Steel Wire Garment Hangers From the People's Republic of China: Affirmative Final Determination of Circumvention of the Antidumping Duty Order, 66895-66899 [2011-27972]
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Federal Register / Vol. 76, No. 209 / Friday, October 28, 2011 / Notices
result of this transition, the scope
language we used in the 1991 Federal
Register notice is slightly different from
the scope language of the original final
determination and antidumping duty
order.
Until January 1, 1989, such
merchandise was classifiable under item
numbers 610.3231, 610.3234, 610.3241,
610.3242, 610.3243, 610.3252, 610.3254,
610.3256, 610.3258, and 610.4925 of the
TSUSA. This merchandise is currently
classifiable under HTS item numbers
7306.30.1000, 7306.30.5025,
7306.30.5032, 7306.30.5040,
7306.30.5055, 7306.30.5085,
7306.30.5090. As with the TSUSA
numbers, the HTS numbers are
provided for convenience and customs
purposes. The written product
description remains dispositive.3 4
Turkey—Welded Carbon Steel Pipe and
Tube (A–489–501)
sroberts on DSK5SPTVN1PROD with NOTICES
The products covered by this order
include circular welded non-alloy steel
pipes and tubes, of circular crosssection, not more than 406.4 millimeters
(16 inches) in outside diameter,
regardless of wall thickness, surface
finish (black, or galvanized, painted), or
end finish (plain end, beveled end,
threaded and coupled). Those pipes and
tubes are generally known as standard
pipe, though they may also be called
structural or mechanical tubing in
certain applications. Standard pipes and
tubes are intended for the low pressure
conveyance of water, steam, natural gas,
air, and other liquids and gases in
plumbing and heating systems, air
conditioner units, automatic sprinkler
systems, and other related uses.
Standard pipe may also be used for light
load-bearing and mechanical
applications, such as for fence tubing,
and for protection of electrical wiring,
such as conduit shells.
The scope is not limited to standard
pipe and fence tubing, or those types of
mechanical and structural pipe that are
used in standard pipe applications. All
carbon steel pipes and tubes within the
physical description outlined above are
included in the scope of this order,
except for line pipe, oil country tubular
goods, boiler tubing, cold-drawn or
cold-rolled mechanical tubing, pipe and
tube hollows for redraws, finished
scaffolding, and finished rigid conduit.
3 Circular Welded Carbon Steel Pipes and Tubes
From Thailand: Final Results of Antidumping Duty
Administrative Review, 75 FR 64696 (October 20,
2010).
4 There was one scope ruling in which British
Standard light pipe 387/67, Class A–1 was found to
be within the scope of the order per remand. See
Scope Rulings, 58 FR 27542, (May 10, 1993).
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Imports of these products are
currently classifiable under the
following Harmonized Tariff Schedule
of the United States (‘‘HTSUS’’)
subheadings: 7306.30.10.00,
7306.30.50.25, 7306.30.50.32,
7306.30.50.40, 7306.30.50.55,
7306.30.50.85, and 7306.30.50.90.
Although the HTSUS subheadings are
provided for convenience and customs
purposes, our written description of the
scope of this proceeding is dispositive.5
[FR Doc. 2011–27957 Filed 10–27–11; 8:45 am]
BILLING CODE 3510–DS–P
DEPARTMENT OF COMMERCE
International Trade Administration
[A–570–918]
Steel Wire Garment Hangers From the
People’s Republic of China:
Affirmative Final Determination of
Circumvention of the Antidumping
Duty Order
Import Administration,
International Trade Administration,
Department of Commerce.
AGENCY:
The Department of Commerce
(‘‘the Department’’) continues to
determine that steel wire garment
hangers (‘‘garment hangers’’) exported
by Angang Clothes Rack Manufacture
Co., Ltd. (‘‘Angang’’) and Quyky Yanglei
International Co., Ltd. (‘‘Quyky’’) are
circumventing the antidumping duty
order 1 on garment hangers from the
People’s Republic of China (‘‘PRC’’),
pursuant to section 781(b) of the Tariff
Act of 1930, as amended (‘‘the Act’’).
SUMMARY:
DATES:
Effective Date: October 28, 2011.
FOR FURTHER INFORMATION CONTACT:
Irene Gorelik, Office 9, Import
Administration, International Trade
Administration, U.S. Department of
Commerce, 14th Street and Constitution
Avenue NW., Washington, DC 20230;
telephone: (202) 482–6905.
SUPPLEMENTARY INFORMATION:
Background
On May 10, 2011, the Department
published in the Federal Register the
affirmative preliminary determination
that garment hangers exported by
Angang and Quyky are circumventing
the Order on garment hangers from the
5 Certain Welded Carbon Steel Pipe and Tube
From Turkey: Notice of Final Antidumping Duty
Administrative Review, 75 FR 64250.64251 (October
19, 2010).
1 See Notice of Antidumping Duty Order: Steel
Wire Garment Hangers from the People’s Republic
of China, 73 FR 58111 (October 6, 2008) (‘‘Order’’).
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66895
PRC, as provided in section 781(b) of
the Act.2
On June 13, 2011, Petitioner 3 and
Angang filed their case briefs. On June
20, 2011, Petitioner and Angang filed
their rebuttal briefs. Quyky did not file
either a case brief or rebuttal brief.
Based on the timely filed request by
Angang, the Department held a public
hearing on June 28, 2011.4 On July 1,
2011, Angang filed a letter requesting
the Department to strike portions of
Petitioner’s rebuttal brief dated June 20,
2011, alleging untimely filed new
factual information and arguments were
included.
Scope of the Antidumping Duty Order
The merchandise that is subject to the
order is steel wire garment hangers,
fabricated from carbon steel wire,
whether or not galvanized or painted,
whether or not coated with latex or
epoxy or similar gripping materials,
and/or whether or not fashioned with
paper covers or capes (with or without
printing) and/or nonslip features such
as saddles or tubes. These products may
also be referred to by a commercial
designation, such as shirt, suit, strut,
caped, or latex (industrial) hangers.
Specifically excluded from the scope of
the order are wooden, plastic, and other
garment hangers that are not made of
steel wire. Also excluded from the scope
of the order are chrome-plated steel wire
garment hangers with a diameter of 3.4
mm or greater. The products subject to
the order are currently classified under
Harmonized Tariff Schedule of the
United States (‘‘HTSUS’’) subheadings
7326.20.0020, 7323.99.9060 and
7323.99.9080.
Although the HTSUS subheadings are
provided for convenience and customs
purposes, the written description of the
merchandise is dispositive.
Scope of the Anti-Circumvention
Inquiry
The products covered by this inquiry
are garment hangers, as described in the
‘‘Scope of the Antidumping Duty
Order’’ section above, that are exported
from the Socialist Republic of Vietnam
(‘‘Vietnam’’), but manufactured from
2 See Steel Wire Garment Hangers from the
People’s Republic of China: Affirmative Preliminary
Determination of Circumvention of the
Antidumping Duty Order and Extension of Final
Determination, 76 FR 27007 (May 10, 2011)
(‘‘Preliminary Determination’’).
3 Petitioner is M&B Metal Products Co.
4 During the public hearing, the Department noted
that Angang provided untimely new factual
information within its presentation, which was
stricken from the record within the hearing
transcript. See Memorandum to the File from Irene
Gorelik, regarding; ‘‘revised transcript of the public
hearing,’’ dated July 19, 2011.
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PRC-origin, semi-finished hangers and
completed in Vietnam with PRC-origin,
paper attachments and other direct
materials such as latex or glue.
