Preliminary Injury Inquiries (Subsection 34(2))

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TABLE OF CONTENTS

• PRELIMINARY DETERMINATION OF INJURY
• STATEMENT OF REASONS
• • BACKGROUND
  • PRODUCT
  • INDUSTRY
  • COMMISSIONER'S DECISION
  • SUMMARY OF COMPLAINT AND SUBMISSIONS
  • ANALYSIS
  • CONCLUSION

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Ottawa, Tuesday, March 20, 2001

Preliminary Injury Inquiry No.: PI-2000-006

IN THE MATTER OF a preliminary injury inquiry, under subsection 34(2) of the Special Import Measures Act, respecting:

THE DUMPING OF CERTAIN FLAT HOT-ROLLED CARBON AND ALLOY STEEL SHEET AND STRIP ORIGINATING IN OR EXPORTED FROM BRAZIL, BULGARIA, THE PEOPLE'S REPUBLIC OF CHINA, CHINESE TAIPEI, INDIA, THE REPUBLIC OF KOREA, THE FORMER YUGOSLAV REPUBLIC OF MACEDONIA, NEW ZEALAND, SAUDI ARABIA, SOUTH AFRICA, THAILAND, UKRAINE AND THE FEDERAL REPUBLIC OF YUGOSLAVIA AND THE SUBSIDIZING OF CERTAIN FLAT HOT-ROLLED CARBON AND ALLOY STEEL SHEET AND STRIP ORIGINATING IN OR EXPORTED FROM INDIA

PRELIMINARY DETERMINATION OF INJURY

The Canadian International Trade Tribunal, under the provisions of subsection 34(2) of the Special Import Measures Act, has conducted a preliminary inquiry into whether the evidence discloses a reasonable indication that the dumping of certain flat hot-rolled carbon and alloy steel sheet and strip (hot-rolled steel sheet products) originating in or exported from Brazil, Bulgaria, the People's Republic of China, Chinese Taipei, India, the Republic of Korea, the former Yugoslav Republic of Macedonia, New Zealand, Saudi Arabia, South Africa, Thailand, Ukraine and the Federal Republic of Yugoslavia and the subsidizing of hot-rolled steel sheet products originating in or exported from India have caused injury or retardation or are threatening to cause injury to the domestic industry.

This preliminary inquiry is pursuant to the notification, on January 19, 2001, by the Acting Director General, Anti-dumping and Countervailing Directorate, Canada Customs and Revenue Agency, that an investigation had been initiated into the alleged dumping and subsidizing of the above-mentioned hot-rolled steel sheet products.

Pursuant to subsection 37.1(1) of the Special Import Measures Act, the Canadian International Trade Tribunal hereby determines that the evidence discloses a reasonable indication that the dumping and subsidizing of the above-mentioned hot-rolled steel sheet products have caused injury to the domestic industry.

Michel P. Granger
Michel P. Granger
Secretary

The statement of reasons will be issued within 15 days.
 
 

Date of Determination:		March 20, 2001
Date of Reasons:		April 4, 2001
Tribunal Members:		Pierre Gosselin, Presiding Member
		James A. Ogilvy, Member
		Ellen Fry, Member
Director of Research:		Sandy Greig
Research Manager:		Richard Cossette
Researcher:		Martin Giroux
Counsel for the Tribunal:		John Dodsworth
		Dominique Laporte
Registrar Officer:		Pierrette Hébert
Participants:		Ronald C. Cheng
		Gregory O. Somers
		Paul D. Conlin
	for	Algoma Steel Inc.
		Ispat Sidbec Inc.
		Lawrence L. Herman
		Craig S. Logie
	for	Stelco Inc.
		Dalton J. Albrecht
		Dunniela Kaufman
	for	IPSCO Inc.
		Steven K. D'Arcy
	for	Dofasco Inc.
		Peter Clark
		Gordon LaFortune
		Yannick Beauvalet
		Jin Li
	for	Macsteel International (Canada) Ltd.
		Macsteel International South Africa (Pty) Ltd.
		ISCOR Limited
		Peter Clark
		Chris Hines
		Sean Clark
		John Currie
	for	Usinas Siderurgicas de Minas Gerais S.A.
		Companhia Siderurgica Nacional
		Companhia Siderurgica Paulista
		Greg A. Tereposky
		Roger Nassrallah
	for	Essar Steel Limited
		Steel Authority of India Limited
		The Tata Iron and Steel Company Limited
		S. R. Mani
		High Commission of India
		Alyson D'Oyley
		Mark N. Sills
		Albert Gourley
		Huy A. Do
		Anthony Eyton
	for	Pohang Iron & Steel Co., Ltd.
		Daewoo Canada Ltd.
		Daewoo Corporation
		Victoria Bazan
		Rob Hyndman
	for	Saudi Iron and Steel Company
		Richard S. Gottlieb
		Jesse I. Goldman
		Darrel H. Pearson
	for	Shanghai Baosteel Group Co.
		Richard G. Dearden
		Adam J. Segal
		Scott P. Little
		Maureen L. Murphy
	for	Angang Group International Trade Group
		Anshan Iron and Steel Group Corporation
		Benxi Iron and Steel Group International Economic
		and Trading Company Ltd.
		William J. Moran
		Stephen Des Lauriers
	for	Sahaviriya Steel Industries Public Company Limited
		Cheng-Chung Tseng
	for	Yieh Loong Enterprise Co., Ltd.

