Certain Steel Nails from the United Arab Emirates: Notice of Final Determination of Sales at Not Less Than Fair Value, 33985-33988 [E8-13490]
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Federal Register / Vol. 73, No. 116 / Monday, June 16, 2008 / Notices
importation of the subject merchandise.
If the ITC determines that material
injury or threat of material injury does
not exist, the proceeding will be
terminated and all securities posted will
be refunded or canceled. If the ITC
determines that such injury does exist,
the Department will issue an
antidumping duty order directing CBP
to assess 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entered, or withdrawn from warehouse,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.
Company Specific Comments:
Notification Regarding APO
This notice also serves as a reminder
to the parties subject to administrative
protective order (‘‘APO’’) of their
responsibility concerning the
disposition of proprietary information
disclosed under APO in accordance
with 19 CFR 351.305. Timely
notification of 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
sanctionable violation. This
determination and notice are issued and
published in accordance with sections
735(d) and 777(i)(1) of the Act.
This determination and notice are
issued and published in accordance
with sections 735(d) and 777(i)(1) of the
Act.
Dated: June 6, 2008.
David M. Spooner,
Assistant Secretary for Import
Administration.
Appendix I
Targeted Dumping:
Comment 1: Appropriateness of
Implementing New Methodology in
These Investigations
Comment 2: Identifying Alleged Targets
Comment 3: Statistical Validity of
Standard Deviation Test
Comment 4: Reliance on Identical
Product Comparisons for Determining
Targeted Dumping
Comment 5: Alleged Masking of
Dumping Under 33% Pattern Test
Threshold
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Comment 6: Flaws of ‘‘Gap Test’’
Comment 7: Alleged Masking of
Dumping by Respondents Under
Standard Deviation Test
Comment 8: Statistical Validity of P/2
Test
F. Unreported Indirect Labor Hours
G. Unreported Market–Economy
Purchases
Comment 21: Xingya Group
A. Market Economy Ocean Freight
B. Partial AFA for Certain CEP
Expenses Reported by Ominfast,
Partial AFA for Senco’s Advertising
Expenses, and Incorporation of
Corrections for USBROKU,
USDUTYU and EARLPYU
C. Senco’s Indirect Selling Expenses
D. Application of Total AFA or an
Intermediate Input Methodology to
Xingya Group Due to the
Misreporting of Its Production
Process
E. SXNC’s Purchases of Collating
Paper
F. Partial AFA for Certain Misreported
and Unreported SXNC Factors of
Production
Comment 22: Misidentification of
Separate Rate Recipients
Comment 23: Separate Rate Calculation
Comment 10: Wire Rod Surrogate Value
Comment 11: Surrogate Companies
Jkt 214001
C. Interest Expense
D. Exclusion of Selling Expenses from
SG&A Ratio
E. Possible Unreported Factors of
Production
Separate Rate Applicants:
Surrogate Values:
17:04 Jun 13, 2008
Comment 20: ITW
A. Database Use
B. Indirect Selling Expense
Calculation
G. Critical Circumstances
Comment 9: Programming Errors
VerDate Aug<31>2005
Comment 12: Scrap Surrogate Value
Comment 13: Sigma Cap for Wire Rod
Comment 14: Carton Surrogate Value
Comment 15: Tape Surrogate Value
Comment 16: Wage Rate
Comment 17: Wire Drawing Powder
Surrogate Value
Comment 18: Hydrochloric Acid
Surrogate Value
Comment 19: Stainless Steel Wire Rod
Surrogate Value
[FR Doc. E8–13474 Filed 6–13–08; 8:45 am]
BILLING CODE 3510–DS–S
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33985
DEPARTMENT OF COMMERCE
International Trade Administration
(A–520–802)
Certain Steel Nails from the United
Arab Emirates: Notice of Final
Determination of Sales at Not Less
Than Fair Value
Import Administration,
International Trade Administration,
Department of Commerce.
SUMMARY: We determine that certain
steel nails (nails) from the United Arab
Emirates (UAE) are not being, or are not
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
estimated margins of sales at not LTFV
are shown in the ‘‘Final Determination’’
section of this notice.
EFFECTIVE DATE: June 16, 2008.
FOR FURTHER INFORMATION CONTACT:
David Goldberger or Kate Johnson, AD/
CVD Operations, Office 2, Import
Administration, International Trade
Administration, U.S. Department of
Commerce, 14th Street and Constitution
Avenue, NW, Washington, DC 20230;
telephone: (202) 482–4136 or (202) 482–
4929, respectively.
SUPPLEMENTARY INFORMATION:
AGENCY:
Background
On January 23, 2008, the Department
published in the Federal Register the
preliminary determination of sales at
LTFV in the antidumping duty
investigation of nails from the UAE. See
Certain Steel Nails From the United
Arab Emirates: Notice of Preliminary
Determination of Sales at Less Than
Fair Value and Postponement of Final
Determination, 73 FR 3945 (January 23,
2008) (Preliminary Determination).
In the Preliminary Determination,
based on our examination of the
petitioners’1 targeted dumping
allegation filed on October 26, 2007, we
preliminarily determined that there is a
pattern of export prices for comparable
merchandise that differs significantly
among purchasers. Therefore, based on
the petitioners’ allegation, we
conducted an analysis to determine
whether targeted dumping occurred.
The Department further stated that it
was in the process of re–assessing the
framework and standards for both
1 The petitioners are: Mid Continent Nail
Corporation; Davis Wire Corporation; Gerdau
Ameristeel Corporation (Atlas Steel & Wire
Division); Maze Nails (Division of W.H. Maze
Company); Treasure Coast Fasteners, Inc.; and
United Steel, Paper and Forestry, Rubber,
Manufacturing, Energy, Allied Industrial and
Service Workers International Union.
