12, 2016)]
[Notices]
[Pages 53424-53428]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-19381]


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DEPARTMENT OF COMMERCE

International Trade Administration

[A-351-845]


Certain Hot-Rolled Steel Flat Products From Brazil: 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 hot-rolled steel flat products (hot-rolled steel) from Brazil 
are being, or are likely to be, sold in the United States at less than 
fair value (LTFV). The period of investigation (POI) is July 1, 2014, 
through June 30, 2015. The final dumping margins of sales at LTFV are 
listed below in the ``Final Determination'' section of this notice.

DATES: Effective August 12, 2016.

FOR FURTHER INFORMATION CONTACT: Peter Zukowski, AD/CVD Operations, 
Office I, Enforcement and Compliance, International Trade 
Administration, U.S. Department of Commerce, 1401 Constitution Avenue 
NW., Washington, DC 20230; telephone: (202) 482-0189.

[[Page 53425]]


SUPPLEMENTARY INFORMATION:

Background

    On March 22, 2016, the Department published the Preliminary 
Determination of this antidumping duty (AD) investigation.\1\ The 
following events occurred since the Preliminary Determination was 
issued. In March 2016, the Department received supplemental cost 
responses and revised sales and cost files from Companhia Siderurgica 
Nacional (CSN), a mandatory respondent in this investigation. In June 
2016, SSAB Enterprises, LLC, and Steel Dynamics, Inc.,\2\ and CSN 
submitted case briefs \3\ and rebuttal briefs.\4\
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    \1\ See Certain Hot-Rolled Steel Flat Products From Brazil: 
Affirmative Preliminary Determination of Sales at Less Than Fair 
Value, Postponement of Final Determination and Extension of 
Provisional Measures, 81 FR 15235 (March 22, 2016) (Preliminary 
Determination).
    \2\ The petitioners in this case are AK Steel Corporation (AK 
Steel), ArcelorMittal USA LLC, Nucor Corporation, SSAB Enterprises, 
LLC, Steel Dynamics, Inc., and United States Steel Corporation 
(collectively, the petitioners). SSAB Enterprises, LLC and Steel 
Dynamics, Inc., submitted case and rebuttal briefs on behalf of all 
of the petitioners.
    \3\ See Letter from SSAB Enterprises, LLC, and Steel Dynamics, 
Inc., ``Certain Hot-Rolled Steel Flat Products From Brazil: 
Petitioners' Case Brief'' (June 17, 2016); Letter from CSN, 
``Certain Cold-Rolled Steel Flat Products from Brazil and Certain 
Hot-Rolled Steel Flat Products from Brazil: CSN's Case Brief'' (June 
17, 2016).
    \4\ See Letter from SSAB Enterprises, LLC, and Steel Dynamics, 
Inc., ``Certain Hot-Rolled Steel Flat Products From Brazil: 
Petitioners' Rebuttal Brief'' (June 22, 2016); Letter from CSN, 
``Certain Hot-Rolled Steel Flat Products from Brazil: CSN's Rebuttal 
Brief'' (June 22, 2016).
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Scope of the Investigation

    The products covered by this investigation are certain hot-rolled 
steel flat products from Brazil. For a complete description of the 
scope of this investigation, see the ``Scope of the Investigation,'' in 
Appendix I of this notice.

Scope Comments

    In accordance with the Preliminary Scope Determination,\5\ the 
Department set aside a period of time for parties to address scope 
issues in case briefs or other written comments on scope issues. No 
interested parties submitted scope comments in case or rebuttal briefs; 
therefore, the scope of this investigation remains unchanged for this 
final determination.
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    \5\ See Memorandum to Christian Marsh, Deputy Assistant 
Secretary for Antidumping and Countervailing Duty Operations, 
``Certain Hot-Rolled Steel Products From Australia, Brazil, Japan, 
the Netherlands, the Republic of Korea, Turkey, and the United 
Kingdom: Scope Comments Decision Memorandum for the Preliminary 
Determinations'' dated March 14, 2016 (Preliminary Scope Decision 
Memorandum).
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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, 
which is hereby adopted by this notice.\6\ 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 Decision Memorandum are identical in 
content.
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    \6\ See Memorandum to Ronald K. Lorentzen, Acting 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 Hot-
Rolled Steel Flat Products from Brazil'' (August 4, 2016) (Issues 
and Decision Memorandum).
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Verification