 
 
Ottawa, Wednesday, April 4, 2001

Preliminary Injury Inquiry No.: PI-2000-006

IN THE MATTER OF a preliminary injury inquiry, under subsection 34(2) of the Special Import Measures Act, respecting:

THE DUMPING OF CERTAIN FLAT HOT-ROLLED CARBON AND ALLOY STEEL SHEET AND STRIP ORIGINATING IN OR EXPORTED FROM BRAZIL, BULGARIA, THE PEOPLE'S REPUBLIC OF CHINA, CHINESE TAIPEI, INDIA, THE REPUBLIC OF KOREA, THE FORMER YUGOSLAV REPUBLIC OF MACEDONIA, NEW ZEALAND, SAUDI ARABIA, SOUTH AFRICA, THAILAND, UKRAINE AND THE FEDERAL REPUBLIC OF YUGOSLAVIA AND THE SUBSIDIZING OF CERTAIN FLAT HOT-ROLLED CARBON AND ALLOY STEEL SHEET AND STRIP ORIGINATING IN OR EXPORTED FROM INDIA

STATEMENT OF REASONS

BACKGROUND

On January 19, 2001, pursuant to subsection 31(1) of the Special Import Measures Act,¹ the Commissioner of the Canada Customs and Revenue Agency (the Commissioner) initiated an investigation respecting the alleged injurious dumping of certain flat hot-rolled carbon and alloy sheet and strip (hot-rolled steel sheet products) originating in or exported from Brazil, Bulgaria, the People's Republic of China (China), Chinese Taipei, India, the Republic of Korea (Korea), the former Yugoslav Republic of Macedonia (Macedonia), New Zealand, Saudi Arabia, South Africa, Thailand, Ukraine and the Federal Republic of Yugoslavia (Yugoslavia), and the alleged injurious subsidizing of certain hot-rolled steel sheet products originating in or exported from India.

The investigation was initiated following a complaint filed by Algoma Steel Inc. (Algoma), Sault Ste. Marie, Ontario, on December 6, 2000. Algoma is supported in its complaint by Stelco Inc. (Stelco), Hamilton, Ontario, Dofasco Inc. (Dofasco), Hamilton, IPSCO Inc. (IPSCO), Regina, Saskatchewan, and Ispat Sidbec Inc. (Ispat Sidbec), Montréal, Quebec. On December 20, 2000, the Canada Customs and Revenue Agency (CCRA) informed Algoma that its complaint was properly documented. The CCRA also informed the governments of the subject countries that a properly documented complaint had been filed.

On January 22, 2001, the Canadian International Trade Tribunal (the Tribunal) issued a notice² advising interested parties that it had initiated a preliminary injury inquiry to determine whether the evidence disclosed a reasonable indication that the dumping and subsidizing had caused injury³ or retardation or were threatening to cause injury.

The record of this preliminary injury inquiry consists of all documents that relate to the Commissioner's decision to initiate the investigation, his statement of reasons for the initiation, and the public and protected versions of the complaint. In addition, the record consists of all submissions filed in response to the Tribunal's notice. All public exhibits were made available to the parties. Protected exhibits were made available only to counsel who had filed a declaration and undertaking with the Tribunal in respect of the use, disclosure, reproduction, protection and storage of confidential information on the record of the proceedings, as well as the disposal of such confidential information at the end of the proceeding or in the event of a change of counsel.