While we acknowledge that Angang
has repeatedly stated on the record that
it also self-produces garment hangers
from steel wire rod,5 the focus and
intent of this proceeding is to determine
whether the semi-finished hangers: (1)
Are manufactured in the PRC; (2) are
exported to Angang’s facility in Vietnam
for completion (by adding PRC-origin
paper attachments, such as tubes, PRCorigin latex or glue); 6 and (3) then are
exported by Angang to the United States
as Vietnamese-origin garment hangers
constitutes circumvention of the Order
under section 781(b) of the Act.
Analysis of Comments Received
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All issues raised in the postpreliminary comments by parties in this
proceeding are addressed in the
‘‘Memorandum from Christian Marsh,
Deputy Assistant Secretary for
Antidumping and Countervailing Duty
Operations, to Ronald K. Lorentzen,
Deputy Assistant Secretary for Import
Administration, re: Steel Wire Garment
Hangers from the People’s Republic of
China: Issues and Decision
Memorandum for the Final
Determination of the AntiCircumvention Inquiry’’ (‘‘Decision
Memorandum’’), dated concurrently
with notice and hereby adopted by this
notice.
A list of the issues which the parties
raised and to which the Department
responds in the Decision Memorandum
is attached to this notice as Appendix I.
The Decision Memorandum is a public
document and is on file electronically
via Import Administration’s
Antidumping and Countervailing Duty
Centralized Electronic Service System
(‘‘IA ACCESS’’). Access to IA ACCESS
is available in the Central Records Unit,
room 7046 of the main Department of
Commerce building. In addition, a
complete version of the Decision
Memorandum can be accessed directly
on the Internet at https://www.trade.gov/
ia/. The signed Decision Memorandum
and the electronic versions of the
5 See Preliminary Determination, 76 FR at 27008.
See also Angang’s Questionnaire Response dated
January 19, 2011, at 5; Angang’s Questionnaire
Response dated February 1, 2011, at Exhibit 9; and
Angang’s Comments dated December 22, 2010, at 2–
5.
6 Angang has reported that the direct materials
applied to the PRC-origin, semi-finished hangers are
also manufactured in, and supplied from, the PRC.
See, e.g., Angang’s Questionnaire Response dated
November 19, 2010, at Exhibit 5; Angang’s
Questionnaire Response dated March 21, 2011, at
4.
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Decision Memorandum are identical in
content.
Affirmative Final Determination of
Circumvention
For the final determination, we
continue to rely on the statutory criteria
that we considered in making our
Preliminary Determination.7 Based on
our review of the record evidence and
our analysis of the comments received,
the Department continues to find that
Quyky’s and Angang’s Vietnamese
exports of garment hangers produced
from PRC-origin, semi-finished hangers
constitute circumvention of the Order
and are properly considered to be
within the same class or kind of
merchandise subject to the Order on
garment hangers from the PRC. For a
complete discussion of the Department’s
analysis, see the Decision
Memorandum.
Quyky
Facts Available
Section 776(a) of the Act requires the
Department to rely on facts otherwise
available if necessary information is not
available on the record or an interested
party or any other person: (A) withholds
information requested by the
Department; (B) fails to provide
requested information by the deadlines
for submission of the information or in
the form and manner requested, subject
to subsections (c)(1) and (e) of section
782 of the Act; (C) significantly impedes
a proceeding; or (D) provides requested
information, but the information cannot
be verified as provided in section 782(i)
of the Act.
As we stated in the Preliminary
Determination, because Quyky failed to
respond to any of the Department’s
requests for information, we found that
it failed to cooperate to the best of its
ability pursuant to sections 776(a)(2)(A)
and (B) of the Act, and, that an adverse
inference is warranted pursuant to
section 776(b) of the Act.8 Further, as an
adverse inference, the Department
found that all of the garment hangers
produced and/or exported by Quyky to
the United States are circumventing the
Order.9 Because no party has contested
the substantial evidence on the record
supporting the Department’s
preliminary determination for Quyky,
we continue to find, using the stated
adverse inference, that all of the
garment hangers produced and/or
exported by Quyky to the United States
are circumventing the Order.
7 See
Preliminary Determination, 76 FR at 27007.
8 See Preliminary Determination, 76 FR at 27008.
9 See id.
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Angang
Statutory Provisions Regarding
Circumvention
Section 781 of the Act addresses
circumvention of antidumping or
countervailing duty orders. With respect
to merchandise assembled or completed
in a third country, section 781(b)(1) of
the Act provides that if: (A) The
merchandise imported into the United
States is of the same class or kind as any
merchandise produced in a foreign
country that is the subject of an
antidumping duty order; (B) before
importation into the United States, such
imported merchandise is completed or
assembled in a third country from
merchandise which is subject to such an
order or is produced in the foreign
country with respect to which such
order applies; (C) the process of
assembly or completion in a third
country is minor or insignificant; (D) the
value of the merchandise produced in
the foreign country to which the
antidumping duty order applies is a
significant portion of the total value of
the merchandise exported to the United
States; and (E) the Department
determines that action is appropriate to
prevent evasion of an order, then the
Department, after taking into account
any advice provided by the United
States International Trade Commission,
under section 781(e) of the Act, may
include such imported merchandise
within the scope of an order at any time
an order is in effect.
In determining whether the process of
assembly or completion in a third
country is minor or insignificant under
section 781(b)(1)(C) of the Act, section
781(b)(2) of the Act directs the
Department to consider: (A) The level of
investment in the third country; (B) the
level of research and development in
the third country; (C) the nature of the
production process in the third country;
(D) the extent of production facilities in
the third country; and (E) whether the
value of processing performed in the
third country represents a small
proportion of the value of the
merchandise imported into the United
States. However, none of these five
factors, by itself, is controlling on the
Department’s determination of whether
the process of assembly or completion
in a third country is minor or
insignificant.10 Accordingly, it is the
Department’s practice to evaluate each
of these factors as they exist in the third
10 See Statement of Administrative Action
(‘‘SAA’’) accompanying the Uruguay Round
Agreements Act, H. Doc. No. 103–316, at 893
(1994).
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country depending on the particular
anti-circumvention inquiry.11
Further, another step in the
circumvention inquiry asks the
Department, under section 781(b)(1)(D)
of the Act, to discern whether the value
of the merchandise produced in the
foreign country to which an
antidumping duty order applies is a
significant portion of the total value of
the merchandise exported to the United
States. The Department must answer
affirmatively to find circumvention.
Finally, section 781(b)(3) of the Act
sets forth the factors to consider in
determining whether to include
merchandise assembled or completed in
a third country in an antidumping duty
order. Specifically, the Department shall
take into account such factors as: (A) the
pattern of trade, including sourcing
patterns; (B) Whether the manufacturer
or exporter of the merchandise is
affiliated with the person who, in the
third country, uses the merchandise to
complete or assemble the merchandise
which is subsequently imported into the
United States; and (C) whether imports
of the merchandise into the third
country have increased after the
initiation of the investigation which
resulted in the issuance of an order.
In making a final determination in
accordance with the criteria enumerated
in section 781(b) of the Act as outlined
above,12 we have continued to rely on
the information obtained from Angang
as well as the information placed on the
record by the Department at the
Preliminary Determination.
Consequently, for the final
determination, we continue to find that,
based on the statutory factors above,
Angang’s process of converting the PRCorigin, semi-finished hangers in
Vietnam and exporting them to the
United States constitutes circumvention
of the Order.
