The threshold requirement for cumulation is satisfied because Petitioner filed a petition with respect to each of the three subject countries on the same day. None of the statutory exceptions to cumulation is applicable.78 We next examine the four factors that the Commission customarily considers in determining whether there is a reasonable overlap of competition.
Domestically produced CFSP and the subject imports in the same form (i.e., web rolls or sheets) from all three countries are substitutable. Subject imports are generally used for the same purpose as the domestic product, that is, for high-end printing applications. The majority of responding U.S. producers reported that the subject imports and the domestic product are always comparable, and the majority of responding importers reported that the subject imports and the domestic product are always comparable.79
U.S. producers concentrate on the production of CFSP in web-roll form. Subject imports, on the other hand, consist almost entirely of CFSP in sheet form.80 The two types of CFSP are used in different kinds of printing presses, and the record generally shows that they are not interchangeable for a particular kind of press.81 Despite the different focus of the subject imports and the domestic producers, we find that the degree of overlap of competition (the approximately 25 percent of domestic production on a volume basis, and somewhat more on a value basis, devoted to sheet82) is sufficient to support finding a reasonable overlap of competition.
Same Geographical Markets
U.S. producers of CFSP are mostly located to the east of the Rocky Mountains, although one producer is in Oregon.83 While the respondents suggested that domestic producers are sometimes reluctant to ship west of the Rocky Mountains,84 eight of the nine responding U.S. producers reported that
they sell nationally.85
Most of the responding importers (six of nine importers from China, four of seven
importers from Indonesia, and six of 12 importers from Korea) reported that they sold nationally.86 Although imports from each of the subject countries tended to be concentrated in the western region of the United States, throughout the POI there were significant imports from each of these countries in each of the other three regions of the United States.87 The foregoing data show that subject imports and the domestic like product are sold in the same geographic markets.
See 19 U.S.C. § 1677(7)(G) (ii).
CR at II-9, PR at II-6.
CR/PR at Table I-3.
Transcript at 67-68 (Tyrone, New Page).
See CR/PR at Table I-3.
CR/PR at Table III-1.
CR at II-2, PR at II-1.
CR/PR at Table IV-3.