[Federal Register Volume 84, Number 247 (Thursday, December 26, 2019)]
[Notices]
[Pages 70948-70951]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-27814]


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DEPARTMENT OF COMMERCE

International Trade Administration

[A-580-878; C-580-879]


Certain Corrosion-Resistant Steel Products From the Republic of 
Korea: Affirmative Final Determinations of Anti-Circumvention Inquiries 
on the Antidumping Duty and Countervailing Duty Orders

AGENCY: Enforcement and Compliance, International Trade Administration, 
Department of Commerce.

SUMMARY: The Department Commerce (Commerce) determines that imports of 
certain corrosion-resistant steel products (CORE), produced in the 
Socialist Republic of Vietnam (Vietnam) using carbon hot-rolled steel 
(HRS) and/or cold-rolled steel flat products (CRS) manufactured in the 
Republic of Korea (Korea), are circumventing the antidumping duty (AD) 
and countervailing duty (CVD) orders on CORE from Korea.

DATES: Applicable December 26, 2019.

FOR FURTHER INFORMATION CONTACT: Chien-Min Yang, AD/CVD Operations, 
Office VII, Enforcement and Compliance, International Trade 
Administration, U.S. Department of Commerce, 1401 Constitution Avenue 
NW, Washington, DC 20230; telephone: (202) 482-5484.

SUPPLEMENTARY INFORMATION: 

Background

    On July 10, 2019, Commerce published the Preliminary Determinations 
\1\ of circumvention of the Korea CORE Orders.\2\ A summary of the 
events that occurred since Commerce published the Preliminary 
Determinations, as well as a full discussion of the issues raised by 
parties for these final determinations, may be found in the Issues and 
Decision Memorandum.\3\ The IDM 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 http://access.trade.gov, and 
it is available to all parties in the Central Records Unit, room B8024 
of the main Commerce building. In addition, a complete version of the 
IDM can be accessed directly at http://enforcement.trade.gov/frn/. The 
signed and electronic versions of the IDM are identical in content.
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    \1\ See Certain Corrosion-Resistant Steel Products from Republic 
of Korea: Affirmative Preliminary Determination of Anti-
Circumvention Inquiries on the Antidumping Duty and Countervailing 
Duty Orders, 84 FR 32871 (July 10, 2019) (Preliminary 
Determinations) and accompanying Preliminary Decision Memorandum.
    \2\ See Certain Corrosion-Resistant Steel Products from India, 
Italy, the People's Republic of China, the Republic of Korea and 
Taiwan: Amended Final Affirmative Antidumping Determination for 
India and Taiwan, and Antidumping Duty Orders, 81 FR 48390 (July 25, 
2016); and Certain Corrosion-Resistant Steel Products from India, 
Italy, Republic of Korea and the People's Republic of China: 
Countervailing Duty Order, 81 FR 48387 (July 25, 2016) 
(collectively, Korea CORE Orders).
    \3\ See Memorandum, ``Issues and Decision Memorandum for Anti-
Circumvention Inquiries on the Antidumping Duty and Countervailing 
Duty Orders on Certain Corrosion-Resistant Steel Products from the 
Republic of Korea,'' dated concurrently with, and hereby adopted by, 
this notice (IDM).
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Scope of the Orders

    The products covered by these orders 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. For a complete description of the 
scope of the orders, see the IDM.\4\
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    \4\ See IDM.
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Scope of the Anti-Circumvention Inquiries

    These anti-circumvention inquiries cover CORE produced in Vietnam 
from HRS or CRS substrate input manufactured in Korea and subsequently 
exported from Vietnam to the United States (merchandise under 
consideration). These final rulings apply to all shipments of 
merchandise under consideration on or after the date of initiation of 
these inquiries. Importers and exporters of CORE produced in Vietnam 
using: (1) HRS manufactured in Vietnam or third countries; (2) CRS 
manufactured in Vietnam using HRS produced in Vietnam or third 
countries; and/or (3) CRS manufactured in third countries, and who 
qualify to

[[Page 70949]]

participate in the certification process, must certify that the HRS or 
CRS processed into CORE in Vietnam did not originate in Korea, as 
provided for in the certifications attached to the Federal Register 
notice. Otherwise, their merchandise may be subject to antidumping and 
countervailing duties in these inquiries.