Summary of Analysis of Statutory
Provisions
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We considered all of the comments
submitted by Angang and Petitioner,
and find that, pursuant to section 781(b)
of the Act, exports to the United States
of garment hangers produced by Angang
11 See Certain Tissue Paper Products from the
People’s Republic of China: Affirmative Final
Determination of Circumvention of the
Antidumping Duty Order, 73 FR 57591, 57592
(October 3, 2008) (‘‘Tissue Paper Anti-Circ 2008’’).
12 See Preliminary Determination, 76 FR at
27008–27015. Furthermore, Angang has not
opposed the Department’s preliminary finding that
it has circumvented the Order, as noted in its case
brief, where Angang stated that it ‘‘has not
challenged the merits of the Department’s
affirmative preliminary determination with respect
to wires formed in China.’’ See Angang’s Case Brief,
dated June 13, 2011 at 22.
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using PRC-origin, semi-finished hangers
constitute circumvention of the Order.
(A) Whether Merchandise Imported Into
the United States Is of the Same Class
or Kind as Other Merchandise That Is
Subject to the Order
As we stated in the Preliminary
Determination, we reviewed the
information provided by Angang in its
questionnaire responses and found that
the record evidence indicates that
Angang’s garment hangers, produced
from PRC-origin, semi-finished hangers
and exported to the United States meet
the written description of the products
subject to the Order.13 Further, we
preliminarily found that the products
identified and described in the product
list are no different than those identified
in the scope of the Order.14 Finally, we
noted that Angang itself admitted that,
from September 2008 through August
2010, it sold garment hangers that meet
the scope of the Order.15 As the facts
have not changed from the Preliminary
Determination, we continue to find that
the merchandise subject to this inquiry
is the same class or kind of merchandise
as that subject to the Order, pursuant to
section 781(b)(1)(A) of the Act. The
Department also preliminarily
determined that, based on record
evidence, Angang’s affiliates in the PRC
were the sole suppliers of the PRCorigin, semi-finished hangers, to which
Angang added either PRC-origin powder
coating or paint and paper attachments
such as tubes and then exported this
merchandise to the United States.16 The
record clearly shows that Angang
purchased semi-finished hangers from
its PRC affiliates, further processed the
unfinished hangers in Vietnam, packed,
and exported the finished garment
hangers to the United States as
Vietnamese-origin.17 As the facts have
not changed from the Preliminary
Determination, we continue to find that
the merchandise subject to this anticircumvention inquiry was completed
or assembled in Vietnam from PRCorigin merchandise which is subject to
the Order, pursuant to section
781(b)(1)(B) of the Act.
13 See
Preliminary Determination, 76 FR at 27009.
id.
15 See id.
16 See id.
17 See id.
14 See
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66897
(B) Whether, Before Importation Into the
United States, Such Imported
Merchandise Is Completed or
Assembled in a Third Country From
Merchandise Which Is Subject to the
Order or Produced in the Foreign
Country That Is Subject to the Order
Pursuant to section 781(b)(1)(C) of the
Act, we preliminarily determined that
the record evidence of this proceeding
supported a finding that the process or
completion of the PRC-origin, semifinished hangers to finished garment
hangers in Vietnam is minor or
insignificant.18 Under section
781(b)(1)(C) of the Act, section 781(b)(2)
of the Act directed us to address other
criteria, which we found to have
supported our preliminary finding that
the processing or completion in
Vietnam was minor or insignificant.19
First, pursuant to section 781(b)(2)(A) of
the Act, we found that Angang’s level of
investment in Vietnam was minimal in
terms of converting PRC-origin, semifinished hangers into finished garment
hangers.20 Second, pursuant to section
781(b)(2)(B) of the Act, we found that
the lack of evidence of research and
development (‘‘R&D’’) initiatives by
Angang in the production of garment
hangers shows that R&D is not a
significant factor in Angang’s
completion of PRC-origin, semi-finished
garment hangers in Vietnam.21 Third,
pursuant to section 781(b)(2)(C) of the
Act, we found that the portion of the
overall production process of garment
hangers in Vietnam conducted by
Angang in assembling or completing the
PRC-origin, semi-finished garment
hangers into finished garment hangers is
limited and minor compared to the PRC
affiliates’ share of the overall production
process in the production of the semifinished garment hangers and the other
direct materials they supply to Angang
to finish the semi-finished hangers in
Vietnam.22 Fourth, pursuant to section
781(b)(2)(D) of the Act, we found that
the extent of Angang’s production
facilities in Vietnam is minor with
respect to completing PRC-origin, semifinished hangers to finished garment
hangers because the energy, labor, and
capital equipment used by Angang in
converting the PRC-origin, semifinished hangers into finished garment
hangers is not substantial in comparison
to the materials, labor, energy, and
capital equipment used by its PRC
affiliates to produce the semi-finished
18 See
id. at 27010.
id. at 27009–27012.
20 See id. at 27010.
21 See id.
22 See id. at 27011.
19 See
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garment hangers.23 Finally, pursuant to
section 781(b)(2)(E) of the Act, we found
that the value of the processing
performed by Angang to convert the
PRC-origin, semi-finished hangers into
finished garment hangers represents a
small proportion of the total value of the
finished merchandise imported into the
United States.24
Therefore, we preliminarily found
that, pursuant to sections 781(b)(2)(A)–
(E) of the Act, Angang’s processing
operation to convert PRC-origin, semifinished hangers into finished garment
hangers in Vietnam is minor or
insignificant.25 We based our
preliminary decision as to whether the
processing operation to convert PRCorigin, semi-finished hangers into
finished garment hangers is minor or
insignificant on the totality of the record
evidence of this anti-circumvention
inquiry and compared the relative
information regarding the production
processes for Angang and its PRC
affiliates. For the final determination,
we continue to find that, based on the
totality of the record, each statutory
criterion under section 781(b)(2) of the
Act and all other factors point to the
conclusion that Angang’s process of
converting the PRC-origin, semifinished hangers in Vietnam was minor
or insignificant and, consistent with our
analysis in prior anti-circumvention
inquiries.26
(C) Whether the Value of the
Merchandise Produced in the Foreign
Country To Which the Order Applies Is
a Significant Portion of the Total Value
of the Merchandise Exported to the
United States
Under section 781(b)(1)(D) of the Act,
the value of the merchandise produced
in the foreign country to which an
antidumping duty order applies must be
a significant portion of the total value of
the merchandise exported to the United
States in order to find circumvention.
As discussed above, we found that the
production process in the PRC
id. at 27011–12.
id. at 27012.
25 See id. at 27012–13.
26 See, e.g., Anti-Circumvention Inquiry of the
Antidumping and Countervailing Duty Orders on
Certain Pasta From Italy: Affirmative Preliminary
Determinations of Circumvention of Antidumping
and Countervailing Duty Orders, 68 FR 46571,
46574–75 (August 6, 2003), unchanged in AntiCircumvention Inquiry of the Antidumping and
Countervailing Duty Orders on Certain Pasta from
Italy: Affirmative Final Determinations of
Circumvention of Antidumping and Countervailing
Duty Orders, 68 FR 54888 (September 19, 2003);
and Hot-Rolled Lead and Bismuth Carbon Steel
Products from Germany and the United Kingdom;
Negative Final Determinations of Circumvention of
Antidumping and Countervailing Duty Orders, 64
FR 40336, 40338–40 (July 26, 1999).
manufactures the main inputs, that all
the direct materials are sourced from the
PRC, and that there exists only limited
production processes in Vietnam,
thereby evincing that a great majority of
the value of the finished merchandise is
based on the PRC-production of the
semi-finished hangers and the other
direct materials which are applied to
those PRC-origin, semi-finished hangers
in Vietnam.27 Based on our analysis and
record evidence, we found that the
value of the PRC-origin, semi-finished
hangers taken as a whole constitutes a
significant portion of the total value of
the finished product ultimately
exported to the United States.
