June 6, 2005
The Honerable Joseph A. Spetrini
Acting Assistant Secretary for Import Administration
U.S. Department of Commerce
Central Records Unit, Room 1870
Pennsylvania Avenue and 14th Street NW
Washington, DC20230
Re: Comments on Market Economy Inputs Practice in Antidumping
Proceedings Involving Non-Market Economy Countries
Dear Mr. Spetrini,
We, China Chamber of Commerce for Import & Export of Machinery and
Electronic Products (CCCME), hereby submit these comments (including an original
one and six copies) on USDOC’s notice of Market Economy Inputs Practice in
Antidumping Proceedings involving Non-Market Economy Countries published on
May 26, 2005. Our comments are as followed:
We think USDOC’s long-standing practice of using market economy import
prices to value an entire input give the respondents an opportunity of fair treatment. It
is also proper to set up a threshold for the share of volume of a given input sourced
from market economy suppliers to qualify as “meaningful” in order for the import
price to be sued to value all of the input. We think, if the import of input from market
economy suppliers is representative, that is “meaningful”. To determine whether it is
representative, 5% import of the total input value is enough. Because in an
antidumping investigation, to determine whether the domestic sale is representative,
the threshold of 5% is introduced.
Another important thing in market economy inputs practice we want to mention
is the criteria to decide whether the input is sourced from market economy countries.
For example, Korea is a market economy country in antidumping investigations, but
when an enterprise in NME country sourced input from Korea, USDOC rejected to
use the price due to general subsidies existed in Korea. In this way, surrogate prices
were applied. We think, if there are really general subsidies existed and the import
prices were biased, USDOC should adjust the import prices by subsidy duties. It is
un