The Tribunal received notices of participation from 25 parties. Nine submissions were received from parties opposed to the complaint. Four reply submissions were received from the domestic producers.

The Tribunal issued its preliminary determination of injury on March 20, 2001.

PRODUCT

The subject goods are defined by the CCRA as "flat hot-rolled carbon and alloy steel sheet and strip, including secondary or `non-prime' material, originating in or exported from Brazil, Bulgaria, the People's Republic of China, Chinese Taipei, India, the Republic of Korea, the former Yugoslav Republic of Macedonia, New Zealand, Saudi Arabia, South Africa, Thailand, Ukraine and the Federal Republic of Yugoslavia, in various widths from 3/4" (19 mm) and wider, and

The subject goods include strip and sheet, but do not include floor plate. Skelp, which is a flat hot-rolled carbon steel sheet product used in the pipe and tube producing industry, is also considered as subject goods. The subject goods are usually classified as either carbon-manganese or high-strength low-alloy (HSLA) steels. They are normally produced to a specification of the ASTM standard or some other international standard or to a proprietary specification. Alloy steel sheet products that are subject to this investigation are alloy steels, other than stainless steel, that contain one or more of certain specified elements in minimum specified proportions by weight.

Hot-rolled steel sheet products may be sold in the open or merchant market or may be used by the domestic producers for further processing into cold-rolled sheet, galvanized sheet or tubular products. They are used in the manufacture of such items as automotive parts, sheet piling, guard rails, pipes and tubes, and agricultural and other machinery.

INDUSTRY

The Canadian producers of the hot-rolled steel sheet products are Algoma, Stelco, Dofasco, IPSCO and Ispat Sidbec.

Based on information supplied in the complaint and information provided by the other producers, the CCRA was satisfied that the complainant, Algoma, represented more than 25 percent of the Canadian production of the goods being investigated. Producers whose collective production accounts for the balance of the domestic production supported Algoma's complaint.

COMMISSIONER'S DECISION

In respect of dumping, the CCRA reported that, during the period of investigation (POI), from January 1 to September 30, 2000, 93.1 percent of the subject goods reviewed appeared to have been dumped. The estimated margins of dumping ranged from 7.3 percent to 34.6 percent when expressed as a percentage of normal value, with an overall weighted average margin of dumping of 17.1 percent of total normal value. The CCRA also reported that imports of the subject goods from each of China, India, Chinese Taipei and Korea were greater than 3 percent. The combined volume of the subject goods from the remaining countries was greater than 7 percent.

In respect of subsidizing, the CCRA estimated that, for India, the amount of subsidy expressed as a percentage of total export price of all goods reviewed was 25.2 percent. The allegedly subsidized imports from India accounted for 19 percent of imports of the subject goods from all countries.

SUMMARY OF COMPLAINT AND SUBMISSIONS

In its complaint, Algoma alleged that the dumping and subsidizing from the subject countries had caused and were threatening to cause material injury in the form of loss of market share, lost sales, price suppression and erosion, underutilization of capacity and deterioration of financial performance. Two other producers, Dofasco and Stelco, supplied evidence in support of their claim that the dumping and subsidizing had caused price erosion, while Stelco also supplied evidence in support of its claim of reduced profits.

Nine submissions opposed the complaint. They were: ISCOR Limited (ISCOR) (South Africa); Companhia Siderurgica Nacional, Companhia Siderurgica Paulista and Usinas Siderurgias de Minas Gerais S.A. (Brazilian mills), which filed a joint submission; Steel Authority of India Limited, Essar Steel Limited and The Tata Iron and Steel Company Limited (Indian mills), which filed a joint submission; the High Commission of India; Pohang Iron & Steel Co., Ltd. (POSCO), Daewoo Canada Ltd. and Daewoo Corporation (Korea), which filed a joint submission; Saudi Iron and Steel Company (Hadeed) (Saudi Arabia); Shanghai Baosteel Group Co. (China); Sahaviriya Steel Industries Public Company Limited (Sahaviriya) (Thailand); and Yieh Loong Enterprise Co., Ltd. (Chinese Taipei).