(D) Other Factors To Consider
As previously noted, section 781(b)(3)
of the Act instructs the Department to
consider, in determining whether to
include merchandise assembled or
completed in a foreign country within
the scope of an order, such factors as:
pattern of trade, including sourcing
patterns; affiliations between
manufacturers or exporters of
merchandise in the country subject to
the order and the person who uses the
merchandise to assemble or complete in
the third country the merchandise that
is exported to the United States; and
whether imports into the third country
of the merchandise described in section
781(b)(1)(B) of the Act have increased
after the initiation of the investigation.
We preliminarily determined that: (1)
The data related to patterns of trade in
this case show that PRC exports have
decreased significantly whereas
Vietnamese exports have increased
exponentially since the initiation of the
less than fair value (‘‘LTFV’’)
investigation; (2) Angang maintained an
affiliation with two PRC companies; 28
and (3) Angang’s imports of PRC-origin,
semi-finished hangers increased after
the initiation of the LTFV investigation
and PRC exports of the same to Vietnam
similarly increased after the initiation of
the LTFV investigation.29 We found at
that time,30 and continue to find in this
23 See
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24 See
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27 See
Preliminary Determination, 76 FR at 27013.
‘‘Memorandum to the File through
Catherine Bertrand, Program Manager, Office 9 from
Irene Gorelik, Senior Analyst, re; Circumvention
Inquiry on Steel Wire Garment Hangers from the
People’s Republic of China: Proprietary Analysis of
Certain Statutory Factors for Angang Clothes Rack
Manufacture Co., Ltd. for the Preliminary
Determination,’’ (‘‘Angang Prelim Analysis
Memo’’), dated May 3, 2011. For the final
determination, we continue to find that affiliation
exists between Angang and these two PRC entities
referenced in Angang Prelim Analysis
Memorandum, pursuant to section 771(33) of the
Act.
29 See Preliminary Determination, 76 FR at
27013–14.
30 See id. at 27014–15.
28 See
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final determination, that these facts and
the related record evidence all support
the conclusion that circumvention of
the Order has occurred.
Affirmative Final Determination
Summary
With respect to Quyky, we
preliminarily found that Quyky
circumvented the Order because it
failed to provide the Department with
any information at all, thus we are
unable to distinguish between its
imports or purchase of semi-finished
hangers from the PRC for purposes other
than assembly into merchandise
covered by the Order. Consequently,
because Quyky refused to comply with
the Department’s request for
information, we continue to find that it
failed to cooperate to the best of its
ability and, therefore, that an adverse
inference is warranted pursuant to
section 776(b) of the Act. Accordingly,
as stated above, as an adverse inference
the Department preliminarily found that
all of the garment hangers produced
and/or exported by Quyky to the United
States are circumventing the Order.
Therefore, in light of our uncontested
Preliminary Determination and the
substantial record evidence supporting
that decision, the Department will
instruct U.S. Customs and Border
Protection (‘‘CBP’’) to suspend
liquidation on all entries of garment
hangers produced and/or exported by
Quyky that were entered, or withdrawn
from warehouse, for consumption on or
after the date of initiation of the anticircumvention inquiry.
Further, with respect to Angang, we
preliminarily found that Angang has
circumvented the Order in accordance
with section 781(b)(1) and (2) of the Act.
Pursuant to section 781(b)(1) of the Act,
we found that the merchandise sold in
the United States is within the same
class or kind of merchandise that is
subject to the Order and was completed
or assembled in a third country.
Additionally, pursuant to section
781(b)(2), we found that the process or
assembly of the PRC-origin semifinished hangers into finished garment
hangers by Angang is minor and
insignificant. Furthermore, in
accordance with section 781(b)(1)(D) of
the Act, we found that the value of the
merchandise produced in the PRC is a
significant portion of the total value of
the merchandise exported to the United
States.
The record evidence continues to
support an affirmative finding of
circumvention in accordance with
section 781(b)(1) and (2) of the Act.
Moreover, we continue to find the
factors required by section 781(b)(3) of
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sroberts on DSK5SPTVN1PROD with NOTICES
the Act indicate that there is
circumvention of the Order.
Consequently, our statutory analysis
leads us to find that there was
circumvention of the Order as a result
of Angang’s assembly of the PRC-origin,
semi-finished hangers into finished
garment hangers in Vietnam for export
to the United States, as discussed above.
Therefore, in light of our final
determination, the Department will
instruct CBP to suspend liquidation on
all entries of garment hangers produced
and/or exported by Angang that were
entered, or withdrawn from warehouse,
for consumption on or after the date of
initiation of the anti-circumvention
inquiry. Should the Department conduct
an administrative review of the Order in
the future, both Quyky and Angang will
have the opportunity to provide
information related to their use of PRCorigin or self-produced garment hangers
so that the Department may determine
the appropriate assessment rate.
Continuation of Suspension of
Liquidation
In accordance with section 733(d) of
the Act, the Department will continue to
direct CBP to suspend liquidation and
to require a cash deposit of estimated
duties, at the PRC-wide rate of 187.25
percent, on all unliquidated entries of
garment hangers produced and/or
exported by Angang and Quyky that
were entered, or withdrawn from
warehouse, for consumption on or after
July 16, 2010, the date of initiation of
the anti-circumvention inquiry.
In comments to the Department,
Angang asked the Department (1) to
revisit its determination to suspend
liquidation of all of Angang’s entries
and (2) to allow certifications for
Angang’s future entries. Angang has
provided conflicting statements on
whether it could segregate PRC-origin,
semi-finished hangers from the selfproduced, semi-finished hangers in
Vietnam,31 and record evidence
supports the conclusion that Angang
commingles the two groups of
merchandise in a work-in-progress
warehouse. Therefore, the Department
declines to grant Angang’s requests. For
further discussion of this issue, see the
Decision Memorandum.32
As stated above, if requested, should
the Department conduct an
administrative review in the future, and
determine in the context of that review
that either Quyky or Angang have not
produced for export garment hangers
using PRC-origin, semi-finished
hangers, the Department will consider a
changed circumstances review pursuant
to section 751(b) of the Act to determine
if the continued suspension of all
garment hangers produced by Quyky or
Angang is warranted.
Notification to Interested Parties
This notice serves as the only
reminder to parties subject to the
administrative protective order (‘‘APO’’)
of their responsibility concerning the
return or destruction of proprietary
information disclosed under APO in
accordance with 19 CFR 351.305.
Timely written 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 terms of an
APO is a violation which is subject to
sanction.
This final affirmative circumvention
determination is published in
accordance with section 781(b) of the
Act and 19 CFR 351.225(h).
Dated: October 21, 2011.
Ronald K. Lorentzen,
Deputy Assistant Secretary for Import
Administration.
Appendix I
Discussion of the Issues
Comment 1: Affirmative Preliminary
Determination of Circumvention
Regarding Quyky
Comment 2: Affirmative Preliminary
Determination of Circumvention
Regarding Angang
Comment 3: Appropriate Suspension of
Liquidation of Angang’s Exports
Comment 4: Whether To Require a
Certification Process for Angang’s
Exports
Comment 5: Appropriate Rate To Assign
to Angang
[FR Doc. 2011–27972 Filed 10–27–11; 8:45 am]
BILLING CODE 3510–DS–P
31 See, e.g., Angang’s Questionnaire Responses
dated October 8, 2010, at Exhibit 1B; November 19,
2010, at 13; March 21, 2011, at 2; Angang’s Case
Brief dated June 13, 2011 at 4–9; see also Decision
Memorandum at Comment 3.