Methodology

    Commerce is conducting these anti-circumvention inquiries in 
accordance with section 781(b) of the Tariff Act of 1930, as amended 
(the Act).

Analysis of Comments Received

    All issues raised in the case and rebuttal briefs by parties in 
these inquiries are addressed in the Issues and Decision Memorandum. A 
list of the issues raised is attached to this notice as Appendix I.

Final Affirmative Determinations of Circumvention

    We determine that exports to the United States of CORE produced in 
Vietnam from HRS or CRS substrate manufactured in Korea are 
circumventing the Korea CORE Orders. We therefore find it appropriate 
to determine that this merchandise falls within the Korea CORE Orders, 
and to instruct U.S. Customs and Border Protection (CBP) to continue to 
suspend liquidation of any entries of CORE from Vietnam produced using 
HRS or CRS substrate manufactured in Korea.

Continuation of Suspension of Liquidation

    As stated above, Commerce has made affirmative determinations of 
circumvention of the Korea CORE Orders by exports to the United States 
of CORE produced in Vietnam using Korea-origin HRS or CRS substrate. 
This circumvention finding applies to CORE produced by any Vietnamese 
company using Korea-origin HRS or CRS substrate. In accordance with 19 
CFR 351.225(l)(3), Commerce will direct CBP to continue to suspend 
liquidation and to require a cash deposit of estimated duties on 
unliquidated entries of CORE produced in Vietnam using Korea-origin HRS 
or CRS substrate that were entered, or withdrawn from warehouse, for 
consumption on or after August 2, 2018, the date of initiation of these 
anti-circumvention inquiries.\5\
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    \5\ See Certain Corrosion-Resistant Steel Products from the 
Republic of Korea and Taiwan: Initiation of AntiCircumvention 
Inquiries on the Antidumping Duty and Countervailing Duty Orders, 83 
FR 37785 (August 2, 2018) (Initiation Notice).
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    The suspension of liquidation and cash deposit instructions will 
remain in effect until further notice. In order to prevent evasion, and 
because the AD and CVD rates established in China CORE Anti-
Circumvention Finals are higher than the rates established for CORE 
from Korea and Taiwan, and the rates established for CORE from Korea 
are higher than the AD rate established for CORE from Taiwan, Commerce 
will instruct CBP to suspend liquidation and collect cash deposits in 
the following manner. In the situation where no certification regarding 
the origin of the substrate is maintained for an entry, and AD/CVD 
orders from three countries (China, Korea, or Taiwan) potentially apply 
to that entry, Commerce will instruct CBP to suspend the entry and 
collect cash deposits at the AD rate established for the China-wide 
entity (199.43 percent) and the CVD rate established for the China all-
others rate (39.05 percent), pursuant to the China CORE Circumvention 
Finals.\6\ In the situation where a certification is maintained for the 
AD/CVD orders on CORE from China (stating that the merchandise was not 
produced from HRS and/or CRS from China), but no other certification is 
maintained, Commerce intends to instruct CBP to suspend the entry and 
collect cash deposits at the AD and CVD all-others rates (i.e., 8.31 
percent and 1.19 percent, respectively) applicable to the AD/CVD orders 
on CORE from Korea.\7\
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    \6\ See Certain Corrosion-Resistant Steel Products from India, 
Italy, the People's Republic of China, the Republic of Korea and 
Taiwan: Amended Final Affirmative Antidumping Determination for 
India and Taiwan, and Antidumping Duty Orders, 81 FR 48390 (July 25, 
2016); and Certain Corrosion-Resistant Steel Products from India, 
Italy, Republic of Korea and the People's Republic of China: 
Countervailing Duty Order, 81 FR 48387 (July 25, 2016) 
(collectively, China CORE Orders).
    \7\ See Certain Corrosion-Resistant Steel Flat Products from 
India, Italy, the People's Republic of China, the Republic of Korea, 
and Taiwan: Amended Final Affirmative Antidumping Duty 
Determination/or India and Taiwan, and Antidumping Duty Orders, 81 
FR 48390 (July 25, 2016). The ``all others rate'' was subsequently 
amended as the result of litigation. See Certain Corrosion-Resistant 
Steel Products from the Republic of Korea: Notice of Court Decision 
Not in Harmony with Final Determination of Investigation and Notice 
of Amended Final Results, 83 FR 39054 (August 8, 2018); see also 
Certain Corrosion-Resistant Steel Products from India, Italy, 
Republic of Korea, and the People's Republic of China: 
Countervailing Duty Order, 81 FR 48387 (July 25, 2016) 
(collectively, Korea CORE Orders).
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    CORE produced in Vietnam from HRS or CRS substrate that is not of 
Korean origin is not subject to these inquiries. Therefore, cash 
deposits are not required for such merchandise. However, CORE produced 
in Vietnam from HRS and/or CRS from China is subject to the AD/CVD 
orders on CORE from China, and CORE produced in Vietnam from HRS and/or 
CRS from Taiwan is subject to the AD order on CORE from Taiwan. If an 
importer imports CORE from Vietnam and claims that the CORE was 
produced from non-Korean HRS or CRS substrate, in order not to be 
subject to cash deposit requirements, the importer and exporter are 
required to meet the certification and documentation requirements 
described in Appendix II. Exporters of CORE produced in Vietnam from 
non-Korea-origin HRS or CRS substrate must prepare and maintain an 
Exporter Certification and documentation supporting the Exporter 
Certification (see Appendix IV). In addition, importers of such CORE 
must prepare and maintain an Importer Certification (see Appendix III) 
as well as documentation supporting the Importer Certification. In 
addition to the Importer Certification, the importer must also maintain 
a copy of the Exporter Certification (see Appendix IV) and relevant 
supporting documentation from its exporter of CORE produced from non-
Korea-origin HRS or CRS substrate.
    For these final determinations, we determine that the following 
companies are not eligible for the certification process: 190 Steel 
Pipe Co., Ltd.; Chinh Dai Steel Limited; Dai Thien Loc Corporation; 
Formosa Ha Tinh Corporation; Hoa Phat Steel Pipe Co.; Hoa Sen Group; 
Perstima Viet Nam; Prima Commodities Co.; Thai Nguyen Iron and Steel 
Corp.; Thong Nhat Flat Steel; Ton Dong A Corp.; Trung Nguyen Steel Co, 
Ltd.; Vietname Germany Steel JSC; Vietnam Steel Corp.; Vietnam Steel 
Pipe; Vian Kyoei Steel Ltd.; Vina One Steel Manufacturing; NS BlueScope 
Vietnam Ltd.; and Southern Steel Sheet Co., Ltd. Accordingly, importers 
of CORE from Vietnam that is produced and/or exported by these 
ineligible companies are similarly ineligible for the certification 
process with regard to those imports. Additionally, exporters are not 
eligible to certify shipments of merchandise produced by the above-
listed companies. Accordingly, Hoa Phat Group Joint Stock Company and 
Hoa Phat Steel Sheet are not eligible to certify shipments of CRS 
produced by Hoa Phat Steel Pipe Co.\8\
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    \8\ See IDM at Comment 11.
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Notification Regarding Administrative Protective Orders

