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were present throughout the period of investigation. Non-subject import volume was 989,659 short tons

in 2003, 1,076,558 short tons in 2004, and 944,088 short tons in 2005.29

Non-subject imports accounted

for *** percent of total imports in 2003, *** percent in 2004, and *** percent in 2005.30 Thus, the volume of non-subject imports exceeded the volume of subject imports in each year of the period examined. Thus, for purposes of these preliminary determinations, I find that non-subject imports of CFSP are at significant levels and are a “significant factor” in the U.S. market.

As to whether non-subject imports are price competitive, the Commission requested product- specific price data from non-subject countries in its importers’ questionnaires. The Commission received a limited amount of price data for non-subject imports from Germany and Japan. Based on these data the prices for Product 1, sold to merchants/distributors, of non-subject imports from Germany were generally higher than the prices for subject imports but below the prices for the domestic like product.31 32 These data for non-subject imports from Japan show that prices for Product 1, sold to merchants/distributors, were much higher than the comparable prices for subject imports and were generally higher than the prices for the domestic like product. 33 The average unit value of non-subject imports exceeded the average unit value of subject imports in each year of the period of investigation.34 The average unit value of all non-subject imports were somewhat higher than the average unit value of U.S. shipments.35 However, the average unit value of non-subject imports from Finland and Canada, the two largest non- subject import sources, were generally lower than, or comparable too, the average unit value of U.S. shipments. The average unit value of non-subject imports from Canada were higher than the average unit value of subject imports, while the average unit value of non-subject imports from Finland were lower

than the average unit value of subject imports.36

Thus, for purposes of these preliminary determinations, I

determinate that non-subject imports of CFSP are price-competitive.

2.

Replacement/Benefit Factors

Having determined that the Bratsk test is triggered, I now analyze whether non-subject imports are likely to replace subject imports and continue to cause injury to the domestic industry. The record in these preliminary investigations indicates that subject imports took market share from non-subject imports. Subject import market share increased from *** percent in 2003 to *** percent in 2005.37 Non- subject import market share declined from *** percent to *** percent over the same period.38 However, the data available in these preliminary investigations indicates that the product mix of non-subject imports may differ from that of subject imports. Between 42.6 and 48.4 percent of non-subject imports were classified as sheets from 2003 to 2005. By comparison, between 79.4 and 81.4 percent of subject imports

29

CR/PR at Table IV-2.

30

CR/PR at Table IV-2.

31

Compare Appendix Table G-1 to Table V-1.

32 Consistent with the Commission’s analysis of the price effects of subject imports, I place more weight on the price data for Product 1 sold to merchants/distributors because this product/channel combination accounts for the largest share of domestic and subject import shipments.

33

34

35

Compare Appendix Table G-1 to Table V-1. CR/PR at Table IV-2 Compare CR/PR at Table III-5 to Table IV-2.

36 Imports from Finland accounted for *** percent of total imports and imports from Canada accounted for *** percent of total imports in 2005. CR/PR at Table IV-2 and CR/PR at Table III-5.

37

CR/PR at Table IV-5.

38

CR/PR at Table IV-5.

34

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