32 See Decision Memorandum at Comments 3, 4,
and 5.
VerDate Mar<15>2010
16:56 Oct 27, 2011
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66899
DEPARTMENT OF COMMERCE
International Trade Administration
[A–351–809, A–201–805, A–580–809, A–583–
814, A–583–008]
Certain Circular Welded Non-Alloy
Steel Pipe From Brazil, Mexico, the
Republic of Korea, and Taiwan; and
Certain Circular Welded Carbon Steel
Pipes and Tubes From Taiwan: Final
Results of the Expedited Third Sunset
Reviews of the Antidumping Duty
Order
Import Administration,
International Trade Administration,
Department of Commerce.
SUMMARY: On August 1, 2011 the
Department of Commerce (Department)
initiated the third five-year (sunset)
reviews of the antidumping duty orders
on certain circular welded non-alloy
steel pipe from Brazil, Mexico, the
Republic of Korea, and Taiwan; and
certain circular welded carbon steel
pipes and tubes from Taiwan, pursuant
to section 751(c) of the Tariff Act of
1930, as amended (the Act). The
Department has conducted expedited
(120-day) sunset reviews of these
antidumping duty orders pursuant to
section 751(c)(3)(B) of the Act and 19
CFR 351.218(e)(1)(ii)(C)(2). As a result
of these reviews, the Department finds
that revocation of the antidumping duty
orders would likely lead to a
continuation or recurrence of dumping,
at the levels indicated in the ‘‘Final
Results of Sunset Reviews’’ section of
this notice, infra.
FOR FURTHER INFORMATION: Steve
Bezirganian, Deborah Scott or Robert
James, AD/CVD Operations, Office 7,
Import Administration, International
Trade Administration, U.S. Department
of Commerce, 14th Street and
Constitution Avenue NW., Washington,
DC 20230; telephone: (202) 482–1131,
(202) 482–2657 or (202) 482–0649,
respectively.
AGENCY:
SUPPLEMENTARY INFORMATION:
Background
On August 1, 2011, the Department
published in the Federal Register the
notice of initiation of the sunset reviews
of the antidumping duty orders on
certain circular welded non-alloy steel
pipe from Brazil, Mexico, the Republic
of Korea, and Taiwan; and certain
circular welded carbon steel pipes and
tubes from Taiwan, pursuant to section
751(c) of the Act. See Initiation of FiveYear (‘‘Sunset’’) Review, 76 FR 38613
(July 1, 2011) (Notice of Initiation).
The Department received a notice of
intent to participate from the following
E:\FR\FM\28OCN1.SGM
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Agencies
[Federal Register Volume 76, Number 209 (Friday, October 28, 2011)]
[Notices]
[Pages 66895-66899]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-27972]
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DEPARTMENT OF COMMERCE
International Trade Administration
[A-570-918]
Steel Wire Garment Hangers From the People's Republic of China:
Affirmative Final Determination of Circumvention of the Antidumping
Duty Order
AGENCY: Import Administration, International Trade Administration,
Department of Commerce.
SUMMARY: The Department of Commerce (``the Department'') continues to
determine that steel wire garment hangers (``garment hangers'')
exported by Angang Clothes Rack Manufacture Co., Ltd. (``Angang'') and
Quyky Yanglei International Co., Ltd. (``Quyky'') are circumventing the
antidumping duty order \1\ on garment hangers from the People's
Republic of China (``PRC''), pursuant to section 781(b) of the Tariff
Act of 1930, as amended (``the Act'').
---------------------------------------------------------------------------
\1\ See Notice of Antidumping Duty Order: Steel Wire Garment
Hangers from the People's Republic of China, 73 FR 58111 (October 6,
2008) (``Order'').
---------------------------------------------------------------------------
DATES: Effective Date: October 28, 2011.
FOR FURTHER INFORMATION CONTACT: Irene Gorelik, Office 9, Import
Administration, International Trade Administration, U.S. Department of
Commerce, 14th Street and Constitution Avenue NW., Washington, DC
20230; telephone: (202) 482-6905.
SUPPLEMENTARY INFORMATION:
Background
On May 10, 2011, the Department published in the Federal Register
the affirmative preliminary determination that garment hangers exported
by Angang and Quyky are circumventing the Order on garment hangers from
the PRC, as provided in section 781(b) of the Act.\2\
---------------------------------------------------------------------------
\2\ See Steel Wire Garment Hangers from the People's Republic of
China: Affirmative Preliminary Determination of Circumvention of the
Antidumping Duty Order and Extension of Final Determination, 76 FR
27007 (May 10, 2011) (``Preliminary Determination'').
---------------------------------------------------------------------------
On June 13, 2011, Petitioner \3\ and Angang filed their case
briefs. On June 20, 2011, Petitioner and Angang filed their rebuttal
briefs. Quyky did not file either a case brief or rebuttal brief. Based
on the timely filed request by Angang, the Department held a public
hearing on June 28, 2011.\4\ On July 1, 2011, Angang filed a letter
requesting the Department to strike portions of Petitioner's rebuttal
brief dated June 20, 2011, alleging untimely filed new factual
information and arguments were included.
---------------------------------------------------------------------------
\3\ Petitioner is M&B Metal Products Co.
\4\ During the public hearing, the Department noted that Angang
provided untimely new factual information within its presentation,
which was stricken from the record within the hearing transcript.
See Memorandum to the File from Irene Gorelik, regarding; ``revised
transcript of the public hearing,'' dated July 19, 2011.
---------------------------------------------------------------------------
Scope of the Antidumping Duty Order
The merchandise that is subject to the order is steel wire garment
hangers, fabricated from carbon steel wire, whether or not galvanized
or painted, whether or not coated with latex or epoxy or similar
gripping materials, and/or whether or not fashioned with paper covers
or capes (with or without printing) and/or nonslip features such as
saddles or tubes. These products may also be referred to by a
commercial designation, such as shirt, suit, strut, caped, or latex
(industrial) hangers. Specifically excluded from the scope of the order
are wooden, plastic, and other garment hangers that are not made of
steel wire. Also excluded from the scope of the order are chrome-plated
steel wire garment hangers with a diameter of 3.4 mm or greater. The
products subject to the order are currently classified under Harmonized
Tariff Schedule of the United States (``HTSUS'') subheadings
7326.20.0020, 7323.99.9060 and 7323.99.9080.
Although the HTSUS subheadings are provided for convenience and
customs purposes, the written description of the merchandise is
dispositive.
Scope of the Anti-Circumvention Inquiry
The products covered by this inquiry are garment hangers, as
described in the ``Scope of the Antidumping Duty Order'' section above,
that are exported from the Socialist Republic of Vietnam (``Vietnam''),
but manufactured from
[[Page 66896]]
PRC-origin, semi-finished hangers and completed in Vietnam with PRC-
origin, paper attachments and other direct materials such as latex or
glue.
While we acknowledge that Angang has repeatedly stated on the
record that it also self-produces garment hangers from steel wire
rod,\5\ the focus and intent of this proceeding is to determine whether
the semi-finished hangers: (1) Are manufactured in the PRC; (2) are
exported to Angang's facility in Vietnam for completion (by adding PRC-
origin paper attachments, such as tubes, PRC-origin latex or glue); \6\
and (3) then are exported by Angang to the United States as Vietnamese-
origin garment hangers constitutes circumvention of the Order under
section 781(b) of the Act.
