International Advisory Services Group, Ltd.
Appellate Body Report, United States - Laws, Regulations and Methodology for Calculating Dumping Margins
(“Zeroing”), WT/DS294/AB/R (Circulated April 18, 2006).
Zeroing Appellate Body Report, para. 263(b).
The sole exception, as we noted in our original comments, is the special case of “targeted dumping.”
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May 4, 2006
Assistant Secretary for Import Administration
U.S. Department of Commerce,
Central Records Unit, Room 1870
Pennsylvania Avenue and 14th Street, NW
Washington, DC 20230
Rebuttal Comments in Response to Federal Register Notice of March 6,
2006 Regarding Antidumping Proceedings: Calculation of the Weighted
Average Dumping Margin During an Antidumping Duty Investigation.
On behalf of the European Confederation of Iron and Steel Industries (Eurofer), and its member
companies and national associations (see attached list), I am pleased to submit the following
comments in further response to the invitation published in the Federal Register of March 6, 2006
(71 Fed. Reg. 11,190). In addition to this original, we are enclosing the requested six (6) copies and
a compact disk with the file in Word Perfect.
In our original submission, we took the simple and clear position that, as a matter of law and
principle, the United States is obliged to end the use of “zeroing” in all phases of all antidumping
proceedings. This applies whether the comparisons are being made average to average, transaction
to transaction, or transaction to average. The sole exception permitted under WTO rules is in the
case of “targeted dumping.”
Nothing in the comments of other parties effectively rebuts that position. Moreover, the recent
decision of the WTO Appellate Body (AB)1 supports each element of our position, some explicitly
and others as a matter of principle and logic. The AB ruled that the “zero