Exporters and foreign mills argued that the Tribunal must address the total production of hot-rolled steel sheet products, including those for the merchant market and those for further processing, in order to assess trends in the merchant market. Concern was also expressed that the producers' own imports were not included in the investigation. The exporters and foreign mills contended that manipulation of the record to shelter captive imports by the producers and to hide the impacts of changes in production for further processing called into question the validity of the complaint.

Several exporters and foreign mills submitted that their exports to Canada should not be cumulated and that, on this basis, the evidence did not disclose a reasonable indication of injury or threat of injury. For example, ISCOR argued that South Africa was a very minor player in the Canadian market and that South Africa's share of total volume of imports and of Canadian consumption in the merchant market had been declining steadily since 1998. The Korean parties argued that an insignificant amount of imports from Korea were shipped to Canada, that imports from Korea served a high-end niche market and that there was a lack of objective and reliable evidence linking imports from Korea to any material injury that the domestic industry may have experienced. Sahaviriya submitted that it exported only one shipment of hot-rolled steel sheet products to Canada during the POI. Because of the relatively high selling price of the subject goods, Sahaviriya contended that the imports from Thailand did not compete with those of low-cost goods from foreign exporters.

Hadeed submitted that the silence of SIMA with respect to any requirement to cumulate at the preliminary injury stage indicates a legislative intention that a cumulative assessment should not be made under section 34. It further submitted that the CCRA applied a different standard from that used for the other subject countries to determine whether imports from Saudi Arabia were negligible. The only subject goods from Saudi Arabia that were included in the analysis were released after the POI. Hadeed submitted that, had the determination been correctly made, the investigation would not have been initiated with respect to goods imported from Saudi Arabia. In these circumstances, Hadeed argued, the investigation ought to be terminated with respect to the subject goods imported from Saudi Arabia.

Several exporters, foreign mills and the High Commission of India argued that the evidence offered by the Canadian mills did not support their claims that the dumping and subsidizing of the subject goods caused injury or threatened to cause injury. In the alternative, they argued that any injury or threat of injury was not material. Some of them argued that the complaint alleged increased imports from the targeted countries only in percentage terms, not in absolute terms; that the average selling price of the subject imports increased from 1999 to 2000; that there was no sharp decline in shipments by domestic producers in Canada; and that domestic prices were going up and, hence, price suppression or price erosion was not established. Moreover, some of them argued that Algoma's total sales revenues, production and financial performance grew during the POI compared to the corresponding 1999 period; that the evidence suggests that Algoma had not experienced unutilized capacity; that there was no correlation between Algoma's plan to reduce employment and the subject imports; that Stelco had provided only limited information about its sales of hot-rolled steel sheet products; and that Ispat Sidbec's assertions that it had suffered price erosion and price suppression, lost orders and experienced adverse financial impact were not positive evidence.

The Brazilian mills submitted that, if evidence had been filed by all supporting producers, the CCRA might have come to a different conclusion. They also submitted that Algoma was the weakest member of the Canadian industry and that it was not a good benchmark of the Canadian industry's situation. Finally, they contended that Algoma had very limited production of downstream hot-rolled steel sheet products and, as a consequence, did not account for 25 percent of total Canadian production of like goods, including production for both the merchant and captive markets.

The Indian mills claimed that a determination of reasonable indication must be based on positive evidence on the record and that there is a substantial gap in the evidential record on whether there is a reasonable indication that any injury suffered by the domestic industry is material. The materiality of any injury, it was argued, can be assessed only in light of the financial impact of depressed or suppressed prices or lost sales on each of the producers comprising the domestic industry. In this regard, the Indian mills submitted that only Algoma and Stelco submitted detailed evidence in the proceeding. They submitted that the other domestic producers should have provided information with respect to prices, costs, inventories, product mix, export sales and profitability figures, all of which are relevant factors that must be considered to determine whether there is a reasonable indication of material injury.

Several exporters, foreign mills and the High Commission of India argued that any injury to the domestic producers had been caused by factors other than the dumping and subsidizing. The Korean parties submitted that any injury caused to the domestic industry was much more likely to have been caused by imports from non-subject countries, such as the United States and Japan. The High Commission of India submitted that Algoma expanded its capacity in 1998 and that this could have led to price pressures in the domestic market. Shanghai Baosteel Group Co. argued that the Canadian producers were unable to meet the demands of the marketplace.