---------------------------------------------------------------------------
\5\ See Preliminary Determination, 76 FR at 27008. See also
Angang's Questionnaire Response dated January 19, 2011, at 5;
Angang's Questionnaire Response dated February 1, 2011, at Exhibit
9; and Angang's Comments dated December 22, 2010, at 2-5.
\6\ Angang has reported that the direct materials applied to the
PRC-origin, semi-finished hangers are also manufactured in, and
supplied from, the PRC. See, e.g., Angang's Questionnaire Response
dated November 19, 2010, at Exhibit 5; Angang's Questionnaire
Response dated March 21, 2011, at 4.
---------------------------------------------------------------------------
Analysis of Comments Received
All issues raised in the post-preliminary comments by parties in
this proceeding are addressed in the ``Memorandum from Christian Marsh,
Deputy Assistant Secretary for Antidumping and Countervailing Duty
Operations, to Ronald K. Lorentzen, Deputy Assistant Secretary for
Import Administration, re: Steel Wire Garment Hangers from the People's
Republic of China: Issues and Decision Memorandum for the Final
Determination of the Anti-Circumvention Inquiry'' (``Decision
Memorandum''), dated concurrently with notice and hereby adopted by
this notice.
A list of the issues which the parties raised and to which the
Department responds in the Decision Memorandum is attached to this
notice as Appendix I. The Decision Memorandum is a public document and
is on file electronically via Import Administration's Antidumping and
Countervailing Duty Centralized Electronic Service System (``IA
ACCESS''). Access to IA ACCESS is available in the Central Records
Unit, room 7046 of the main Department of Commerce building. In
addition, a complete version of the Decision Memorandum can be accessed
directly on the Internet at https://www.trade.gov/ia/. The signed
Decision Memorandum and the electronic versions of the Decision
Memorandum are identical in content.
Affirmative Final Determination of Circumvention
For the final determination, we continue to rely on the statutory
criteria that we considered in making our Preliminary Determination.\7\
Based on our review of the record evidence and our analysis of the
comments received, the Department continues to find that Quyky's and
Angang's Vietnamese exports of garment hangers produced from PRC-
origin, semi-finished hangers constitute circumvention of the Order and
are properly considered to be within the same class or kind of
merchandise subject to the Order on garment hangers from the PRC. For a
complete discussion of the Department's analysis, see the Decision
Memorandum.
---------------------------------------------------------------------------
\7\ See Preliminary Determination, 76 FR at 27007.
---------------------------------------------------------------------------
Quyky
Facts Available
Section 776(a) of the Act requires the Department to rely on facts
otherwise available if necessary information is not available on the
record or an interested party or any other person: (A) withholds
information requested by the Department; (B) fails to provide requested
information by the deadlines for submission of the information or in
the form and manner requested, subject to subsections (c)(1) and (e) of
section 782 of the Act; (C) significantly impedes a proceeding; or (D)
provides requested information, but the information cannot be verified
as provided in section 782(i) of the Act.
As we stated in the Preliminary Determination, because Quyky failed
to respond to any of the Department's requests for information, we
found that it failed to cooperate to the best of its ability pursuant
to sections 776(a)(2)(A) and (B) of the Act, and, that an adverse
inference is warranted pursuant to section 776(b) of the Act.\8\
Further, as an adverse inference, the Department found that all of the
garment hangers produced and/or exported by Quyky to the United States
are circumventing the Order.\9\ Because no party has contested the
substantial evidence on the record supporting the Department's
preliminary determination for Quyky, we continue to find, using the
stated adverse inference, that all of the garment hangers produced and/
or exported by Quyky to the United States are circumventing the Order.
---------------------------------------------------------------------------
\8\ See Preliminary Determination, 76 FR at 27008.
\9\ See id.
---------------------------------------------------------------------------
Angang
Statutory Provisions Regarding Circumvention
Section 781 of the Act addresses circumvention of antidumping or
countervailing duty orders. With respect to merchandise assembled or
completed in a third country, section 781(b)(1) of the Act provides
that if: (A) The merchandise imported into the United States is of the
same class or kind as any merchandise produced in a foreign country
that is the subject of an antidumping duty order; (B) before
importation into the United States, such imported merchandise is
completed or assembled in a third country from merchandise which is
subject to such an order or is produced in the foreign country with
respect to which such order applies; (C) the process of assembly or
completion in a third country is minor or insignificant; (D) the value
of the merchandise produced in the foreign country to which the
antidumping duty order applies is a significant portion of the total
value of the merchandise exported to the United States; and (E) the
Department determines that action is appropriate to prevent evasion of
an order, then the Department, after taking into account any advice
provided by the United States International Trade Commission, under
section 781(e) of the Act, may include such imported merchandise within
the scope of an order at any time an order is in effect.
In determining whether the process of assembly or completion in a
third country is minor or insignificant under section 781(b)(1)(C) of
the Act, section 781(b)(2) of the Act directs the Department to
consider: (A) The level of investment in the third country; (B) the
level of research and development in the third country; (C) the nature
of the production process in the third country; (D) the extent of
production facilities in the third country; and (E) whether the value
of processing performed in the third country represents a small
proportion of the value of the merchandise imported into the United
States. However, none of these five factors, by itself, is controlling
on the Department's determination of whether the process of assembly or
completion in a third country is minor or insignificant.\10\
Accordingly, it is the Department's practice to evaluate each of these
factors as they exist in the third
[[Page 66897]]
country depending on the particular anti-circumvention inquiry.\11\
---------------------------------------------------------------------------
\10\ See Statement of Administrative Action (``SAA'')
accompanying the Uruguay Round Agreements Act, H. Doc. No. 103-316,
at 893 (1994).
\11\ See Certain Tissue Paper Products from the People's
Republic of China: Affirmative Final Determination of Circumvention
of the Antidumping Duty Order, 73 FR 57591, 57592 (October 3, 2008)
(``Tissue Paper Anti-Circ 2008'').
---------------------------------------------------------------------------
Further, another step in the circumvention inquiry asks the
Department, under section 781(b)(1)(D) of the Act, to discern whether
the value of the merchandise produced in the foreign country to which
an antidumping duty order applies is a significant portion of the total
value of the merchandise exported to the United States. The Department
must answer affirmatively to find circumvention.
Finally, section 781(b)(3) of the Act sets forth the factors to
consider in determining whether to include merchandise assembled or
completed in a third country in an antidumping duty order.
Specifically, the Department shall take into account such factors as:
(A) the pattern of trade, including sourcing patterns; (B) Whether the
manufacturer or exporter of the merchandise is affiliated with the
person who, in the third country, uses the merchandise to complete or
assemble the merchandise which is subsequently imported into the United
States; and (C) whether imports of the merchandise into the third
country have increased after the initiation of the investigation which
resulted in the issuance of an order.
In making a final determination in accordance with the criteria
enumerated in section 781(b) of the Act as outlined above,\12\ we have
continued to rely on the information obtained from Angang as well as
the information placed on the record by the Department at the
Preliminary Determination. Consequently, for the final determination,
we continue to find that, based on the statutory factors above,
Angang's process of converting the PRC-origin, semi-finished hangers in
Vietnam and exporting them to the United States constitutes
circumvention of the Order.
---------------------------------------------------------------------------
\12\ See Preliminary Determination, 76 FR at 27008-27015.