    As provided in section 782(i) of the Tariff Act of 1930, as amended 
(the Act), in April and May 2016, the Department verified the sales and 
cost data reported by CSN, pursuant to section 782(i) of the Act. We 
used standard verification procedures, including an examination of 
relevant accounting and production records, and original source 
documents provided by the respondent.\7\
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    \7\ See Memoranda to the File: ``Certain Hot-Rolled Steel Flat 
Products from Brazil: Sales Verification Report for Companhia 
Siderugica Nacional,'' dated May 20, 2016; ``Certain Hot-Rolled 
Steel Flat Products from Brazil: Sales Verification Report for 
Companhia Siderugica Nacional LLC USA,'' dated June 2, 2016; 
``Verification of the Further Manufacturing Response of Companhia 
Siderugica Nacional S.A. in the Antidumping Duty Investigation of 
Hot-Rolled Steel Flat Products from Brazil,'' dated June 3, 2016; 
and, ``Verification of the Cost of Production Response of Companhia 
Siderugica Nacional S.A. in the Antidumping Duty Investigation of 
Certain Hot-Rolled Steel Flat Products from Brazil,'' dated June 8, 
2016.
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Use of Adverse Facts Available

    The Department found in the Preliminary Determination that Usiminas 
Siderurgicas de Minas Gerais S.A. (Usiminas) withheld requested 
information, significantly impeded the proceeding, and did not 
cooperate to the best of its ability in responding to the Department's 
requests for information.\8\ Therefore, in accordance with sections 
776(a)(2)(A) and (C) of the Act, 776(b) of the Act, and 19 CFR 
351.308(a), the Department preliminarily determined the weighted-
average dumping margin for Usiminas based on facts otherwise available 
with an adverse inference and preliminarily selected 34.28 percent as 
the adverse facts-available dumping margin for Usiminas, which is the 
highest margin alleged in the petition.\9\ This rate was assigned to 
Usiminas because Usiminas failed to respond to sections B, C, and D of 
the Department's questionnaire in this investigation.\10\
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    \8\ See Preliminary Determination.
    \9\ Id. See also Memorandum to the File entitled, ``Certain Hot-
Rolled Steel Flat Products from Brazil: Corroboration of a Rate 
Based on Adverse Facts Available,'' dated March 14, 2016.
    \10\ Id.
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    The Department received no comments regarding its preliminary 
application of the adverse facts-available dumping margin to Usiminas. 
For the final determination, the Department has not altered its 
analysis or its decision to apply the adverse facts-available dumping 
margin to Usiminas.

Changes Since the Preliminary Determination

    Based on CSN's supplemental cost responses and revised sales and 
cost files, our findings at verification and our analysis of the 
comments received, we made certain changes to the margin calculations 
for CSN. For a discussion of these changes, see the ``Margin 
Calculations'' and ``Comparisons to Fair Value'' sections of the Issues 
and Decision Memorandum. We have also revised the all-others rate.

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 and de 
minimis margins, and any margins determined entirely under section 776 
of the Act. For purposes of this final determination, we are assigning 
33.14 percent as the ``all-others'' rate, which is based on the 
estimated dumping margin calculated for CSN, the only mandatory 
respondent for which we calculated a dumping margin.\11\
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    \11\ See Memorandum to the File, ``Antidumping Duty 
Investigation of Certain Hot-Rolled Steel Flat Products from Brazil: 
Calculation of All-Others Rate'' (All-Others Rate Memorandum), dated 
August 4, 2016.