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Federal Register / Vol. 73, No. 116 / Monday, June 16, 2008 / Notices
targeted dumping allegations and
targeted dumping analyses, and that it
intended to develop a new framework in
the context of this proceeding. We
invited comments regarding certain
principles involved in targeted dumping
allegations and analyses. Accordingly,
we received comments from the
petitioners and the respondent Dubai
Wire FZE/Global Fasteners Ltd (Dubai
Wire) on February 15, 2008. These
parties submitted rebuttal comments on
March 10, 2008.
From March 3 through March 12,
2008, we verified the constructed value
(CV) and sales questionnaire responses
of Dubai Wire. On March 31 and April
1, 2008, we issued the CV and sales
verification reports, respectively. See
Memorandum to the File entitled
‘‘Verification of the Cost Response of
Dubai Wire FZE in the Antidumping
Investigation of Certain Steel Nails from
the UAE,’’ dated March 31, 2008 (CVR),
and Memorandum to the File entitled
‘‘Verification of the Sales Response of
Dubai Wire FZE and Its Affiliate Global
Fasteners Ltd in the Antidumping
Investigation of Certain Steel Nails from
the United Arab Emirates,’’ dated April
1, 2008 (SVR).
On April 21, 2008, the Department
issued a decision memorandum in this
investigation and the companion
investigation on nails from the People’s
Republic of China (PRC) (Nails from the
PRC), in which the Department
described the application of a new
methodology to analyze targeted
dumping. Based on this analysis, the
Department did not find a pattern of
export prices for identical merchandise
that differed significantly among
purchasers. See Memorandum to David
Spooner, Assistant Secretary for Import
Administration, entitled ‘‘Post–
Preliminary Determinations on Targeted
Dumping,’’ dated April 21, 2008; and
Memorandum to James Maeder,
Director, AD/CVD Operations, Office 2,
entitled ‘‘Post–Preliminary
Determination on Targeted Dumping:
Results for Dubai Wire FZE/Global
Fasteners Ltd,’’ dated April 21, 2008. As
a result, we applied the average–toaverage methodology to all U.S. sales
and found a de minimis margin (0.09
percent) for Dubai Wire. On April 24,
2008, the Department issued a letter to
all parties in the two investigations
providing clarifications concerning the
post–preliminary determinations.
On April 30, 2008, the petitioners and
Hilti, Inc. (Hilti), an importer of the
subject merchandise, filed case briefs.
Dubai Wire filed a case brief on May 1,
2008. On May 7, 2008, the petitioners
and Dubai Wire filed rebuttal briefs.
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On May 6, 2008, National Nail Corp.,
an importer of subject merchandise in
Nails from the PRC, requested that the
Department confirm that the scope of
this investigation excludes plastic cap
roofing nails.2 The Department rejected
this request, and all submissions
associated with this request, as untimely
filed on June 2, 2008. See Letter from
Irene Darzenta Tzafolias to White and
Case, dated June 2, 2008.
On May 15, 2008, Illinois Tool Works,
Inc. and Paslode Fasteners (Shanghai)
Co., Ltd. (collectively, ITW) submitted
the public version of their scope
arguments contained in the public
version of ITW’s rebuttal brief filed on
May 8, 2008, in Nails from the PRC. See
‘‘Scope Comments’’ section, below.
As the Department established a
separate briefing schedule on targeted
dumping issues, the petitioners and
Suzhou Xingya Nail Co., Ltd., Senco–
Xingya Metal Products (Taicang) Co.,
Ltd., Senco Products, Inc., and Omnifast
LLC (collectively, Xingya Group), a
respondent in Nails from the PRC,
submitted case briefs with respect to
these issues on May 7, 2008.3 On May
14, 2008, the Xingya Group, ITW, and
Dubai Wire submitted rebuttal briefs to
the petitioners’ targeted dumping brief.4
On May 19, 2008, we held a joint public
hearing on the targeted dumping issues
raised in this investigation and Nails
from the PRC.
Period of Investigation
The period of investigation (POI) is
April 1, 2006, through March 31, 2007.
This period corresponds to the four
most recent fiscal quarters prior to the
month of the filing of the petition (i.e.,
May 2007).
Scope of Investigation
The merchandise covered by this
investigation includes certain steel nails
having a shaft length up to 12 inches.
Certain steel nails include, but are not
2 The May 6, 2008, submission was filed on the
record of the UAE investigation on May 7, 2008. On
May 12, 2008, the petitioners submitted a letter for
the record of the PRC investigation opposing
National Nail Corp.’s exclusion request. This letter
was submitted for the record of the UAE
investigation on May 27, 2008. National Nail Corp.
responded to this letter on May 20, 2008.
3 The public version of Xingya Group’s brief was
submitted for the record of this investigation on
May 12, 2008.
4 Dubai Wire resubmitted its rebuttal brief on May
16, 2008, as the Department rejected the original
rebuttal brief because it contained arguments that
did not address comments made in the petitioners’
targeted dumping case brief. See Memorandum to
The File entitled ‘‘Return of Dubai Wire FZE (Dubai
Wire) Rebuttal Brief on Targeted Dumping Issues,’’
dated May 16, 2008. The public versions of the
petitioners’ and ITW’s targeted dumping rebuttal
briefs filed in Nails from the PRC were submitted
to this record on May 15, 2008.
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limited to, nails made of round wire and
nails that are cut. Certain steel nails may
be of one piece construction or
constructed of two or more pieces.
Certain steel nails may be produced
from any type of steel, and have a
variety of finishes, heads, shanks, point
types, shaft lengths and shaft diameters.