    This notice will serve as the only reminder to all parties subject 
to administrative protective order (APO) of their responsibility 
concerning the destruction of proprietary information disclosed under 
APO in accordance with 19 CFR 351.305(a)(3). Timely written 
notification of return/

[[Page 70950]]

destruction or 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.

Notification to Interested Parties

    These determinations are issued and published in accordance with 
section 781(b) of the Act and 19 CFR 351.225(f).

    Dated: December 13, 2019.
Jeffrey I. Kessler,
Assistant Secretary for Enforcement and Compliance.

Appendix I

List of Topics Discussed in the Issues and Decision Memorandum

I. Summary
II. Background
III. Scope of the Korea Core Orders
IV. Scope of the Anti-Circumvention Inquiries
V. Changes Since the Korea Core Anti-Circumvention Preliminary 
Determination
VI. Statutory Framework
VII. Use of Facts Available and Facts Available With an Adverse 
Inference
VIII. Anti-Circumvention Determinations
IX. Discussion of the Issues
    Comment 1: Whether Companies That Did Not Receive Commerce's 
Quantity and Value (Q&V) Questionnaire Should Be Permitted to 
Participate in the Certification Process
    Comment 2: Whether Commerce Lacks Statutory Authority to Apply 
AFA Where Respondents Did Not Deprive Commerce of Information 
Regarding Its Ability to Trace Inputs
    Comment 3: Whether Commerce's Use of AFA Impermissibly Departs 
Without Explanation from Its Decision in the China Anti-
Circumvention Inquiries.
    Comment 4: Whether Precluding Certain Importers and Exporters 
From Participating in the Certification Process is Inappropriate and 
Unfairly Punishes Importers
    Comment 5: Whether Commerce Should Allow Additional Time for 
Completing Certification for Pre-Preliminary Determinations Entries
    Comment 6: Whether Country-Wide Determinations Are Justified
    Comment 7: Whether Commerce's Interpretation of Section 781(b) 
of the Act Supports the CORE Production Process in Vietnam and 
Expands the Scope of the Korea CORE Orders
    Comment 8: Whether Commerce Should Amend the Exporter 
Certification Language to Prevent Funneling
    Comment 9: Whether to Apply AFA to Certain Vietnamese Producers 
That Are Affiliated with Those That Are Deemed Non-Responsive
    Comment 10: Whether Commerce Should Preclude Companies That 
Failed to Cooperate in Both the CORE from China and CORE from Taiwan 
Inquiries from Participating in the Certification Regime
    Comment 11: Whether to Apply the Highest the Petition Rate or 
Investigation Calculated Rate as the Cash Deposit Rate for Non-
Responsive Companies
    Comment 12: Whether Commerce Should Continue to Apply AFA to 
SSSC
    Comment 13:Whether Commerce Should Apply Section 232 Duties 
Against the Vietnam CORE Products Found Using Korean Substrates
    X. Recommendation

Appendix II

Certification Requirements

    If an importer imports certain corrosion-resistant steel 
products (CORE) from the Socialist Republic of Vietnam (Vietnam) and 
claims that the CORE was not produced from hot-rolled steel and/or 
cold-rolled steel substrate (substrate) manufactured in Korea, the 
importer is required to complete and maintain the importer 
certification attached hereto as Appendix III and all supporting 
documentation. Where the importer uses a broker to facilitate the 
entry process, it should obtain the entry number from the broker. 
Agents of the importer, such as brokers, however, are not permitted 
to make this certification on behalf of the importer.
    The exporter is required to complete and maintain the exporter 
certification, attached as Appendix IV, and is further required to 
provide the importer a copy of that certification and all supporting 
documentation.
    As discussed in the Issues and Decision Memorandum for these 
final determinations, we are extending the period for completing 
certifications for shipments and/or entries during the August 2, 
2018 through July 18, 2019 period established in the Preliminary 
Determinations. Accordingly, for shipments and/or entries on or 
after August 2, 2018 through July 18, 2019 for which certifications 
are required, importers and exporters should complete the required 
certification within 30 days of the publication of these final 