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[[Page 53426]]

Final Determination

    The Department determines that the final weighted-average dumping 
margins are as follows:

------------------------------------------------------------------------
                                             Weighted-
            Exporter/Producer             average margin   Cash deposit
                                             (percent)    rate (percent)
------------------------------------------------------------------------
Companhia Siderurgica Nacional..........           33.14           29.07
Usiminas Siderurgicas de Minas Gerais              34.28           30.51
 S.A. (Usiminas)........................
All-Others..............................           33.14           29.07
------------------------------------------------------------------------

Disclosure

    We intend to 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 December 9, 2015, the Department found that critical 
circumstances existed for merchandise exported by CSN and Usiminas, but 
not for ``all others.'' \12\ Based on the final sales data submitted by 
CSN and further analysis following the Preliminary Determination of 
Critical Circumstances, we are modifying our findings for the final 
determination, in part. For the final determination with respect to 
CSN, our analysis of the reported monthly shipment data demonstrates 
that shipments of hot-rolled steel by CSN during the comparison period 
increased by less than 15 percent over shipments during the base 
period, and thus, we find that critical circumstances do not exist for 
CSN. As discussed in the ``Use of Adverse Facts Available'' section 
above, Usiminas did not cooperate with this investigation. Thus, we 
based our critical circumstances determination with respect to Usiminas 
on AFA and find that critical circumstances exist with respect to it. 
For all others, we determined that the imports during the comparison 
period increased less than 15 percent over imports during the base 
period and, accordingly, that critical circumstances do not exist with 
respect to all other producers and exporters of hot-rolled steel from 
Brazil. For a complete discussion of this issue, see the ``Final 
Determination of Critical Circumstances'' section of the Issues and 
Decision Memorandum.
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    \12\ See ``Antidumping Duty Investigations of Certain Hot-Rolled 
Steel Flat Products From Australia, Brazil, Japan, and the 
Netherlands and Countervailing Duty Investigation of Certain Hot-
Rolled Steel Flat Products From Brazil: Preliminary Determinations 
of Critical Circumstances'', 80 FR 76444 (December 9, 2015) 
(Preliminary Determination of Critical Circumstances).
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Continuation of 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 hot-rolled steel from 
Brazil, as described in Appendix I of this notice, which were entered, 
or withdrawn from warehouse, for consumption on or after March 22, 
2016, the date of publication of the Preliminary Determination of this 
investigation in the Federal Register. Because of our affirmative 
determination of critical circumstances for Usiminas, in accordance 
with section 735(a)(3) and (c)(4)(C) of the Act, suspension of 
liquidation of hot-rolled steel from Brazil, shall continue to apply, 
for Usiminas, to unliquidated entries of merchandise entered, or 
withdrawn from warehouse, for consumption on or after the date which is 
90 days before the publication of the Preliminary Determination. 
Because we find in this final determination that critical circumstances 
do not exist for CSN and for exporters not individually examined and 
subject to the all-others rate, consistent with section 735(c)(3) of 
the Act, we will instruct CBP to terminate the suspension of 
liquidation of entries, and to liquidate without regard to antidumping 
duties, entries of hot-rolled steel exported by CSN and all other 
companies, and entered, or withdrawn from warehouse for consumption on 
or after December 23, 2015, and before March 22, 2016.
    Further, the Department will instruct CBP to require a cash deposit 
equal to the estimated amount by which the normal value exceeds the 
U.S. price as shown above, adjusted where appropriate for export 
subsidies found in the final determination of the companion 
countervailing duty investigation. Consistent with our longstanding 
practice, where the product under investigation is also subject to a 
concurrent countervailing duty investigation, we instruct CBP to 
require a cash deposit equal to the amount by which the NV exceeds the 
U.S. price, less the amount of the countervailing duty determined to 
constitute any export subsidies.\13\ Therefore, in the event that a 
countervailing duty order is issued and suspension of liquidation is 
resumed in the companion countervailing duty investigation on hot-
rolled steel flat products from Brazil the Department will instruct CBP 
to require cash deposits adjusted by the amount of export subsidies, as 
appropriate. These adjustments are reflected in the final column of the 
rate chart, above.\14\ Until such suspension of liquidation is resumed 
in the companion countervailing duty investigation, and so long as 
suspension of liquidation continues under this antidumping duty 
investigation, the cash deposit rates for this antidumping duty 
investigation will be the rates identified in the weighted-average 
margin column in the rate chart, above.
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    \13\ See, e.g., Welded Line Pipe From the Republic of Turkey: 
Final Determination of Sales at Less Than Fair Value, 80 FR 61362 
(October 13, 2015) and Notice of Final Determination of Sales at 
Less Than Fair Value and Negative Critical Circumstances 
Determination: Bottom Mount Combination Refrigerator-Freezers From 
the Republic of Korea, 77 FR 17413 (March 26, 2012).
    \14\ See Countervailing Duty Investigation of Certain Hot-Rolled 
Steel Flat Products from Brazil: Final Affirmative Determination, 
and Final Determination of Critical Circumstances, in Part, dated 
August 4, 2016; see also the All-Others Rate Memorandum dated 
concurrently with this notice.
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International Trade Commission Notification

