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sales of imports of this product to end users), the subject imports undersold the domestic product in 29 out of 30 price comparisons at margins ranging from 1.9 percent to 29.3 percent. 129

On the basis of these data, we find significant price underselling by the subject imports and find that these imports have depressed prices to a significant degree. In reaching this conclusion, we are relying principally on the data for Product 1, because the bulk of the pricing data for subject imports were for this product.130 We recognize that the data for Product 2 show mostly overselling by subject imports, and rising domestic prices. However, we deem the pricing data for Product 2 to be less reliable because it appears that it may involve a comparison of imported sheeter rolls with sales of domestically produced web rolls.131 As noted above, CFSP in sheeter-roll form generally commands a premium over CFSP in web-roll form. We also give less weight to the price comparison data for Product 3, which, as explained above, shows widespread underselling by subject imports but also rising prices for the domestically produced product because of the relatively small quantities of subject imports involved. 132

In sum, we find for purposes of the preliminary phase of these investigations that the subject imports have had significant adverse price effects on the price of the domestic like product.


Impact of the Subject Imports133

Section 771(7)(C)(iii) provides that the Commission, in examining the impact of the subject imports on the domestic industry, “shall evaluate all relevant economic factors which have a bearing on

the state of the industry.”134

These factors include output, sales, inventories, capacity utilization, market

share, employment, wages, productivity, profits, cash flow, return on investment, ability to raise capital, research and development, and factors affecting domestic prices. No single factor is dispositive and all relevant factors are considered “within the context of the business cycle and conditions of competition that are distinctive to the affected industry.”135

We have examined performance indicators in trade and financial data for the domestic industry. The trade data are somewhat mixed, but are generally positive over the POI. The industry’s financial data, however, show a marked decline in the 2003-2004 period, and continued weakness into 2005. 136



CR/PR at Table V-9. Compare CR/PR at Tables V-1 and V-2 with Tables V-3 through V-5.

131 ***. CR/PR at Table V-3 notes 2 and 3. We do not have specific information on whether sales of domestically produced Product 2 consisted of sheeter rolls or web rolls, but given the concentration of domestic production in web rolls, it is reasonable to assume that at least a significant portion of the data for domestically produced Product 2 consisted of web rolls.


Compare CR/PR at Tables V-1 and V2 with Table V-5.

133 In its notice of initiation of the antidumping duty investigations, Commerce estimated the following dumping margins for imports from the three subject countries: 99.65 percent for China; from 99.14 percent for Indonesia; and 71.81 percent for Korea. 71 Fed. Reg. 68537, 68541 (Nov. 27, 2006).

134 19 U.S.C. § 1677(7)(C)(iii); see also SAA at 851 and 885 (“In material injury determinations, the Commission considers, in addition to imports, other factors that may be contributing to overall injury. While these factors, in some cases, may account for the injury to the domestic industry, they also may demonstrate that an industry is facing difficulties from a variety of sources and is vulnerable to dumped or subsidized imports.”) SAA at 885.

135 19 U.S.C. § 1677(7)(C)(iii); see also SAA at 851, 885; Live Cattle from Canada and Mexico, Inv. Nos. 701- TA-386, 731-TA-812-813 (Preliminary), USITC Pub. 3155 at 25 n.148 (Feb. 1999).

136 We recognize that, because demand for CFSP is somewhat seasonal, full-year financial data may merit greater weight than partial-year data. In any final phase of these investigations, we intend to consider the extent to which seasonality affects the reliability of partial-year financial data.


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