determinations notice in the Federal Register.
    For companies that were not eligible to certify pursuant to the 
Preliminary Determinations, but are now eligible pursuant to the 
final determinations, we are also extending the period for 
completion of their certifications for shipments and/or entries from 
August 2, 2018 through the date of Federal Register publication of 
the final determinations until 30 days after publication of these 
determinations.
    Accordingly, where appropriate, the relevant bullet in the 
certification should be edited to reflect that the certification was 
completed within the time frame specified above. For example, the 
bullet in the importer certification that reads: ``This 
certification was completed at or prior to the time of Entry,'' 
could be edited as follows: ``The imports referenced herein entered 
before July 19, 2019. This certification was completed on mm/dd/
yyyy, within 30 days of the Federal Register notice publication of 
the final determinations of circumvention.'' Similarly, the bullet 
in the exporter certification that reads, ``This certification was 
completed at or prior to the time of shipment,'' could be edited as 
follows: ``The shipments/products referenced herein shipped before 
July 19, 2019. This certification was completed on mm/dd/yyyy, 
within 30 days of the Federal Register notice publication of the 
final determinations of circumvention.'' For such entries/shipments, 
importers and exporters each have the option to complete a blanket 
certification covering multiple entries/shipments, individual 
certifications for each entry/shipment, or a combination thereof.
    For shipments and/or entries on or after the date of publication 
of this notice in the Federal Register, for which certifications are 
required, importers should complete the required certification at or 
prior to the date of Entry and exporters should complete the 
required certification and provide it to the importer at or prior to 
the date of shipment.
    For shipments and/or entries made on or after 10 days after the 
date of publication of these final determinations, parties should 
use the exporter and importer certifications contained below that 
incorporate additional information that was not in the preliminary 
determinations certifications. Specifically, the exporter 
certification now requires identification of the producer of the 
merchandise being exported to the United States and, also notes that 
CVD deposits may be required in addition to AD deposits as a result 
of the failure to maintain the required certification or the 
inability to substantiate the claims made in the certification. 
Similarly, the importer certification also notes that CVD deposits 
may be required in addition to AD deposits as a result of the 
failure to maintain the required certification or the inability to 
substantiate the claims made in the certification. The importer and 
Vietnamese exporter are also required to maintain sufficient 
documentation supporting their certifications. The importer will not 
be required to submit the certifications or supporting documentation 
to U.S. Customs and Border Protection (CBP) as part of the entry 
process at this time. However, the importer and the exporter will be 
required to present the certifications and supporting documentation, 
to Commerce and/or CBP, as applicable, upon request by the 
respective agency. Additionally, the claims made in the 
certifications and any supporting documentation are subject to 
verification by Commerce and/or CBP. The importer and exporter are 
required to maintain the certifications and supporting documentation 
for the later of (1) a period of five years from the date of entry 
or (2) a period of three years after the conclusion of any 
litigation in United States courts regarding such entries.
    In the situation where no certification is maintained for an 
entry, and AD/CVD orders from three countries (China, Korea, or 
Taiwan) potentially apply to that entry, Commerce intends to 
instruct CBP to suspend the entry and collect cash deposits at the 
China CORE Circumvention Final rates (i.e., the AD rate established 
for the China-wide entity (199.43 percent) and the CVD rate 
established for China all-others rate (39.05 percent)).\9\ In the 
situation where a