    In accordance with section 735(d) of the Act, we will notify the 
International Trade Commission (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

[[Page 53427]]

material injury, by reason of imports of hot-rolled steel from Brazil 
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

    This notice serves as a reminder to parties subject to an 
Administrative Protective Order (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: August 4, 2016.
Ronald K. Lorentzen,
Acting Assistant Secretary for Enforcement and Compliance.

Appendix I--Scope of the Investigation

    The products covered by this investigation are certain hot-
rolled, flat-rolled steel products, with or without patterns in 
relief, and whether or not annealed, painted, varnished, or coated 
with plastics or other non-metallic substances. The products covered 
do not include those that are clad, plated, or coated with metal. 
The products covered include coils that have a width or other 
lateral measurement (``width'') of 12.7 mm or greater, regardless of 
thickness, and 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 of 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 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 achieve 
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 unless the resulting measurement makes the product 
covered by the existing antidumping \15\ or countervailing duty \16\ 
orders on Certain Cut-To-Length Carbon-Quality Steel Plate Products 
From the Republic of Korea (A-580-836; C-580-837), and
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    \15\ Notice of Amendment of Final Determinations of Sales at 
Less Than Fair Value and Antidumping Duty Orders: Certain Cut-To-
Length Carbon-Quality Steel Plate Products From France, India, 
Indonesia, Italy, Japan and the Republic of Korea, 65 FR 6585 
(February 10, 2000).
    \16\ Notice of Amended Final Determinations: Certain Cut-to-
Length Carbon-Quality Steel Plate From India and the Republic of 
Korea; and Notice of Countervailing Duty Orders: Certain Cut-To-
Length Carbon-Quality Steel Plate From France, India, Indonesia, 
Italy, and the Republic of Korea, 65 FR 6587 (February 10, 2000).
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    (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, or
     0.80 percent of molybdenum, or
     0.10 percent of niobium, 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, high strength low alloy (HSLA) steels, the 
substrate for motor lamination steels, Advanced High Strength Steels 
(AHSS), and Ultra High Strength Steels (UHSS). 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. The substrate for motor 
lamination steels contains micro-alloying levels of elements such as 
silicon and aluminum. AHSS and UHSS are considered high tensile 
strength and high elongation steels, although AHSS and UHSS are 
covered whether or not they are high tensile strength or high 
elongation steels.
    Subject merchandise includes hot-rolled steel that has been 
further processed in a third country, including but not limited to 
pickling, oiling, levelling, annealing, tempering, temper rolling, 
skin passing, 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 hot-rolled 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:
     Universal mill plates (i.e., hot-rolled, flat-rolled 
products not in coils that have been rolled on four faces or in a 
closed box pass, of a width exceeding 150 mm but not exceeding 1250 
mm, of a thickness not less than 4.0 mm, and without patterns in 
relief);
     Products that have been cold-rolled (cold-reduced) 
after hot-rolling; \17\
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    \17\ For purposes of this scope exclusion, rolling operations 
such as a skin pass, levelling, temper rolling or other minor 
rolling operations after the hot-rolling process for purposes of 
surface finish, flatness, shape control, or gauge control do not 
constitute cold-rolling sufficient to meet this exclusion.
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     Ball bearing steels; \18\
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    \18\ Ball bearing steels are defined as steels which contain, in 
addition to iron, each of the following elements by weight in the 
amount specified: (i) Not less than 0.95 nor more than 1.13 percent 
of carbon; (ii) not less than 0.22 nor more than 0.48 percent of 
manganese; (iii) none, or not more than 0.03 percent of sulfur; (iv) 
none, or not more than 0.03 percent of phosphorus; (v) not less than 
0.18 nor more than 0.37 percent of silicon; (vi) not less than 1.25 
nor more than 1.65 percent of chromium; (vii) none, or not more than 
0.28 percent of nickel; (viii) none, or not more than 0.38 percent 
of copper; and (ix) none, or not more than 0.09 percent of 
molybdenum.
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     Tool steels; \19\ and
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    \19\ Tool steels are defined as steels which contain the 
following combinations of elements in the quantity by weight 
respectively indicated: (i) More than 1.2 percent carbon and more 
than 10.5 percent chromium; or (ii) not less than 0.3 percent carbon 
and 1.25 percent or more but less than 10.5 percent chromium; or 
(iii) not less than 0.85 percent carbon and 1 percent to 1.8 
percent, inclusive, manganese; or (iv) 0.9 percent to 1.2 percent, 
inclusive, chromium and 0.9 percent to 1.4 percent, inclusive, 
molybdenum; or (v) not less than 0.5 percent carbon and not less 
than 3.5 percent molybdenum; or (vi) not less than 0.5 percent 
carbon and not less than 5.5 percent tungsten.
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     Silico-manganese steels; \20\
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    \20\ Silico-manganese steel is defined as steels containing by 
weight: (i) Not more than 0.7 percent of carbon; (ii) 0.5 percent or 
more but not more than 1.9 percent of manganese, and (iii) 0.6 
percent or more but not more than 2.3 percent of silicon.
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    The products subject to this investigation are currently 
classified in the Harmonized Tariff Schedule of the United States 
(HTSUS) under item numbers: 7208.10.1500, 7208.10.3000, 
7208.10.6000, 7208.25.3000, 7208.25.6000, 7208.26.0030, 
7208.26.0060, 7208.27.0030, 7208.27.0060, 7208.36.0030, 
7208.36.0060, 7208.37.0030, 7208.37.0060, 7208.38.0015, 
7208.38.0030, 7208.38.0090,