Finishes include, but are not limited to,
coating in vinyl, zinc (galvanized,
whether by electroplating or hot–
dipping one or more times), phosphate
cement, and paint. Head styles include,
but are not limited to, flat, projection,
cupped, oval, brad, headless, double,
countersunk, and sinker. Shank styles
include, but are not limited to, smooth,
barbed, screw threaded, ring shank and
fluted shank styles. Screw–threaded
nails subject to this proceeding are
driven using direct force and not by
turning the fastener using a tool that
engages with the head. Point styles
include, but are not limited to,
diamond, blunt, needle, chisel and no
point. Finished nails may be sold in
bulk, or they may be collated into strips
or coils using materials such as plastic,
paper, or wire. Certain steel nails
subject to this proceeding are currently
classified under the Harmonized Tariff
Schedule of the United States (HTSUS)
subheadings 7317.00.55, 7317.00.65 and
7317.00.75.
Excluded from the scope of this
proceeding are roofing nails of all
lengths and diameter, whether collated
or in bulk, and whether or not
galvanized. Steel roofing nails are
specifically enumerated and identified
in ASTM Standard F 1667 (2005
revision) as Type I, Style 20 nails. Also
excluded from the scope of this
proceeding are corrugated nails. A
corrugated nail is made of a small strip
of corrugated steel with sharp points on
one side. Also excluded from the scope
of this proceeding are fasteners suitable
for use in powder–actuated hand tools,
not threaded and threaded, which are
currently classified under HTSUS
7317.00.20 and 7317.00.30. Also
excluded from the scope of this
proceeding are thumb tacks, which are
currently classified under HTSUS
7317.00.10. Also excluded from the
scope of this proceeding are certain
brads and finish nails that are equal to
or less than 0.0720 inches in shank
diameter, round or rectangular in cross
section, between 0.375 inches and 2.5
inches in length, and that are collated
with adhesive or polyester film tape
backed with a heat seal adhesive. Also
excluded from the scope of this
proceeding are fasteners having a case
hardness greater than or equal to 50
HRC, a carbon content greater than or
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Federal Register / Vol. 73, No. 116 / Monday, June 16, 2008 / Notices
equal to 0.5 percent, a round head, a
secondary reduced–diameter raised
head section, a centered shank, and a
smooth symmetrical point, suitable for
use in gas–actuated hand tools.
While the HTSUS subheadings are
provided for convenience and customs
purposes, the written description of the
scope of this investigation is dispositive.
Scope Comments
Banded Brads and Finish Nails
On July 30, 2007,5 Stanley Fastening
Systems, LP (Stanley), an interested
party in this proceeding, requested that
banded brads and finish nails imported
with a ‘‘nailer kit’’ or ‘‘combo kit’’ as a
single package be excluded from this
investigation as being outside the ‘‘class
or kind’’6 of merchandise.7 Based on the
scope exclusion request from Stanley,
the fact that the petitioners are in
agreement with this request, and that
there appears to be no impediment to
enforceability by CBP, we preliminarily
determined that the above–described
products are not subject to the scope of
this investigation. Since the Preliminary
Determination, no party to this
proceeding has commented on this issue
and we have found no additional
information that would compel us to
reverse our preliminary finding. Thus,
for purposes of the final determination,
we continue to find that the above–
described products are not subject to the
scope of this investigation.
Fasteners Suitable for Use in Gas–
Actuated Hand Tools
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In its case brief filed on April 30,
2008, Hilti, an interested party in this
proceeding, reiterated its request,
submitted on January 8, 2008, that the
Department modify the scope of the
investigation to exclude fasteners
suitable for use in gas–actuated hand
tools.8 Hilti claimed that modification of
the scope to exclude these fasteners was
5 This submission was filed on the record of Nails
from the PRC on July 30, 2007, and on the record
of the instant investigation on January 7, 2008.
6 A ‘‘nailer kit’’ consists of a pneumatic nailer, a
‘‘starter box’’ of branded products and a carrying
case. A ‘‘combo kit’’ consists of an air compressor,
a pneumatic nailer, and a ‘‘starter box’’ of banded
products and related accessories, such as an air
hose.
7 On December 12, 2007, Stanley revised its July
30, 2007, scope exclusion request arguing that its
new request reflects a broader exclusion and could
be easily administered by U.S. Customs and Border
Protection (CBP) because the description of the
excluded brads and finish nails is framed solely in
terms of their physical characteristics.
8 We stated in the Preliminary Determination that
we received this request too late to consider for
purposes of the preliminary determination, but
would consider it for the final determination.
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17:04 Jun 13, 2008
Jkt 214001
supported by the petitioners9 and,
additionally, because the description of
the excluded nails is framed solely in
terms of their physical characteristics,
the exclusion could be easily
administered by CBP. Furthermore, Hilti
pointed out that the principles and
rationale the Department applied to
Stanley’s scope request (see discussion
above) in the Preliminary Determination
applied equally to Hilti’s scope request.
Hilti rebutted ITW’s January 8, 2008,
submission arguing that ITW offered no
material reason for seeking the
imposition of antidumping duties
against the product at issue, other than
its assertion that it is a U.S.
manufacturer of such merchandise.
Moreover, Hilti claimed that ITW has
never opposed the petitioners’ own
initial exclusion of nails suitable for use
in powder- actuated hand tools, which
Hilti claimed are functionally similar
and competitive with nails suitable for
use in gas–actuated tools, but simply
classified under a different HTSUS
subheading.
In its rebuttal brief submitted on May
8, 2008, in Nails from the PRC,10 ITW
reiterated its arguments in its January 8,
2008, submission that, because it is the
only U.S. producer of the product at
issue, the petitioners’ agreement to the
proposed exclusion is not relevant in
light of ITW’s opposition. In addition,
ITW claimed that it is perfectly
reasonable and legitimate for it to
oppose a petition generally, while at the
same time opposing certain exclusions
to that petition.