[[Page 70951]]

certification is maintained for the AD/CVD orders on CORE from China 
(stating that the merchandise was not produced from HRS and/or CRS 
from China), but no other certification is maintained, then Commerce 
intends to instruct CBP to suspend the entry and collect cash 
deposits at the AD and CVD all-others rates (i.e., 8.31 percent and 
1.19 percent, respectively) applicable to the AD/CVD orders on CORE 
from Korea.\10\
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    \9\ See China CORE Circumvention Final, 83 FR at 23896.
    \10\ See China CORE Orders.
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Appendix III

Importer Certification

    I hereby certify that:
     My name is {INSERT COMPANY OFFICIAL'S NAME HERE{time}  
and I am an official of {INSERT NAME OF IMPORTING COMPANY{time} ;
     I have direct personal knowledge of the facts regarding 
the importation into the Customs territory of the United States of 
the corrosion-resistant steel products produced in Vietnam that 
entered under entry number(s) {INSERT ENTRY NUMBER(S){time}  and are 
covered by this certification. ``Direct personal knowledge'' refers 
to facts the certifying party is expected to have in its own 
records. For example, the importer should have ``direct personal 
knowledge'' of the importation of the product (e.g., the name of the 
exporter) in its records;
     I have personal knowledge of the facts regarding the 
production of the imported products covered by this certification. 
``Personal knowledge'' includes facts obtained from another party, 
(e.g., correspondence received by the importer (or exporter) from 
the producer regarding the source of the input used to produce the 
imported products);
     These corrosion-resistant steel products produced in 
Vietnam do not contain hot-rolled steel and/or cold-rolled steel 
substrate produced in Korea:
     I understand that {INSERT NAME OF IMPORTING 
COMPANY{time}  is required to maintain a copy of this certification 
and sufficient documentation supporting this certification (i.e., 
documents maintained in the normal course of business, or documents 
obtained by the certifying party, for example, mill certificates, 
productions records, invoices, etc.) for the later of (1) a period 
of five years from the date of entry or (2) a period of three years 
after the conclusion of any litigation in the United States courts 
regarding such entries;
     I understand that {INSERT NAME OF IMPORTING 
COMPANY{time}  is required to provide this certification and 
supporting records, upon request, to U.S. Customs and Border 
Protection (CBP) and/or the Department of Commerce (Commerce);
     I understand that {INSERT NAME OF IMPORTING 
COMPANY{time}  is required to maintain a copy of the exporter's 
certification for the later of (1) a period of five years from the 
date of entry or (2) a period of three years after the conclusion of 
any litigation in United States courts regarding such entries;
     I understand that {INSERT NAME OF IMPORTING 
COMPANY{time}  is required to maintain and provide a copy of the 
exporter's certification and supporting records, upon request, to 
CBP and/or Commerce;
     I understand that the claims made herein, and the 
substantiating documentation, are subject to verification by CBP 
and/or Commerce;
     I understand that failure to maintain the required 
certification and/or failure to substantiate the claims made herein 
will result in:
    [cir] Suspension of liquidation of all unliquidated entries (and 
entries for which liquidation has not become final) for which these 
requirements were not met and
    [cir] the requirement that the importer post applicable 
antidumping/countervailing duty (AD and/or CVD) cash deposits equal 
to the rates as determined by Commerce;
     I understand that agents of the importer, such as 
brokers, are not permitted to make this certification;
     This certification was completed at or prior to the 
time of Entry; and
     I am aware that U.S. law (including, but not limited 
to, 18 U.S.C. 1001) imposes criminal sanctions on individuals who 
knowingly and willfully make materially false statements to the U.S. 
government.