In their reply submissions, the domestic producers argued that the reasonable indication test in a preliminary injury inquiry under subsection 34(2) of SIMA was a lower threshold than the injury test in an injury inquiry under section 42 and was essentially the same as the test under section 34 of the former SIMA. Further, they argued that the reasonable indication test had been adequately met in this preliminary injury inquiry. In this regard, Algoma submitted that the Tribunal had, at the preliminary stage, consistently sought evidence of a correlation between the presence of dumped imports and injury to domestic production, while proof of causation was appropriate only at the final injury inquiry.

Stelco argued that the Tribunal has no jurisdiction under subsection 34(2) of SIMA to deal with the following matters raised by opposing parties: the definition and scope of the subject goods and like goods; the standing of the complaint; and negligibility.

Algoma argued that hot-rolled steel sheet products for further processing should be excluded from the scope of like goods, as the question of whether goods are "like" is to be determined by market considerations. Algoma further submitted that the goods sold in the merchant market do not compete with domestically produced hot-rolled steel sheet products that are directed to further processing by the producers.

Regarding cumulation, the domestic producers argued that it defied logic to argue that the Tribunal can cumulate in determining injury in an injury inquiry under section 42 of SIMA, but that cumulation is not permissible under subsection 34(2).

ANALYSIS

Pursuant to subsection 34(2) of SIMA, the Tribunal is required to conduct a preliminary inquiry into whether the evidence discloses a reasonable indication of injury, retardation or threat of injury to the domestic industry as a result of the dumping and subsidizing of the subject goods.

The CCRA determined that the complaint had standing. In addition, the CCRA found that the volume of dumped and subsidized imports from each of the subject countries was not negligible and that their respective margins of dumping, and amount of subsidy, were not insignificant. It remains for the Tribunal to determine whether the evidence discloses a reasonable indication that the dumping and subsidizing of these imports have caused injury or retardation or are threatening to cause injury to the domestic producers of hot-rolled steel sheet products.⁴

The Tribunal had to determine first which domestically produced hot-rolled steel sheet products were "like goods" to the subject goods and, specifically, whether hot-rolled steel sheet products used for further processing, i.e. as feedstock for further internal processing into downstream products, such as cold-rolled steel sheet, galvanized sheet or tubular products, are "like goods".

In Inquiry No. NQ-92-008,⁵ the Tribunal determined that hot-rolled steel sheet products used as feedstock, as well as hot-rolled steel sheet products internally transferred by the manufacturers, were like goods. In Inquiry No. NQ-98-004,⁶ the Tribunal collected information for the totality of domestic production, including feedstock used for further processing. The Tribunal sees no reason to depart from its previous conclusion expressed in Inquiry No. NQ-92-008 and the approach taken in both cases and is of the view that, in this case, hot-rolled steel sheet products used by the industry for further processing are like goods to the subject goods.

Regarding the representativeness of the information provided by the domestic industry, the Tribunal notes that detailed evidence for most of the key factors normally considered by the Tribunal was filed by Algoma. Dofasco and Stelco did provide evidence of price erosion, and Stelco also supplied financial statements covering sales of hot-rolled steel sheet products as evidence of reduced profits. On this basis, the CCRA estimated that it had received evidence of injury from producers of well over 80 percent of the Canadian production for the merchant market.

In the context of this preliminary injury inquiry, the Tribunal had to focus on hot-rolled steel sheet products sold in the merchant market, as no evidence was submitted in respect of the overall domestic production. From its decision in Inquiry No. NQ-98-004, the Tribunal has a strong indication that the production of hot-rolled steel sheet products destined for the merchant market currently represents an important proportion of total production.⁷ As noted above, the CCRA was satisfied that, in the present case, evidence had been submitted from producers of well over 80 percent of the Canadian production for the merchant market. In light of the above, the Tribunal is of the view that the evidence on record is sufficient to assess whether there exists, at this stage, a reasonable indication of injury to the domestic industry, considering the relatively low threshold of the preliminary injury inquiry. Nevertheless, the Tribunal notes that it would have been preferable if data for overall domestic production, including hot-rolled steel sheet products used for further processing, had been provided for purposes of the preliminary injury inquiry. The Tribunal wishes to make it clear that it will require this information in future cases.