Based on the scope exclusion request
from Hilti, the fact that the petitioners
are in agreement with this request, and
that there appears to be no impediment
to enforceability by CBP,11 we have
determined that the above–described
products are not subject to the scope of
this investigation.12
Aluminum Nails and Stainless Steel
Nails
On February 27, 2008, Duo–Fast
Northeast (Duo–Fast), an interested
party in this proceeding, requested that
the Department exclude two types of
nails from the scope of this proceeding:
9 On January 9, 2008, the petitioners filed a letter
stating that they agree with Hilti’s January 8, 2008,
scope exclusion request.
10 This brief was submitted for the UAE record on
May 15, 2008.
11 See Memorandum to the File from Kate
Johnson, Senior Case Analyst, entitled ‘‘Scope
Exclusion Request,’’ dated May 1, 2008.
12 While the Department notes ITW’s objection, it
strives to craft a scope that both includes the
specific products for which the petitioners have
requested relief, and excludes those products which
may fall within the general scope definition, but for
which the petitioners do not seek relief.
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33987
(1) aluminum nails, and (2) stainless
steel nails.13 The plain language of the
scope indicates that the scope does not
cover aluminum nails because nails
made from aluminum are not made from
steel and are, thus, not subject
merchandise. However, stainless steel
nails are explicitly covered in the scope
of this proceeding, as the plain language
of the scope covers nails produced from
any type of steel, without limitation.
Therefore, we have not modified the
scope of investigation in accordance
with Duo–Fast’s requests.
Targeted Dumping
We have analyzed the case and
rebuttal briefs with respect to targeted
dumping issues submitted for the record
in this investigation and in Nails from
the PRC. As a result of our analysis, we
made certain changes in the targeted
dumping test we applied in the post–
preliminary determination for purposes
of the final determination. These
changes continued to result in a
negative targeted dumping finding for
Dubai Wire. For further discussion, see
Comments 1 through 9 in the ‘‘Issues
and Decision Memorandum’’ (Decision
Memo) from Stephen J. Claeys, Deputy
Assistant Secretary for Import
Administration, to David M. Spooner,
Assistant Secretary for Import
Administration, dated June 6, 2008,
which is hereby adopted by this notice.
See also Memorandum to The File
entitled ‘‘Dubai Wire FZE/Global
Fasteners Ltd. Final Determination
Margin Calculation,’’ dated June 6,
2008.
Analysis of Comments Received
All issues raised in the case and
rebuttal briefs submitted by the parties
to this investigation are addressed in the
Decision Memo. A list of the issues that
parties have raised and to which we
have responded, all of which are in the
Decision Memo, is attached to this
notice as an appendix. Parties can find
a complete discussion of all issues
raised in this investigation and the
corresponding recommendations in this
public memorandum which is on file in
the Central Records Unit, room 1117 of
the main Department building. In
addition, a complete version of the
Decision Memo can be accessed directly
on the Web at https://ia.ita.doc.gov/frn.
The paper copy and electronic version
of the Decision Memo are identical in
content.
13 On March 18, 2008, the petitioners submitted
a letter for the record opposing Duo-Fast’s exclusion
request.
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Federal Register / Vol. 73, No. 116 / Monday, June 16, 2008 / Notices
Verification
As provided in section 782(i) of the
Act, we verified the sales and cost
information submitted by Dubai Wire
for use in our final determination. We
used standard verification procedures
including an examination of relevant
accounting and production records, and
original source documents provided by
Dubai Wire. See CVR and SVR.
Changes Since the Preliminary
Determination
Based on our analysis of the
comments received and our findings at
verification, we have made certain
changes to the margin calculation for
Dubai Wire. For a discussion of these
changes, see the ‘‘Margin Calculations’’
section of the Decision Memo.
Final Determination Margins
We determine that the weighted–
average dumping margins are as follows:
Weighted–Average
Margin Percentage
%
Dubai Wire FZE/Global
Fasteners Ltd. ...........
All Others ......................
0.00
0.00
Disclosure
We will disclose the calculations
performed within five days of the date
of publication of this notice to parties in
this proceeding in accordance with 19
CFR 351.224(b).
Termination of Suspension of
Liquidation
Because the estimated weighted–
average dumping margin for the sole
investigated company is 0.00 percent
(de minimis), we will direct CBP to
terminate the suspension of liquidation
of all imports of subject merchandise
that are entered, or withdrawn from
warehouse, for consumption on or after
January 23, 2008, and to release any
bond or other security, and refund any
cash deposit.
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ITC Notification
In accordance with section 735(d) of
the Act, we have notified the ITC of our
final determination.
Return or Destruction of Proprietary
Information
This notice will serve as the only
reminder to 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/
destruction of APO materials or
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19:01 Jun 13, 2008
Jkt 214001
conversion to judicial protective order is
hereby requested. Failure to comply
with the regulations and the terms of an
APO is a sanctionable violation.
We are issuing and publishing this
determination and notice in accordance
with sections 735(d) and 777(i) of the
Act.
Dated: June 6, 2008.
David M. Spooner,
Assistant Secretary for Import
Administration.