Furthermore, Angang has not opposed the Department's preliminary
finding that it has circumvented the Order, as noted in its case
brief, where Angang stated that it ``has not challenged the merits
of the Department's affirmative preliminary determination with
respect to wires formed in China.'' See Angang's Case Brief, dated
June 13, 2011 at 22.
---------------------------------------------------------------------------
Summary of Analysis of Statutory Provisions
We considered all of the comments submitted by Angang and
Petitioner, and find that, pursuant to section 781(b) of the Act,
exports to the United States of garment hangers produced by Angang
using PRC-origin, semi-finished hangers constitute circumvention of the
Order.
(A) Whether Merchandise Imported Into the United States Is of the Same
Class or Kind as Other Merchandise That Is Subject to the Order
As we stated in the Preliminary Determination, we reviewed the
information provided by Angang in its questionnaire responses and found
that the record evidence indicates that Angang's garment hangers,
produced from PRC-origin, semi-finished hangers and exported to the
United States meet the written description of the products subject to
the Order.\13\ Further, we preliminarily found that the products
identified and described in the product list are no different than
those identified in the scope of the Order.\14\ Finally, we noted that
Angang itself admitted that, from September 2008 through August 2010,
it sold garment hangers that meet the scope of the Order.\15\ As the
facts have not changed from the Preliminary Determination, we continue
to find that the merchandise subject to this inquiry is the same class
or kind of merchandise as that subject to the Order, pursuant to
section 781(b)(1)(A) of the Act. The Department also preliminarily
determined that, based on record evidence, Angang's affiliates in the
PRC were the sole suppliers of the PRC-origin, semi-finished hangers,
to which Angang added either PRC-origin powder coating or paint and
paper attachments such as tubes and then exported this merchandise to
the United States.\16\ The record clearly shows that Angang purchased
semi-finished hangers from its PRC affiliates, further processed the
unfinished hangers in Vietnam, packed, and exported the finished
garment hangers to the United States as Vietnamese-origin.\17\ As the
facts have not changed from the Preliminary Determination, we continue
to find that the merchandise subject to this anti-circumvention inquiry
was completed or assembled in Vietnam from PRC-origin merchandise which
is subject to the Order, pursuant to section 781(b)(1)(B) of the Act.
---------------------------------------------------------------------------
\13\ See Preliminary Determination, 76 FR at 27009.
\14\ See id.
\15\ See id.
\16\ See id.
\17\ See id.
---------------------------------------------------------------------------
(B) Whether, Before Importation Into the United States, Such Imported
Merchandise Is Completed or Assembled in a Third Country From
Merchandise Which Is Subject to the Order or Produced in the Foreign
Country That Is Subject to the Order
Pursuant to section 781(b)(1)(C) of the Act, we preliminarily
determined that the record evidence of this proceeding supported a
finding that the process or completion of the PRC-origin, semi-finished
hangers to finished garment hangers in Vietnam is minor or
insignificant.\18\ Under section 781(b)(1)(C) of the Act, section
781(b)(2) of the Act directed us to address other criteria, which we
found to have supported our preliminary finding that the processing or
completion in Vietnam was minor or insignificant.\19\ First, pursuant
to section 781(b)(2)(A) of the Act, we found that Angang's level of
investment in Vietnam was minimal in terms of converting PRC-origin,
semi-finished hangers into finished garment hangers.\20\ Second,
pursuant to section 781(b)(2)(B) of the Act, we found that the lack of
evidence of research and development (``R&D'') initiatives by Angang in
the production of garment hangers shows that R&D is not a significant
factor in Angang's completion of PRC-origin, semi-finished garment
hangers in Vietnam.\21\ Third, pursuant to section 781(b)(2)(C) of the
Act, we found that the portion of the overall production process of
garment hangers in Vietnam conducted by Angang in assembling or
completing the PRC-origin, semi-finished garment hangers into finished
garment hangers is limited and minor compared to the PRC affiliates'
share of the overall production process in the production of the semi-
finished garment hangers and the other direct materials they supply to
Angang to finish the semi-finished hangers in Vietnam.\22\ Fourth,
pursuant to section 781(b)(2)(D) of the Act, we found that the extent
of Angang's production facilities in Vietnam is minor with respect to
completing PRC-origin, semi-finished hangers to finished garment
hangers because the energy, labor, and capital equipment used by Angang
in converting the PRC-origin, semi-finished hangers into finished
garment hangers is not substantial in comparison to the materials,
labor, energy, and capital equipment used by its PRC affiliates to
produce the semi-finished
[[Page 66898]]
garment hangers.\23\ Finally, pursuant to section 781(b)(2)(E) of the
Act, we found that the value of the processing performed by Angang to
convert the PRC-origin, semi-finished hangers into finished garment
hangers represents a small proportion of the total value of the
finished merchandise imported into the United States.\24\
---------------------------------------------------------------------------
\18\ See id. at 27010.
\19\ See id. at 27009-27012.
\20\ See id. at 27010.
\21\ See id.
\22\ See id. at 27011.
\23\ See id. at 27011-12.
\24\ See id. at 27012.
---------------------------------------------------------------------------
Therefore, we preliminarily found that, pursuant to sections
781(b)(2)(A)-(E) of the Act, Angang's processing operation to convert
PRC-origin, semi-finished hangers into finished garment hangers in
Vietnam is minor or insignificant.\25\ We based our preliminary
decision as to whether the processing operation to convert PRC-origin,
semi-finished hangers into finished garment hangers is minor or
insignificant on the totality of the record evidence of this anti-
circumvention inquiry and compared the relative information regarding
the production processes for Angang and its PRC affiliates. For the
final determination, we continue to find that, based on the totality of
the record, each statutory criterion under section 781(b)(2) of the Act
and all other factors point to the conclusion that Angang's process of
converting the PRC-origin, semi-finished hangers in Vietnam was minor
or insignificant and, consistent with our analysis in prior anti-
circumvention inquiries.\26\
---------------------------------------------------------------------------
\25\ See id. at 27012-13.
\26\ See, e.g., Anti-Circumvention Inquiry of the Antidumping
and Countervailing Duty Orders on Certain Pasta From Italy:
Affirmative Preliminary Determinations of Circumvention of
Antidumping and Countervailing Duty Orders, 68 FR 46571, 46574-75
(August 6, 2003), unchanged in Anti-Circumvention Inquiry of the
Antidumping and Countervailing Duty Orders on Certain Pasta from
Italy: Affirmative Final Determinations of Circumvention of
Antidumping and Countervailing Duty Orders, 68 FR 54888 (September
19, 2003); and Hot-Rolled Lead and Bismuth Carbon Steel Products
from Germany and the United Kingdom; Negative Final Determinations
of Circumvention of Antidumping and Countervailing Duty Orders, 64
FR 40336, 40338-40 (July 26, 1999).
---------------------------------------------------------------------------
(C) Whether the Value of the Merchandise Produced in the Foreign
Country To Which the Order Applies Is a Significant Portion of the
Total Value of the Merchandise Exported to the United States
Under section 781(b)(1)(D) of the Act, the value of the merchandise
produced in the foreign country to which an antidumping duty order
applies must be a significant portion of the total value of the
merchandise exported to the United States in order to find
circumvention. As discussed above, we found that the production process
in the PRC manufactures the main inputs, that all the direct materials
are sourced from the PRC, and that there exists only limited production
processes in Vietnam, thereby evincing that a great majority of the
value of the finished merchandise is based on the PRC-production of the
semi-finished hangers and the other direct materials which are applied
to those PRC-origin, semi-finished hangers in Vietnam.\27\ Based on our
analysis and record evidence, we found that the value of the PRC-
origin, semi-finished hangers taken as a whole constitutes a
significant portion of the total value of the finished product
ultimately exported to the United States.