[[Page 53428]]

7208.39.0015, 7208.39.0030, 7208.39.0090, 7208.40.6030, 
7208.40.6060, 7208.53.0000, 7208.54.0000, 7208.90.0000, 
7210.70.3000, 7211.14.0030, 7211.14.0090, 7211.19.1500, 
7211.19.2000, 7211.19.3000, 7211.19.4500, 7211.19.6000, 
7211.19.7530, 7211.19.7560, 7211.19.7590, 7225.11.0000, 
7225.19.0000, 7225.30.3050, 7225.30.7000, 7225.40.7000, 
7225.99.0090, 7226.11.1000, 7226.11.9030, 7226.11.9060, 
7226.19.1000, 7226.19.9000, 7226.91.5000, 7226.91.7000, and 
7226.91.8000. The products subject to the investigation may also 
enter under the following HTSUS numbers: 7210.90.9000, 7211.90.0000, 
7212.40.1000, 7212.40.5000, 7212.50.0000, 7214.91.0015, 
7214.91.0060, 7214.91.0090, 7214.99.0060, 7214.99.0075, 
7214.99.0090, 7215.90.5000, 7226.99.0180, and 7228.60.6000.
    The HTSUS subheadings above are provided for convenience and 
U.S. 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. Scope of the Investigation
IV. Final Determination of Critical Circumstances
V. Margin Calculations
VI. Comparisons to Fair Value
VII. Discussion of Issues
    Comment 1: Duty Drawback
    Comment 2: Inventory Carrying Costs
    Comment 3: Credit Revenue
    Comment 4: Model Match
    Comment 5: Calculation of CSN LLC's G&A Expense Ratio
    Comment 6: Whether To Use a Consolidated or Non-Consolidated 
Financial Expense Ratio
    Comment 7: The Market Value for Affiliated Energy Inputs
    Comment 8: Whether To Include Certain Expenses Recorded Directly 
to Cost of Goods Sold (COGS)
VIII. Recommendation

[FR Doc. 2016-19381 Filed 8-11-16; 8:45 am]
 BILLING CODE 3510-DS-P