Targeted Dumping Issues
Comment 1: Appropriateness of
Implementing New Methodology in this
Investigation
Comment 2: Identifying Alleged Targets
Comment 3: Statistical Validity of
Standard Deviation Test
Comment 4: Reliance on Identical
Products for Determining Targeted
Dumping
Comment 5: Alleged Masking of
Dumping Under 33–Percent Pattern Test
Threshold
Comment 6: Flaws of ‘‘Gap Test≥
Comment 7: Alleged Masking of
Dumping by Respondents Under
Standard Deviation Test
Comment 8: Statistical Validity of P/2
Test
Comment 9: Programming Errors
Company–Specific Calculation Issues
Comment 10: Addition of G&A,
Financial and Selling Expenses to GFL
Processing Costs
Comment 11: Weight–Averaging of
Dubai Wire and GFL Expenses for G&A
and Financial Expense Ratios
Comment 12: Scrap Offset Revisions
Comment 13: Affiliated Party Loans and
Leases
Comment 14: Calculation of Financial
Expense Offset
Comment 15: Adjustment of GFL CV
Profit Ratio for COM Revisions
Comment 16: Calculation of CV Selling
Expenses and Profit Based on GFL
Screw Sales
Comment 17: LOT Adjustment for CV
Comparisons
[FR Doc. E8–13490 Filed 6–13–08; 8:45 am]
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International Trade Administration
A–570–865
Final Rescission of Antidumping Duty
Administrative Review: Certain Hot–
Rolled Carbon Steel Flat Products from
the People’s Republic of China
Import Administration,
International Trade Administration,
Department of Commerce.
EFFECTIVE DATE: June 16, 2008.
FOR FURTHER INFORMATION CONTACT: Toni
Dach or Scot Fullerton, AD/CVD
Operations, Office 9, Import
Administration, International Trade
Administration, U.S. Department of
Commerce, 14th Street and Constitution
Avenue, NW, Washington, DC 20230;
telephone: (202) 482–1655 and (202)
482–1386, respectively.
SUPPLEMENTARY INFORMATION:
AGENCY:
Appendix - Issues in Decision
Memorandum
BILLING CODE 3510–DS–S
DEPARTMENT OF COMMERCE
Background
On November 1, 2007, the Department
of Commerce (‘‘Department’’) published
a notice of opportunity to request an
administrative review of the
antidumping duty order on certain hot–
rolled carbon steel flat products from
the People’s Republic of China (‘‘PRC’’)
for the period of review (‘‘POR’’)
November 1, 2006, through October 31,
2007. See Antidumping or
Countervailing Duty Order, Finding, or
Suspended Investigation; Opportunity
to Request Administrative Review, 72
FR 61859 (November 1, 2007). On
November 30, 2007, Nucor Corporation
(‘‘Petitioner’’), a domestic producer of
certain hot–rolled carbon steel flat
products, requested that the Department
conduct an administrative review of
Baosteel Group Corporation, Shanghai
Baosteel International Economic &
Trading Co., Ltd., and Baoshan Iron and
Steel Co., Ltd. (collectively ‘‘Baosteel’’).
On December 27, 2007, the Department
published a notice of initiation of an
antidumping duty administrative review
on certain hot–rolled carbon steel flat
products from the PRC. See Initiation of
Antidumping and Countervailing Duty
Administrative Reviews, (‘‘Notice of
Initiation’’), 72 FR 73315 (December 27,
2007).
On April 14, 2008, we preliminarily
rescinded this review based on evidence
on the record indicating that there were
no entries into the United States. See
Preliminary Rescission of Antidumping
Duty Administrative Review: Certain
Hot–Rolled Carbon Steel Flat Products
From The People’s Republic of China,
(‘‘Preliminary Rescission’’), 73 FR 20021
(April 14, 2008). We invited interested
parties to submit comments on our
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Agencies
[Federal Register Volume 73, Number 116 (Monday, June 16, 2008)]
[Notices]
[Pages 33985-33988]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-13490]
-----------------------------------------------------------------------
DEPARTMENT OF COMMERCE
International Trade Administration
(A-520-802)
Certain Steel Nails from the United Arab Emirates: Notice of
Final Determination of Sales at Not Less Than Fair Value
AGENCY: Import Administration, International Trade Administration,
Department of Commerce.
SUMMARY: We determine that certain steel nails (nails) from the United
Arab Emirates (UAE) are not being, or are not 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 estimated
margins of sales at not LTFV are shown in the ``Final Determination''
section of this notice.
EFFECTIVE DATE: June 16, 2008.
FOR FURTHER INFORMATION CONTACT:
David Goldberger or Kate Johnson, AD/CVD Operations, Office 2, Import
Administration, International Trade Administration, U.S. Department of
Commerce, 14th Street and Constitution Avenue, NW, Washington, DC
20230; telephone: (202) 482-4136 or (202) 482-4929, respectively.
SUPPLEMENTARY INFORMATION:
Background
On January 23, 2008, the Department published in the Federal
Register the preliminary determination of sales at LTFV in the
antidumping duty investigation of nails from the UAE. See Certain Steel
Nails From the United Arab Emirates: Notice of Preliminary
Determination of Sales at Less Than Fair Value and Postponement of
Final Determination, 73 FR 3945 (January 23, 2008) (Preliminary
Determination).
In the Preliminary Determination, based on our examination of the
petitioners'\1\ targeted dumping allegation filed on October 26, 2007,
we preliminarily determined that there is a pattern of export prices
for comparable merchandise that differs significantly among purchasers.
Therefore, based on the petitioners' allegation, we conducted an
analysis to determine whether targeted dumping occurred. The Department
further stated that it was in the process of re-assessing the framework
and standards for both
[[Page 33986]]
targeted dumping allegations and targeted dumping analyses, and that it
intended to develop a new framework in the context of this proceeding.
We invited comments regarding certain principles involved in targeted
dumping allegations and analyses. Accordingly, we received comments
from the petitioners and the respondent Dubai Wire FZE/Global Fasteners
Ltd (Dubai Wire) on February 15, 2008. These parties submitted rebuttal
comments on March 10, 2008.