Some parties argued that imports from individual countries should not be cumulated by the Tribunal in examining the question of a reasonable indication of injury or a threat of injury. Subsection 42(3) of SIMA provides, in part, that, in making a final injury inquiry under section 42, the Tribunal shall make an assessment of the cumulative effect of the dumping or subsidizing of goods that are imported into Canada if the Tribunal is satisfied that certain conditions are met. Pursuant to this subsection, the Tribunal must be satisfied that, among other things, an assessment of the cumulative effect of the subject goods would be appropriate, taking into account the conditions of competition between the goods from any of the subject countries, the other dumped or subsidized goods and like goods. As stated in Preliminary Injury Inquiry No. PI-2000-005,⁸ while this subsection deals with final injury inquiries and does not explicitly cover preliminary injury inquiries, it seems to the Tribunal that it would be inconsistent not to cumulate at this stage when the evidence to date appears to justify cumulation.

With respect to the conditions of competition in the cumulation context, the Tribunal is satisfied, on the basis of the information before it at this stage, that the subject goods compete with each other and with the like goods. The Tribunal notes, in that connection, that there is little contradictory evidence at this stage that suggests that any goods from any subject country are not fungible with those of the other subject countries and with the like goods produced by the domestic industry. Accordingly, the Tribunal has made an assessment of the cumulative effect of the dumping and subsidizing of hot-rolled steel sheet products originating in or exported from all the subject countries.

Turning to the question of injury, the evidence shows that, between 1997 and the first nine months of 2000, imports from the subject countries rose significantly not only in absolute terms but in terms of market share. In fact, the combined imports from the subject countries doubled their share of the market in the first nine months of 2000, as compared to 1999. At the same time, the market share held by the domestic producers declined by 11 points. There is also evidence of hot-rolled steel sheet products entering Canada during the POI from the subject countries at average price levels below those of Algoma's and Stelco's average quarterly net revenues per ton and lower than the average price of imports from the United States. The industry's claims of lost sales, price erosion and price suppression are supported by industry evidence. Finally, there is evidence of reduced gross margins and reduced net income before taxes, starting in the third quarter of 2000 for both Algoma and Stelco. The Tribunal is therefore satisfied that the evidence shows that, as the volume of the imports from the subject countries increased, the industry suffered a loss in market share, price erosion, price suppression and a reduction in its financial performance. In the Tribunal's opinion, the evidence at this stage provides a reasonable indication that the dumping and subsidizing of the subject goods have caused injury to the domestic industry.

Having found that there is a reasonable indication that the dumped and subsidized imports have caused injury, the Tribunal is of the opinion that it is not necessary to determine whether there is retardation or threat of injury.

The Tribunal would like to note that, should a preliminary determination be issued by the CCRA, it will collect information from domestic producers on the volume and value of the total production of hot-rolled steel sheet products, including production for the merchant market in Canada and for export, and production for further processing in Canada and elsewhere. As well, regarding total production of hot-rolled steel sheet products, the Tribunal will collect information on other economic indicators, such as inventories, production costs, employment, investment and capacity, and capacity utilization. Finally, information on imports of hot-rolled steel sheet products made by the domestic producers, whether destined for further processing or for sale in the merchant market, will also be requested and included in total imports from all countries.

CONCLUSION

On the basis of the information before it, the Tribunal determines, pursuant to subsection 37.1(1) of SIMA, that the evidence discloses a reasonable indication that the dumping of hot-rolled steel sheet products originating in or exported from Brazil, Bulgaria, China, Chinese Taipei, India, Korea, Macedonia, New Zealand, Saudi Arabia, South Africa, Thailand, Ukraine and Yugoslavia, and the subsidizing of hot-rolled steel sheet products originating in or exported from India have caused injury to the domestic industry.

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1 . R.S.C. 1985, c. S-15 (hereinafter SIMA).

2 . C. Gaz. 2001.I.288.

3 . Subsection 2(1) of SIMA defines "injury" as material injury to the domestic industry.

4 . See Preliminary Injury Inquiry Nos. PI-2000-001 and PI-2000-002 at 4-5 for a description of this test.

5 . Finding (31 May 1993), Statement of Reasons (15 June 1993) (CITT).

6 . Finding (2 July 1999), Statement of Reasons (19 July 1999) (CITT).

7 . Administrative record, ISCOR submission, at 7.

8 . Finding (2 February 2001), Statement of Reasons (16 February 2001) (CITT).

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Initial publication: April 5, 2001