---------------------------------------------------------------------------
\27\ See Preliminary Determination, 76 FR at 27013.
---------------------------------------------------------------------------
(D) Other Factors To Consider
As previously noted, section 781(b)(3) of the Act instructs the
Department to consider, in determining whether to include merchandise
assembled or completed in a foreign country within the scope of an
order, such factors as: pattern of trade, including sourcing patterns;
affiliations between manufacturers or exporters of merchandise in the
country subject to the order and the person who uses the merchandise to
assemble or complete in the third country the merchandise that is
exported to the United States; and whether imports into the third
country of the merchandise described in section 781(b)(1)(B) of the Act
have increased after the initiation of the investigation.
We preliminarily determined that: (1) The data related to patterns
of trade in this case show that PRC exports have decreased
significantly whereas Vietnamese exports have increased exponentially
since the initiation of the less than fair value (``LTFV'')
investigation; (2) Angang maintained an affiliation with two PRC
companies; \28\ and (3) Angang's imports of PRC-origin, semi-finished
hangers increased after the initiation of the LTFV investigation and
PRC exports of the same to Vietnam similarly increased after the
initiation of the LTFV investigation.\29\ We found at that time,\30\
and continue to find in this final determination, that these facts and
the related record evidence all support the conclusion that
circumvention of the Order has occurred.
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\28\ See ``Memorandum to the File through Catherine Bertrand,
Program Manager, Office 9 from Irene Gorelik, Senior Analyst, re;
Circumvention Inquiry on Steel Wire Garment Hangers from the
People's Republic of China: Proprietary Analysis of Certain
Statutory Factors for Angang Clothes Rack Manufacture Co., Ltd. for
the Preliminary Determination,'' (``Angang Prelim Analysis Memo''),
dated May 3, 2011. For the final determination, we continue to find
that affiliation exists between Angang and these two PRC entities
referenced in Angang Prelim Analysis Memorandum, pursuant to section
771(33) of the Act.
\29\ See Preliminary Determination, 76 FR at 27013-14.
\30\ See id. at 27014-15.
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Affirmative Final Determination Summary
With respect to Quyky, we preliminarily found that Quyky
circumvented the Order because it failed to provide the Department with
any information at all, thus we are unable to distinguish between its
imports or purchase of semi-finished hangers from the PRC for purposes
other than assembly into merchandise covered by the Order.
Consequently, because Quyky refused to comply with the Department's
request for information, we continue to find that it failed to
cooperate to the best of its ability and, therefore, that an adverse
inference is warranted pursuant to section 776(b) of the Act.
Accordingly, as stated above, as an adverse inference the Department
preliminarily found that all of the garment hangers produced and/or
exported by Quyky to the United States are circumventing the Order.
Therefore, in light of our uncontested Preliminary Determination and
the substantial record evidence supporting that decision, the
Department will instruct U.S. Customs and Border Protection (``CBP'')
to suspend liquidation on all entries of garment hangers produced and/
or exported by Quyky that were entered, or withdrawn from warehouse,
for consumption on or after the date of initiation of the anti-
circumvention inquiry.
Further, with respect to Angang, we preliminarily found that Angang
has circumvented the Order in accordance with section 781(b)(1) and (2)
of the Act. Pursuant to section 781(b)(1) of the Act, we found that the
merchandise sold in the United States is within the same class or kind
of merchandise that is subject to the Order and was completed or
assembled in a third country. Additionally, pursuant to section
781(b)(2), we found that the process or assembly of the PRC-origin
semi-finished hangers into finished garment hangers by Angang is minor
and insignificant. Furthermore, in accordance with section 781(b)(1)(D)
of the Act, we found that the value of the merchandise produced in the
PRC is a significant portion of the total value of the merchandise
exported to the United States.
The record evidence continues to support an affirmative finding of
circumvention in accordance with section 781(b)(1) and (2) of the Act.
Moreover, we continue to find the factors required by section 781(b)(3)
of
[[Page 66899]]
the Act indicate that there is circumvention of the Order.
Consequently, our statutory analysis leads us to find that there was
circumvention of the Order as a result of Angang's assembly of the PRC-
origin, semi-finished hangers into finished garment hangers in Vietnam
for export to the United States, as discussed above. Therefore, in
light of our final determination, the Department will instruct CBP to
suspend liquidation on all entries of garment hangers produced and/or
exported by Angang that were entered, or withdrawn from warehouse, for
consumption on or after the date of initiation of the anti-
circumvention inquiry. Should the Department conduct an administrative
review of the Order in the future, both Quyky and Angang will have the
opportunity to provide information related to their use of PRC-origin
or self-produced garment hangers so that the Department may determine
the appropriate assessment rate.
Continuation of Suspension of Liquidation
In accordance with section 733(d) of the Act, the Department will
continue to direct CBP to suspend liquidation and to require a cash
deposit of estimated duties, at the PRC-wide rate of 187.25 percent, on
all unliquidated entries of garment hangers produced and/or exported by
Angang and Quyky that were entered, or withdrawn from warehouse, for
consumption on or after July 16, 2010, the date of initiation of the
anti-circumvention inquiry.
In comments to the Department, Angang asked the Department (1) to
revisit its determination to suspend liquidation of all of Angang's
entries and (2) to allow certifications for Angang's future entries.
Angang has provided conflicting statements on whether it could
segregate PRC-origin, semi-finished hangers from the self-produced,
semi-finished hangers in Vietnam,\31\ and record evidence supports the
conclusion that Angang commingles the two groups of merchandise in a
work-in-progress warehouse. Therefore, the Department declines to grant
Angang's requests. For further discussion of this issue, see the
Decision Memorandum.\32\
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\31\ See, e.g., Angang's Questionnaire Responses dated October
8, 2010, at Exhibit 1B; November 19, 2010, at 13; March 21, 2011, at
2; Angang's Case Brief dated June 13, 2011 at 4-9; see also Decision
Memorandum at Comment 3.
\32\ See Decision Memorandum at Comments 3, 4, and 5.
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As stated above, if requested, should the Department conduct an
administrative review in the future, and determine in the context of
that review that either Quyky or Angang have not produced for export
garment hangers using PRC-origin, semi-finished hangers, the Department
will consider a changed circumstances review pursuant to section 751(b)
of the Act to determine if the continued suspension of all garment
hangers produced by Quyky or Angang is warranted.
Notification to Interested Parties
This notice serves as the only reminder to parties subject to the
administrative protective order (``APO'') of their responsibility
concerning the return or destruction of proprietary information
disclosed under APO in accordance with 19 CFR 351.305. Timely written
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 terms of an APO is a violation which is
subject to sanction.
This final affirmative circumvention determination is published in
accordance with section 781(b) of the Act and 19 CFR 351.225(h).
Dated: October 21, 2011.
Ronald K. Lorentzen,
Deputy Assistant Secretary for Import Administration.
Appendix I
Discussion of the Issues
Comment 1: Affirmative Preliminary Determination of Circumvention
Regarding Quyky
Comment 2: Affirmative Preliminary Determination of Circumvention
Regarding Angang
Comment 3: Appropriate Suspension of Liquidation of Angang's Exports
Comment 4: Whether To Require a Certification Process for Angang's
Exports
Comment 5: Appropriate Rate To Assign to Angang
[FR Doc. 2011-27972 Filed 10-27-11; 8:45 am]
BILLING CODE 3510-DS-P