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\1\ The petitioners are: Mid Continent Nail Corporation; Davis
Wire Corporation; Gerdau Ameristeel Corporation (Atlas Steel & Wire
Division); Maze Nails (Division of W.H. Maze Company); Treasure
Coast Fasteners, Inc.; and United Steel, Paper and Forestry, Rubber,
Manufacturing, Energy, Allied Industrial and Service Workers
International Union.
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From March 3 through March 12, 2008, we verified the constructed
value (CV) and sales questionnaire responses of Dubai Wire. On March 31
and April 1, 2008, we issued the CV and sales verification reports,
respectively. See Memorandum to the File entitled ``Verification of the
Cost Response of Dubai Wire FZE in the Antidumping Investigation of
Certain Steel Nails from the UAE,'' dated March 31, 2008 (CVR), and
Memorandum to the File entitled ``Verification of the Sales Response of
Dubai Wire FZE and Its Affiliate Global Fasteners Ltd in the
Antidumping Investigation of Certain Steel Nails from the United Arab
Emirates,'' dated April 1, 2008 (SVR).
On April 21, 2008, the Department issued a decision memorandum in
this investigation and the companion investigation on nails from the
People's Republic of China (PRC) (Nails from the PRC), in which the
Department described the application of a new methodology to analyze
targeted dumping. Based on this analysis, the Department did not find a
pattern of export prices for identical merchandise that differed
significantly among purchasers. See Memorandum to David Spooner,
Assistant Secretary for Import Administration, entitled ``Post-
Preliminary Determinations on Targeted Dumping,'' dated April 21, 2008;
and Memorandum to James Maeder, Director, AD/CVD Operations, Office 2,
entitled ``Post-Preliminary Determination on Targeted Dumping: Results
for Dubai Wire FZE/Global Fasteners Ltd,'' dated April 21, 2008. As a
result, we applied the average-to-average methodology to all U.S. sales
and found a de minimis margin (0.09 percent) for Dubai Wire. On April
24, 2008, the Department issued a letter to all parties in the two
investigations providing clarifications concerning the post-preliminary
determinations.
On April 30, 2008, the petitioners and Hilti, Inc. (Hilti), an
importer of the subject merchandise, filed case briefs. Dubai Wire
filed a case brief on May 1, 2008. On May 7, 2008, the petitioners and
Dubai Wire filed rebuttal briefs.
On May 6, 2008, National Nail Corp., an importer of subject
merchandise in Nails from the PRC, requested that the Department
confirm that the scope of this investigation excludes plastic cap
roofing nails.\2\ The Department rejected this request, and all
submissions associated with this request, as untimely filed on June 2,
2008. See Letter from Irene Darzenta Tzafolias to White and Case, dated
June 2, 2008.
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\2\ The May 6, 2008, submission was filed on the record of the
UAE investigation on May 7, 2008. On May 12, 2008, the petitioners
submitted a letter for the record of the PRC investigation opposing
National Nail Corp.'s exclusion request. This letter was submitted
for the record of the UAE investigation on May 27, 2008. National
Nail Corp. responded to this letter on May 20, 2008.
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On May 15, 2008, Illinois Tool Works, Inc. and Paslode Fasteners
(Shanghai) Co., Ltd. (collectively, ITW) submitted the public version
of their scope arguments contained in the public version of ITW's
rebuttal brief filed on May 8, 2008, in Nails from the PRC. See ``Scope
Comments'' section, below.
As the Department established a separate briefing schedule on
targeted dumping issues, the petitioners and Suzhou Xingya Nail Co.,
Ltd., Senco-Xingya Metal Products (Taicang) Co., Ltd., Senco Products,
Inc., and Omnifast LLC (collectively, Xingya Group), a respondent in
Nails from the PRC, submitted case briefs with respect to these issues
on May 7, 2008.\3\ On May 14, 2008, the Xingya Group, ITW, and Dubai
Wire submitted rebuttal briefs to the petitioners' targeted dumping
brief.\4\ On May 19, 2008, we held a joint public hearing on the
targeted dumping issues raised in this investigation and Nails from the
PRC.
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\3\ The public version of Xingya Group's brief was submitted for
the record of this investigation on May 12, 2008.
\4\ Dubai Wire resubmitted its rebuttal brief on May 16, 2008,
as the Department rejected the original rebuttal brief because it
contained arguments that did not address comments made in the
petitioners' targeted dumping case brief. See Memorandum to The File
entitled ``Return of Dubai Wire FZE (Dubai Wire) Rebuttal Brief on
Targeted Dumping Issues,'' dated May 16, 2008. The public versions
of the petitioners' and ITW's targeted dumping rebuttal briefs filed
in Nails from the PRC were submitted to this record on May 15, 2008.
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Period of Investigation
The period of investigation (POI) is April 1, 2006, through March
31, 2007. This period corresponds to the four most recent fiscal
quarters prior to the month of the filing of the petition (i.e., May
2007).
Scope of Investigation
The merchandise covered by this investigation includes certain
steel nails having a shaft length up to 12 inches. Certain steel nails
include, but are not limited to, nails made of round wire and nails
that are cut. Certain steel nails may be of one piece construction or
constructed of two or more pieces. Certain steel nails may be produced
from any type of steel, and have a variety of finishes, heads, shanks,
point types, shaft lengths and shaft diameters. Finishes include, but
are not limited to, coating in vinyl, zinc (galvanized, whether by
electroplating or hot-dipping one or more times), phosphate cement, and
paint. Head styles include, but are not limited to, flat, projection,
cupped, oval, brad, headless, double, countersunk, and sinker. Shank
styles include, but are not limited to, smooth, barbed, screw threaded,
ring shank and fluted shank styles. Screw-threaded nails subject to
this proceeding are driven using direct force and not by turning the
fastener using a tool that engages with the head. Point styles include,
but are not limited to, diamond, blunt, needle, chisel and no point.
