April 3, 2006
Assistant Secretary for Import Administration
US Department of Commerce
Central Records Unit
Pa. Ave and 14th Street
Washington, DC 20230
Attn: Weighted Average Dumping Margin
Re: Federal Register Notice, March 6, 2006, 71 Fed. Reg. 1189.
Request for comments on “zeroing” in anti-dumping investigations
Dear Mr. Spooner:
The following comments are made on behalf of the American Institute for International Steel
(AIIS) in response to the Department of Commerce’s request for comments regarding its
proposal on zeroing. AIIS represents US importers, exporters, consumers and distributors of
steel, port authorities, stevedoring firms and other logistics companies involved in the movement
of steel products.
The DOC proposal is to eliminate zeroing for initial investigations and then only when it uses the
average-to-average comparison. By making this proposal DOC is tacitly admitting that zeroing
is inconsistent with WTO obligations and poor policy. While the DOC proposal is a start, it is
not enough. Logical consistency suggests that zeroing should be eliminated in all its forms,
initial investigations, administrative reviews, sunset reviews and all its methodologies, whether
average to average or transaction to transaction.
While the legal and WTO issues surrounding this issue have been and will be discussed in detail
by others, AIIS believes it is important to point out the negative commercial ramifications of
zeroing on US manufacturing.
1. The scope of steel cases cover both commodity and high value added steel products under
the same investigation, whether hot rolled sheet, galvanized sheet, wire rod, plates, etc.
2. Commodity grade materials traded in these categories are generally the source of the
“positive” anti-dumping margins. These products are much more likely to be sold on a
highly competitive price basis – such imports historically carry a 5-10% discount from
domestic producers’ ma