Signature
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NAME OF COMPANY OFFICIAL
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TITLE

Appendix IV

Exporter Certification

    I hereby certify that:
     My name is {INSERT COMPANY OFFICIAL'S NAME HERE{time}  
and I am an official of {INSERT NAME OF EXPORTING COMPANY{time} ;
     I have direct personal knowledge of the facts regarding 
the production and exportation of the corrosion-resistant steel 
products that were sold to the United States under invoice number(s) 
INSERT INVOICE NUMBER(S). ``Direct personal knowledge'' refers to 
facts the certifying party is expected to have in its own books and 
records. For example, an exporter should have ``direct personal 
knowledge'' of the producer's identity and location.
     The {MERCHANDISE{time}  covered this certification was 
produced by {NAME OF PRODUCING COMPANY{time} , located at {ADDRESS 
OF PRODUCING COMPANY{time} ; for each additional company, repeat: 
{NAME OF PRODUCING COMPANY{time} , located at {ADDRESS OF PRODUCING 
COMPANY{time} .
     These corrosion-resistant steel products produced in 
Vietnam do not contain hot-rolled steel and/or cold-rolled steel 
substrate produced in Korea:
     I understand that {INSERT NAME OF EXPORTING 
COMPANY{time}  is required to maintain a copy of this certification 
and sufficient documentation supporting this certification (i.e., 
documents maintained in the normal course of business, or documents 
obtained by the certifying party, for example, mill certificates, 
productions records, invoices, etc.) for the later of (1) a period 
of five years from the date of entry or (2) a period of three years 
after the conclusion of any litigation in the United States courts 
regarding such entries;
     I understand that {INSERT NAME OF EXPORTING 
COMPANY{time}  must provide this Exporter Certification to the U.S. 
importer by the time of shipment;
     I understand that {INSERT NAME OF EXPORTING 
COMPANY{time}  is required to provide a copy of this certification 
and supporting records, upon request, to U.S. Customs and Border 
Protection (CBP) and/or the Department of Commerce (Commerce);
     I understand that the claims made herein, and the 
substantiating documentation are subject to verification by CBP and/
or Commerce;
     I understand that failure to maintain the required 
certification and/or failure to substantiate the claims made herein 
will result in:
    [cir] suspension of all unliquidated entries (and entries for 
which liquidation has not become final) for which these requirements 
were not met and
    [cir] the requirement that the importer post applicable 
antidumping/antidumping duty (AD and/or CVD) cash deposits equal to 
the rates as determined by Commerce;
     This certification was completed at or prior to the 
time of shipment; and
     I am aware that U.S. law (including, but not limited 
to, 18 U.S.C. 1001) imposes criminal sanctions on individuals who 
knowingly and willfully make materially false statements to the U.S. 
government.

Signature
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Name of Company Official
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Title
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Date

[FR Doc. 2019-27814 Filed 12-23-19; 8:45 am]
 BILLING CODE 3510-DS-P