Finished nails may be sold in bulk, or they may be collated into strips
or coils using materials such as plastic, paper, or wire. Certain steel
nails subject to this proceeding are currently classified under the
Harmonized Tariff Schedule of the United States (HTSUS) subheadings
7317.00.55, 7317.00.65 and 7317.00.75.
Excluded from the scope of this proceeding are roofing nails of all
lengths and diameter, whether collated or in bulk, and whether or not
galvanized. Steel roofing nails are specifically enumerated and
identified in ASTM Standard F 1667 (2005 revision) as Type I, Style 20
nails. Also excluded from the scope of this proceeding are corrugated
nails. A corrugated nail is made of a small strip of corrugated steel
with sharp points on one side. Also excluded from the scope of this
proceeding are fasteners suitable for use in powder-actuated hand
tools, not threaded and threaded, which are currently classified under
HTSUS 7317.00.20 and 7317.00.30. Also excluded from the scope of this
proceeding are thumb tacks, which are currently classified under HTSUS
7317.00.10. Also excluded from the scope of this proceeding are certain
brads and finish nails that are equal to or less than 0.0720 inches in
shank diameter, round or rectangular in cross section, between 0.375
inches and 2.5 inches in length, and that are collated with adhesive or
polyester film tape backed with a heat seal adhesive. Also excluded
from the scope of this proceeding are fasteners having a case hardness
greater than or equal to 50 HRC, a carbon content greater than or
[[Page 33987]]
equal to 0.5 percent, a round head, a secondary reduced-diameter raised
head section, a centered shank, and a smooth symmetrical point,
suitable for use in gas-actuated hand tools.
While the HTSUS subheadings are provided for convenience and
customs purposes, the written description of the scope of this
investigation is dispositive.
Scope Comments
Banded Brads and Finish Nails
On July 30, 2007,\5\ Stanley Fastening Systems, LP (Stanley), an
interested party in this proceeding, requested that banded brads and
finish nails imported with a ``nailer kit'' or ``combo kit'' as a
single package be excluded from this investigation as being outside the
``class or kind''\6\ of merchandise.\7\ Based on the scope exclusion
request from Stanley, the fact that the petitioners are in agreement
with this request, and that there appears to be no impediment to
enforceability by CBP, we preliminarily determined that the above-
described products are not subject to the scope of this investigation.
Since the Preliminary Determination, no party to this proceeding has
commented on this issue and we have found no additional information
that would compel us to reverse our preliminary finding. Thus, for
purposes of the final determination, we continue to find that the
above-described products are not subject to the scope of this
investigation.
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\5\ This submission was filed on the record of Nails from the
PRC on July 30, 2007, and on the record of the instant investigation
on January 7, 2008.
\6\ A ``nailer kit'' consists of a pneumatic nailer, a ``starter
box'' of branded products and a carrying case. A ``combo kit''
consists of an air compressor, a pneumatic nailer, and a ``starter
box'' of banded products and related accessories, such as an air
hose.
\7\ On December 12, 2007, Stanley revised its July 30, 2007,
scope exclusion request arguing that its new request reflects a
broader exclusion and could be easily administered by U.S. Customs
and Border Protection (CBP) because the description of the excluded
brads and finish nails is framed solely in terms of their physical
characteristics.
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Fasteners Suitable for Use in Gas-Actuated Hand Tools
In its case brief filed on April 30, 2008, Hilti, an interested
party in this proceeding, reiterated its request, submitted on January
8, 2008, that the Department modify the scope of the investigation to
exclude fasteners suitable for use in gas-actuated hand tools.\8\ Hilti
claimed that modification of the scope to exclude these fasteners was
supported by the petitioners\9\ and, additionally, because the
description of the excluded nails is framed solely in terms of their
physical characteristics, the exclusion could be easily administered by
CBP. Furthermore, Hilti pointed out that the principles and rationale
the Department applied to Stanley's scope request (see discussion
above) in the Preliminary Determination applied equally to Hilti's
scope request.
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\8\ We stated in the Preliminary Determination that we received
this request too late to consider for purposes of the preliminary
determination, but would consider it for the final determination.
\9\ On January 9, 2008, the petitioners filed a letter stating
that they agree with Hilti's January 8, 2008, scope exclusion
request.
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Hilti rebutted ITW's January 8, 2008, submission arguing that ITW
offered no material reason for seeking the imposition of antidumping
duties against the product at issue, other than its assertion that it
is a U.S. manufacturer of such merchandise. Moreover, Hilti claimed
that ITW has never opposed the petitioners' own initial exclusion of
nails suitable for use in powder- actuated hand tools, which Hilti
claimed are functionally similar and competitive with nails suitable
for use in gas-actuated tools, but simply classified under a different
HTSUS subheading.
In its rebuttal brief submitted on May 8, 2008, in Nails from the
PRC,\10\ ITW reiterated its arguments in its January 8, 2008,
submission that, because it is the only U.S. producer of the product at
issue, the petitioners' agreement to the proposed exclusion is not
relevant in light of ITW's opposition. In addition, ITW claimed that it
is perfectly reasonable and legitimate for it to oppose a petition
generally, while at the same time opposing certain exclusions to that
petition.
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\10\ This brief was submitted for the UAE record on May 15,
2008.
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Based on the scope exclusion request from Hilti, the fact that the
petitioners are in agreement with this request, and that there appears
to be no impediment to enforceability by CBP,\11\ we have determined
that the above-described products are not subject to the scope of this
investigation.\12\
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\11\ See Memorandum to the File from Kate Johnson, Senior Case
Analyst, entitled ``Scope Exclusion Request,'' dated May 1, 2008.
\12\ While the Department notes ITW's objection, it strives to
craft a scope that both includes the specific products for which the
petitioners have requested relief, and excludes those products which
may fall within the general scope definition, but for which the
petitioners do not seek relief.
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Aluminum Nails and Stainless Steel Nails
On February 27, 2008, Duo-Fast Northeast (Duo-Fast), an interested
party in this proceeding, requested that the Department exclude two
types of nails from the scope of this proceeding: (1) aluminum nails,
and (2) stainless steel nails.\13\ The plain language of the scope
indicates that the scope does not cover aluminum nails because nails
made from aluminum are not made from steel and are, thus, not subject
merchandise. However, stainless steel nails are explicitly covered in
the scope of this proceeding, as the plain language of the scope covers
nails produced from any type of steel, without limitation. Therefore,
we have not modified the scope of investigation in accordance with Duo-
Fast's requests.
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\13\ On March 18, 2008, the petitioners submitted a letter for
the record opposing Duo-Fast's exclusion request.
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Targeted Dumping
We have analyzed the case and rebuttal briefs with respect to
targeted dumping issues submitted for the record in this investigation
and in Nails from the PRC. As a result of our analysis, we made certain
changes in the targeted dumping test we applied in the post-preliminary
determination for purposes of the final determination. These changes
continued to result in a negative targeted dumping finding for Dubai
Wire. For further discussion, see Comments 1 through 9 in the ``Issues
and Decision Memorandum'' (Decision Memo) from Stephen J. Claeys,
Deputy Assistant Secretary for Import Administration, to David M.
Spooner, Assistant Secretary for Import Administration, dated June 6,
2008, which is hereby adopted by this notice. See also Memorandum to
The File entitled ``Dubai Wire FZE/Global Fasteners Ltd. Final
Determination Margin Calculation,'' dated June 6, 2008.
Analysis of Comments Received
All issues raised in the case and rebuttal briefs submitted by the
parties to this investigation are addressed in the Decision Memo. A
list of the issues that parties have raised and to which we have
responded, all of which are in the Decision Memo, is attached to this
notice as an appendix. Parties can find a complete discussion of all
issues raised in this investigation and the corresponding
recommendations in this public memorandum which is on file in the
Central Records Unit, room 1117 of the main Department building. In
addition, a complete version of the Decision Memo can be accessed
directly on the Web at https://ia.ita.doc.gov/frn. The paper copy and
electronic version of the Decision Memo are identical in content.
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Verification
As provided in section 782(i) of the Act, we verified the sales and
cost information submitted by Dubai Wire for use in our final
determination. We used standard verification procedures including an
examination of relevant accounting and production records, and original
source documents provided by Dubai Wire. See CVR and SVR.
Changes Since the Preliminary Determination
Based on our analysis of the comments received and our findings at
verification, we have made certain changes to the margin calculation
for Dubai Wire. For a discussion of these changes, see the ``Margin
Calculations'' section of the Decision Memo.
Final Determination Margins
We determine that the weighted-average dumping margins are as
follows:
------------------------------------------------------------------------
Weighted-Average
Margin Percentage
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Dubai Wire FZE/Global Fasteners Ltd................. 0.00
All Others.......................................... 0.00
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Disclosure
We will disclose the calculations performed within five days of the
date of publication of this notice to parties in this proceeding in
accordance with 19 CFR 351.224(b).
Termination of Suspension of Liquidation
Because the estimated weighted-average dumping margin for the sole
investigated company is 0.00 percent (de minimis), we will direct CBP
to terminate the suspension of liquidation of all imports of subject
merchandise that are entered, or withdrawn from warehouse, for
consumption on or after January 23, 2008, and to release any bond or
other security, and refund any cash deposit.
ITC Notification
In accordance with section 735(d) of the Act, we have notified the
ITC of our final determination.
Return or Destruction of Proprietary Information
This notice will serve as the only reminder to 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/destruction of APO materials or conversion to
judicial protective order is hereby requested. Failure to comply with
the regulations and the terms of an APO is a sanctionable violation.
We are issuing and publishing this determination and notice in
accordance with sections 735(d) and 777(i) of the Act.
Dated: June 6, 2008.
David M. Spooner,
Assistant Secretary for Import Administration.
Appendix - Issues in Decision Memorandum
Targeted Dumping Issues
Comment 1: Appropriateness of Implementing New Methodology in this
Investigation
Comment 2: Identifying Alleged Targets
Comment 3: Statistical Validity of Standard Deviation Test
Comment 4: Reliance on Identical Products for Determining Targeted
Dumping
Comment 5: Alleged Masking of Dumping Under 33-Percent Pattern Test
Threshold
Comment 6: Flaws of ``Gap Test
Comment 7: Alleged Masking of Dumping by Respondents Under Standard
Deviation Test
Comment 8: Statistical Validity of P/2 Test
Comment 9: Programming Errors
Company-Specific Calculation Issues
Comment 10: Addition of G&A, Financial and Selling Expenses to GFL
Processing Costs
Comment 11: Weight-Averaging of Dubai Wire and GFL Expenses for G&A and
Financial Expense Ratios
Comment 12: Scrap Offset Revisions
Comment 13: Affiliated Party Loans and Leases
Comment 14: Calculation of Financial Expense Offset
Comment 15: Adjustment of GFL CV Profit Ratio for COM Revisions
Comment 16: Calculation of CV Selling Expenses and Profit Based on GFL
Screw Sales
Comment 17: LOT Adjustment for CV Comparisons
[FR Doc. E8-13490 Filed 6-13-08; 8:45 am]
BILLING CODE 3510-DS-S